DRC-2015-002149 - 0901a0688051df0b

m ENE
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
ChiEDnvaicri c Lakewood, CO, US, 80228
303 974 2140
www.enertivfuels.com DRC-2015-002149
April 6, 2015
VIA EXPRESS DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Dear Mr. Lundberg:
Re: Utah Ground Water Discharge Permit No. UGW3700004
White Mesa Uranium Mill - Discharge Minimization Technology Monitoring Plan ("DMT
Plan")
Pