DRC-2012-001895 - 0901a06880307c32

RC-20«2-00 1895
Licensee
RSO
JJT_L200jl79 Lie Cat 2-h
Date Request Received
Action Requested _
LICENSING ACTION ROUTING SHEET
License #
Pnonty
Expedite
Timely*^
Action #
Amend # 05 /S-iMt^
1 Phase I Reviewed by Staff
2 Phase II Reviewed by Staff
Connie
Connie
Dave John
Dave John
End Date Comments ^
LICENSING ACTIO
Conducted by
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Date Licensee Name • Status
^ Address • Exp Date
• RSO • Term Date
• Category • Telephone
• Contact • Fax Number
• Email • Med Users
• NONE • Med Info
License renewal states 'in its entirety "
Licensee name, address correct
Pnonty & license type correct
Expiration date correct, database correct
Items 6, 7, 8, & 9 correct, subitems match, locations and uses
SS&D's venfied
RSO correct, Database correct
Authonzed users venfied, supervision adequate
Leak test procedures adequate & appropnate 3-yr, 1 -yr, or Ra-226
L C appropnate, L T, inventory, transportation, ventilation, pacemaker, IND's, non-r
Preceptors, or other medical certificates for training
DIS authonzed, waste procedures
ALARA
Dosimetry, bioassy
Area monitonng, surveys, instruments, calibration, adequacy of, opening, ordenng, safe use RAM, emergency procedures
Incineration or other unusual authonzations, etc
RSC, meeting frequency, personnel, adequacy
Administrative procedures for Broad Scope Licenses
Technically well drafted
Appropnate license conditions used
License properly supported by information in file
Unusual lapse of time between application and licensing
Compliance record considered
Application deficiencies corrected
Management Comments ^^»^^>>vW'^^'^ f^J^yn/fy^Ci/i/^
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8/24/12 amendment dated 8/3/12 / gg
David 0 Frydenlund
Vice President & General Counsel
Denison Mines (USA) Corp (DUSA)
445 Union Blvd Ste 121
Lakewood CO 80228-14239
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8/24/12 amendment dated 8/3/12 / gg
David C Frydenlund
Vice President & General Counsel
Denison Mines (USA) Corp (DUSA)
445 Union Blvd Ste 121
Lakewood CO 80228-14239
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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
1
CERTIFIED MAIL
RETURN RECEIPT REOUIRED
August 24, 2012
David Frydenlund
Vice President Regulatory Affairs and Counsel
Energy Fuels Resources (USA) Inc
225 Union Boulevard, Suite 600
Lakewood, Colorado 80228
RE License Amendment as Requested in Letter Dated August 3, 2012 for Radioactive Matenal
License Number UT 1900479, and Permit Modification as Requested in Letter Dated
August 14, 2012 for Utah Ground Water Discharge Permit Number UGW370004
Dear Mr Frydenlund
Please find enclosed your Utah Radioactive Matenal License Amendment No 05 and the
modified Utah Ground Water Discharge Permit
If you have any questions or require clanfication concermng the amendment or modification, you
may contact us at [phone]
Sincerely,
Rusty Lundberg, Director
Division of Radiation Control
Enclosure
RL/geg
195 North 1950 West • Salt Lake City, UT
Maihng Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq Utah gov
Pnnted on 100% recycled paper
PemutNo UGW370004
STATE OF UTAH
DIVISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALITY BOARD
SALT LAKE CITY, UTAH 84114-4870
GROUND WATER DISCHARGE PERMIT
In compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,
Energy Fuels Resources (USA) Inc
225 Umon Boulevard, Suite 600
Lakewood, CO 80228
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 m Sections 28,29,32, and 33, Township 37 South, Range 22 East, SaU Lake Base and
Mendian, San Juan County, Utah
The permit is based on representations made by the Permittee and other information contained in the
adihmistrative record It is the responsibility of the Permittee to read and understand all provisions of
this Permit
The miUmg 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 pennits for this facility issued previously
This Permit shall become effective on August 30. 2012
This Permit shall expire March 8, 2010 (This Permit is in Timely Renewal)
Application for Permit Renewal was received September 1, 2009, and resubmitted on July 13,
2012 at the request ofthe DRC
Signed this/fH day of ftU^U/^U 2012
Director
Division of Radiation Control
Table of Contents
PART I SPECIFIC PERMIT CONDITIONS 1
A GROUND WATER CLASSIFICATION 1
B BACKGROUND WATER QUALITY . 1
C PERMIT LIMITS . . 22
1 Ground Water Compliance Limits • 22
2 Taihngs Cell Operations . 2S
3 Prohibited Discharges 22
D DISCHARGE MINIMIZATION AND BEST AVAILABLE TECHNOLOGY STANDARDS . .66
I DMT Design Standards for Existing Tailmgs Cells 1, 2, and 3 . 66
2. Existing Tailings Cell Construction Authonzed .. .. 8§
3 Existmg Facility DMT Performance Standards ... 8S
4 Best Available Technology Requirements for New Construction . 1144
5 BAT Design Standards for Tailings Cell 4A . . . 1144
6 BAT Perforaiance Standards for Tailings Cell 4A 1444
7 Defimtionof lle(2) Waste 1444
8 Closed Cell Performance Requirements . • • 1444
9 Facility Reclamation Requirements . . 154-^
10 Stormwater Management and Spill Control Requirements . 154-§
II Requirements for Feedstock Matenal Stored Outside the Feedstock Storage Area 154^
12 BAT Design Standards for Tailings Cell 4B 1^
13 BAT Performance Standards for Tailings Cell 4B . . -19-^
14. BAT Performance Standards for the New Decontamination Pad 194^
E GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING 2020
1 Routine Groundwater Compliance Momtonng . . 2020
2 Groundwater Momtonng General Momtonng Wells MW-20 and MW-22 .2134-
3 Groundwater Head Momtonng . . 2134
4 Groundwater Monitonng Well Design and Construction Cntena . 2134
5 Monitonng Procedures for Wells . .. .. 2233
6 White Mesa Seep and Spnng Monitonng ..... . 2233
7 DMT Performance Standard Momtonng 2333^
8 BAT Performance Standard Monitonng ... . 2434
9 On-site Chemicals Inventory . . 253#
10 Tailings Cell Wastewater Quality Monitonng 252&
11 Groundwater Momtonng Modifications . .. • 2636
12 BAT Performance Standard Momtonng . . . 2636
F REPORTING REQUIREMENTS . . . 2737
1 Routine Groundwater Momtonng Reports . • 2737
2 Routine DMT Performance Standard Monitonng Report . 283S
3 Routine BAT Performance Standard Momtonng Reports . .. 2939
4 DMT and BAT Performance Upset Reports . .2939
5 Other hifomiation . 2939
6 Groundwater Monitonng Well As-Built Reports 2939
7 White Mesa Seeps and Spnngs Monitonng Reports 30^
8 Chemicals Inventory Report . . 3134-
9 Tailings Cell Wastewater Quality Reports 31^
10 Revised Hydrogeologic Report 3134-
11 Annual Slimes Dram Recovery Head Report 3134
12 Decontamination Pads Annual Inspection Report 3233
G OUT OF COMPLIANCE STATUS 3233
1 Accelerated Monitonng Status 3233
2 Violation of Permit Limits . 3233
3 Failure to Maintain DMT or BAT Required by Permit 3233
4 Facility Out of Compliance Status 33^
H COMPLL\NCE 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-2 353^
4 Installation of New Groundwater Momtonng Wells 36^
5 Background Groundwater Quality Report for New Monitonng Wells . 36^
6 Detailed Southwest Hydrogeologic Investigation . 373^
PARTE REPORTING REQUIREMENTS . . 3939
A REPRESENTATIVE SAMPLING ... . 3939
B ANALYTICAL PROCEDURES . 39^
C PENALTIES FOR TAMPERING . . . 3939
D. REPORTING OF MONITORING RESULTS ... . . 39^
E COMPLIANCE SCHEDULES . . . 39^
F ADDITIONAL MONITORING BY THE PERMITTEE . ... 3939
G RECORDS CONTENTS . . • 393^
H RETENTION OF RECORDS . . . 3940
I NOTICE OF NONCOMPLIANCE REPORTING . . ... 4040
J OTHER NONCOMPLL\NCE REPORTING . 4040
K INSPECTION AND ENTRY . . 4040
PARTm COMPLIANCE RESPONSIBILITIES . 4144
A DUTY TO COMPLY . . . 4144
B PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS . 4144
C NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE . 4144
D DUTY TO MITIGATE . 4144
E PROPER OPERATION AND MAINTENANCE 4144
PARTIV GENERAL REQUIREMENTS . . . 4243
A PLANNED CHANGES . . . 4243
B ANTICIPATED NONCOMPLL\NCE 4243
C PERMIT ACTIONS .. ... 4243
D DUTY TO REAPPLY . 4243
E DUTY TO PROVIDE INFORMATION .. ... . 4243
F OTHER INFORMATION . 4243
G SIGNATORY REQUIREMENTS .. ... 4243
H PENALTIES FOR FALSIFICATION OF REPORTS 434^
I AVAILABILITY OF REPORTS . . 434^
J PROPERTY RIGHTS . 434^
K SEVERABILITY . 434^
L TRANSFERS . 434^
M STATE LAWS 4444
N REOPENER PROVISIONS . 4444
11
List of Tables
Table 1 Ground Water Classification 1
Table 2 Groundwater Compliance Limits 33^
Table 3 DMT Engineenng Design and Specifications 66
Table 4 Feedstock Storage Area Coordinates 104-0
Table 5 Approved Tailings Cell 4A Engineenng Design and Specifications . 1144
Table 6. Approved Tailings Cell 4B Engineenng Design and Specifications 164-6
Table 7 Groundwater Monitonng Reporting Schedule. . ... 2838
111
Part IA & IB
Perniit No UGW370004
PART I SPECIFIC PERMIT CONDITIONS
A GROUND WATER CLASSIFICATION - the groundwater classification ofthe 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^^^ Well ID
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 TED TED 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 penod between October, 1979 and December, 2007 This
data was obtained from the Permittee's background groundwater quality reports dated October 2007 and Apnl 30,2008
3) Background concentrations of uranium in well MW-18 (55 1 ^g/L) and thallium m MW-19 (2 1 ug/L) exceed the GWQS, 30 ^g/L and 2 0
Ug/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 monitonng wells, but instead are general momtonng wells as per Part IE 2 Average
concentrations and standard deviations for wells MW-20 and MW-22 were provided by the Permittee for the penod 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 ug/L) exceeds the GWQS, therefore well MW-25 has been classified as Class
in groundwater rather than Class II groundwater
6) Well MW-26 was onginally named TW4-15 and was installed as part of the chlorofomi contammant investigation at the facility Under this
Permit, MW-26 is defined as a Point of Compliance (POC) well for the tailings cells (see Part 1 E 1)
7) Background concentrations of uranium in well MW-27 (34 ug/L) and selenium in MW-31 (71 [igfL) exceed the GWQS, therefore these wells
have been classified as Class 111 groundwater rather than Class 11 groundwater
8) Well MW-32 was onginally named TW4-17 and was installed as part ofthe chloroform contaminant investigation at the facility Under this
Permit it is included as a POC well for the tailings cells in Part IE 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 IB & IC
PemiitNo UGW370004
background ground\yater quality is determined on a well-by-well basis, pursuant to Environmental
Protection Agency (EPA) guidance, and documented m the Permittee's background groundwater
quahty reports dated October 2007 and Apnl 30, 2008
C PERMIT LIMITS - the Permittee shall comply with the following permit limits
1 Ground Water Compliance Limits - contammant concentrations measured m each momtonng
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 m R317-6 even though this permit does not require monitonng for
each specific contaminant
2 Tailings Cell Operations - only 11 e (2) by-product matenal authonzed by Utah Radioactive
Matenals License No UT-2300478 (hereafter License) shall be discharged to or disposed of
m the tailmgs ponds
3 Prohibited Discharges - discharge of other compounds such as pamts, used oil, antifi-eeze,
pesticides, or any other contaminant not defined as 1 le (2) matenal is prohibited.
Table 2 Groundwater Compliance Limits (GWCL)
Upgradient Wells Down or Lateral Gradient Wells
MW-1
(Class ID
MW-18
(Class ni)
MW-19
(Class m)
MW-27
(Class 111)
MW-2
(Class ni)
MW-3
(Class m)
MW-3A
(Class m)
MW-5
(Class n)
MW-11
(Class II)
MW-12
(Class m)
MW-14
(Class ni)
MW-15
(Class ni)
Contaminant GWQS^'^ GWCL^*^ GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL^'^ GWCL GWCL GWCL
Nutrients (mg/L)
Ammonia (as N) 25 6 25 0 27 031 12 5 12 5 1 16 06 1 02 6 25 06 12 5 0 21
Nitrate + Nitrite (as N) 10 25 25 2 83 56 0 12 0 73 1 3 25 25 5 5 0 27
Heavy Metals (jug/L)
Arsenic 50 12 5 25 25 25 25 25 25 17 15 25 25 25
Beryllium 4 1 2 2 2 2 2 2 1 1 2 2 2
Cadmium 5 42 W 25 25 25 25 4 67 83 2 1 25 7 25 25
Chromium 100 50 50 50 SO 50 50 50 25 25 50 50 50
Cobalt 730 182 5 365 365 365 365 365 365 182 5 182 5 365 365 365
Copper 1,300 325 650 650 650 650 650 650 325 325 650 650 650
Iron 11,000 2,750 414 68 5,500 5,500 151 6 427 13 5,500 2,750 2,750 5,500 5,500 81 7
Lead 15 5 59 75 75 75 75 75 75 41 3 75 75 75 75
Manganese 800 289 350 400 400 378 76 4,233 6,287 376 74 131 29 2,088 80 2,230 30 400
Mercury 2 05 1 1 1 1 1 1 1 05 1 1 1
Molybdenum 40 W 10 20 20 20 20 20 20 10 10 20 25 30
Nickel 100 25 50 50 50 60 100 105 44 1 46 2 60 50 97
Selenium 50 12 5 25 28 96 25 26 6 37 89 12 5 12 5 25 25 128 7
Silver 100 25 50 50 50 50 50 50 25 25 50 50 50
Thallium 2 05 1 95 2 1 1 1 1 6 1 4 05 05 1 1 1
Tin 17,000 4,250 8,500 8,500 8,500 8,500 8,500 8,500 4,250 4,250 8,500 8,500 8,500
Uranium 30(3) 7 28 55 1 21 43 34 18 45 47 32 35 75 75 23 5 98 65 7
Vanadium 60 w 15 30 30 30 30 30 30 15 15 30 30 40
Zinc 5,000 251 2,500 2,500 2,500 2,500 173 19 155 87 38 1.250 2.500 35 04 2,500
Radiologics (pCi/L)
Gross Alpha | 15 |3 75| 75 | 2 36 | 2 | 32 | I |75 | 3 75 | 3 75 I 75 | 75 | 75
Volatile Organic Compounds (ug/L) <
Acetone 700 ^"^ 175 350 350 350 350 350 350 175 175 350 350 350
Benzene 5 1 25 25 25 25 25 25 25 125 1 25 25 25 25
2-Butanone (MEK) 4,000 1,000 2,000 2.000 2,000 2,000 2,000 2,000 1,000 1,000 2,000 2,000 2,000
Carbon Tetrachloride 5 1 25 25 25 25 25 25 25 1 25 1 25 25 25 25
Chloroform 70 W 17 5 35 35 35 35 35 35 17 5 17 5 35 35 35
Chloromethane 30(2) 75 15 15 15 15 15 94 75 75 15 15 15
Dichloromethane 5<^> 1 25 25 25 25 25 25 25 I 25 1 25 25 25 25
Naphthalene 100 25 50 50 50 50 50 50 25 25 50 50 50
Tetrahydrofuran 46(*) 11 5 23 23 23 23 23 23 11 5 11 5 23 23 23
Toluene 1,000 250 500 500 500 500 500 500 250 250 500 500 500
Xylenes (total) 10,000 2,500 5,000 5,000 5,000 5,000 5,000 5,000 2,500 2,500 5,000 5,000 5,000
Others
Field pH (S U) 65-8 5 6 77 - 8 5 6 25 - 8 5 6 78 - 8 5 65-85 65-85 65-85 65-85 65-85 65-85 65-85 65-85 6 62 - 8 5
Fluoride (mg/L) 4 0 56 0 45 1 39 0 85 0 43 0 68 I 6 142 1 2 02 2
Chloride (mg/L) 22 1 69 23 104 41 38 20 76 70 71 39 16 80 5 27 57 1
Sulfate (mg/L) 838 1,938 90 2,534 10 462 2,147 3,663 3,640 1.518 1,309 2,560 2,330 2,549 02
TDS (mg/L) 1,567 3,198 77 4,257 42 1,075 3,800 6,186 5,805 2.575 2,528 4,323 4,062 4.530
Table 2 Continued Groundwater Compliance Limits (GWCL)
Down or Lateral Gradient Wells
MW-17 MW-23 MW-24 MW-25 MW-26 MW-28 MW-29 MW-30 MW-31 MW-32 MW-35
(Class ni) (Class III) (Class III) (Class ni) (Class ni) (Class ni) (Class in) (Class 10 (Class ni) (Class m) (Class n)
Contaminant GWQS GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL '-'^ GWCL
Nutrients (mg/l)
Ammonia (as N) 25 0 26 06 7 0.77 0 92 12 5 1 3 0 14 12 5 1 17 6 25
Nitrate + Nitrite (asN) 10 5(8) 5 5 5 0 62 5 5 25 5 5 25
Heavy Metals (ug/l)
Arsenic 50 25 25 17 25 25 21 25 12 5 25 25 12 5
Beryllium 4 2 2 2 2 2 2 2 1 2 2 1
Cadmium 5 25 25 25 15 25 52 25 125 25 4 72 1 25
Chromium 100 50 50 50 50 50 50 50 25 SO 50 25
Cobalt 730 365 365 365 365 365 47 365 182 5 365 75 21 182 5
Copper 1,300 650 650 650 650 650 650 650 325 650 650 325
Iron 11.000 5,500 5,500 4,162 5,500 2,675 83 299 1.869 2,750 5,500 14,060 2.750
Lead 15 75 75 75 75 75 75 75 3 75 75 75 3 75
Manganese 800 9154 550 7,507 1,806 1,610 1,837 5,624 61 400 5,594 90 200
Mercury 2 1 1 1 1 1 1 1 05 1 1 05
Molybdenum 40(2) 20 20 20 20 20 20 20 10 20 20 10
Nickel 100 50 50 50 50 50 50 50 25 50 94 25
Selenium 50 25 25 25 25 25 11 I 25 34 71 25 12 5
Silver 100 50 50 50 SO 50 50 50 25 50 50 25
Thallium 2 1 1 5 1 1 1 1 1 1 2 05 1 1 05
Tin 17.000 8,500 8,500 8,500 8,500 8,500 8,500 8,500 4,250 8,500 8,500 4.250
Uranium 30(3) 46 66 32 119 65 41 8 49 15 8 32 9 1 5 26 75
Vanadium 60(*) 30 30 30 30 30 30 30 15 30 30 15
Zinc 5,000 2,500 74 2,500 2,500 2,500 83 30 1.250 2,500 230 1.250
Radiologics (pCi/l)
Gross Alpha 15 28 2 86 75 75 4 69 2 42 2 3 75 75 3 33 3 75
Volatile Organic Compounds (ug/l)
Acetone 700 350 350 350 350 350 350 350 175 350 350 175
Benzene 5 25 25 25 25 25 25 25 1 25 25 25 1 25
2-Butanone (MEK) 4,000 2,000 2,000 2,000 2,000 2.000 2,000 2.000 1,000 2,000 2,000 1,000
Carbon Tetrachloride 5 25 25 25 25 5 25 25 1 25 25 25 1 25
Chloroform 70(4) 35 35 35 35 70 35 35 17 5 35 35 175
Chloromethane 30(2) 15 57 15 15 30 46 15 75 61 15 75
Dichloromethane 5(3) 25 25 25 25 5 25 25 1 25 25 25 1 25
Naphthalene 100 50 50 50 50 50 50 50 25 50 50 25
Tetrahydrofuran 46 23 23 23 23 23 23 23 11 5 23 23 11 5
Toluene 1,000 500 500 500 500 500 500 500 250 500 500 250
Xylenes (total) 10,000 5,000 5,000 5,000 5,000 5,000 5.000 5,000 2,500 5,000 5,000 2.500
Others
Field pH (S U ) 65-85 6 40 - 8 5 65-85 65-85 65-85 6 74 - 8 5 61-85 6 46 - 8 5 65-85 65-85 64-85
Fluoride (mg/l) 4 2 2 0 36 0 42 2 0 73 1 1 0 51 2 2 1
Chloride (mg/l) 46 8 10 71 35 58 31 105 41 128 143 35 39
Sulfate (mg/l) 2,860 2,524 2,903 1,933 2,082 06 2,533 2,946 972 532 2.556 70
TDS (mg/l) 5,085 42 3,670 4,450 2,976 3,284 19 3,852 4,400 1,918 1,320 3.960
Footnotes
1) Utah Ground Water Quality Standards (GWQS) as defined in UAC R317-6. Table 2 Ad hoc GWQS also provided herein, as noted, and as allowed by UAC R317-6-2 2
2) Ad hoc GWQS for ammonia (as N). molybdenum. 2-Butanone (MEK). chloromethane. and naphthalene based on EPA drinking water lifetime health advisories
3) Ad hoc GWQS for nickel, uranium, and dichloromethane (methylene chlonde, CAS No 75-09-2) based on final EPA drinking water maximum concentration limits (MCL)
4) Ad hoc GWQS for manganese, tm. vanadium, acetone, chloroform (CAS No 67-66-3), and tetrahydrofuran based on drinking %ater ad hoc lifetime health advisories prepared by or m collaboration with EPA Region 8 staff
5) Ad hoc GWQS for cobalt and iron based on EPA Region 3 Risk Based Concentration limits for tap water
6) Ground Water Compliance Limits (GWCL) were set after Director review and approval of two Background Groundwater Quality Reports dated October_2007 and April 30, 2008 from the Permittee
7) GWCLs listed in the table above in Normal Font are those proposed by the Permittee in the October 2007 and April 30, 2008 DUSA Background Groundwater Quality Reports, and approved by the Director
8) GWCLs listed in the table above in Bold Text are values modified by the Director after review of GWCLs proposed in the Permittee's October 2007 and Apnl 30,2008 Background Groundwater Quality Reports For wells MW-1,
MW-2. MW-3, MW-5, MW-11, MW-12, MW-14. MW-15, MW-17, MW-18, MW-19, MW-26, and MW-32, these modificaUons are documented in the June 16.2008 URS Completeness Review for the October. 2007 Revised
Background Groundwater Quality Report for Existing Wells For wells MW-3A, MW-23, MW-24, MW-25, MW-27, MW-28, MW-29, MW-30, and MW-31, these modifications are documented in the June 24, 2008 DRC Findings
Memorandum regarding the April 30, 2008 Revised Background Groundwater Quality Report for New Wells
9) Because background quality has not yet been determined at monitonng well MW-35, which was installed in September 2010 for Tailings Cell 4B, the Director has set GWCLs equal to the fraction ofthe GWQS (0 25) for Class U
Groundwater After submittal and approval of the Background Groundwater Quality Report, required by Part IH 5 of this Permit, the Director will re-open and modify the GWCLs to be equal to the mean concentration plus two
standard deviations (X+2a) for each contaminant
Part ID
PennitNo UGW370004
D DISCHARGE MINEVQZATION AND BEST AVAILABLE TECHNOLOGY STANDARDS - the tailings
disposal facility must be built, operated, and maintained according to the following Discharge
Mimmization 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 descnbed by design and construction mformation provided by the Perrmttee,
as summanzed m Table 3 below for Tailings Cells 1, 2, and 3
Table 3 DMT Engineenng Design and Specifications
Tailings
Cell
Report
Type Engineenng Report Design Figures
Construction
Specifications
Celll Design June, 1979 D'Appoloma
Consulting Engineers, Inc
Appendix A, Sheets 2,4, 8,
9,12-15
Appendix B
Cell 2 Design June, 1979 D'Appoloma
Consulting Engineers, Inc ^'^
Appendix A, Sheets 2, 4, 7-
10,12-15
Appendix E
As-Euilt February, 1982 D'Appoloma
Consulting Engineers, Inc
Figures 1, 2, and 11 N/A
Cell 3 Design May, 1981 D'Appoloma
Consulting Engineers, Inc
Sheets 2-5 Appendix B
As-Euilt March, 1983 Energy Fuels
Nuclear, Inc ^'^^
Figures 14 N/A
Footnotes
1) D'Appoloma Consuhing 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'Appoloma 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'Appoloma Consulting Engineers, Inc , May, 1981, "Engineer's Report Second Phase Design - Cell 3 Tailings Management System White
Mesa Uranium Project Blanding, Utah Energy Fuels Nuclear, Inc Denver, Colorado", unpublished consultants report, approximately 20 pp , 1
figure. 5 sheets, and 3 appendices
4) Energy Fuels Nuclear. Inc , March, 1983. "Construction Report Second Phase Tailings Management System White Mesa Uranium Project
Energy Fuels Nuclear, Inc ", unpublished company report, 18 pp . 3 tables. 4 figures. 5 appendices
a) Tailings Cell 1 - consisting of the following major design elements*
1) Cross-valley Dike and East Dike - constructed on the south side of the pond of native
granular matenals with a 3 1 slope, a 20-foot crest width, and a crest elevation of
about 5,620 ft above mean sea level (amsl) A dike of similar design was constructed
on the east margin ofthe pond, which forms a continuous earthen structure with the
south dike The remaining mtenor slopes are cut-slopes at 3 1 grade
2) Lmer System - including a single 30 mil PVC flexible membrane Imer (FML)
constructed 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 constructed immediately over the FML with a
thickness of 12-inches on the cell floor and 18-inches on the intenor sideslope
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer
Beneath this underlay, native sandstone and other foundation matenals were graded
to dram to a single low point near the upstream toe of the south cross-valley dike
Inside this layer, an east-west onented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike
Part ID
Permit No UGW370004
b) Tailings Cell 2 - which consists of the following major design elements
1) Cross-valley Dike - constructed at the south margin of Cell 2 of native granular
matenals with a 3 1 slope, a 20-foot crest width, and crest elevation of about 5,615 ft
amsl The east and west intenor 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 of5,620 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 hner 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 (mside sideslope) soil protective blanket was constructed of native
sands fi-om on-site excavated soils
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-mch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer
Beneath this underlay, native sandstone and other foundation matenals 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 onented pipe was installed to gather fluids at the
upstream toe ofthe cross-valley dike
4) Slimes Drain Collection System immediately above the FML a nommal 12-mch thick
protective blanket layer was constructed of native silty-sandy soil On top of this
protective blanket, a network of 1 5-inch PVC perforated pipe laterals was installed
on a gnd spacing interval of about 50-feet These pipe laterals gravity drain to a 3-
inch diameter perforated PVC collector pipe which also drains toward the south dike
and is accessed from the ground surface via a 24-inch diameter, vertical non-
perforated HDPE access pipe Each run of lateral drainpipe and collector piping was
covered with a 12 to 18-inch thick berm of native granular filter matenal 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 followmg major design elements.
1) Cross-valley Dike - constructed at the south margin of Cell 3 of native granular
matenals with a 3 1 slope, a 20-foot crest width, and a crest elevation of 5,610 ft
amsl The east and west intenor 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) Lmer System - includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes dram collection
system Top elevation of the FML liner m 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 Imers
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 matenals were graded
Part ID
PennitNo UGW370004
to drain to a single low point near the upstream toe ofthe south cross-valley dike
Inside this layer, an east-west onented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike
4) Slimes Dram Collection Layer and System - immediately above the FML, a nominal
12-inch (cell floor) to 18-inch (inside sideslope) soil protective blanket was
constructed of native sands from on-site excavated soils (70%) and dewatered and
cyclone separated tailings sands from the mill (30%) On top of this protective
blanket, a network of 3-inch PVC perforated pipe laterals was installed on
approximately 50-foot centers. This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a 12-inch diameter, inclined HDPE access pipe
Each run ofthe 3-inch lateral drainpipe and collector pipe was covered with a 12 to
18-mch thick berm of native granular filter media At cell closure, leachate head
mside the pipe network will be removed via a submersible pump installed inside the
12-inch diameter inclined access pipe
Existing Tailmgs Cell Construction Authonzed - tailmgs disposal in existing Tailings Cells
1, 2, and 3 is authonzed by this Permit as defined m Table 3 and Part LD 1, above
Authonzed operation and maximum disposal capacity in each of the existing tailings cells
shall not exceed the levels authonzed 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 engineenng design parameter at these existing tailings cells
shall require pnor Director approval, modification of this Permit, and issuance of a
construction permit
Existing Facility DMT Performance Standards - the Permittee shall operate and maintam
certam mill site facilities and the existing tailings disposal cells to minimize the potential for
wastewater release to groundwater and the environment, mcluding, but not limited to the
following additional DMT compliance measures
a) DMT Monitonng Wells at Tailings Cell 1 - at all times the Permittee shall operate and
maintain Tailings Cell 1 to prevent groundwater quality conditions m any nearby
momtonng well from exceeding any Ground Water Compliance Limit established in
Table 2 of this Permit
b) Tailmgs Cells 2 and 3 - including the following performance cntena.
1) Slimes Dram Maximum Allowable Head - the Permittee shall at all times maintain
the average wastewater recovery head in the slimes dram access pipe to be as low as
reasonably achievable (ALARA) in each tailmgs disposal cell, in accordance with the
currently approved DMT Momtonng Plan
2) Quarterly Slimes Dram 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 mimmum requirements
1 Includes a duration of at least 90-hours, as measured from the time that pumping
ceases, and
Part ID
PennitNo UGW370004
11 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 m the slimes drain access pipe, as determmed pursuant
to the currently approved DMT Monitonng Plan, meets the conditions in Equation 1,
below
Equation 1
[EEy+ EEy.l+ EEy-2]/[Ny + Ny.l+Ny.2]<[LEy-l+ EEy-2+ i:Ey.3 ] / [ Ny., + Ny.2 + Ny.3 ]
Where
EEy = Sum of all monthly and quarterly slimes dram tailmgs fluid elevation measurements that
meet the test performance standards found m the sub-paragraphs of Part ID 3(b)(2), dunng the
calendar year of mterest Hereafter, these water level measurements are referred to as slimes dram
recovery elevations (SDRE) Pursuant to the applicable frequency and method of the approved DMT
Momtormg Plan at the time of each SDRE test, these recovery tests are to be conducted and the SDRE
values reported m umts of feet above mean sea level (amsl) However, when monthly and quarterly
measurements are combmed m the above equation, the quarterly values shall be multiphed by a
coefficient of three (3)
EEy-i = Sum of all SDRE measurements made m the year previous to the calendar year of
mterest However, when monthly and quarterly measurements are combmed m the equation above,
each quarterly value shall be multiplied by a coefficient of three (3)
SEy.2 = Sum of all SDRE measurements made m the second year previous to the calendar year of
mterest However, when monthly and quarterly measurements are combmed m the equation above,
each quarterly value shall be multiplied by a coefficient of three (3)
EEy.3 = Sum of all SDRE measurements made mtbe third year previous to the calendar year of
mterest However, when monthly and quarterly measurements are combmed m 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 m Part
ID 3(b)(2), conducted dunng the calendar year of mterest However, when monthly and quarterly
measurements are used m the equation above, each quarterly test shall be counted as three (3) separate
tests
Ny.i = Total number of SDRE tests th^t meet the test performance standards found m Part
ID 3(b)(2), conducted m the year previous to the calendar year of mterest However, when monthly
and quarterly measurements are used m 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 m Part ID 3(b)(2), conducted m the second year previous to the calendar
year of mterest However, when monthly and quarterly measurements are used m 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 m Part
ID 3(b)(2), conducted m the third year previous to the calendar year of mterest However, when
monthly and quarterly measurements are used m the equation above, each quarterly test shall be
counted as three (3) separate tests
Pnor to January 1,2013, the following values for E and N values m Equation 1 shall
be based on SDRE data from the following calendar years
Part ID
PennitNo UGW370004
Report for
Calendar
Year
Source of Data By Calendar Year for Equation 1 Variables (ng It side) Report for
Calendar
Year Ev 1 Ev-2 EyO Nv-i Nv2 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 m Equation 1 shall constitute DMT failure and non-
compliance with this Permit For Cell 3, this requirement shall apply after initiation of
de-watenng operations.
c) Maximum Tailmgs Waste Solids Elevation - upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation of the tailmgs waste solids does not
exceed the top of the FML liner
d) DMT Momtonng Wells - at all tunes the Permittee shall operate and maintain Tailmgs
Cells 2 and 3 to prevent groundwater quality conditions in any nearby monitonng 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
mimmum 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 m
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 matenals at the facility
awaiting mill processing shall be limited to the eastem portion of the mill site area
descnbed m Table 4, below. Storage of feedstock matenals at the facility outside this
area, shall meet the requirements m Part ID 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 mimmum 4-foot
wide buffer zone on the mside margm of the Feedstock Storage Area between the storage
area fence and the Feedstock which shall be absent of feed matenal m order to assure that
matenals do not encroach on the boundary of the storage area
Comer Northing (ft) EasUng (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 ID
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 m
the currently approved Stormwater Best Management Practices Plan For any new
construction of reagent storage facilities, said secondary containment and control shall
prevent any contact of the spilled or otherwise released reagent or product with the
ground surface.
Best Available Technology Requirements for New Construction - any constmction,
modification, or operation of new waste or wastewater disposal, treatment, or storage
facilities shall require submittal of engineenng design plans and specifications, and pnor
Director review and approval All engineenng 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 Director
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 construction conform to the requirements of the June 25, 2007
Director design approval letter for the relimng of former existing Tailings Cell No 4A, and
as summanzed by the engmeermg drawings, specifications, and descnption in Table 5,
below
Table 5 Approved Tailmgs Cell 4A Engineenng 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
Sheet 5 of 7 June 15,2007 Rev 1 Lining System Details I
Sheet 6 of 7 June 15,2007 Rev 1 Lining System Details II
Sheet 7 of 7 June 15,2007 Rev 1 Lmmg 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 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 Geosyntec Consultants
11
Part ID
Permit No UGW370004
Leakage Detection System Underlying a
Geomembrane Lmer
June 22, 2006 Slope Stability Analysis Cell 4A - Intenm
Conditions
Geosyntec Consultants
June 23, 2006 Settlement Evaluation of Eerms Geosyntec Consultants
August 22, 2006 Pipe Stiength Calculations Geosyntec Consultants
September 27, 2007 DMC Cell 4A - GCL Hydration Geosyntec Consultants
Footnotes
1) As qualified by conditions found in May 2,2007 Division of Radiation Control letter
2) As clarified by February 8,2007 Division of Radiation Control Round 6 Interrogatory
Tailings Cell 4A Design and Constmction - approved by the Director 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 intenor slope of 2H to IV Width of these dikes
vanes, each has a mimmum crest width of at least 15 feet to support an access road Base
width also vanes from 89-feet on the east dike (with no extenor embankment), to 211-
feet at the west dike
b) Foundation - including existing subgrade soils over bedrock matenals 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 tailmgs matenal storage (as
measured below the required 3-foot freeboard)
d) Liner and Leak Detection Systems - including the following layers, in descending order
1) Pnmary Flexible Membrane Lmer (FML) - consisting of impermeable 60 mil high
density polyethylene (HDPE) membrane that extends across both the entire cell floor
and the mside side-slopes, and is anchored in a trench at the top of the dikes on all
four sides The pnmary FML will be m direct physical contact with the tailmgs
matenal over most of the Cell 4A floor area In other locations, the pnmary FML will
be m contact with the slimes drain collection system (discussed below)
2) Leak Detection System - includes a permeable HDPE geonet fabnc that extends
across the entire area under the pnmary 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 mside diameter (ID) PVC pipe placed down the mside slope, located between
the pnmary and secondary FML liners At its base this pipe will be surrounded with a
gravel filter set m the leak detection sump, having dimensions of 10 feet by 10 feet by
2 feet deep In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabnc The purpose of both the gravel and geotextile fabnc is to serve as a
fiher
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet Said FML also extends across the
12
Part ID
PennitNo UGW370004
entire Cell 4A floor, up the inside side-slopes and is also anchored m a trench at the
top of all four dikes ^
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay lmer (GCL)
composed of 0 2-inch of low permeability bentomte clay centered and stitched
between two layers of geotextile Pnor 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 stiip drains and
perforated collection pipes both installed immediately above the pnmary FML, as
follows-
1) Honzontal Stnp Drain System - is installed in a hemngbone pattem across the floor
of Cell 4A that dram to a "backbone" of perforated collection pipes These stiip
drains are made of a prefabncated two-part geo-composite dram matenal (solid
polymer drainage stnp) core surrounded by an envelope of non-woven geotextile
filter fabnc The stnp drains are placed immediately over the pnmary FML on 50-
foot centers, where they conduct fluids downgradient m a southwesterly direction to a
physical and hydraulic connection to the perforated slimes dram collection pipe A
senes of continuous sand bags, filled with filter sand cover the stnp drains The sand
bags are composed of a woven polyester fabnc filled with well graded filter sand to
protect the drainage system from plugging.
2) Honzontal Slimes Dram Collection Pipe System - includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes dram collection (SDC) pipe
found at the dovmgradient end ofthe stnp dram lines This pipe is in tum overlam by
a berm of gravel that runs the entne diagonal length of the cell, surrounded by a
geotextile fabnc cushion m immediate contact with the pnmary FML In tum, the
gravel is overlain by a layer of non-woven geotextile to serve as an additional filter
matenal This perforated collection pipe serves as the "backbone" to the slunes drain
system and runs from the far northeast comer downhill to the far southwest comer of
Cell 4A where it joms the slimes dram access pipe
3) Slimes Drain Access Pipe - consisting of an 18-mch ID Schedule 40 PVC pipe placed
down the mside slope of Cell 4A at the southwest comer, above the pnmary FML
Said pipe then merges with another honzontal pipe of equivalent diameter and
matenal, where it is enveloped by gravel and woven geotextile that serves as a
cushion to protect the pnmary FML A reducer connects the honzontal 18-inch pipe
with the 4-inch SDC pipe At some fiiture time, a pump will be set in this 18-inch
pipe and used to remove tailmgs wastewaters for purposes of de-watenng the tailmgs
cell
f) Cell 4A North Dike Splash Pads - three 20-foot wide splash pads will be constincted on
the north dike to protect the pnmary FML from abrasion and scounng 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 mlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope
13
Part ID
Permit No UGW370004
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
pnmary FML m a 4-foot deep trapezoidal channel No other spillway or overflow
stmcture will be constmcted at Cell 4A All stormwater runoff and tailmgs wastewaters
not retained in Cells 2 and 3, will be managed and contained in Cell 4A, including the
Probable Maximum Precipitation and flood event
BAT Performance Standards for Tailmgs Cell 4A - the Permittee shall operate and maintain
Tailmgs Cell 4A so as to prevent release of wastewater to groundwater and the environment
in accordance with the currently approved Cell 4A BAT, Momtonng, 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 Director in
accordance with Part IG 3 Performance standards for Tailmgs 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 lmer
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 honzontal 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) Shmes Drain Annual Average Recovery Head Cntena - after the Permittee imtiates
pumping conditions in the slimes drain layer m Cell 4A, the Permittee will provide* 1)
continuous declimng fluid heads m the slimes dram layer, in a manner equivalent to the
requirements found in Part ID 3(b), and 2) a maxunum head of 1 0 feet m the tailmgs (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 m Cell 4A, as measured from the top ofthe upper FML
Defimtion of 1 le (2) Waste - for purposes of this Penmt, 1 le (2) waste is defined as "
tailings or wastes produced by the extraction or concentration of uramum or thonum from
any ore processed pnmanly for its source matenal 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 descnbed by a March 7,2003 NRC letter from Paul H Lohaus to
William J Sinclair
Closed Cell Performance Requirements - before reclamation and closure of any tailmgs
disposal cell, the Permittee shall ensure that the final design, constmction, and operation of
the cover system at each tailmgs cell will comply with all requirements of an approved
Reclamation Plan, and will for a penod of not less than 200 years meet the following
minimum performance requirements
a) Minimize infiltration of precipitation or other surface water into the tailmgs, including,
but not limited to the radon bamer.
14
Part ID
PennitNo UGW370004
b) Prevent the accumulation of leachate head within the tailings waste layer that could nse
above or over-top the maximum FML lmer elevation internal to any disposal cell, i e
create a "bathtub" effect, and
c) Ensure that groundwater quality at the compliance monitonng wells does not exceed the
Ground Water Quality Standards or Ground Water Compliance Limits specified in Part
IC 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 tailmgs cells in compliance with all engmeermg design and
specifications m an approved Reclamation Plan The Director reserves the nght 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 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 mimmum 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 m 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 Director in accordance with
UAC 19-5-114
Reconstmction of stormwater management and/or chemical reagent storage facilities,
existing at the time of onginal Permit issuance, may be required by the Director after
occurrence of a major spill or catastrophic failure, pursuant to Part FV N 3 of this Permit
11 BAT Requirements for Feedstock Matenal Stored Outside the Feedstock Storage Area - the
Permittee shall store and manage feedstock matenals outside the ore storage pad in
accordance with the following mimmum performance requirements.
a) Feedstock matenals will be stored at all times in water-tight contamers, 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 pnor 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
15
Part ID
PemutNo UGW370004
2) A storage area designed, constmcted, and operated in accordance with engineenng
plans and specifications approved m advance by the Director All such engineenng
plans or specifications submitted shall demonstrate compliance with Part ID 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 Director, or
5) Other storage facilities and means approved in advance by the Director
12. BAT Design Standards for Tailmgs Cell 4B - the BAT design standard for Tailmgs Cell 4B
shall be defined by and constmcted in accordance with the requirements as summanzed by
the engineenng drawings, specifications, and descnption in Table 6, below
Table 6 Approved Tailings Cell 4B Engineenng Design and Specifications
Engineerin 2 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
Sheets of 8 January 2009 Rev 1 Base Gradmg 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 II
Sheet 7 of 8 January 2009 Rev 1 Lining System Details III
Sheet 8 of 8 January 2009 Rev 1 Lining System Details IV
Figure 1 January 2009 -Mill Site Drainage Basins (suppomng 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 Companson of Flow Though Compacted
Clay Lmer 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 Fabnc Calculations
August 2009 Constmction Quality Assurance Plan for the
Constmction of Cell 4E Lmmg 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 Geosyntec Consultants
16
Part ID
PennitNo UGW370004
Computation
January 2009 Slope Stability Analysis Calculation Package Geosyntec Consultants
Tailmgs Cell 4B Design and Constmction - approved by the Director 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 intenor slopes of 2H to IV The extenor
slopes of the southem and westem dikes will have typical slopes of 3H to IV Limited
portions of the Cell 4B intenor sideslopes m the northwest comer and southeast comer of
the cell, (where the shmes dram and leak detection sump will be located will also have a
slope of 3H to 1V The base width ofthe southem dikes vanes from approximately 92
feet at the westem end to approximately 190 feet at the eastem end of the dike, with no
extenor embankment present on any other side of the cell
b) Foundation - including existing subgrade soils over bedrock matenals Foimdation
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 determmed 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) Tailmgs Capacity - the floor and mside 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 matenal storage (as measured below the required 3-foot
freeboard)
d) Liner and Leak Detection Systems - including the following layers, in descending order
1) Pnmary Flexible Membrane Lmer (FML) - consisting of 60-rml high density
polyethylene (HDPE) membrane that extends across both the entue cell floor and the
inside side-slopes, and is anchored in a trench at the top of the dikes on all four sides
The pnmary FML will be m direct physical contact with the tailings matenal over
most of the Cell 4B floor area In other locations, the pnmary FML will be in contact
with the shmes dram collection system (discussed below)
2) Leak Detection System - includes a permeable HDPE geonet that extends across the
entire area under the pnmary 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 pnmary
and secondary FML liners At its base this pipe will be surrounded with a gravel filter
set m 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 fabnc The purpose of both the gravel and geotextile fabnc is
to serve as a filter
3) Secondary FML - consisting of a 60-mil HDPE membrane found unmediately 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 lmer (GCL)
composed of 0 2-inch of low permeability bentomte clay centered and stitched
17
Part ID
PennitNo UGW370004
between two layers of geotextile Pnor to disposal of any wastewater in Cell 4B, the
Permittee shall demonstrate that the GCL has achieved a moismre content of at least
50% by weight
e) Slimes Dram Collection System - including a two-part system of stnp drains and
perforated collection pipes both installed immediately above the pnmary FML, as
follows
1) Honzontal Stnp Dram System - is installed in a hemngbone pattem across the floor
of Cell 4B that drain to a "backbone" of perforated collection pipes These stnp
drains are made of a prefabncated two-part geo-composite drain matenal (solid
polymer drainage stnp) core surrounded by an envelope of non-woven geotextile
filter fabnc The stnp drams are placed immediately over the pnmary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated shmes drain collection pipe A
senes of continuous sand bags, filled with filter sand cover the stnp drains The sand
bags are composed of a woven polyester fabnc filled with well graded filter sand to
protect the drainage system from plugging
2) Honzontal Shmes Drain Collection Pipe System - includes a "backbone" piping
system of 4-inch ED Schedule 40 perforated PVC shmes drain collection (SDC) pipe
found at the downgradient end of the stnp drain lines This pipe is m tum overlain by
a berm of gravel that nms the entire diagonal length of the cell, surrounded by a
geotextile fabnc cushion in immediate contact with the pnmary FML In tum, the
gravel is overlain by a layer of non-woven geotextile to serve as an additional filter
matenal This perforated collection pipe serves as the "backbone" to the shmes dram
system and runs from the far northwest comer downhill to the far southeast comer of
Cell 4B where it joins the slimes dram access pipe
3) Shmes Drain Access Pipe - consisting of an 18-mch ID Schedule 40 PVC pipe placed
down the inside slope of Cell 4B at the southeast comer, above the pnmary FML
Said pipe then merges with another honzontal pipe of equivalent diameter and
matenal, where it is enveloped by gravel and woven geotextile that serves as a
cushion to protect the pnmary FML A reducer connects the honzontal 18-inch pipe
with the 4-inch SDC pipe At some fiiture time, a pump will be set in this 18-inch
pipe and used to remove tailmgs wastewaters for purposes of de-watenng the tailmgs
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 pnmary FML from abrasion and
scounng by tailmgs 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 mside slope of
Cell 4B, from the top of the dike, under the mlet pipe, and down the mside 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
fabnc installed within it at its midsection, set atop a cushion geotextile placed directly
over the pnmary FML in a 4-foot deep trapezoidal channel A 100-foot wide, 60-mil
18
Part ID
PennitNo UGW370004
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 runoff and
tailmgs wastewaters not retamed 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
Tailmgs Cell 4B so as to prevent release of wastewater to groundwater and the environment
in accordance with the currently approved Cell 4B BAT, Momtonng, Operations and
Maintenance 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 Director in
accordance with Part IG 3 Performance standards for Tailmgs 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
m a honzontal 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) Shmes Dram Annual Average Recovery Head Cntena - after the Permittee initiates
pumping conditions in the shmes drain layer m Cell 4B, the Permittee will provide 1)
continuous declimng fluid heads in the shmes drain layer, in a manner equivalent to the
requirements found m Part ID 3(b), and 2) a maximum head of 1 0 feet m 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 mamtam the New Decontamination Pad (NDP) to prevent release of wastewater to
groundwater and the environment m accordance with the currently approved DMT
Monitonng 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 Director in
accordance with Part IG 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 m any of the LDS access pipes of more than or equal to 6 2 feet as
measured from the water measunng point (top of access pipe)
b) Soil and debns will be removed from the wash pad ofthe NDP, in accordance with the
currently approved DMT Monitonng Plan Cracks in the wash pad greater than 1 /8 inch
(width) will be repaired withm five workmg days of discovery.
19
Part IE
PennitNo UGW370004
GROUND WATER COMPLL\NCE AND TECHNOLOGY PERFORMANCE MONITORING - begmnmg 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 momtormg wells, tailing cell wastewaters, seeps
and spnngs, monitor groundwater levels, momtor water levels of process solutions, and momtor
and keep records of the operation of the facility, as follows
1 Routine Groundwater Compliance Momtonng - the Permittee shall monitor upgradient,
lateral gradient, and downgradient groundwater momtonng 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 Momtonng Quality Assurance Plan - all groundwater monitonng and
analysis performed under this Permit shall be conducted in accordance with a Quality
Assurance Plan (QAP) currently approved by the Director Any non-conformance with
QAP requirements m a given quarterly groundwater monitonng penod will be corrected
and reported to the Director on or before submittal of the next quarterly groundwater
momtormg report pursuant to Part IF 1
b) Quarterly Momtonng - the Permittee shall monitor on a quarterly basis all monitonng
wells listed m Table 2 of this Permit where local groundwater average Imear velocity has
been found by the Director to be equal to or greater than 10 feet/year For purposes of this
Permit, quarterly monitonng is required at the followmg 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) Future Cell 4B Downgradient Wells to be Installed - quarterly momtonng shall begm
within 30 calendar days of mstallation of new groundwater momtormg wells MW-36,
MW-37, or any other well required by Part IH 4 of this Permit, and contmue until
otherwise determined by the Director pursuant to Part IH 5
c) Semi-annual Momtonng - the Permittee shall momtor on a semi-annual basis all
momtonng wells listed m Table 2 of this Permit where local groundwater average linear
velocity has been found by the Director to be less than 10 feet/year For purposes of this
Permit, semi-annual momtonng is requued 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 Momtonng Wells MW-20 and MW-22
d) Compliance Momtormg 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
Part IE
PemutNo UGW370004
I GWCL Parameters - all contaminants specified in Table 2
II General Inorganics - chlonde, sulfate, carbonate, bicarbonate, sodium, potassium,
magnesium, calcium, and total anions and cations
e) Special Provisions for Groundwater Monitonng - the Permittee shall ensure that all
groundwater monitonng conducted and reported complies with the following
requirements*
1) Depth to Groundwater Measurements - shall always be made to the nearest 0 01 foot.
2) Mimmum 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 Vanance - 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 vanance 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
matenals
2 Groundwater Monitonng General Monitonng Wells MW-20 and MW-22 - the Permittee
shall monitor wells MW-20 and MW-22 on a semi-annual basis Said samplmg shall comply
with the following Permit requirements
a) Routine groundwater compliance monitonng requirements of Part IE 1
b) Groundwater head momtonng requirements of Part I E.3
c) Well momtonng procedure requirements of Part IE 5
3 Groundwater Head Momtonng - on a quarterly basis and at the same frequency as
groundwater momtonng required by Part IE 1, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers.
a) Point of Compliance Wells - identified in Table 2 and Part IE 1 of this Permit
b) Piezometers - P-1, P-2, P-3, P-4, and P-5
c) Head Momtonng Well - MW-34
d) General Momtonng Wells - MW-20 and MW-22
e) Contaminant Investigation Wells - any well required by the Director as a part of a
contaminant investigation or groundwater corrective action
f) Any other wells or piezometers required by the Director
4 Groundwater Monitonng Well Design and Constmction Cntena - all new groundwater
monitonng wells installed at the facility shall comply with the following design and
constmction cntena
21
Part IE
Permit No UGW370004
a) Located as close as practical to the contamination source, tailings cell, or other potential
ongin 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 the EPA
RCRA Ground Water Momtonng Techmcal Enforcement Guidance Document, 1986,
OSWER-9950 1
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity
5 Momtonng Procedures for Wells - begmnmg with the date of Perrmt issuance, all momtonng
shall be conducted by the Permittee m conformance with the following procedures
a) Sampling - grab samples shall be taken of the groundwater, only after adequate removal
or purging of standmg 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 monitonng 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 Momtonng Wells - if any monitor well is damaged or is otherwise rendered
inadequate for its mtended purpose, the Permittee shall notify the Director in wnting
within five calendar days of discovery
e) Field Momtormg Equipment Calibration and Records - immediately pnor to each
momtonng event, the Permittee shall calibrate all field monitonng equipment m
accordance with the respective manufacturer's procedures and guidelines The Permittee
shall make and preserve on-site wntten records of such equipment calibration in
accordance with Part HG 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 Spnngs Monitonng - the Permittee shall conduct annual momtonng
of all seeps and spnngs identified in the currently approved Sampling Plan for Seeps and
Spnngs in the Vicimty ofthe White Mesa Uramum Mill Said momtonng shall include, but
IS not limited to
a) Field Measurements - including pH, temperature, and specific conductivity
b) Water Quality Sampling and Analysis - the Perrmttee 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 IE 1 of this Permit
e) Mimmum Detection Limits - all seeps or spnngs water quality analyses reported shall
have a minimum detection limit or reporting limit that is less than or equal to the
respective
22
Part IE
PemutNo UGW370004
1) Ground Water Quality Standards concentrations defined in Table 2 of this Permit,
and
2) For TDS, Sulfate, and Chlonde, the Mimmum Detection Limit for those constituents
for seeps and spnngs monitonng 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 spnngs sampling, in accordance with the requuements
of Section 4 3 of the currently approved QAP, pursuant to Part IE 1 of this Permit Said
QC samples shall include, but are not limited to tnp blanks, duplicate samples, and
equipment nnse blanks
g) Pnor Notification - at least 15 calendar days before any fieldwork or water quality sample
collection, the Permittee shall provide wntten notice to allow the Director to observe or
split sample any or all seeps or spnngs
DMT Performance Standards Momtonng - the Permittee shall perform technology
performance momtonng in accordance with the currently approved DMT Momtonng Plan
to determine if DMT is effective in mimmizing and controlling the release of contammants
pursuant to the provisions of Parts ID 1 and ID 3 of this Permit, including, but not limited
to the following activities
a) Weekly Tailings Wastewater Pool Elevation Monitonng Cells 1 and 3 - the Permittee
shall momtor and record weekly the elevation of wastewater in Tailings Cells 1 and 3 to
ensure compliance with the maximum wastewater elevation cntena 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 Slimes Drain Water Level Monitonng Cells 2 and 3 - the Permittee shall
momtor and record quarterly the depth to wastewater in the shmes drain access pipes as
descnbed in Part ID 3 of this Permit and the currently approved DMT Momtonng Plan
at Tailings Cells 2 and 3 to determine the recovery head For purposes of said
momtonng, the Perrmttee shall at each tailmgs cell
1) Perform at least 1 separate shmes drain recovery test at each disposal cell in each
quarterly penod of each calendar year that meets the requirements of Part ID 3,
2) Designate, operate, maintain, and preserve one water level measunng point at the
centerline of the shmes drain access pipe that has been surveyed and certified by a
Utah licensed engmeer or land surveyor,
3) Make all shmes drain recovery head test (depth to fluid) measurements from the
same designated water level measunng 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 imtiation of tailings de-watenng
operations
c) Weekly Wastewater Level Monitonng Roberts Pond - the Permittee shall monitor and
record weekly wastewater levels at the Roberts Pond to determine compliance with the
23
Part IE
PennitNo UGW370004
DMT operations standards in Part ID 3 Said measurements shall be made m accordance
to the currently approved DMT Monitonng Plan
d) Weekly Feedstock Storage Area Inspection - the Permittee shall conduct weekly
inspections of all feedstock storage to 1) Confirm the bulk feedstock matenals are
maintained withm the approved Feedstock Storage Area defined by Table 4, and 2)
Venfy that all altemate feedstock matenals located outside the Feedstock Area defined in
Table 4, are stored in accordance with the requirements found in Part ID 11
e) Feedstock Matenal Stored Outside the Feedstock Storage Area Inspections
1) Weekly Inspection - the Permittee will conduct weekly mspections to venfy that each
feed matenal container complies with the requirements of Part ID 11
2) Hardened Surface Storage Area - m the event the Permittee constmcts a hardened
surface storage area for feed matenals, pursuant to Part ID 11, pnor Director
approval will be secured for the following
I Engineenng Design and Specifications - in accordance with the requirements of
Part ID 4, and
II Operation and Maintenance Plan.
f) Inspections of Tailing Cell and Pond Liner Systems - the Permittee shall inspect the liner
system at Tailing Cells 1, 2, and 3 on a daily basis pursuant to the requirements of
Sections 2 1 and 2 2 of the currently approved DMT Monitonng 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 dunng a liner system inspection, the Permittee
shall 1) report and repair said defect or damage pursuant to Part IG 3 by implementation
ofthe currently approved Liner Mamtenance Provisions, and 2) report all repairs made
pursuant to Part IF 2
g) Weekly New Decontamination Pad Inspection - the Permittee shall conduct weekly
inspections ofthe New Decontamination Pad as descnbed in Part I D.M of this Permit
and the currently approved DMT Momtonng Plan
Cell 4A BAT Performance Standards Momtonng and Maintenance - in accordance with the
cmrently approved Cell 4A BAT, Momtonng, Operations and Maintenance Plan, the
Permittee shall immediately implement all monitonng and recordkeeping requirements
therein The Cell 4A BAT momtonng includes the following
a) Weekly Leak Detection System (LDS) Momtonng - including
1) Leak Detection System Pumping and Momtormg Equipment - the Permittee shall
provide continuous operation of the leak detection system pumping and momtonng
equipment, including, but not limited to, the submersible pump, pump controller,
head monitonng, and flow meter equipment approved by the Director Failure of any
LDS pumping or monitonng equipment not repaired and made fully operational
withm 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 Director Under no circumstance shall fluid head in the
24
Part IE
Permit No UGW370004
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 momtonng 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 Mimmum Vertical Freeboard Cntena - the Permittee shall operate and
maintain wastewater levels to provide a 3-foot Minimum of vertical freeboard m
Tailings Cell 4A Said measurements shall be made to the nearest 0 1 foot
b) Quarterly Slimes Dram Recovery Head Momtonng - immediately after the Permittee
imtiates pumping conditions in the Tailmgs Cell 4A slimes dram system, quarterly
recovery head tests and fluid level measurements will be made m accordance with the
requirements of Parts ID 3 and IE 7(b) of this Permit and the currently approved Cell
4A BAT, Momtonng, Operations and Maintenance Plan
c) Lmer Maintenance and Repair - all repairs to the lmer 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 Perrmt
Repairs shall be performed by qualified lmer repair persormel and shall be reported m a
Liner Repair Report, certified by a Utah hcensed Professional Engmeer The Liner Repair
Report shall be submitted to for Director approval in accordance with Part IF 3 ofthe
Permit Any leak, hole, or other damage to the liner will be reported to the Director
pursuant to the requirements found m Part IG 3
9 On-site Chemicals Inventory - the Permittee shall momtor 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) Determmation of volume and mass of each raw chemical currently held in storage at the
facility
10 Tailings Cell Wastewater Quality Momtonng - 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 shmes drain wastewater access pipe at each of Tailings Cells 2,3,4 A, and 4B For
Cells 3, 4A, and 4B, this requirement shall apply immediately after initiation of de-
watenng operations at these cells, and
c) One leak detection wastewater access pipe at Tailings Cells 4A and 4B
d) All such samplmg shall be conducted in August of each calendar year in compliance with
the currently approved White Mesa Uranium Mill Tailing and Shmes Drain Sampling
Program Said annual monitonng shall include, but is not limited to
1) Water Quality Sampling and Analysis - the Permittee shall collect grab samples and
perform laboratory analysis of all
25
Part IE
Permit No UGW370004
I Water quality parameters identified in Table 2 of this Permit, and
II Semi-volatile compounds identified in EPA Method 8270D
2) Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified laboratory
3) Analytical Methods - all laboratory analysis shall be conducted using analytical
methods listed in the currently approved QAP pursuant to Part IE 1 of this Permit.
4) Mimmum Detection Limits - all water quality analyses reported shall have a
mimmum detection limit or reporting limit that is less than or equal to the respective
I Ground Water Quality Standards concentrations defined m Table 2 of this Permit,
II For TDS, Sulfate, and Chlonde, the Minimum Detection Limit for those
constiments for Tailing Cell wastewater momtonng will be as follows 1,000
mg/L, 1,000 mg/L, and 1 mg/L, respectively, and
III Lower limits of quantitation for groimdwater for semi-volatile orgamc
compoimds listed in Table 2 of EPA Method 8270D, Revision 4, dated Febmary,
2007
5) Quality Control Samples - the Permittee will conduct quality control (QC) sampling
and analysis as a part of all tailmgs wastewater sampling, in accordance with the
requirements of Section 4 3 of the currently approved QAP, pursuant to Part IE 1 of
this Permit Said QC samples shall include, but are not limited to tnp blanks,
duplicate samples, and equipment nnse blanks >
6) Pnor Notification - at least 30 calendar days before any water quality sample
collection, the Permittee shall provide wntten notice to allow the Director to observe
or split sample any tailings cell, slimes dram, or leak detection wastewaters
7) Sample Omission - in the course of each aimual sampling event, the Permittee shall
sample and analyze all tailings cell, shmes dram, and leak detection wastewater
sources identified in the currently approved Tailings and Slimes Dram 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 dunng said annual
event, without pnor wntten approval from the Director
11 Groundwater Momtormg Modifications - before any modification of groundwater momtonng
or analysis procedures, methods, or equipment, the Permittee must obtain pnor wntten
approval from the Director
12 Cell 4B BAT Performance Standards Momtonng and Maintenance - immediately followmg
Director approval of the Cell 4B BAT, Momtonng, Operations and Maintenance Plan, the
Permittee shall immediately implement all momtonng and recordkeeping requirements
therein The Cell 4B BAT monitonng shall include the following
a) Weekly Leak Detection System (LDS) Momtonng - including
1) Leak Detection System Pumping and Monitonng Equipment - the Permittee shall
provide continuous operation ofthe leak detection system pumping and monitonng
equipment, including, but not limited to, the submersible pump, pump controller,
26
Part IE & IF
PemutNo UGW370004
head monitonng, and flow meter equipment approved by the Director Failure of any
LDS pumping or related monitonng 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 Director Under no circumstance shall fluid head in the
leak detection system (LDS) sump exceed a 1-foot level above the lowest pomt in the
lower flexible membrane liner on the cell floor Any occurrence of leak detection
system fluids above this 1-foot limit shall constitute failure of BAT, and a violation
of this Permit
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS Under no cucumstances shall the average
daily LDS flow volume exceed 26,145 gallons/day
4) 3-foot Mimmum Vertical Freeboard Cntena - the Permittee shall operate and
maintain wastewater levels to provide a 3-foot Minimum of vertical freeboard in
Tailmgs Cell 4B Said measurements shall be made to the nearest 0 1 foot
b) Quarterly Shmes Drain Recovery Head Monitonng - immediately after the Pemuttee
imtiates pumping conditions m the Tailings Cell 4B shmes dram system, quarterly
recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts ID 3 and IE 7(b) of this Pemut and the currently approved Cell 4B
BAT, Momtonng, Operations and Maintenance Plan
c) Liner Maintenance and Repairs - all repairs to the liner shall be completed m 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 Pemut
Repairs shall be performed by qualified liner repair personnel and shall be reported in a
Liner Repair Report, certified by a Utah licensed Professional Engmeer The Lmer Repair
Report shall be submitted for Director approval m accordance with Part IF 3 of the
Perrmt. Any leak, hole, or other damage to the liner will be reported pursuant to the
requirements found in Part IG 3
F REPORTING REQUIREMENTS - The following reporting procedures for routine and compliance
reports must be met
1 Routine Groundwater Monitonng Reports - the Permittee shall submit quarterly monitonng
reports of field and laboratory analyses of all well monitonng and samples descnbed in Parts
IE1,IE2,IE3, and IE 5 of this Permit for Director review and approval Reports shall be
submitted according to the following schedule
27
Part IF
PemutNo UGW370004
Table 7 Groundwater Monitonng Reporting Schedule
Quarter Penod Due Date
First January - March June 1
Second Apnl - 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 monitonng reports shall include, but are not limited to, the following minimum
information
a) Field Data Sheets - or copies thereof that provide the followmg well name, date and time
ofwell purging, date and time ofwell sampling, type and condition of well pump, depth
to groimdwater 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 followmg information
laboratory result or concentration, umts of measurement, minimum detection limit or
reporting limit, analytical method, date of analysis, counting error for radiological
analyses, total cations and amons 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 m feet above
mean sea level, and isocontour lines to delineate groundwater flow directions observed
dunng the quarterly samplmg event
d) Quality Assurance Evaluation and Data Validation - including a wntten descnption and
findings of all quality assurance and data validation efforts conducted by the Perrmttee in
compliance with the currently approved Groundwater Monitonng Quality Assurance
Plan Said report shall venfy the accuracy and reliability of the groundwater quality
compliance data, after evaluation of sample collection techmques and equipment, sample
handling and preservation, analytical methods used, etc
e) Non-conformance disclosure - with each quarterly groundwater momtonng report the
Permittee shall fully and completely disclose all non-conformance with requirements of
the currently approved QAP, mandated by Part IE 1(a)
f) Electronic Data Files and Format - m addition to wntten results required for every
sampling report, the Permittee shall provide an electromc copy of all laboratory results
for groundwater quality momtormg conducted Said electronic files shall consist of
Comma Separated Values (CSV) format, or as otherwise approved by the Director
g) Time Concentration Plots - with each quarterly groundwater monitonng report the
Permittee shall submit time concentration plots for each monitonng well for the
following constiments chlonde, fluonde, sulfate, and uranium
Routine DMT Performance Standards Monitonng Report - the Permittee shall provide
quarterly monitonng reports of all DMT performance standards momtonng reqmred by Parts
ID 3 and IE 7 of this Permit DMT monitonng shall be conducted in compliance with this
28
Part IF
PennitNo UGW370004
Permit and the currently approved DMT Monitonng Plan When a lmer 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 monitonng reports and results shall be submitted for Director approval on the
schedule provided in Table 7, above.
3 Routine Cell 4A and 4B BAT Performance Standards Monitonng Reports - the Permittee
shall provide quarterly monitonng reports of all BAT performance standards monitonng
requued by Parts IE 8 and IE 12 of this Permit BAT Monitonng at Cells 4A and 4B shall
be conducted in compliance with the currently approved BAT Monitonng, Operations and
Maintenance Plan When a liner repair is performed at Tailings Cell 4A or 4B, a Repair
Report is required by Parts IE 8(c) and IE 12(c) of the Permit This Repair Report shall be
included with the next quarterly BAT Report Said momtonng report and results shall be
submitted for Director approval on the schedule provided m Table 7 above At a minimum,
reporting of BAT momtonng for Cells 4 A and 4B will include
a) LDS Monitonng - mcluding
1) Report on the operational status of the LDS pumping and monitonng equipment
dunng the quarter, mcludmg 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) Shmes Drain Recovery Head Momtonng as per the requirements of Parts ID 6 and
IE 8(b).
4 DMT and BAT Performance Upset Reports - the Permittee shall report any non-compliance
with the DMT or BAT performance cntena of Part ID 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 m a permit application or
m any report to the Director, the Permittee shall submit such facts or information within 10
calendar days of discovery
6 Groundwater Momtonng Well As-Built Reports - as-built reports for new groundwater
monitonng wells shall be submitted for Director approval within 60 calendar days of well
completion, and at a mimmum will include the followmg information
a) Geologic Logs - that detail all soil and rock lithologies and physical properties of all
subsurface matenals encountered dunng dnlling Said logs shall be prepared by a
29
Part IF
PemutNo UGW370004
Professional Geologist licensed by the State of Utah, or otherwise approved beforehand
by the Director
b) Well Completion Diagram - that detail all physical attnbutes of the well constmction,
including
1) Total depth and diameters of bonng,
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 matenals
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 honzontal coordinates and elevation of water level measunng pomt, 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 Spnngs Momtonng Reports - a seeps and spnngs momtonng report
shall be submitted for Director review and approval with the 3*^^ Quarter Routine
Groundwater Momtonng 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 IF 1(a) of this Permit,
b) Laboratory Results - for each sample collected that comply with the requirements of Part
IF 1(b) of this Permit,
c) Water Table Contour Map - that includes groundwater elevations for each well at the
facility and the elevations of the phreatic surfaces observed at each of the seeps and
spnngs sampled The contour map will include all water level data measurements from
seeps, spnngs, and momtonng wells at the site from the 3*^^ Quarter Routine Groundwater
Momtonng event of each year The contour map shall be at a map scale, such that, all
seeps and spnngs listed m the approved Sampling Plan for Seeps and Spnngs in the
Vicimty ofthe White Mesa Uramum Mill and the monitonng 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 spnngs water
quality data that meets the requirements of Part IF 1(d),
f) Electronic Data Files and Format - that meet the requirements of Part IF 1(e) of this
Permit, and
g) Survey data for the seeps and spnngs 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
PartIF
PennitNo UGW370004
vertical elevations The surveyed coordinates and elevations of the seeps and spnngs
shall be withm 1 foot ofthe highest point ofthe saturated seepage face on the day ofthe
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 IHI Said report
shall provide all inventory information gathered pursuant to Part I E.9.
9 Tailmgs Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part IE. 10 shall be reported to the Director 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 requued by Part IF. 1 (a), (b), (d), and (e) of this Permit, and
c) For shmes drain samples, the Permittee shall report depth to wastewater measurements
from the water level measurement point Said wastewater level shall be measured
immediatel)^ before sample collection
10 Revised Hydrogeologic Report - pursuant to Part IV D of this Permit, and at least 180
calendar days pnor to Permit expiration, the Permittee shall submit for Director 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 m the shallow aquifer, mcludmg, but not lirmted to local
geologic conditions; time relationships and distnbution of shallow aquifer head
measurements from facility wells and piezometers, local groundwater flow directions,
and distnbution of aquifer permeability and average linear groundwater velocity across
the site, and
b) Well specific groundwater quality conditions measured at facihty momtormg wells for all
groundwater momtonng parameters required by this Pemut, mcluding, but not limited to
temporal contaminant concentrations and trends from each momtormg well, statistical
tests for normality of each contaminant and well, mcludmg umvanate or eqmvalent tests,
calculation of the mean concentration and standard deviation for each well and
contaminant
11 Annual Shmes Drain Recovery Head Report - on or before March 1 of each year the
Permittee shall submit for Director approval an annual shmes drain recovery head report for
Tailings Cells 2 and 3 Said report shall conform to the requirements of Part ID 3(b),
IE 7(b), and n G of this Permit, and
a) Provide the individual shmes dram recovery head monitonng data for the previous
calendar year, including, but not limited to date and time for the start and end of
recovery test, imtial 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
31
Part IF & IG
PemutNo UGW370004
c) Include a time senes chart to show trends of the recovery water level elevations at each
shmes drain
d) Include the results of a quality assurance evaluation and data validation Said
examination shall provide wntten descnptions and findings that
1) Evaluate all data collected, data collection methods, and all related calculations
required by this Permit, and
2) Venfy the accuracy and reliability of both the data and calculations reported
e) Demonstrate compliance stams with the requirements of Part ID 3(b) and LE 7(b) of this
Pemut
12 Decontammation Pads Annual Inspection Report - the New Decontamination Pad and
Existing Decontamination Pad will be taken out of service and inspected annually dunng the
second quarter of each year, to ensure mtegnty of the concrete wash pad surfaces If physical
defects in the wash pad as defined by Part ID 14 of the Permit are identified dunng the
inspection, repairs shall be made pnor to resuming the use of the facility Said defects
include, but are not limited to concrete detenoration, cracking, subsidence, etc The results
of the annual inspection and all repaus will be documented on inspection forms in
accordance with the currently approved DMT Monitonng Plan The inspection forms and
documentation of all repairs completed shall be included m the Quarter DMT Momtormg
Report due September 1, of each calendar year
G OUT OF COMPLIANCE STATUS
1 Accelerated Momtonng Status - is required if the concentration of a pollutant in any
compliance momtonng sample exceeds a GWCL in Table 2 of the Permit, the facility shall
then
a) Notify the Director in wnting within 30 calendar days of receipt of data, and
b) Immediately initiate accelerated sampling of the pollutant as follows.
1) Quarterly Baseline Momtonng Wells - for wells defined by Part IE 1(b) the
Permittee shall imtiate monthly monitonng
2) Semi-annual Baseline Momtonng Wells - for wells defined by Part IE 1(c) the
Permittee shall initiate quarterly momtonng
Said accelerated momtonng shall continue at the frequencies defined above until the
compliance stams of the facility can be determined by the Duector
2 Violation of Permit Limits - out-of-compliance stams exists when the concentration of a
pollutant in two consecutive samples from a compliance momtonng pomt exceeds a GWCL
m Table 2 of this Permit
3 Failure to Maintain DMT or BAT Required by Permit
a) Permittee to Provide Information - m 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 Director a notification and descnption of the failure
according to R317-6-6 16(C)( 1) Notification shall be given orally withm 24- hours of the
32
Part IG
Permit No UGW370004
Permittee's discovery of the failure of DMT or BAT, and shall be followed up by wntten
notification, including the information necessary to make a deterrmnation 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 Director shall use the information provided under R317-6-6 16 C(l) and any
additional information provided by the Permittee to determine whether to imtiate a
compliance action against the Permittee for violation of Pemut conditions A compliance
action shall not be initiated, if the Director determines that the Permittee has met the
standards for an affirmative defense, as specified m R317-6-6 16(C)(3)(c)
c) Affirmative Defense - in the event a compliance action is initiated against the Perrmttee
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 m failure to act,
3) - The Permittee has taken adequate measures to meet Permit conditions m a timely
maimer or has submitted to the Director, for the Director'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 Director of the out of compliance status within 24-hours
after detection of that stams, followed by a wntten notice withm 5 calendar days of the
detection
b) The Permittee shall continue accelerated sampling pursuant to Part IG 1, unless the
Director determines that other penodic samplmg is appropnate, until the facility is
brought into compliance
c) The Permittee shall prepare and submit within 3 0 calendar days to the Director 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
monitonng point and that DMT or BAT will be reestablished
d) The Director 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 momtonng point or to reestablish DMT or BAT as defined m
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 Director
33
PartlH
PemutNo UGW370004
H COMPLIANCE SCHEDULE REQUIREMENTS The Permittee will comply with the schedules as
descnbed and summanzed below
1 On-site Chemicals Inventory Report - the Permittee shall complete a histoncal review, and
conduct an inventory of all chemical compounds or reagents stored, used, or currently m use
at the facility Said report shall include
a) Identification of all chemicals used m the milling and milling related processes at White
Mesa, and
b) Determmation of the total volumes currently in use and histoncally used, as data is
available At the time of Permit renewal, the Permittee shall submit an updated
inventory report pursuant to Part IF 8
2 Infiltration and Contaminant Transport Modeling Work Plan and Report - the Permittee shall
submit for Director approval an infiltration and contammant transport modeling report that
demonstrates the long-term ability of the tailmgs 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 engineenng 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 Director
approval, that
a) Identifies all applicable and pertinent histonc smdies and modelmg reports relevant to
tailings cell cover design and tailmgs cell system performance
b) Determmes and justifies all information necessary for infiltration and contammant
transport modeling, including but not limited to representative input values for vadose
zone and aquifer soil-water partitioning (Kd) coefficients, tailings source term
concentrations, tailmgs waste leach rates, vadose zone and aquifer groimdwater
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 descnbes all computer models used to simulate long-term
performance of the tailmgs cells cover system All predictive models used shall be
publicly available computer codes that adequately represent field charactenstics and
physical processes at the tailings disposal site Said descnption will also include specific
mformation on model design, including, but not lunited to govemmg equations and their
applicability to site conditions, gnd design, duration of simulation, and selection of time
steps
d) Determines the conceptual model used and justifies why it is representative or
conservative of actual field conditions at the site Said conceptual model will identify the,
physical domain(s) and geometnes simulated including the tailmgs cell design and
constmction, all boundary and initial conditions assigned in the model(s), and the
shallow aquifer locations where fUmre potential contaminant concentrations have been
predicted
34
PartlH
PennitNo 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 ID 8 of this Permit
f) Provides, descnbes and justifies the following
1) Model Results - including electronic input and output files from all infiltration,
groimdwater flow and contaminant transport models used the report
2) Model Calibration - including descnption of results and efforts used to demonstrate
how the model adequately reproduced field measured heads, flows, and contammant
concentrations
3) Steady State Conditions - including a demonstration that the models achieved a
steady state condition dunng 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 descnption of vanous model simulations nm and
evaluated to define the range of model uncertainty Such uncertainty includes, but is
not limited to boundary and imtial conditions, model input values, and spatial and
^temporal distnbution 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 charactenstics 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 IH 2
and submit a final report for Director 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 momtonng parameters,
tailings cell cover system engmeenng design and constmction specifications, tailings cell
operational requirements, etc In the event the Director requires additional information, the
Permittee will provide all requested information withm a time frame approved by the
Director Upon Director 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 m water supply well WW-2, and to ensure adequate well casing and
annular seals, m compliance with the regulations of the Utah State Engineer (UAC R655-4-
9), with special emphasis on creating both a physical bamer 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 venfy that the casing and
annular seal is intact and creates both a physical bamer 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
PartlH
Permit No UGW370004
b) Show that the well casing and annular seal have physical and hydraulic integnty 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 techmques required under
Part IH 3(a) to demonstrate existence of the required hydraulic isolation, and
c) Submit a wntten report for Duector 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 Momtonng Wells - the Permittee shall install at least
two additional hydraulically downgradient wells adjacent to Tailmgs 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 Momtormg Wells MW-36 and MW-37 - install at least two new
compliance monitonng 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 IE 4 ofthe 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 Bmshy Basin
Member of the Momson Formation, or as approved by the Director
5) All new wells shall provide early detection of tailmgs cell contamination of
shallow groimdwater from Tailings Cell 4B
6) All new wells shall provide discrete groundwater momtonng for tailings Cell 4B
b) On or before June 30, 2011 or as otherwise approved by the Director, the Permittee
shall submit a monitonng well As-Built report for all new wells installed to document
said well constmction for Director approval Said report shall comply with the
requirements of Part IF 6 In the event the Director requires additional information,
the Permittee will provide all requested information withm a time frame approved by
the Director
c) The Permittee shall provide at least a 14 calendar day wntten notice to allow the
Director to observe all dnlling and well installation activities In the event the
Director determines that additional monitonng 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 Director
5 Background Groundwater Quality Report for Well MW-35 and New Monitonng Wells -
within 30 calendar days of Director approval of the new momtonng well As-built Report,
36
PartlH
Permit No UGW370004
required by Part IH 4, above, the Permittee shall commence a quarterly groundwater
sampling program that will comply with the following Permit requirements
a) Routine groundwater compliance monitonng requirements of Part IE I
b) Well momtonng procedure requirements of Part IE 5
c) After completion of eight consecutive quarters of groundwater sampling and analysis of
well MW-35 and the new wells requued by Part IH 4, the Permittee shall submit a
Background Report for Director approval, that will include
1) Data preparation and statistical analysis of groundwater quality data, including, but
not limited to, evaluation of data charactenstics and internal data consistency,
treatment of non-detectable values, and statistical methods used These statistics shall
be calculated using the Decision Tree/Flowchart used for the previous Background
Reports that was conditionally approved by the DRC on August 24,2007
2) Shallow aquifer average linear groundwater velocity calculated for the new wells,
based on well specific hydraulic conductivity, hydraulic gradient, and effective
aquifer porosity.
d) If after review of the report, and the Director determines that additional information is
required, the Permittee shall provide all requested information, resolve all issues
identified, and re-submit the report for Director review and approval withm a timeframe
approved by the Director After approval of this report, the Director will re-open this
Permit and establish an appropnate monitonng frequency in accordance with the cntena
found in Part IE 1 (b) or (c), and establish Groimdwater Compliance Limits m Table 2 for
well MW-35 and the each of the new wells
Detailed Southwest Hydrogeologic Investigation and Report - the purpose of this
investigation is to define, demonstrate, and charactenze 1) hydraulic connection and local
groundwater flow directions between the area near Tailmgs Cell 4B, and the westem margm
of White Mesa, including Westwater and Cottonwood Seeps, and Rum Spnng, 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 bonngs and / or momtormg wells to completely enclose and define
both 1) the subsurface stmctural high area of the upper Bmshy Basm Shale Member
geologic contact and 2) the honzontal limits of saturation in the Burro Canyon
Formation Said smdy shall include, but is not limited to a subsurface area between
Tailmgs Cell 4B, and the Westwater and Cottonwood Seeps, and Ruin Spnng At a
mimmum the charactenzation / defimtion 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 ofthe 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 mimmum
inside diameter of 3 inches The Perrmttee shall complete hydraulic testing of all
such wells and piezometers m accordance with Part IF 6(c) of this Permit
37
PartlH
PemutNo UGW370004
b) Demonstrate the fiill geologic and physical extent of the apparent unsaturated
stmcmral high between Tailmgs Cell 4B and the westem margin of White Mesa,
including Westwater and Cottonwood Seeps and Ruin Spnng
c) Demonstrate the location and direction of all groundwater flow paths between
Tailmgs Cell 4B and nearby Westwater and Cottonwood Seeps and Ruin Spnng.
Determine average linear groimdwater velocity to said groundwater discharge
locations
d) Perform geologic logging of all bonngs / wells, and submit geologic logs performed
and certified by a Utah licensed Professional Geologist
e) Submit the investigation report for Director 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
PartIF 6
2) A revised equipotential map to descnbe both the physical extent ofthe dry zone
and all groundwater flow directions near Tailings Cell 4B and Westwater and
Cottonwood Seeps, and Ruin Spnng Said map shall demonstrate flowpaths
(steammbes) to all respective groundwater discharge locations at the westem
margm of White Mesa
3) A revised s^tmctural 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 groimdwater head
data for the Burro Canyon aquifer for the facility and physical extent of White
Mesa
5) Appropnate geologic and hydrogeologic maps and cross-sections (to scale)
6) Results and interpretation of aquifer permeability testmg as per Part IF 6(c) of
this Permit
g) The Permittee shall provide at least a 14 calendar day wntten notice to allow the
Director to observe all dnllmg and well installation activities
h) In the event the Director determines that additional mformation is required, this
information will be submitted withm a time frame approved by the Director
7 Modification to the DMT Monitonng and Cell 4A and Cell 4B BAT O&M Plans - on or
before August 1, 2011, the Permittee shall submit proposed modifications to the currently
approved DMT Monitonng and Cell 4A and Cell 4B BAT O&M Plans for Director approval
Said changes shall conform to the requirements of Parts LD 3(b), ID 6(c), ID 13(c), IE 7(b),
IE 8(b), IE 12( b), and IF 11 of this Pemut
38
Partn
PemutNo UGW370004
PART n REPORTING REQUIREMENTS
A REPRESENTATIVE SAMPLING Samples taken in compliance with the monitonng 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 imless 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 monitonng device or method required to be maintamed under
this Permit shall, upon conviction, be punished by a fine of not more than $ 10,000 per violation,
or by impnsonment for not more than six months per violation, or by both.
D REPORTING OF MONITORING RESULTS Momtonng results obtained dunng reporting penods
specified in the Permit, shall be submitted to the Director, Utah Division of Water Quahty at the
following address no later than the date specified following the completed reporting penod
Attention Compliance and Monitonng Program
State of Utah
Division of Water Quality
Department of Environmental Quality
Salt Lake City, Utah 84114-4870
The quarterly due dates for reporting are June 1, September 1, December 1, and March 1
E COMPLL\NCE SCHEDULES Reports of compliance or noncomphance with, or any progress reports
on intenm and final requirements contained in any Compliance Schedule of this Pemut shall be
submitted no later than 14 calendar days following each schedule date
F ADDITIONAL MONITORING BY THE PERMITTEE If the Permittee momtors any pollutant more
frequently than required by this Permit, using approved test procedures as specified m this
Permit, the results of this monitonng shall be included m the calculation and reportmg of the data
submitted Such increased frequency shall also be indicated
G RECORDS CONTENTS
1 Records of monitonng information shall include
a) The date, exact place, and time of sampling, observations, or measurements
b) The individual(s) who performed the sampling, observations, or measurements,
c) The date(s) and time(s) analyses were performed,
d) The name of the certified laboratory which performed the analyses,
e) The analytical techniques or methods used, and,
f) The results of such analyses
H RETENTION OF RECORDS The Permittee shall retain records of all monitonng information,
including all calibration and maintenance records and copies of all reports required by this
39
Partn
PennitNo UGW370004
Permit, and records of all data used to complete the application for this Permit, for a penod of at
least five years from the date of the sample, measurement, report or application This penod may
be extended by request of the Director at any time
I NOTICE OF NONCOMPLL\NCE 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], dunng normal business hours (8 00 am
- 5 00 pm Mountain Time)
2 A wntten submission shall also be provided to the Director within five calendar days ofthe
time that the Permittee becomes aware of the circumstances The wntten submission shall
contain
a) A descnption ofthe noncompliance and its cause,
b) The penod of noncompliance, including exact dates and times,
c) The estimated tune 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 n D, Reportmg of Momtonng Results
J OTHER NONCOMPLIANCE REPORTING. Instances of noncompliance not required to be reported
withm 5 calendar days, shall be reported at the time that momtormg reports for Part n D are
submitted
K INSPECTION AND ENTRY The Permittee shall allow the Director, or an authonzed 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 monitonng and control
equipment), practices, or operations regulated or required under this Permit, and,
4 Sample or momtor at reasonable tunes, for the purpose of assunng Permit compliance or as
otherwise authonzed by the Act, any substances or parameters at any location
40
Partm
PennitNo UGW370004
PART m COMPLLANCE RESPONSIBILITIES
A DUTY TO COMPLY The Permittee must comply with all conditions of this Permit Any Permit
noncompliance constitutes a violation of the Act and is grounds for enforcement action, for
permit termination, revocation and re-issuance, or modification, or for demal of a perrmt renewal
application The Permittee shall give advance notice to the Director of the Division of Water
Quality of any planned changes in the permitted facility or activity which may result m
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 pumshed by a fine not
exceeding $50,000 per day Nothing in this Permit shall be constmed to relieve the Permittee of
the civil or cnminal penalties for noncompliance
C NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE It shall not be a defense for a Permittee m
an enforcement action that it would have been necessary to halt or reduce the permitted activity
in order to maintain compliance with the conditions of this Permit
D DUTY TO MITIGATE The Permittee shall take all reasonable steps to mimmize or prevent any
discharge in violation of this Pemut which has a reasonable likelihood of adversely affecting
human health or the environment
E PROPER OPERATION AND MAINTENANCE The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the Permittee to achieve compliance with the conditions of this Pemut
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
41
PartrV
PemutNo UGW370004
PARTIV GENERAL REQUIREMENTS
A PLANNED CHANGES The Permittee shall give notice to the Director as soon as possible of any
planned physical alterations or additions to the permitted facility Notice is required when the
alteration or addition could sigmficantly change the nature of the facility or increase the quantity
of pollutants discharged
B ANTICIPATED NONCOMPLL\NCE The Permittee shall give advance notice of any planned changes
m 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 pemut modification, revocation and re-issuance, or
termination, or a notification of planned changes or anticipated noncompliance, does not stay any
permit condition
D DUTY TO REAPPLY If the Permittee wishes to continue an activity regulated by this Permit after
the expiration date of this Permit, the Permittee must apply for and obtain a new permit The
application should be submitted at least 180 calendar days before the expiration date of this
Permit
E DUTY TO PROVIDE INFORMATION The Permittee shall fiirmsh to the Director, withm a reasonable
time, any information which the Director may request to determine whether cause exists for
modifying, revoking and reissuing, or tenmnating this Permit, or to determine compliance with
this Permit The Permittee shall also fiimish to the Duector, 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 Director, it shall promptly submit such facts or information
G SIGNATORY REQUIREMENTS All applications, reports or information submitted to the Director
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 propnetorship by a general partner or the propnetor,
respectively
c) For a municipality. State, Federal, or other public agency by either a pnncipal executive
officer or ranking elected official
2 All reports required by the Permit and other information requested by the Director shall be
signed by a person descnbed above or by a duly authonzed representative of that person A
person is a duly authonzed representative only if
a) The authonzation is made in wnting by a person descnbed above and submitted to the
Director, and.
42
Part IV
Permit No UGW370004
b) The authonzation 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, supenntendent, position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company (A duly authonzed representative may thus be
either a named individual or any individual occupying a named position)
3 Changes to Authonzation If an authonzation 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 authonzation satisfying the requirements of Part FV G 2 must be submitted to
the Director pnor to or together with any reports, information, or applications to be signed by
an authonzed representative
4 Certification Any person sigmng 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 gathenng the information, the information submitted is, to the best of my
knowledge and belief, tme, accurate, and complete I am aware that there are sigmficant
penalties for submitting false information, including the possibility of fine and
impnsonment 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 requued to be maintained under this Permit, mcludmg momtormg 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 impnsonment for not more than six months per violation, or by both
I AVAILABILITY OF REPORTS Except for data determmed 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 Director 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 nghts of any sort,
or any exclusive pnvileges, nor does it authonze any injury to pnvate property or any invasion of
personal nghts, nor any infiingement of federal, state or local laws or regulations
K SEVERABILITY The provisions of this Permit are severable, and if any provision of this Pemut, 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 Director at least 30 calendar days in advance of the
proposed transfer date,
43
PartrV^
PemiUNo UGW370004
2 The notice includes a wntten agreement between the existing and new Permittee contammg a
specific date for transfer of permit responsibility, coverage, and liabihty between them, and,
3 The Director 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 m 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 authonty 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 appropnate 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 ofthe Permit or to mclude pollutants covered by new standards
The Permittee may apply for a vanance under the conditions outlined m R317-6-6 4(D)
2 Changes have been determined m background groundwater quality
3 The Director determines permit modification is necessary to protect human health or the
environment
44
RADIOACTIVE MATERIAL LICENSE NO UT 1900479 AND
UTAH GROUND WATER DISCHARGE PERMIT UGW370004
STATEMENT OF BASIS
Active Uranium Mill
Energy Fuels Resources (USA), Inc
225 Umon Blvd , Suite 600
Lakewood, CO 80228
August 2012
Purpose
This Statement of Basis descnbes proposed changes to Radioactive Matenal License (RML) No UT
1900479 (hereafter License) and the Utah Ground Water Discharge Permit (GWDP) Permit No
UGW370004 (hereafter Permit) for the Denmson Mines (USA) Inc (hereafter Licensee or Permittee)
uranium milling facility near Blanding, San Juan County, Utah This License authonzes the receipt,
storage, processing, and disposal of lie(2) byproduct matenal in accordance with statements,
descnptions, and representations contained m the licensee's application, as submitted and approved
by the Utah Division of Radiation Control (DRC) The Permit was granted for the operation of a
uranium mill and tailings disposal facility by the Permittee
On June 27,2012, the Director of the Utah Division of Radiation Control (Director) authonzed the
Licensee to indirectly transfer control of the License to Energy Fuels, Inc As a result of the
subsequent transfer of control of the License, the Licensee requested amendments to the License and
Permit to modify the Licensee's and Permittee's name and mailing address The Division of
Radiation Control has reviewed the amendment requests and has concluded that a public comment
penod IS not necessary, because the changes are considered minor
In accordance with R313-17-2(l)(a), the Director is required to provide an opportunity for pubhc
comment for this License if the changes constitute a proposed major licensing action as descnbed m
R313-17-2( 1 )(a) Proposed changes to the Licensee's/Permittee's name and mailing address are not
represented in the major licensing actions listed in R313-17-2( 1 )(a)(ii)(A) through (J) Changes are
typically considered minor in nature by the Director if these result in either a more restnctive license
condition, the license condition remains just as protective, or there are administrative changes to
clanfy the license condition Therefore, the changes to both the Permit and the License are
considered to be minor
Page 1 of7
U \rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\DUSA License\License Amendment 5
- Name Change Denmson to Energy Fuels & Director DRC\Statement of Basis amendment 5 Draft 2 docx
The changes considered below succeed the previous license and will be incorporated into
Amendment 5 ofthe License
License Change Summary
General modifications throughout the License and Permit
• Minor corrections for typographical and non-substantive errors,
• References to "Executive Secretary" were modified to "Director" in response to changes
made to Utah Code Annotated Title 19, Chapter 3, as amended in Senate Bill 21 of the 2012
Utah General Session, and
• References to the "Utah Radiation Control Board" were modified to "Utah Division of
Radiation Control" in response to changes made to Utah Code Annotated Title 19, Chapter 3,
as amended in Senate Bill 21 of the 2012 Utah General Session
Specific modifications made to the License are listed by item or license condition in the following
table
License
Condition/Item
Modified or
Permit
Modiflcation
Minor/Major
Change Description of Modification
Item 1 0 of
UT 1900479
And Permittee
Name on
UGW370004
Minor Change Licensee/Permittee name to reflect indirect ownership
transfer Persormel providing oversight of mill operations will
remain the same and activities conducted under the License
will be conducted with the same commitments and restnctions
that the Licensee previously followed
Item 2 0 of
UT 1900479
And Permittee
Mailing
Address on
UGW370004
Minor After the amendment request was received, the Division
received notification that the mailing address of the Licensee's
Corporate Office was changing Since this effects only where
mail IS sent, this was considered to be a minor change
9 1 Minor Previously, the use location was generally stated in License
Condition 9 1 of the License and more specifically stated m
License Condition 2 of the License The specific use location
was moved to License Condition 9 1 so that the Corporate
mailing address could be listed for the mailing address Since
the use location was not modified, this was considered to be a
minor change
Page 2 of7
U \rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\DUSA License\License Amendment 5
- Name Change Denmson to Energy Fuels & Director DRC\Statement of Basis amendment 5 Draft 2 docx
An additional modification was made to License Condition 9 1
to restnct the Licensee from beginning constmction of new
tailings disposal embankments until after reclamation plan 5 0
IS approved by the Director Since the wording that was added
to License Condition 9 1 clanfies the present situation
regarding the constmction of new embankments and results in
an outcome that is as protective or more restnctive than present
requirements, the Division considered this to be a minor
change
93 Minor License Condition 9 3 was reformatted and moved to a new
section, "Section 13 - Closeout Condition," to allow for
expansion of the condition as documents are added and to
improve the readability ofthe License Condition The License
Condition retains the same degree of protection as was in place
for Amendment 4, therefore, the Division considers this
modification to be a minor change The empty License
Condition 9 3 was marked as "Reserved" and left as an empty
place holder in the License
13 1 Minor This license condition was reformatted and moved from
License Condition 9 3 of the License Since the License
Condition contains the same requirements as previously stated
and IS as protective as what was previously contained in the
License, the Division considered this to be a minor change
Specific License and Permit Changes
1 General Modifications
The majonty of modifications made in the License amendment and the Permit modification
are administrative changes initiated by the Division of Radiation Control In the 2012
General Session of the Utah Legislature, Senate Bill 21 (SB 21) was passed As a result of
the changes in SB 21, references to the "Executive Secretary" were modified to read
"Director " This is a non-substantial change in that the "Executive Secretary of the Utah
Radiation Control Board" has histoncally been the "Director of the Utah Division of
Radiation Control " SB 21 replaced references to the "Executive Secretary ofthe Utah
Radiation Control Board" with "Director of the Division of Radiation Control", therefore,
duties and responsibilities previously held by the "Executive Secretary" were transferred to
the "Director" of the Division of Radiation Control The modifications maintain the same
level of protection that existed in Amendment 4 of the License, therefore, the changes are
considered to be "Minor "
Page 3 of 7
U \rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMill\DUSA License\License Amendment 5
- Name Change Denmson to Energy Fuels & Director DRC\Statement of Basis amendment 5 Draft 2 docx
License Condition 9 1
License Condition 9 1 was modified to include the specific address of the location of use
which was previously stated in Item 1 of the license Item 1 of the License previously
contained the address of the location of use which should have been listed m License
Condition 9 1, therefore, dunng the modification of the License, a correction was made to
insert the mailing address in Item 1 of the License and place the address for the location of
use m License Condition 9 1 Since nothing regarding the operations, oversight or location
of use was modified, this is considered to be a "Minor" modification
Additionally, a clanfication was added to License Condition 9 1 Wording was added to the
License to clanfy that pnor to new constmction of any tailings disposal embankment is
prohibited until the reclamation plan is approved by the Director At this time, the Licensee
would not be able to begin new constmction of any tailings disposal embankment until
approval was granted by the Director The wording was added to clanfy that in order to
obtain approval for the new constmction, the Licensee must complete and have the
reclamation plan approved This is not adding new restnctions on the Licensee, but is
clanfies conditions that must be met pnor to the approval of new constmction of any tailmgs
embankment The additional wording provides the same level of protection as previously
existed in the License, therefore, the modification is considered to be "Minor "
License Condition 9 3
The information found in License Condition 9 3 of the License is typically found at the end of
radioactive matenals licenses issued by the Director Therefore, for consistency, readability,
and ease of updating the License Condition, License Condition 9 3 was reformatted and
moved to a new section. Section 13, of the License as a "Closeout Condition" The
information previously included in License Condition 9 3 was not modified License
Condition 13 1 now contains the information and allows the same degree of protection, but
increases the clanty of the License Since the same degree of protection exists, the
modification to the License is considered to be "Minor "
Since License Condition 9 3 was moved, the License Condition was marked as "Reserved" for
fiiture use
License Condition 13 1
License Condition 13 1 contains the information previous found in License Condition 9 3
Please see Item 3 of this document for additional information
References
Page 4 of7
U \rad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMillNDUSA License\License Amendment 5
- Name Change Denmson to Energy Fuels & Director DRC\Statement of Basis amendment 5 Draft 2 docx
Denmson Mills (USA) Corp , Licensee's letters dated May 25,2012 & June 27,2012, Radioactive
Matenals License UT 1900479 - Request for approval of an "indirect change of control" of the
License from Deimison Mines (USA) Corp to Energy Fuels Inc
DRC, June 27,2012, Radioactive Matenal License (RML) Number UT 1900479 - Approval for an
indirect transfer of control of RML UT 1900479 from Denmson Mines (USA) Corp. to Energy Fuels
Inc
Denmson Mills (USA) Corp , Licensee's letters dated August 3,2012, Radioactive Matenals License
UT 1900479 - Request to change name on RML UT 1900479 from Denmson Mmes (USA) Corp to
Energy Fuels Resources (USA) Inc
Energy Fuels Resources (USA) Inc , Electronic Mail Transmission from David Frydenland to John
Hultquist dated August 15,2012 Radioactive Matenals License UT 1900479 - Notice of change of
maihng address and Corporate Office information
Energy Fuels Resources (USA) Inc , Licensee's letter dated August 14, 2012, Utah Ground Water
Discharge Permit (UGWDP) UGW370004 - Request to change Permittee's name and mailing
address
Utah Senate Bill 21, 2012 General Session RML UT 1900479 & UGWDP UGW370004 -
Modifications to the Utah Radiation Control Act (Act) found in Utah Code Annotated, Title 19,
Chapter 3 Previous references to the Executive Secretary of the Utah Radiation Control Board were
modified to read "Director" of the Utah Division of Radiation Control Duties and responsibilities
previously delegated to the Executive Secretary were reassigned to the Director
Page 5 of7
U Vad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMiIl\DUSA LicenseNLicense Amendment 5
- Name Change Denmson to Energy Fuels & Director DRC\Statement of Basis amendment 5 Draft 2 docx
Attachment A
Redline/Stnkeout text of Energy Fuels Resources (USA) Inc lie (2) License
Page 6 of 7
U \rad\COMMON\Uramum millsM le(2)UTl 900479 Denison Mines - White Mesa UMill\DUSA License\License Amendment 5
- Name Change Denmson to Energy Fuels & Director DRC\Statement of Basis amendment 5 Draft 2 docx
PennitNo UGW370004
STATE OF UTAH
DIVISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALITY BOARD
SALT LAKE CITY, UTAH 84114-4870
GROUND WATER DISCHARGE PERMIT
In compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,
Energy Fuels Resources (USA) Inc Denison Mines (USA) Corp.
225 Umon Boulevard, Suite 600
Lakewood CO 80228
Independence Plaza, Suite 950
105017*^ 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
Mendian, San Juan County, Utah
The permit is based on representations made by the Permittee and other information contamed m 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 m accordance with conditions
set forth in the Permit and the Utah Ground Water Quality Protection Regulations
This modified Ground Water Quality Discharge Permit amends and supersedes all other Ground
Water Discharge permits for this facility issued previously
This Permit shall become effective on August ^30, 2012
This Permit shall expire March 8, 2010 (This Permit is in Timely Renewal)
Application for Permit Renewal was received September 1, 2009, and resubmitted on July 13,
2012 at the request ofthe DRC
I Signed this day of ,30442012
Director
Division of Radiation Control
Table of Contents
PART I SPECIFIC PERMIT CONDITIONS 1
A GROUND WATER CLASSIFICATION 1
B BACKGROUND WATER QUALITY 1
C PERMIT LIMITS 23
1 Ground Water Compliance Limits 23
2 Tailmgs Cell Operations 23
3 Prohibited Discharges 23
D DISCHARGE MINIMIZATION AND BEST AVAILABLE TECHNOLOGY STANDARDS 66
1 DMT Design Standards for Existing Tailings Cells 1, 2, and 3 66
2 Existing Tailings Cell Constmction Authonzed 8^
3 Existing Facility DMT Performance Standards 8§
4 Best Available Technology Requirements for New Constmction 1144
5 BAT Design Standards for Tailings Cell 4A 1144-
6 BAT Performance Standards for Tailmgs Cell 4A 1444
7 Defimtion of 11 e (2) Waste 1444
8 Closed Cell Performance Requirements 1444
9 Facility Reclamation Requirements 154^
10 Stormwater Management and Spill Control Requirements 154-5^
11 Requirements for Feedstock Matenal Stored Outside the Feedstock Storage Area 154-^
12 BAT Design Standards for Tailings Cell 4B 1646
13 BAT Performance Standards for Tailings Cell 4B . 194^
14 BAT Performance Standards for the New Decontamination Pad 194-9
E GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING 2130
1 Routine Groundwater Compliance Monitonng 2130
2 Groundwater Monitonng General Monitonng Wells MW-20 and MW-22 2234
3 Groimdwater Head Monitonng 2234
4 Groimdwater Monitonng Well Design and Constmction Cntena 2234
5 Monitonng Procedures for Wells 2333
6 White Mesa Seep and Spnng Monitonng 2333
7 DMT Performance Standard Monitonng 2433-
8 BAT Performance Standard Momtonng 2534
9 On-site Chemicals Inventory 2635
10 Tailings Cell Wastewater Quality Momtonng 2635
11 Groimdwater Momtonng Modifications . . 2736
12 BAT Performance Standard Monitonng 2736
F REPORTING REQUIREMENTS 2837
1 Routine Groimdwater Monitonng Reports 2837
2 Routine DMT Performance Standard Momtonng Report 292%
3 Routine BAT Performance Standard Monitonng Reports . 3039
4 DMT and BAT Performance Upset Reports 3039
5 Other hiformation 3029
6 Groundwater Monitonng Well As-Built Reports 3039
7 White Mesa Seeps and Spnngs Monitonng Reports 3130
8 Chemicals Inventory Report 32^
9 Tailings Cell Wastewater Quality Reports 3234
10 Revised Hydrogeologic Report 3234
11 Annual Shmes Drain Recovery Head Report 3234
12 Decontamination Pads Annual Inspection Report 33^
G OUT OF COMPLIANCE STATUS 3333
1 Accelerated Monitonng Status 33^
2 Violation of Permit Limits 3333
3 Failure to Maintain DMT or BAT Required by Permit . 33^
4 Facility Out of Compliance Status . 343^
H COMPLL\NCE SCHEDULE REQUIREMENTS 35^
1 On-site Chemicals Inventory Report 3534
2 Infiltration and Contaminant Transport Modelmg Work Plan and Report 3534
3 Plan for Evaluation of Deep Supply Well WW-2 3635
4 Installation of New Groimdwater Monitonng Wells 37^
5 Background Groundwater Quality Report for New Monitonng Wells 38^
6 Detailed Southwest Hydrogeologic Investigation . 3837
PART n REPORTING REQUIREMENTS 41^
A REPRESENTATIVE SAMPLING 4439
B ANALYTICAL PROCEDURES . . 4139
C PENALTIES FOR TAMPERING 4139
D REPORTING OF MONITORING RESULTS . 41^
E COMPLL\NCE SCHEDULES 41^
F. ADDITIONAL MONITORING BY THE PERMITTEE 41^
G RECORDS CONTENTS 4139
H RETENTION OF RECORDS . 4240
I NOTICE OF NoNCOMPLL\NCE REPORTING 4240
J OTHER NONCOMPLL\NCE REPORTING 4240
K INSPECTION AND ENTRY 4240
PARTm C0MPLL\NCERESPONSIBILITIES . 4344
A DUTY TO COMPLY 4344
B PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS 4344
C NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE . 4344
D DUTY TO MITIGATE . . . 4344
E PROPER OPERATION AND MAINTENANCE 4344
PARTIV GENERAL REQUIREMENTS 4443
A PLANNED CHANGES . 4443
B ANTICIPATED NONCOMPLIANCE 4443
C PERMIT ACTIONS . 4443
D DUTY TO REAPPLY 4443
E DUTY TO PROVIDE INFORMATION 4443
F OTHER INFORMATION . 4443
G SIGNATORY REQUIREMENTS 4443
H PENALTIES FOR FALSIFICATION OF REPORTS . 4543
I AVAILABILITY OF REPORTS . 454^
J PROPERTY RIGHTS . 454^
K SEVERABILITY 454^
L TRANSFERS 4543
M STATE LAWS 4644
N REOPENER PROVISIONS 4644
11
List of Tables
Table 1 Ground Water Classification 1
Table 2 Groundwater Compliance Limits 33^
Table 3 DMT Engineenng Design and Specifications . 66
Table 4 Feedstock Storage Area Coordinates 1040
Table 5 Approved Tailings Cell 4A Engineenng Design and Specifications 1144
Table 6 Approved Tailings Cell 4B Engineenng Design and Specifications 164-6
Table 7 Groundwater Monitonng Reporting Schedule 292%
111
Part IA & IB
PemutNo UGW370004
PART I SPECIFIC PERMIT CONDITIONS
A GROUND WATER CLASSIFICATION - the groundwater classification of the shallow aquifer under
the tailings facility has been determined on a well-by-well basis, as defined in Table 1, below
Table 1 Ground Water Classification
Class II Groundwater
Average TDS (mg/L)
DUSA Data
Class III Groundwater
Average TDS (mg/L)
DUSA Data
Well
ID
Average
Concentration^^)
Standard
Deviation^^) Well ID
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 = Numt)er of Samples
2) Based on histonc total dissolved solids (TDS) data provided by the Permittee for penod between October, 1979 and December. 2007 This
data was obtained from the Permittee's background groundwater quality reports dated October 2007 and Apnl 30.2008
3) Background concentrations of uranium in well MW-18 (55 1 \ig/L) and thallium in MW-19 (2 1 ug/L) exceed the GWQS. 30 ^g/L and 2 0
\ig/L, respectively Therefore these wells have been classified as Class III groundwater rather than Class II groundwater
4) Wells MW-20 and MW-22 are not point of compliance momtonng wells, but instead are general monitonng wells as per Part IE 2 Average
concentrations and standard deviations for wells MW-20 and MW-22 were provided by the Permittee for the penod 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 |ig/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 onginally named TW4-15 and was installed as part of the chloroform contaminant investigation at the facility Under this
Permit. MW-26 is defined as a Point of Compliance (POC) well for the tailings cells (see Part I E 1)
7) Background concentrations of uranium in well MW-27 (34 ug/L) and selenium in MW-31 (71 ug/L) exceed the GWQS. therefore these wells
have been classified as Class 111 groundwater rather than Class II groundwater
8) Well MW-32 was onginally 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 IB & IC
PemutNo UGW370004
background groundwater quality is determined on a well-by-well basis, pursuant to Enviromnental
Protection Agency (EPA) guidance, and documented in the Permittee's background groimdwater
quality reports dated October 2007 and Apnl 30,2008
C PERMIT LIMITS - the Permittee shall comply with the following permit limits
1 Ground Water Compliance Limits - contammant concentrations measured m each momtormg
well shall not exceed the Ground Water Compliance Limits (GWCL) defined m 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 momtonng for
each specific contaminant
2 Tailings Cell Operations - only 11 e (2) by-product matenal authonzed by Utah Radioactive
Matenals 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) matenal is prohibited
Table 2 Groimdwater Compliance Limits (GWCL)
Upgradient Wells Down or Lateral Gradient Wells
MW-1
(Class If)
MW-18
(Class no
MW-19
(Class in)
MW-27
(Class in)
MW-2
(Class III)
MW-3
(Class no
MW-3A
(Class no
MW-5
(Class 10
MW-11
(Class 10
MW-12
(Class 110
MW-14
(Class no
MW-15
(Class no
Contammant GWQS^'^ GWCL^*^ GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL^'^ GWCL GWCL GWCL
Nutrients (mg/L)
Ammonia (as N) 25 6 25 0 27 0 31 12 5 12 5 1 16 06 1 02 6 25 06 125 0 21
Nitrate + Nitrite (as N) 10 25 25 2 83 56 0 12 0 73 1 3 25 25 5 5 0 27
Heavy Metals (ug/L)
Arsenic 50 12 5 25 25 25 25 25 25 17 15 25 25 25
Beryllium 4 1 2 2 2 2 2 2 1 1 2 2 2
Cadmium 5 42W 25 25 25 25 4 67 83 2 1 25 7 25 25
Chromium 100 50 50 50 50 50 50 50 25 25 50 50 50
Cobalt 730 182 5 365 365 365 365 365 365 182 5 182 5 365 365 365
Copper 1,300 325 650 650 650 650 650 650 325 325 650 650 650
Iron 11.000 2.750 414 68 5,500 5,500 151 6 427 13 5,500 2,750 2,750 5,500 5.500 81 7
Lead 15 5 59 75 75 75 75 75 75 41 3 75 75 75 75
Manganese 800 289 350 400 400 378 76 4,233 6.287 376 74 131 29 2,088 80 2,230 30 400
Mercury 2 05 1 1 1 1 1 1 1 05 1 1 1
Molybdenum 40(2) 10 20 20 20 20 20 20 10 10 20 25 30
Nickel 100 25 50 50 50 60 100 105 44 1 46 2 60 50 97
Selenium 50 12 5 25 28 96 25 26 6 37 89 12 5 12 5 25 25 128 7
Silver 100 25 50 50 50 50 50 50 25 25 50 50 50
Thallium 2 05 1 95 2 1 1 1 1 6 1 4 05 05 1 1 1
Tm 17,000 4,250 8,500 8.500 8,500 8,500 8,500 8,500 4,250 4,250 8,500 8,500 8,500
Uranium 30(3) 7 28 55 1 21 43 34 18 45 47 32 35 75 75 23 5 98 65 7
Vanadium 60 W 15 30 30 30 30 30 30 15 15 30 30 40
Zinc 5,000 251 2,500 2.500 2,500 2,500 173 19 155 87 38 1.250 2,500 35 04 2,500
Radiologics (pCi/L)
Gross Alpha | 15 |3 75| 75 | 2 36 | 2 |32| 1 75|3 75|3 75| 75 | 75 | 75
Volatile Organic Compounds (ug/L)
Acetone 700 175 350 350 350 350 350 350 175 175 350 350 350
Benzene 5 1 25 25 25 25 25 25 25 1 25 1 25 25 25 25
2-Butanone (MEK) 4,000 1,000 2,000 2.000 2,000 2,000 2,000 2.000 1,000 1,000 2,000 2,000 2,000
Carbon Tetrachlonde 5 1 25 25 25 25 25 25 25 1 25 1 25 25 25 25
Chloroform 70(4) 17 5 35 35 35 35 35 35 17 5 17 5 35 35 35
Chloromethane 30(2) 75 15 15 15 15 15 94 75 75 15 15 15
Dichloromethane 1 25 25 25 25 25 25 25 1 25 1 25 25 25 25
Naphthalene 100 25 50 50 50 50 50 50 25 25 50 50 50
Tetrahydrofuran 46(''> 11 5 23 23 23 23 23 23 115 11 5 23 23 23
Toluene 1,000 250 500 500 500 500 500 500 250 250 500 500 500
Xylenes (total) 10.000 2,500 5,000 5,000 5,000 5,000 5,000 5.000 2,500 2,500 5,000 5,000 5,000
Others
Field pH (S U ) 65-85 6 77 - 8 5 6 25 - 8 5 6 78 - 8 5 65-85 65-85 65-85 65-85 65-85 65-85 65-85 65-85 6 62 - 8 5
Fluonde (mg/L) 4 0 56 0 45 139 0 85 0 43 0 68 1 6 1 42 1 2 02 2
Chlonde (mg/L) 22 1 69 23 104 41 38 20 76 70 71 39 16 80 5 27 57 1
Sulfate (mg/L) 838 1,938 90 2.534 10 462 2,147 3,663 3,640 1,518 1,309 2,560 2,330 2,549 02
TDS (mg/L) 1,567 3,198 77 4.257 42 1,075 3,800 6,186 5,805 2,575 2,528 4.323 4,062 4,530
Table 2 Continued Groundwater Compliance Limits (GWCL)
Down or Lateral Gradient Wells
MW-17 MW-23 MW-24 MW-25 MW-26 MW-28 MW-29 MW-30 MW-31 MW-32 MW-35
(Class no (Class no (Class no (Class no (Class in) (Class no (Class no (Class 10 (Class no (Class no (Class 10
Contaminant GWQS GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL'"'
Nutrients (mg/l)
Ammonia (as N) 25 0 26 06 7 0 77 0 92 12 5 1 3 0 14 12 5 1 17 ^ 6 25
Nitrate + Nitnte (asN) 10 5«i) 5 5 5 0 62 5 5 25 5 5 25
Heavy Metals (ug/l)
Arsenic 50 25 25 17 25 25 21 25 125 25 25 125
Beryllium 4 2 2 2 2 2 2 2 1 2 2 1
Cadmium 5 25 25 25 1 5 25 52 25 1 25 25 4 72 1 25
Chromium 100 50 50 50 SO 50 50 50 25 SO 50 25
Cobalt 730 365 365 365 365 365 47 365 182 5 365 75 21 182 5
Copper 1.300 650 650 650 650 650 650 650 325 650 650 325
Iron 11.000 5,500 5,500 4,162 5,500 2,675 83 299 1,869 2,750 5,500 14,060 2,750
Lead 15 75 75 75 75 75 75 75 3 75 75 75 3 75
Manganese 800 9154 550 7,507 1,806 1,610 1.837 5,624 61 400 5,594 90 200
Mercury 1 1 1 1 1 1 1 1 05 1 1 05
Molybdenum 40(2) 20 20 20 20 20 20 20 10 20 20 10
Nickel 100 50 50 50 50 50 50 50 25 50 94 25
Selenium 50 25 25 25 25 25 11 1 25 34 71 25 12 5
Silver 100 50 50 50 50 50 50 50 25 50 50 25
Thalhum 2 1 1 5 1 1 1 1 1 1 2 05 1 1 05
Tin 17.000 8.500 8,500 8,500 8,500 8,500 8,500 8,500 4,250 8,500 8,500 4,250
Uranium 30(3) 46 66 32 11 9 65 41 8 49 15 8 32 9 1 5 26 75
Vanadium 60 w 30 30 30 30 30 30 30 15 30 30 15
Zinc 5.000 2.500 74 2,500 2,500 2,500 83 30 1.250 2,500 230 1,250
Radiologics (pCi/l)
Gross Alpha 15 13. 2 86 75 75 4 69 2 42 2 3 75 75 3 33 3 75
Volatile Organic Compounds (ug/l)
Acetone 700 350 350 350 350 350 350 350 175 350 350 175
Benzene 5 25 25 25 25 25 25 25 1 25 25 25 1 25
2-Butanone (MEK) 4.000 2,000 2,000 2,000 2,000 2.000 2,000 2,000 1,000 2,000 2,000 1,000
Carbon Tetrachloride 5 25 25 25 25 5 25 25 1 25 25 25 1 25
Chloroform 70(4) 35 35 35 35 70 35 35 17 5 35 35 17 5
Chloromethane 30(2) 15 57 15 15 30 46 15 75 61 15 75
Dichloromethane 5('> 25 25 25 25 5 25 25 I 25 25 25 1 25
Naphthalene 100 50 50 50 50 50 50 50 25 50 50 25
Tetrahydrofuran 46('*) 23 23 23 23 23 23 23 11 5 23 23 11 5
Toluene 1.000 500 500 500 500 500 500 500 250 500 500 250
Xylenes (total) 10.000 5,000 5,000 5,000 5,000 5,000 5.000 5.000 2,500 5,000 5,000 2,500
Others
Field pH (S U) 65-85 6 40 - 8 5 65-85 65-85 65-85 6 74 - 8 5 61-85 6 46 - 8 5 65-85 65-85 64-85
Fluonde (mg/l) 4 2 2 0 36 0 42 2 0 73 1 1 0 51 2 2 1
Chlonde (mg/l) 46 8 10 71 35 58 31 105 41 128 143 35 39
Sulfate (mg/l) 2,860 2,524 2,903 1,933 2,082 06 2,533 2,946 972 532 2,556 70
TDS (mg/l) 5,085 42 3,670 4,450 2,976 3,284 19 3,852 4.400 1,918 1,320 3.960
Footnotes
1) Utah Ground Water Quality Standards (GWQS) as defined in UAC R317-6, Table 2 Ad hoc GWQS also provided herein, as noted, and as allowed by UAC R317-6-2 2
2) Ad hoc GWQS for ammonia (as N). molybdenum. 2-Butanone (MEK), chloromethane, and naphthalene based on EPA dnnking water lifetime health advisones
3) Ad hoc GWQS for nickel, uranium, and dichloromethane (methylene chlonde, CAS No 75-09-2) based on final EPA dnnking water maximum concentration limits (MCL)
4) Ad hoc GWQS for manganese, tin, vanadium, acetone, chloroform (CAS No 67-66-3), and tetrahydrofuran based on dnnking water ad hoc lifetime health advisones prepared by or in collaboration with EPA Region 8 staff
5) Ad hoc GWQS for cobalt and iron based on EPA Region 3 Risk Based Concentration limits for tap water
6) Ground Water Compliance Limits (GWCL) were set after h\ecutive SecietaryDircaor review and approval of two Background Groundwater Quality Reports dated October_2007 and Apnl 30,2008 from the Permittee
7) GWCLs listed in the table above in Normal Font are those proposed by the Permittee in the October 2007 and Apnl 30,2008 DUSA Background Groundwater Quality Reports, and approved by the i^vecutive SecietarvDiiector
8) GWCLs listed in the table above in Bold Text are values modified by the I-xec»tive SecretaryDirector after review of GWCLs proposed in the Permittee's October 2007 and Apnl 30, 2008 Background Groundwater Quality Reports
For wells MW-1. MW-2, MW-3, MW-5, MW-11. MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-26, and MW-32, these modifications are documented m the June 16, 2008 URS Completeness Review for the October,
2007 Revised Background Groundwater Quality Report for Existing Wells For wells MW-3 A, MW-23, MW-24. MW-25. MW-27. MW-28, MW-29, MW-30, and MW-31, these modifications are documented in the June 24, 2008
DRC Findings Memorandum regarding the Apnl 30, 2008 Revised Background Groundwater Quality Report for New Wells
9) Because background quality has not yet been determined at momtonng well MW-35, which was installed m September 2010 for Tailings Cell 4B, the Lxetuiive SecretaryDircctor has set GWCLs equal to the fraction of the GWQS
(0 25) for Class II Groundwater After submittal and approval of the Background Groundwater Quality Report, required by Part I H 5 of this Permit, the l^xecutive SecietaryDircaor will re-open and modify the GWCLs to be equal
to the mean concentration plus two standard deviations (X+2a) for each contaminant
Part ID
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 Existmg Tailings Cells 1, 2, and 3 - shall be based on existing
constmction as descnbed by design and constmction information provided by the Permittee,
as summanzed in Table 3 below for Tailmgs Cells 1, 2, and 3
Table 3 DMT Engineenng Design and Specifications
Tailmgs
Cell
Report
Type Engineenng Report Design Figures
Constmction
Specifications
Cell 1 Design June, 1979 D'Appoloma
Consulting Engineers, Inc
Appendix A, Sheets 2,4, 8,
9,12-15
Appendix B
Cell 2 Design June, 1979 D'Appoloma
Consulting Engineers, Inc
Appendix A, Sheets 2,4, 7-
10, 12-15
Appendix B
As-Buih February, 1982 D'Appoloma
Consuhing Engineers, Inc
Figures 1, 2, and 11 N/A
Cell 3 Design May, 1981 D'Appoloma
Consulting Engineers, Inc
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear, Inc ^'*)
Figures 14 N/A
Footnotes
1) D'Appoloma 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'Appoloma 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'Appoloma 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) Tailmgs Cell 1 - consisting of the following major design elements
1) Cross-valley Dike and East Dike - constmcted on the south side ofthe pond of native
granular matenals 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 intenor 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 intenor 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 matenals 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 onented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike
# Part ID
PemutNo UGW370004
b) Tailmgs Cell 2 - which consists ofthe following major design elements
1) Cross-valley Dike - constmcted at the south margin of Cell 2 of native granular
matenals with a 3 1 slope, a 20-foot crest width, and crest elevation of about 5,615 ft
amsl The east and west intenor 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 m 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) 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 matenals 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 onented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike
4) Shmes Drain Collection System immediately above the FML a nommal 12-mch 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 gnd spacing interval of about 50-feet These pipe laterals gravity drain to a 3-
inch diameter perforated PVC collector pipe which also drains toward the south dike
and IS accessed from the ground surface via a 24-inch diameter, vertical non-
perforated HDPE access pipe Each run of lateral drainpipe and collector piping was
covered with a 12 to 18-inch thick berm of native granular filter matenal 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 - constincted at the south margin of Cell 3 of native granular
matenals with a 3 1 slope, a 20-foot crest width, and a crest elevation of 5,610 ft
amsl The east and west intenor 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 constincted of solvent
welded seams on a prepared sub-base, and overlain by a shmes drain collection
system Top elevation ofthe 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 matenals were graded
Part ID
PemutNo UGW370004
to drain to a single low point near the upstream toe of the south cross-valley dike
Inside this layer, an east-west onented pipe was installed to gather fluids at the
upstream toe ofthe cross-valley dike
4) Shmes 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 tailmgs sands from the mill (30%) On top of this protective
blanket, a network of 3-inch PVC perforated pipe laterals was installed on
approximately 50-foot centers This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a 12-inch diameter, inclined HDPE access pipe
Each run of the 3-inch lateral drainpipe and collector pipe was covered with a 12 to
18-inch thick berm of native granular filter media At cell closure, leachate head
inside the pipe network will be removed via a submersible pump installed inside the
12-inch diameter inclined access pipe
2 Existing Tailings Cell Constmction Authonzed - tailings disposal in existing Taihngs Cells
1, 2, and 3 is authonzed by this Permit as defined in Table 3 and Part ID 1, above
Authonzed operation and maximum disposal capacity in each of the existing tailings cells
shall not exceed the levels authonzed 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 engineenng design parameter at these existing tailmgs cells
shall require pnor Executive SecretaryDirector 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 Monitonng Wells at Tailmgs Cell 1 - at all times the Permittee shall operate and
maintain Tailings Cell 1 to prevent groundwater quality conditions in any nearby
monitonng well from exceeding any Ground Water Compliance Limit established m
Table 2 of this Permit
b) Tailings Cells 2 and 3 - including the following performance cntena
1) Shmes Dram 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 tailmgs disposal cell, m accordance v^th the
currently approved DMT Momtonng Plan
2) Quarterly Shmes Drain Recovery Test - effective July 11,2011, the Permittee shall
conduct a quarterly shmes drain recovery test at each tailings cell shmes dram that
meets the following minimum requirements
1 Includes a duration of at least 90-hours, as measured from the time that pumping
ceases, and
Part ID
PemutNo UGW370004
11 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 Shmes Drain Compliance - shall be achieved when the average annual
wastewater recovery elevation m the shmes drain access pipe, as determined pursuant
to the currently approved DMT Momtonng Plan, meets the conditions in Equation 1,
below
Equation 1
[EEy+ EEy.l+ EEy.2]/[Ny + Ny.l+Ny.2]<[EEy-l+ EEy-2+ lEy.3]/[Ny.l+Ny.2+Ny.3]
Where
EEy = Sum of all monthly and quarterly slimes dram tailmgs fluid elevation measurements that
meet the test performance standards found m the sub-paragraphs of Part ID 3(b)(2), dunng the
calendar year of mterest Hereafter, these water level measurements are referred to as slimes dram
recovery elevations (SDRE) Pursuant to the applicable frequency and method of the approved DMT
Momtormg Plan at the time of each SDRE test, these recovery tests are to be conducted and the SDRE
values reported m umts of feet above mean sea level (amsl) However, when monthly and quarterly
measurements are combmed m the above equation, the quarterly values shall be multiplied by a
coefficient of three (3)
SEy.i = Sum of all SDRE measurements made m the year previous to the calendar year of
mterest However, when monthly and quarterly measurements are combmed m the equation above,
each quarterly value shall be multiplied by a coefficient of three (3)
BEy-2 = Sum ofall SDRE measurements made m the second year previous to the calendar year of
mterest However, when monthly and quarterly measurements are combmed m the equation above,
each quarterly value shall be multiplied by a coefficient of three (3)
EEy-3 = Sum of all SDRE measurements made m the third year previous to the calendar year of
mterest However, when monthly and quarterly measurements are combmed m 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 m Part
ID 3(b)(2), conducted dunng the calendar year of mterest However, when monthly and quarterly
measurements are used m 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 m Part
ID 3(b)(2), conducted m the year previous to the calendar year of mterest However, when monthly
and quarterly measurements are used m 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 m Part ID 3(i5)(2), conducted m the second year previous to the calendar
year of mterest However, when monthly and quarterly measurements are used m 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 m Part
ID 3(b)(2), conducted m the third year previous to the calendar year of mterest However, when
monthly and quarterly measurements are used m the equation above, each quarterly test shall be
counted as three (3) separate tests
Pnor 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 ID
PemutNo UGW370004
Report for
Calendar
Year
Source of Data By Calendar Year for Equation 1 Vanables (nght side) Report for
Calendar
Year Ev-i Ev-2 Ev-3 Nv-i 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-watenng operations
c) Maximum Tailings Waste Solids Elevation - upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation ofthe tailmgs waste solids does not
exceed the top of the FML lmer
d) DMT Monitonng Wells - at all times the Permittee shall operate and maintain Tailings
Cells 2 and 3 to prevent groimdwater quality conditions in any nearby momtonng well
from exceeding any Ground Water Compliance Limit estabhshed in Table 2 of this
Permit
e) Roberts Pond - the Permittee shall operate this wastewater pond so as to provide a
mimmum 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 contaimnent m Tailings Cell 1 withm 72-hours of discovery At the time
of mill site closure, the Permittee shall reclaim and decommission the Roberts Pond m
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 matenals at the facility
awaiting mill processing shall be limited to the eastem portion of the mill site area
descnbed in Table 4, below Storage of feedstock matenals at the facility outside this
area, shall meet the requirements in Part ID 11 At the time of mill site closure, the
Permittee shall reclaim and decommission the Feedstock Storage Area m 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 matenal m order to assure that
matenals do not encroach on the boundary of the storage area
Table 4 Feedstock Storage Area Coordinates
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 ID
PemutNo 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
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 engineenng design plans and specifications, and pnor
Executive SecrotarvDirector review and approval All engineenng 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 SecrotarvDirector 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 SecrotarvDirector design approval letter for the relimng of former existmg Tailmgs
Cell No 4A, and as summanzed by the engineenng drawmgs, specifications, and descnption
in Table 5, below
Table 5 Approved Tailings Cell 4A Engineenng 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 H
Sheet 7 of 7 June 15,2007 Rev 1 Lmmg System Details HI
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 Study MFG Consulting Scientists
11
Part ID
PemutNo 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 - Intenm
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 clanfied by February 8, 2007 Division of Radiation Control Round 6 Interrogatory
Tailings Cell 4A Design and Constmction - approved by the Executive SecretaryDirectoi
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 intenor slope of 2H to IV Width of these dikes
vanes, each has a minimum crest width of at least 15 feet to support an access road Base
width also vanes from 89-feet on the east dike (with no extenor embankment), to 211-
feet at the west dike
b) Foundation - including existing subgrade soils over bedrock matenals 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) Tailmgs 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 tailmgs matenal storage (as
measured below the required 3-foot freeboard)
d) Liner and Leak Detection Systems - including the following layers, in descending order
1) Pnmary Flexible Membrane Lmer (FML) - consisting of impermeable 60 mil high
density polyethylene (HDPE) membrane that extends across both the entue cell floor
and the inside side-slopes, and is anchored m a trench at the top of the dikes on all
four sides The pnmary FML will be m direct physical contact with the tailings
matenal over most of the Cell 4 A floor area In other locations, the pnmaiy FML will
be in contact with the shmes drain collection system (discussed below)
Leak Detection System - includes a permeable HDPE geonet fabnc that extends
across the entire area under the pnmary FML m 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 pnmary 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 mm, the gravel filter layer will be enclosed in an envelope of
geotextile fabnc The purpose of both the gravel and geotextile fabnc is to serve as a
filter
2)
12
Part ID
PemutNo 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 Pnor to disposal of any wastewater in Cell 4 A, 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) Shmes Drain Collection System - including a two-part system of stnp drains and
perforated collection pipes both installed immediately above the pnmary FML, as
follows
1) Honzontal Stnp Drain System - is installed m a hemngbone pattem across the floor
of Cell 4A that dram to a "backbone" of perforated collection pipes These stnp
drains are made of a prefabncated two-part geo-composite dram matenal (solid
polymer drainage stnp) core surrounded by an envelope of non-woven geotextile
filter fabnc The stnp drains are placed immediately over the pnmary FML on 50-
foot centers, where they conduct fluids downgradient m a southwesterly direction to a
physical and hydraulic cormection to the perforated shmes dram collection pipe A
senes of continuous sand bags, filled with filter sand cover the stnp drains The sand
bags are composed of a woven polyester fabnc filled with well graded filter sand to
protect the drainage system from plugging
2) Honzontal Shmes Drain Collection Pipe System - includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC shmes dram collection (SDC) pipe
found at the downgradient end of the stnp drain lines This pipe is in tum overlam by
a berm of gravel that runs the entire diagonal length of the cell, surrounded by a
geotextile fabnc cushion in immediate contact with the pnmary FML In tum, the
gravel is overlain by a layer of non-woven geotextile to serve as an additional filter,
matenal This perforated collection pipe serves as the "backbone" to the slimes drain
system and nms from the far northeast comer downhill to the far southwest comer of
Cell 4A where it joins the shmes drain access pipe
3) Shmes 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 pnmary FML
Said pipe then merges with another honzontal pipe of equivalent diameter and
matenal, where it is enveloped by gravel and woven geotextile that serves as a
cushion to protect the pnmary FML A reducer connects the honzontal 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 tailmgs wastewaters for purposes of de-watenng 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 pnmary FML from abrasion and scounng by tailings slurry
These pads will consist of an extra layer of 60 mil HDPE membrane that will be mstalled
m the anchor trench and placed down the inside slope of Cell 4A, from the top of the
13
Part ID
PemutNo 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 lined spillway will be constmcted near the
westem comer of the north dike to allow emergency runoff from Cell 3 into Cell 4A
This spillway will be limited to a 6-inch reinforced concrete slab set directly over the
pnmary FML m a 4-foot deep trapezoidal channel No other spillway or overflow
stmcture 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
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, Monitonng, Operations and
Maintenance Plan Any failure to achieve or maintam the required BAT performance
standards shall constitute a violation of the Permit and shall be reported to the Executive
SecrotarvDirector m accordance with Part IG 3 Performance standards for Tailmgs 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 lmer
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 honzontal 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) Shmes Drain Annual Average Recovery Head Cntena - after the Permittee initiates
pumping conditions in the shmes drain layer m Cell 4A, the Permittee will provide 1)
continuous declining fluid heads m the shmes drain layer, in a manner equivalent to the
requirements found m Part ID 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 ofthe upper FML
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 thonum from
any ore processed pnmanly for its source matenal 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 sti*eams descnbed by a March 7,2003 NRC letter from Paul H Lohaus to
WilhamJ Sinclair
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 penod of not less than 200 years meet the following
minimum performance requirements
14
Part ID
PemutNo UGW370004
a) Minimize infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon bamer,
b) Prevent the accumulation of leachate head within the tailings waste layer that could nse
above or over-top the maximum FML liner elevation internal to any disposal cell, i e
create a "bathmb" effect, and
c) Ensure that groundwater quality at the compliance monitonng wells does not exceed the
Ground Water Quality Standards or Ground Water Compliance Limits specified in Part
IC 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 tailmgs cells in compliance with all engmeermg design and
specifications in an approved Reclamation Plan The Executive SecretaryDircctor reserves
the nght to require modifications of the Reclamation Plan for purposes of compliance with
the Utah Ground Water Quality Protection Regulations, including but not limited to
containment and control of contaminants, or discharges, or potential discharges to Waters of
the State
10 Stormwater Management and Spill Control Requirements - the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices Plan Said
plan includes the following minimum provisions
a) Protect groundwater quality or other waters of the state by design, 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 SecretaryDirector
in accordance with UAC 19-5-114
Reconstmction of stormwater management and/or chemical reagent storage facilities,
existing at the time of ongmal Permit issuance, may be required by the Executive
SecrotarvDirector after occurrence of a major spill or catastrophic failure, pursuant to Part
rVN3ofthis Permit
11 BAT Requirements for Feedstock Matenal Stored Outside the Feedstock Storage Area - the
Permittee shall store and manage feedstock matenals outside the ore storage pad in
accordance with the following minimum performance requirements
a) Feedstock matenals 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 pnor to
storage, or
15
Part ID
PemutNo UGW370004
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 engineenng
plans and specifications approved in advance by the Executive SecretaryDirector All
such engineenng plans or specifications submitted shall demonstrate compliance
with Part ID 4,
3) A storage area that provides containment berms to control stormwater mn-on and
mn-off, and
4) Stormwater drainage works approved m advance by the Executive Secretar\Puector,
or
5) Other storage facilities and means approved m advance by the Executive
SecretaryDirector
12 BAT Design Standards for Tailmgs Cell 4B - the BAT design standard for Tailings Cell 4B
shall be defined by and constmcted in accordance with the requirements as summanzed by
the engineenng drawings, specifications, and descnption m Table 6, below
Table 6 Approved Tailings Cell 4B Engineenng Design and Specifications
Engmeerin 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
Sheet 5 of 8 December 2007 Rev 0 Lining System Details I
Sheet 6 of 8 January 2009 Rev 1 Lining System Details II
Sheet 7 of 8 January 2009 Rev 1 Lining System Details III
Sheet 8 of 8 January 2009 Rev 1 Lining System Details IV
Figure 1 January 2009 -Mill Site Drainage Basins (supporting reference)
Engineering Specifications
Date Document Title Prepared by
January 2009 Slope Stability Analysis Calculation Package Geosyntec Consultants
January 2009 Seismic Deformation Analysis Calculation
Package
Geosyntec Consultants
January 2009 Revised Pipe Strength Analysis Calculation
Package
Geosyntec Consultants
January 2009 Revised Companson of Flow Though Compacted
Clay Lmer 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 Consuhants
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 Fabnc Calculations
16
Part ID
PennitNo UGW370004
August 2009 Constmction Quality Assurance Plan for the
Constmction of Cell 4B Lining System
Geosyntec Consultants
September 2009 (Revised) Techmcal 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 SecretaryDirector will
consist of the following major elements
a) Dikes - consisting of newly constmcted dikes on the south and west side of the cell, each
including a 20-foot wide road at the top (minimum) to support an access road The
grading plan for the Cell 4B excavation includes intenor slopes of 2H to IV. The extenor
slopes of the southem and westem dikes will have typical slopes of 3H to 1V Limited
portions of the Cell 4B intenor sideslopes in the northwest comer and southeast comer of
the cell, (where the shmes drain and leak detection sump will be located will also have a
slope of 3H to 1V The base width of the southem dikes vanes from approximately 92
feet at the westem end to approximately 190 feet at the eastem end of the dike, with no
extenor embankment present on any other side of the cell
b) Foundation - including existing subgrade soils over bedrock matenals 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 tailmgs matenal storage (as measured below the required 3-foot
freeboard)
d) Lmer and Leak Detection Systems - including the following layers, in descending order
1) Pnmary 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 pnmary FML will be in direct physical contact with the tailings matenal over
most of the Cell 4B floor area In other locations, the pnmary FML will be m contact
with the shmes drain collection system (discussed below)
2) Leak Detection System - includes a permeable HDPE geonet that extends across the
entire area under the pnmary FML m Cell 4B, and drains to a leak detection sump in
the southeast comer Access to the leak detection sump is via an 18-inch mside
diameter (ID) PVC pipe placed down the inside slope, located between the pnmary
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 m an
17
Part ID
PemutNo UGW370004
envelope of geotextile fabnc The purpose of both the gravel and geotextile fabnc 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 - consistmg of a manufactured geosynthetic clay lmer (GCL)
composed of 0 2-inch of low permeability bentomte clay centered and stitched
between two layers of geotextile Pnor 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 stnp drains and
perforated collection pipes both installed immediately above the pnmary FML, as
follows
1) Honzontal Stnp Dram System - is installed in a hemngbone pattem across the floor
of Cell 4B that drain to a "backbone" of perforated collection pipes These stnp
drains are made of a prefabncated two-part geo-composite drain matenal (solid
polymer drainage stnp) core surrounded by an envelope of non-woven geotextile
filter fabnc The stnp drains are placed immediately over the pnmary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated shmes drain collection pipe A
senes of continuous sand bags, filled with filter sand cover the stnp drains The sand
bags are composed of a woven polyester fabnc filled with well graded filter sand to
protect the drainage system from plugging
2) Honzontal Shmes Drain Collection Pipe System - includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC shmes dram collection (SDC) pipe
found at the downgradient end of the stnp dram 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 fabnc cushion in immediate contact with the pnmary FML In tum, the
gravel is overlain by a layer of non-woven geotextile to serve as an additional filter
matenal This perforated collection pipe serves as the "backbone" to the shmes dram
system and mns from the far northwest comer downhill to the far southeast comer of
Cell 4B where it joins the shmes 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 pnmary FML
Said pipe then merges with another honzontal pipe of equivalent diameter and
matenal, where it is enveloped by gravel and woven geotextile that serves as a
cushion to protect the pnmary FML A reducer cormects the honzontal 18-inch pipe
with the 4-inch SDC pipe At some fiiture time, a pump will be set in this 18-inch
pipe and used to remove tailings wastewaters for purposes of de-watenng 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 pnmary FML from abrasion and
scounng by tailmgs slurry These pads will consist of an extra layer of 60 mil HDPE
membrane that will be installed in the anchor trench and placed dovm the mside slope of
18
r
Part ID
PemutNo UGW370004
Cell 4B, from the top of the dike, under the mlet 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 ofthe 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 wue
fabnc installed within it at its midsection, set atop a cushion geotextile placed directly
over the pnmary 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 runoff and
tailings wastewaters not retained in Cells 2 and 3, and 4A will be managed and contamed
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 groimdwater and the environment
m accordance with the currently approved Cell 4B BAT, Monitonng, 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
SecretaryDirector in accordance with Part IG 3 Performance standards for Tailmgs 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 lmer
on the cell floor At all times the Permittee shall operate the LDS pump and transducer
in a honzontal 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) Shmes Drain Annual Average Recovery Head Cntena - after the Permittee initiates
pumping conditions m the shmes drain layer in Cell 4B, the Permittee will provide 1)
continuous declining fluid heads in the shmes drain layer, in a manner equivalent to the
requirements found in Part ID 3(b), and 2) a maximum head of 1 0 feet m the tailmgs (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
Momtonng 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
S ecretar\Oirector m accordance with Part IG 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 m any LDS access pipe, at any time Compliance will be defined as a depth to
19
Part ID
PemutNo UGW370004
standing water present in any of the LDS access pipes of more than or equal to 6 2 feet as
measured from the water measunng pomt (top of access pipe)
b) Soil and debns will be removed from the wash pad ofthe NDP, m accordance with the
currently approved DMT Momtonng Plan Cracks in the wash pad greater than 1 /8 inch
(width) will be repaired withm five working days of discovery
20
Part IE
Permit No UGW370004
GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING - begmnmg 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 monitonng wells, tailing cell wastewaters, seeps
and spnngs, momtor groimdwater levels, monitor water levels of process solutions, and momtor
and keep records ofthe operation ofthe facility, as follows
1 Routine Groundwater Compliance Momtonng - the Permittee shall monitor upgradient,
lateral gradient, and downgradient groundwater monitonng wells completed m the shallow
aquifer in the vicimty ofall potential discharge sources that could affect local groundwater
conditions at the facility, as follows
a) Ground Water Momtonng Quality Assurance Plan - all groundwater monitonng and
analysis performed under this Permit shall be conducted in accordance with a Quality
Assurance Plan (QAP) currently approved by the Executive SecretarvDirector Any non-
conformance with QAP requirements in a given quarterly groundwater monitonng
penod will be corrected and reported to the Executive SecretarvDirector on or before
submittal of the next quarterly groimdwater momtonng report pursuant to Part IF 1
b) Quarterly Momtonng - the Permittee shall monitor on a quarterly basis all monitonng
wells listed m Table 2 of this Permit where local groundwater average Imear velocity has
been found by the Executive SecretawDirector to be equal to or greater than 10 feet/year
For purposes of this Permit, quarterly monitonng is required at the following wells
1) Upgradient Wells none
2) Lateral or Downgradient Wells MW-11, MW-14, MW-25, MW-26 (fonnerlyTW4-
15), MW-30, MW-31, and MW-35
3) Future Cell 4B Dovmgradient Wells to be Installed - quarterly momtonng shall begin
within 30 calendar days of mstallation of new groimdwater momtormg wells MW-36,
MW-37, or any other well required by Part IH 4 of this Permit, and continue until
otherwise determined by the Executive SecretarvDirector pursuant to Part IH 5
c) Semi-armual Monitonng - the Permittee shall monitor on a semi-annual basis all
momtonng wells listed in Table 2 of this Permit where local groundwater average linear
velocity has been found by the Executive SecretaryDirector to be less than 10 feet/year
For purposes of this Permit, semi-annual momtonng 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 (fonnerly TW4-17)
3) General Momtonng Wells MW-20 and MW-22
d) Compliance Momtonng Parameters - all groundwater samples collected shall be analyzed
for the following parameters
1) Field Parameters - depth to groimdwater, pH, temperature, specific conductance, and
redox potential (Eh)
2) Laboratory Parameters
21
Part IE
PemutNo UGW370004
I GWCL Parameters - all contaminants specified m Table 2
II General Inorgamcs - chlonde, sulfate, carbonate, bicarbonate, sodium, potassium,
magnesium, calcium, and total amons and cations
e) Special Provisions for Groimdwater Monitonng - the Permittee shall ensure that all
groundwater monitonng conducted and reported complies with the following
requirements
1) Depth to Groundwater Measurements - shall always be made to the nearest 0 01 foot
2) Mimmum Detection Limits - all groundwater quality analyses reported shall have a
mimmum detection limit or reporting limit that is less than its respective Ground
Water Compliance Limit concentration defined in Table 2
3) Gross Alpha Counting Vanance - 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 vanance 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
matenals
Groundwater Monitonng General Monitonng Wells MW-20 and MW-22 - the Permittee
shall monitor wells MW-20 and MW-22 on a semi-annual basis Said samplmg shall comply
with the following Permit requirements
a) Routine groundwater compliance momtonng requirements of Part IE 1
b) Groimdwater head momtonng requirements of Part IE 3
c) Well momtonng procedure requirements of Part IE 5
Groundwater Head Momtonng - on a quarterly basis and at the same frequency as
groundwater monitonng required by Part IE 1, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers
a) Point of Compliance Wells - identified m Table 2 and Part LE 1 of this Permit
b) Piezometers - P-1, P-2, P-3, P-4, and P-5
c) Head Monitonng Well - MW-34
d) General Momtonng Wells - MW-20 and MW-22
e) Contaminant Investigation Wells - any well required by the Executive SecretarvDuector
as a part of a contaminant investigation or groimdwater corrective action
f) Any other wells or piezometers required by the Executive SecretarvDirector
Groundwater Momtonng Well Design and Constmction Cntena - all new groundwater
momtonng wells installed at the facility shall comply with the following design and
constmction cntena
22
Part IE
Permit No UGW370004
a) Located as close as practical to the contamination source, tailings cell, or other potential
ongm 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), mcludmg the EPA
RCRA Ground Water Monitonng Technical Enforcement Guidance Document, 1986,
OSWER-9950 1
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity
5 Monitonng Procedures for Wells - beginning with the date of Pemut issuance, all momtormg
shall be conducted by the Permittee m 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 momtonng 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 Momtonng Wells - if any monitor well is damaged or is otherwise rendered
inadequate for its intended purpose, the Permittee shall notify the Executive
SecretarvDirector in wnting within five calendar days of discovery.
e) Field Momtonng Equipment Calibration and Records - immediately pnor to each
momtonng event, the Permittee shall calibrate all field monitonng equipment in
accordance with the respective manufacturer's procedures and guidelines The Pemuttee
shall make and preserve on-site wntten records of such equipment calibration in
accordance with Part HG 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 Spnngs Momtonng - the Permittee shall conduct annual momtonng
of all seeps and spnngs identified m the currently approved Sampling Plan for Seeps and
Spnngs in the Vicinity of the White Mesa Uramum Mill Said monitonng shall include, but
is not limited to
a) Field Measurements - including pH, temperature, and specific conductivity
b) Water Quality Sampling and Analysis - the Permittee shall collect grab samples and
perform laboratory analysis of all water quality parameters identified in Table 2 of this
Permit
c) Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified laboratory
d) Analytical Methods - all laboratory analysis shall be conducted using analytical methods
listed in the currently approved QAP pursuant to Part IE 1 of this Permit
e) Minimum Detection Limits - all seeps or spnngs water quality analyses reported shall
have a minimum detection limit or reporting limit that is less than or equal to the
respective
23
Part IE
Permit No UGW370004
1) Ground Water Quality Standards concentrations defined in Table 2 of this Permit,
and
2) For TDS, Sulfate, and Chlonde, the Minimum Detection Limit for those constiments
for seeps and spnngs monitonng 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 apart of all seeps and spnngs sampling, in accordance with the requirements
of Section 4 3 of the currently approved QAP, pursuant to Part IE 1 of this Permit Said
QC samples shall include, but are not limited to tnp blanks, duplicate samples, and
equipment nnse blanks
g) Pnor Notification - at least 15 calendar days before any fieldwork or water quahty sample
collection, the Permittee shall provide wntten notice to allow the Executive
SecretarvDirector to observe or split sample any or all seeps or spnngs
DMT Performance Standards Monitonng - the Permittee shall perform technology
performance monitonng in accordance with the currently approved DMT Momtonng Plan
to determine if DMT is effective m minimizing and controlling the release of contaminants
pursuant to the provisions of Parts ID 1 and ID 3 of this Permit, including, but not lunited
to the following activities
a) Weekly Tailings Wastewater Pool Elevation Monitonng Cells 1 and 3 - the Permittee
shall monitor and record weekly the elevation of wastewater m Tailings Cells 1 and 3 to
ensure compliance with the maximum wastewater elevation cntena 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 Shmes Drain Water Level Momtonng Cells 2 and 3 - the Permittee shall
monitor and record quarterly the depth to wastewater m the shmes dram access pipes as
descnbed in Part ID 3 of this Permit and the currently approved DMT Momtonng Plan
at Tailmgs Cells 2 and 3 to determine the recovery head For purposes of said
momtonng, the Permittee shall at each tailings cell
1) Perform at least 1 separate shmes dram recovery test at each disposal cell m each
quarterly penod of each calendar year that meets the requirements of Part ID 3,
2) Designate, operate, maintain, and preserve one water level measunng point at the
centerline ofthe shmes dram access pipe that has been surveyed and certified by a
Utah licensed engineer or land surveyor,
3) Make all shmes drain recovery head test (depth to fluid) measurements from the
same designated water level measunng 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 tailmgs de-watenng
operations
c) Weekly Wastewater Level Monitonng Roberts Pond - the Permittee shall monitor and
record weekly wastewater levels at the Roberts Pond to determine compliance with the
24
Part IE
Permit No UGW370004
DMT operations standards m Part ID 3 Said measurements shall be made in accordance
to the currently approved DMT Momtonng Plan
d) Weekly Feedstock Storage Area Inspection - the Permittee shall conduct weekly
inspections of all feedstock storage to 1) Confirm the bulk feedstock matenals are
maintained within the approved Feedstock Storage Area defined by Table 4, and 2)
Venfy that all altemate feedstock matenals located outside the Feedstock Area defined in
Table 4, are stored m accordance with the requirements found in Part ID 11
e) Feedstock Matenal Stored Outside the Feedstock Storage Area Inspections
1) Weekly Inspection - the Permittee will conduct weekly inspections to venfy that each
feed matenal container complies with the requirements of Part ID 11
2) Hardened Surface Storage Area - in the event the Permittee constmcts a hardened
surface storage area for feed matenals, pursuant to Part ID 11, pnor Executive
Secretar\drector approval will be secured for the following
I Engineenng Design and Specifications - m accordance with the requirements of
Part ID 4, and
II Operation and Maintenance Plan
f) Inspections of Tailing Cell and Pond Liner Systems - the Permittee shall inspect the lmer
system at Tailing Cells 1, 2, and 3 on a daily basis pursuant to the requirements of
Sections 2 1 and 2 2 of the currently approved DMT Momtonng 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 dunng a liner system inspection, the Permittee
shall 1) report and repair said defect or damage pursuant to Part IG 3 by implementation
ofthe currently approved Liner Maintenance Provisions, and 2) report all repairs made
pursuant to Part IF 2
g) Weekly New Decontamination Pad Inspection - the Permittee shall conduct weekly
inspections of the New Decontamination Pad as descnbed in Part ID 14 of this Permit
and the currently approved DMT Momtonng Plan
Cell 4A BAT Performance Standards Momtonng and Maintenance - in accordance with the
currently approved Cell 4A BAT, Momtonng, Operations and Maintenance Plan, the
Permittee shall immediately implement all momtonng and recordkeeping requirements
therein The Cell 4A BAT monitonng includes the following
a) Weekly Leak Detection System (LDS) Momtonng - including
1) Leak Detection System Pumping and Momtonng Equipment - the Permittee shall
provide continuous operation of the leak detection system pumping and momtonng
equipment, including, but not limited to, the submersible pump, pump controller,
head momtonng, and flow meter equipment approved by the Executive
SecretaryDirector Failure of any LDS pumping or monitonng 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 SecretaryDirector Under no circumstance
25
Part IE
PemutNo UGW370004
shall fluid head m 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 monitonng 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 cucumstances shall the average
daily LDS flow volume exceed 24,160 gallons/day
4) 3-foot Minimum Vertical Freeboard Cntena - the Permittee shall operate and
maintain wastewater levels to provide a 3-foot Mimmum of vertical freeboard in
Tailmgs Cell 4A Said measurements shall be made to the nearest 0 1 foot
b) Quarterly Shmes Drain Recovery Head Monitonng - immediately after the Permittee
imtiates pumping conditions m the Tailings Cell 4A shmes drain system, quarterly
recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts ID 3 and IE 7(b) of this Permit and the currently approved Cell
4A BAT, Monitonng, 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 persormel and shall be reported in a
Liner Repair Report, certified by a Utah licensed Professional Engmeer The Lmer Repair
Report shall be submitted to for Executive SecretarvDirector approval m accordance with
Part IF 3 of the Permit Any leak, hole, or other damage to the liner will be reported to
the Executive SecretarvDirector pursuant to the requirements found in Part IG 3
9 On-site Chemicals Inventory - the Permittee shall monitor and maintain a current inventory
ofall 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 Momtonng - on an armual basis, the Pemuttee 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 Tailmgs Cells 1,3,4A, and 4B
b) One shmes dram wastewater access pipe at each of Tailings Cells 2,3,4 A, and 4B For
Cells 3, 4A, and 4B, this requirement shall apply immediately after initiation of de-
watenng 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 m compliance with
the currently approved White Mesa Uramum Mill Tailing and Shmes Drain Sampling
Program Said annual momtonng shall include, but is not limited to
26
Part IE
PemutNo UGW370004
1) 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
2) Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified laboratory
3) Analytical Methods - all laboratory analysis shall be conducted using analytical
methods listed m the currently approved QAP pursuant to Part IE 1 of this Permit
4) Mimmum Detection Limits - all water quality analyses reported shall have a
mimmum detection limit or reporting limit that is less than or equal to the respective
I Ground Water Quality Standards concentrations defined m Table 2 of this Pemut,
II For TDS, Sulfate, and Chlonde, the Minimum Detection Limit for those
constiments for Tailing Cell wastewater monitonng will be as follows 1,000
mg/L, 1,000 mg/L, and 1 mg/L, respectively, and
III Lower limits of quantitation for groimdwater for seim-volatile orgamc
compounds listed in Table 2 of EPA Method 8270D, Revision 4, dated Febmary,
2007
5) Quality Control Samples - the Permittee will conduct quality control (QC) sampling
and analysis as a part of all tailings wastewater sampling, in accordance with the
requirements of Section 4 3 of the currently approved QAP, pursuant to Part IE 1 of
this Permit Said QC samples shall include^ but are not limited to tnp blanks,
duplicate samples, and equipment nnse blanks
6) Pnor Notification - at least 30 calendar days before any water quality sample
collection, the Permittee shall provide wntten notice to allow the Executive
SecretaryDirector to observe or split sample any tailings cell, slimes dram, or leak
detection wastewaters
7) Sample Omission - in the course of each annual sampling event, the Permittee shall
sample and analyze all tailings cell, shmes drain, and leak detection wastewater
sources identified in the currently approved Tailmgs and Shmes 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 dunng said annual
event, without pnor wntten approval from the Executive SecretarvDirector
11 Groundwater Momtormg Modifications - before any modification of groundwater momtormg
or analysis procedures, methods, or equipment, the Permittee must obtain pnor wntten
approval from the Executive SecretarvDirector
12 Cell 4B BAT Performance Standards Momtonng and Maintenance - immediately followmg
Executive SecretaryDirector approval of the Cell 4B BAT, Momtonng, Operations and
Maintenance Plan, the Permittee shall immediately implement all monitonng and
recordkeeping requirements therein The Cell 4B BAT momtonng shall include the
following
27
PartlE&IF
PemutNo UGW370004
a) Weekly Leak Detection System (LDS) Monitonng - including
1) Leak Detection System Pumping and Monitonng Equipment - the Permittee shall
provide continuous operation of the leak detection system pumping and monitonng
equipment, including, but not limited to, the submersible pump, pump controller,
head monitonng, and flow meter equipment approved by the Executive
SecretarvDirector Failure of any LDS pumping or related monitonng 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 SecretarvDirector Under no circumstance
shall fluid head in the leak detection system (LDS) sump exceed a 1-foot level above
the lowest point in the lower flexible membrane liner on the cell floor Any
occurrence of leak detection system fluids above this 1-foot limit shall constitute
failure of BAT, and a violation of this Permit
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS Under no cucumstances shall the average
daily LDS flow volume exceed 26,145 gallons/day
4) 3-foot Minimum Vertical Freeboard Cntena - the Permittee shall operate and
maintain wastewater levels to provide a 3-foot Minimum of vertical freeboard in
Tailmgs Cell 4B Said measurements shall be made to the nearest 0 1 foot
b) Quarterly Shmes Drain Recovery Head Momtonng - immediately after the Permittee
initiates pumping conditions in the Tailmgs Cell 4B shmes drain system, quarterly
recovery head tests and fluid level measurements will be made m accordance with the
requirements of Parts ID 3 and IE 7(b) of this Permit and the currently approved Cell 4B
BAT, Monitonng, 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 Pemut
Repairs shall be performed by qualified liner repair personnel and shall be reported in a
Liner Repair Report, certified by a Utah hcensed Professional Engmeer The Liner Repair
Report shall be submitted for Executive SecretarvDirector approval in accordance with
Part IF 3 of the Permit Any leak, hole, or other damage to the lmer will be reported
pursuant to the requirements found m Part IG 3
F REPORTING REQUIREMENTS - The following reporting procedures for routine and compliance
reports must be met
1 Routine Groimdwater Monitonng Reports - the Permittee shall submit quarterly momtonng
reports of field and laboratory analyses ofall well momtonng and samples descnbed in Parts
IE 1, IE 2, IE 3, and IE 5 of this Permit for Executive SecretanDirector review and
approval Reports shall be submitted according to the following schedule
28
PartIF
PennitNo UGW370004
Table 7 Groimdwater Monitonng Reporting Schedule
Quarter Penod Due Date
First January - March June 1
Second Apnl - 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 monitonng reports shall include, but are not limited to, the following mimmum
information
a) Field Data Sheets - or copies thereof that provide the following well name, date and time
of well purging, date and time of well sampling, type and condition of well pump, depth
to groundwater before purging and sampling, calculated well casing volume, volume of
water purged before sampling, volume of water collected for analysis, types of sample
containers and preservatives
b) Laboratory Results - or copies thereof that provide the following date and time sampled,
date received by laboratory, and for each parameter analyzed, the followmg information
laboratory result or concentration, umts of measurement, mimmum 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 groimdwater flow directions observed
dunng the quarterly sampling event
d) Quality Assurance Evaluation and Data Validation - including a vmtten descnption and
findings of all quality assurance and data validation efforts conducted by the Permittee in
compliance with the currently approved Groundwater Momtonng Quality Assurance
Plan Said report shall venfy the accuracy and reliability of the groundwater quality
compliance data, after evaluation of sample collection techmques and eqmpment, sample
handling and preservation, analytical methods used, etc
e) Non-conformance disclosure - with each quarterly groimdwater monitonng report the
Permittee shall fully and completely disclose all non-conformance with requirements of
the currently approved QAP, mandated by Part IE 1(a)
f) Electromc Data Files and Format - in addition to wntten resuhs required for every
sampling report, the Permittee shall provide an electronic copy of all laboratory results
for groimdwater quality momtonng conducted Said electromc files shall consist of
Comma Separated Values (CSV) format, or as otherwise approved by the Executive
SecretaryDirector
g) Time Concentration Plots - with each quarterly groimdwater momtonng report the
Permittee shall submit time concentration plots for each momtonng well for the
following constituents chlonde, fluonde, sulfate, and uramum
Routine DMT Performance Standards Monitonng Report - the Permittee shall provide
quarterly monitonng reports of all DMT performance standards momtonng required by Parts
29
PartIF
Permit No UGW370004
ID 3 and IE 7 of this Permit DMT monitonng shall be conducted m compliance with this
Permit and the currently approved DMT Momtonng Plan When a lmer 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 monitonng reports and results shall be submitted for Executive
SecrotaryDirector approval on the schedule provided in Table 7, above
3 Routine Cell 4A and 4B BAT Performance Standards Momtonng Reports - the Permittee
shall provide quarterly monitonng reports of all BAT performance standards monitonng
required by Parts IE 8 and IE 12 of this Permit BAT Monitonng at Cells 4 A and 4B shall
be conducted in compliance with the currently approved BAT Momtonng, Operations and
Maintenance Plan When a liner repair is performed at Tailings Cell 4A or 4B, a Repair
Report IS required by Parts IE 8(c) and IE 12(c) ofthe Permit This Repair Report shall be
included with the next quarterly BAT Report Said monitonng report and results shall be
submitted for Executive SecretarvDirector approval on the schedule provided in Table 7
above. At a minimum, reporting of BAT momtonng for Cells 4A and 4B will include
a) LDS Momtonng - including
1) Report on the operational status of the LDS pumping and monitonng equipment
dunng 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 m the Cells 4A and 4B to
determine freeboard
c) Shmes Dram Recovery Head Monitonng as per the requirements of Parts ID 6 and
IE 8(b)
4 DMT and BAT Performance Upset Reports - the Permittee shall report any non-compliance
with the DMT or BAT performance cntena of Part ID in accordance with the requirements
of Part IG 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 m a permit application or
in any report to the Executive SecretarvDirector, the Permittee shall submit such facts or
information within 10 calendar days of discovery
6 Groimdwater Momtonng Well As-Built Reports - as-built reports for new groimdwater
momtonng wells shall be submitted for Executive SecretarvDirector approval within 60
calendar days of well completion, and at a mimmum will include the following information
a) Geologic Logs - that detail all soil and rock lithologies and physical properties of all
subsurface matenals encountered dunng dnllmg Said logs shall be prepared by a
30
PartIF
Permit No UGW370004
Professional Geologist licensed by the State of Utah, or otherwise approved beforehand
by the Executive SecretaryDirector
b) Well Completion Diagram - that detail all physical attnbutes of the well constmction,
including
1) Total depth and diameters of bonng,
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 matenals
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 honzontal coordinates and elevation of water level measunng 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 Spnngs Monitonng Reports - a seeps and spnngs momtonng report
shall be submitted for Executive SecretarvDirector review and approval with the 3^*^ Quarter
Routine Groundwater Momtonng 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 IF 1(a) of this Permit,
b) Laboratory Results - for each sample collected that comply with the requuements of Part
IF 1(b) of this Penmt,
c) Water Table Contour Map - that includes groimdwater elevations for each well at the
facility and the elevations of the phreatic surfaces observed at each of the seeps and
spnngs sampled The contour map will include all water level data measurements from
seeps, spnngs, and monitonng wells at the site from the 3'^'^ Quarter Routme Groundwater
Momtonng event of each year The contour map shall be at a map scale, such that, all
seeps and spnngs listed in the approved Sampling Plan for Seeps and Spnngs in the
Vicinity of the White Mesa Uranium Mill and the monitonng 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 spnngs water
quality data that meets the requirements of Part IF 1(d),
f) Electromc Data Files and Format - that meet the requirements of Part IF 1(e) of this
Permit, and
g) Survey data for the seeps and spnngs 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
PartIF
PemutNo UGW370004
vertical elevations The surveyed coordinates and elevations of the seeps and spnngs
shall be within 1 foot of the highest point of the saturated seepage face on the day ofthe
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 IHI Said report
shall provide all inventory information gathered pursuant to Part IE 9
9 Tailmgs Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part IE 10 shall be reported to the Executive SecretarvDirector 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 IF 1(a), (b), (d), and (e) of this Permit, and
c) For shmes drain samples, the Permittee shall report depth to wastewater measurements
from the water level measurement point Said wastewater level shall be measured
immediately before sample collection
10 Revised Hydrogeologic Report - pursuant to Part IV D of this Permit, and at least 180
calendar days pnor to Permit expiration, the Permittee shall submit for Executive
SecretarvDirector 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 m the shallow aquifer, including, but not linuted to local
geologic conditions, time relationships and distnbution of shallow aquifer head
measurements from facility wells and piezometers, local groundwater flow directions,
and distnbution of aquifer permeability and average linear groundwater velocity across
the site, and
b) Well specific groundwater quality conditions measured at facility momtonng wells for all
groundwater momtonng parameters requued by this Permit, mcludmg, but not linuted to
temporal contaminant concentrations and trends from each momtonng well, statistical
tests for normality of each contaminant and well, including umvanate or eqmvalent tests,
calculation of the mean concentration and standard deviation for each well and
contammant
11 Annual Shmes Dram Recovery Head Report - on or before March 1 of each year the
Permittee shall submit for Executive SecrotarvDirector approval an annual shmes drain
recovery head report for Tailings Cells 2 and 3 Said report shall conform to the requuements
of Part ID 3(b), IE 7(b), and E G of this Pemut, and
a) Provide the individual shmes drain recovery head monitonng 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 shmes drain recovery head for the previous calendar year
32
Part IF & IG
PemutNo UGW370004
c) Include a time senes chart to show trends of the recovery water level elevations at each
shmes dram
d) Include the results of a quality assurance evaluation and data validation Said
examination shall provide wntten descnptions and findings that
1) Evaluate all data collected, data collection methods, and all related calculations
required by this Permit, and
2) Venfy the accuracy and reliability of both the data and calculations reported
e) Demonstrate compliance stams with the requirements of Part ID 3(b) and IE 7(b) of this
Permit
12 Decontamination Pads Annual Inspection Report - the New Decontamination Pad and
Existing Decontamination Pad will be taken out of service and inspected annually dunng the
second quarter of each year, to ensure integnty of the concrete wash pad surfaces If physical
defects m the wash pad as defined by Part ID 14 of the Permit are identified dunng the
inspection, repairs shall be made pnor to resuming the use of the facility Said defects
include, but are not limited to concrete detenoration, 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 Momtonng Plan The inspection forms and
documentation of all repairs completed shall be included in the 2"*^ Quarter DMT Momtonng
Report due September 1, of each calendar year
G OUT OF CoMPLL\NCE STATUS
1 Accelerated Momtonng Stams - is required if the concentration of a pollutant in any
compliance momtonng sample exceeds a GWCL in Table 2 of the Permit, the facility shall
then
a) Notify the Executive SecretarvDirector in wnting withm 30 calendar days of receipt of
data, and
b) Immediately imtiate accelerated sampling of the pollutant as follows
1) Quarterly Baseline Momtonng Wells - for wells defined by Part IE 1(b) the
Permittee shall initiate monthly monitonng
2) Semi-annual Baseline Monitonng Wells - for wells defined by Part IE 1(c) the
Permittee shall imtiate quarterly monitonng
Said accelerated monitonng shall continue at the frequencies defined above until the
compliance status of the facility can be determined by the Executive SecretarvDirector
2 Violation of Permit Limits - out-of-comphance status exists when the concentration of a
pollutant m two consecutive samples from a compliance monitonng 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 SecretarvDirector a notification and descnption
33
Part IG
PennitNo UGW370004
of the failure according to R317-6-6 16(C)(1) Notification shall be given orally withm
24- hours of the Permittee's discovery of the failure of DMT or BAT, and shall be
followed up by wntten 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 SecretaryDirector shall use the information provided under R317-6-
6 16 C( 1) and any additional information provided by the Pemuttee to detemune whether
to imtiate a compliance action against the Permittee for violation of Permit conditions A
compliance action shall not be initiated, if the Executive SecretaryDirector 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 - m 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 m
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 SecretaryDirector, for the Executive
SecretaryDirector'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 SecretaryDirector of the out of compliance
status within 24-hours after detection of that status, followed by a wntten notice within 5
calendar days of the detection
b) The Permittee shall continue accelerated sampling pursuant to Part IG 1, unless the
Executive SecretaryDirector determines that other penodic sampling is appropnate, until
the facility is brought into compliance
c) The Permittee shall prepare and submit within 30 calendar days to the Executive
SecretaryDirector 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 groimdwater quality to insure that Permit limits will not be
exceeded at the compliance momtonng point and that DMT or BAT will be
reestablished
d) The Executive SecretaryDirector 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 momtonng point or to reestablish DMT or BAT as
defined in the Permit
34
PartlH
PennitNo UGW370004
e) Where it is infeasible to reestablish DMT or BAT as defined in the Permit, the Permittee
may propose an alternative DMT or BAT for approval by the Executive
SecretaryDirector
H COMPLIANCE SCHEDULE REQUIREMENTS The Permittee will comply with the schedules as
descnbed and summanzed below
1 On-site Chemicals Inventory Report - the Permittee shall complete a histoncal review, and
conduct an inventory ofall chemical compoimds 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 histoncally used, as data is
available At the time of Permit renewal, the Permittee shall submit an updated
inventory report pursuant to Part IF 8
2 Infiltration and Contaminant Transport Modeling Work Plan and Report - the Permittee shall
submit for Executive SecretaryDirector approval an infiltration and contaminant transport
modeling report that demonstrates the long-term ability ofthe tailmgs 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 engineenng
design and specifications will comply with the minimum performance requirements of Part
ID 8 of this Permit The Permittee shall submit an infiltration and contammant modelmg for
Executive SecrotarvDirector approval, that
a) Identifies all applicable and pertinent histonc studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance
b) Determines and justifies all information necessary for infiltration and contaminant
transport modeling, including but not limited to representative input values for vadose
zone and aquifer soil-water partitioning (Kd) coefficients, tailings source term
concentrations, tailings waste leach rates, vadose zone and aquifer groundwater
velocities, vadose zone and aquifer dispersivity, contaminant half-life or other rates of
decay, etc In the event that any required information is not currently available, the
Permittee may select conservative assumptions for use in the required infiltration and
contaminant transport models
c) Identifies and adequately descnbes 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 charactenstics and
physical processes at the tailings disposal site Said descnption will also include specific
information on model design, including, but not limited to govemmg equations and then
applicability to site conditions, gnd design, duration of simulation, and selection of time
steps
35
PartlH
PemutNo UGW370004
d) Determmes the concepmal model used and justifies why it is representative or
conservative of acmal field conditions at the site Said conceptual model will identify the
physical domain(s) and geometnes 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
e) Justifies how the infiltration and contaminant transport problem has been adequately
concepmalized, planned, and executed to demonstrate compliance with the requirements
of Part ID 8 of this Permit
f) Provides, descnbes and justifies the following
1) Model Results - including electromc input and output files from all infiltration,
groundwater flow and contaminant transport models used the report
2) Model Calibration - including descnption 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 dunng 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 descnption of vanous model simulations mn 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 distnbution of model parameters used m the problem domain
5) Post-model Audit Plan - including plans to revisit the modeling effort at some fiiture
time to re-assess its ability to represent site charactenstics and predict long-term
performance of tailings cell design and constmction, and groimdwater protection
The Permittee shall complete all modeling in accordance with the requirements of Part IH 2
and submit a final report for Executive SecretarvDirector 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
momtonng parameters, tailings cell cover system engineenng design and constmction
specifications, tailings cell operational requirements, etc In the event the Executive
SecretarvDirector requires additional information, the Permittee will provide all requested
information within a time frame approved by the Executive SecretarvDirector Upon
Executive SecretarvDirector 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 m water supply well WW-2, and to ensure adequate well casing and
annular seals, in compliance wilh the regulations of the Utah State Engineer (UAC R655-4-
9), with special emphasis on creating both a physical bamer and hydraulic isolation between
the shallow unconfined and the deep confined aquifers
36
PartlH
PemutNo UGW370004
On or before January 31, 2012, the Permittee shall
a) Conduct an investigation of water supply well WW-2 to venfy that the casing and
armular seal is intact and creates both a physical bamer and hydraulic isolation between
the shallow unconfined and the deep confined aquifers, said investigation shall include
one or more of the following investigation techniques performed in accordance with
applicable guidance from the U S Environmental Protection Agency well casing video
logs, cement bond logs, and/or temperature logs,
b) Show that the well casing and annular seal have physical and hydraulic mtegnty 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 repau 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 IH 3(a) to demonstrate existence of the required hydraulic isolation, and
c) Submit a wntten report for Executive SecretarvDirector 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
Installation of New Groimdwater Momtonng Wells - the Permittee shall install at least
two additional hydraulically dovmgradient 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 Monitonng Wells MW-36 and MW-37 - install at least two new
compliance momtonng 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 m accordance with Part IE 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 Bmshy Basin
Member of the Momson Formation, or as approved by the Executiv^e
SecretaryDirector
5) All new wells shall provide early detection of tailings cell contamination of
shallow groundwater from Tailmgs Cell 4B
6) All new wells shall provide discrete groimdwater monitonng for tailings Cell 4B
b) On or before June 30, 2011 or as otherwise approved by the Executive
SecretarvDirector, the Permittee shall submit a momtonng well As-Built report for all
new wells installed to document said well constmction for Executive
SecretaryDirector approval Said report shall comply with the requirements of Part
IF 6 In the event the Executive SecretanDirector requires additional information,
the Permittee will provide all requested information withm a time frame approved by
37
PartlH
PemutNo UGW370004
the Executiv^e SecretaryDirector
c) The Permittee shall provide at least a 14 calendar day wntten notice to allow the
Executive SecretarvDirector to observe all dnlling and well installation activities In
the event the Executive Secrctai-yDirector determines that additional monitonng 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 Exeoutiv^e
SecretaryDirector
Background Groundwater Quality Report for Well MW-35 and New Momtonng Wells -
withm 30 calendar days of Executive SecrotarvDirector approval of the new momtonng
well As-built Report, required by Part IH 4, above, the Permittee shall commence a
quarterly groundwater sampling program that will comply with the following Permit
requirements
a) Routine groundwater compliance monitonng requirements of Part IE 1
b) Well momtonng procedure requirements of Part IE 5
c) After completion of eight consecutive quarters of groundwater sampling and analysis of
well MW-35 and the new wells required by Part IH 4, the Permittee shall submit a
Background Report for Executive Secretai vDirector approval, that will include
1) Data preparation and statistical analysis of groundwater quality data, including, but
not limited to, evaluation of data charactenstics and internal data consistency,
treatment of non-detectable values, and statistical methods used These statistics shall
be calculated using the Decision Tree/Flowchart used for the previous Background
Reports that was conditionally approved by the DRC on August 24, 2007
2) Shallow aquifer average linear groimdwater 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 SecretarvDirector determines that
additional information is required, the Permittee shall provide all requested mformation,
resolve all issues identified, and re-submit the report for Executive SecretaryDirector
review and approval withm a timeframe approved by the Executive SecretarvDirector
After approval of this report, the Executive SecretarvDirector will re-open this Permit
and establish an appropnate monitonng frequency in accordance with the cntena found
in Part IE 1 (b) or (c), and establish Groundwater Compliance Limits in Table 2 for well
MW-35 and the each of the new wells
Detailed Southwest Hydrogeologic Investigation and Report - the purpose of this
investigation is to define, demonstrate, and charactenze 1) hydraulic cormection and local
groundwater flow directions between the area near Tailmgs Cell 4B, and the westem margin
of White Mesa, including Westwater and Cottonwood Seeps, and Rum Spnng, and 2) the fiill
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 bonngs and / or momtonng wells to completely enclose and define
both 1) the subsurface stmctural high area ofthe upper Bmshy Basin Shale Member
geologic contact and 2) the honzontal limits of saturation in the Burro Canyon
38
PartlH
PemutNo UGW370004
Formation Said study shall include, but is not limited to a subsurface area between
Tailmgs Cell 4B, and the Westwater and Cottonwood Seeps, and Ruin Spnng At a
minimum the charactenzation / defimtion 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 ofthe 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 IF 6(c) of this Permit
b) Demonstrate the fiill geologic and physical extent of the apparent unsaturated
stmctural high between Tailmgs Cell 4B and the westem margin of White Mesa,
including Westwater and Cottonwood Seeps and Ruin Spnng
c) Demonstrate the location and direction of all groundwater flow paths between
Tailings Cell 4B and nearby Westwater and Cottonwood Seeps and Ruin Spnng
Determine average linear groundwater velocity to said groundwater discharge
locations
d) Perform geologic logging of all bonngs / wells, and submit geologic logs performed
and certified by a Utah licensed Professional Geologist
e) Submit the investigation report for Executive SecretarvDirector 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 IF 6
2) A revised equipotential map to descnbe both the physical extent of the dry zone
and all groundwater flow directions near Tailmgs Cell 4B and Westwater and
Cottonwood Seeps, and Rum Spnng 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) Appropnate geologic and hydrogeologic maps and cross-sections (to scale)
6) Results and interpretation of aquifer permeabihty testing as per Part IF 6(c) of
this Permit
g) The Permittee shall provide at least a 14 calendar day wntten notice to allow the
Executive SecretarvDirector to observe all dnllmg and well installation activities
h) In the event the Executive SecretaryDirector determines that additional information is
required, this information will be submitted within a time frame approved by the
Executive SecretaryDirector
39
PartlH
PemutNo UGW370004
7 Modification to the DMT Monitonng and Cell 4A and Cell 4B BAT O&M Plans - on or
before August 1, 2011, the Permittee shall submit proposed modifications to the currently
approved DMT Monitonng and Cell 4A and Cell 4B BAT O&M Plans for Executive
SecretarvDirector approval Said changes shall conform to the requirements of Parts ID 3(b),
ID 6(c), ID 13(c), IE 7(b), IE 8(b), IE 12( b), and IF 11 of this Pemut
40
Partn
PemutNo UGW370004
PART n REPORTING REQUIREMENTS
A REPRESENTATIVE SAMPLING Samples taken m compliance with the monitonng 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 monitonng device or method required to be mamtamed under
this Permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation,
or by impnsonment for not more than six months per violation, or by both
D REPORTING OF MONITORING RESULTS Momtonng results obtained dunng reporting penods
specified in the Permit, shall be submitted to the Executive SecretarvDirector, Utah Division of
Water Quality at the following address no later than the date specified following the completed
reporting penod
Attention Compliance and Monitonng Program
State of Utah
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 COMPLL\NCE SCHEDULES Reports of compliance or noncompliance with, or any progress reports
on intenm and final requirements contained m any Compliance Schedule of this Permit shall be
submitted no later than 14 calendar days following each schedule date
F ADDITIONAL MONITORING BY THE PERMITTEE If the Permittee momtors any pollutant more
frequently than required by this Permit, using approved test procedures as specified in this
Permit, the results of this monitonng shall be included in the calculation and reportmg of the data
submitted Such increased frequency shall also be indicated
G RECORDS CONTENTS
1 Records of momtonng 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
41
Partn
PennitNo UGW370004
H RETENTION OF RECORDS The Permittee shall retain records of all momtonng 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 penod of at
least five years from the date ofthe sample, measurement, report or application This penod may
be extended by request of the Executiv^e SecretarvDirector at any time
I NOTICE OF NONCOMPLL\NCE 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], dunng normal business hours (8 00 am
- 5 00 pm Mountain Time)
2 A wntten submission shall also be provided to the Executive SecretaryDirector withm five
calendar days of the time that the Permittee becomes aware of the cucumstances The wntten
submission shall contain
a) A descnption of the noncompliance and its cause,
b) The penod of noncompliance, mcluding 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 n D, Reporting of Momtonng Results
J OTHER NONCOMPLL\NCE REPORTING Instances of noncompliance not required to be reported
within 5 calendar days, shall be reported at the time that monitonng reports for Part n D are
submitted
K INSPECTION AND ENTRY The Permittee shall allow the Executive SecretarvDirector, or an
authonzed 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 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 monitonng and control
equipment), practices, or operations regulated or required under this Permit, and,
4 Sample or monitor at reasonable times, for the purpose of assunng Permit compliance or as
otherwise authonzed by the Act, any substances or parameters at any location
42
•
Partm
PemutNo UGW370004
PART m COMPLDVNCE RESPONSIBILITIES
A DUTY TO COMPLY The Permittee must comply with all conditions of this Permit Any Permit
noncompliance constitutes a violation of the Act and is grounds for enforcement action, for
permit termination, revocation and re-issuance, or modification, or for demal of a permit renewal
application The Permittee shall give advance notice to the Executive SecretaryDirector 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 pumshed by a fine not
exceeding $50,000 per day Nothing in this Permit shall be constmed to relieve the Permittee of
the civil or cnminal penalties for noncompliance
C NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE It shall not be a defense for a Permittee m
an enforcement action that it would have been necessary to halt or reduce the permitted activity
in order to maintain compliance with the conditions of this Permit
D DUTY TO MITIGATE The Permittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this Permit which has a reasonable likelihood of adversely affecting
human health or the environment
E PROPER OPERATION AND MAINTENANCE The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the Permittee to achieve compliance with the conditions of this Permit
Proper operation and maintenance also includes adequate laboratory controls and quality
assurance procedures This provision requires the operation of back-up or auxiliary facilities or
similar systems which are installed by a Permittee only when the operation is necessary to
achieve compliance with the conditions ofthe Permit
43
PartlV
PemutNo UGW370004
PARTFV GENERAL REQUIREMENTS
A PLANNED CHANGES The Permittee shall give notice to the Executive SecretarvDirector as soon
as possible of any planned physical alterations or additions to the permitted facility Notice is
required when the alteration or addition could significantly change the nature of the facility or
increase the quantity of pollutants discharged
B ANTICIPATED NONCOMPLL\NCE The Permittee shall give advance notice of any planned changes
in the permitted facility or activity which may result m noncompliance v^th Permit requirements
C PERMIT ACTIONS This Permit may be modified, revoked and reissued, or terminated for cause
The filing of a request by the Permittee for a permit modification, revocation and re-issuance, or
termination, or a notification of planned changes or anticipated noncompliance, does not stay any
permit condition
D DUTY TO REAPPLY If the Permittee wishes to continue an activity regulated by this Permit after
the expiration date of this Permit, the Permittee must apply for and obtain a new permit The
application should be submitted at least 180 calendar days before the expiration date of this
Permit
E DUTY TO PROVIDE INFORMATION The Permittee shall flirmsh to the Executive SecretaryDirector,
within a reasonable time, any information which the Executive SecretarvDirector may request to
determine whether cause exists for modifying, revoking and reissumg, or terminatmg this Pemut,
or to determine compliance with this Permit The Permittee shall also fumish to the Executive
SecretaryDirector, 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 SecretarvDirector. it shall promptly submit such facts or information
G SIGNATORY REQUIREMENTS All applications, reports or information submitted to the Executive
SecrotarvDirector 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 propnetorship by a general partner or the propnetor,
respectively
c) For a municipality. State, Federal, or other public agency by either a pnncipal executive
officer or ranking elected official
2 All reports required by the Permit and other information requested by the Executive
Secretai-yDirector shall be signed by a person descnbed above or by a duly authonzed
representative of that person A person is a duly authonzed representative only if
a) The authonzation is made in vmting by a person descnbed above and submitted to the
Executive SecretarvDirector, and.
44
PartFV
PemutNo UGW370004
b) The authonzation specified either an individual or a position havmg 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, supenntendent, position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company (A duly authonzed representative may thus be
either a named individual or any individual occupying a named position)
3 Changes to Authonzation If an authonzation under Part FV G 2 is no longer accurate
because a different individual or position has responsibility for the overall operation ofthe
facility, a new authonzation satisfying the requirements of Part FV G 2 must be submitted to
the Executive SecretarvDirector pnor to or together with any reports, information, or
applications to be signed by an authonzed representative
4 Certification Any person sigmng 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 mformation submitted Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathenng the information, the information submitted is, to the best of my
knowledge and belief, tme, accurate, and complete I am aware that there are sigmficant
penalties for submitting false information, including the possibility of fine and
impnsonment 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 Pemut, mcludmg momtonng 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 impnsonment 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 SecretaryDirector 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 nghts of any sort,
or any exclusive pnvileges, nor does it authonze any injury to pnvate property or any invasion of
personal nghts, 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 Penmt, 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
45
PartFV
Permit No UGW370004
1 The current Permittee notifies the Executive SecretaryDirector at least 30 calendar days in
advance of the proposed transfer date,
2 The notice includes a wntten agreement between the existing and new Pemuttee contaimng a
specific date for transfer of permit responsibility, coverage, and liability between them, and,
3 The Executive SecretaryDirector does not notify the existmg 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 m this Permit shall be constmed to preclude the instimtion of any legal
action or relieve the Permittee from any responsibilities, liabilities, penalties established pursuant
to any applicable state law or regulation under authonty preserved by Section 19-5-115 of the
Act
N REOPENER PROVISIONS This Permit may be reopened and modified (following proper
admimstrative procedures) to include the appropnate 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 vanance under the conditions outlined in R317-6-6 4(D)
2 Changes have been determined in background groundwater quality
3 The Executive SecretaryDirector determines permit modification is necessary to protect
human health or the environment
46
Page 1 of2
John Hultquist - Changes of Titles and Contact Information for Energy Fuels Resources (USA)
Inc.
From: David Frydenlund <DFrydenlund@energyfuels com>
To: Phillip Goble <Pgoble@utah gov>, John Hultquist <jhultquist(gutah gov>. Rusty Lundberg
<rlundberg@utah gov>
Date: 8/15/2012 12 33 PM
Subject: Changes of Titles and Contact Information for Energy Fuels Resources (USA) Inc
CC: Harold Roberts <HRoberts@energyfuels com>, Jo Ann Tischler
<JTischler@energyfuels com>, David Turk <DTurk@energyfuels com>, Kathy Weinel
<KWeinel@energyfuels com>
Phil,
Further to our call yesterday morning, this is to confirm that Demson Mines (USA) Corp changed its name to
Energy Fuels Resources (USA) Inc effective July 25, 2012 The name has changed, but the entity remains the
same
Also, some changes have been made in the titles of certain personnel The following table sets out the current
titles and contact information for the key personnel that DRC corresponds with on a regular basis regarding
White Mesa Mill matters
Name Current Title Comments Email Address Direct
Telephone
Number
Stephen P
Antony
President and Chief
Executive Officer
santony^aenergyfuels com (303) 974-
2142
Harold R
Roberts
Executive Vice
President and Chief
Operating Officer
hroberts(a)enerKvfuels com (303) 389-
4160
David C
Frydenlund
Senior Vice
President,
Regulatory Affairs
and General Counsel
dfrvdenlund@energvfuels com (303) 389-
4130
Jo Ann S
Tischler
Director, Compliance itischlerCSenerRvfuels com (303) 389-
4132
Katherme A
Weinel
Quality Assurance
Manager
(No Change to
Title)
kwemel^energyfuels com (303) 389-
4134
Daniel L Hillsten Mill Manager (No Change to
Title)
dhillsten(S)energvfuels com (435) 678-
4105
David E Turk Manager,
Environmental,
Health and Safety
dturk@energvfuels com (435) 678-
4113
Ronnie B Nieves Mill Radiation Safety
Officer
rnieves(5)energvfuels com (435) 678-
4114
Jaime J Massey Environmental
Compliance Assistant
(No Change to
Title)
imassevti^energvfuels com (303) 389-
4167
file//C\Users\jhultqui\AppData\Local\Temp\XPgrpwise\502B970EEQDOMAINEQRAD 8/22/2012
Page 2 of 2
Effective August 20, 2012, Energy Fuels Resources (USA) Inc will be moving its offices to the following address
Energy Fuels Resources (USA) Inc
225 Union Blvd , Suite 600
Lakewood, CO 80228
The mam phone number will continue to be [phone]
The fax number will continue to be [phone]
Please let me know if you have any questions, or require any further information
Dave
David Frydenlund
Vice President, Regulatory Affairs, Counsel and Corp Secretary
Energy Fuels Resources (USA) Inc
t 303-389-4130 |f 303-389-4125
1050 17th Street Suite 950
Denver, CO, US, 80265
http //www energyfueis com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s) This message and any attached files with it are confidential
and may contain privileged or proprietary information If you are not the intended recipient(s) please delete this message and notify the sender You
may not use, distribute pnnt or copy this message if you are not the intended recipient(s)
file //C \Users\jhultqui\AppData\Local\Temp\XPgrpwise\502B970EEQDOMAINEQRAD 8/22/2012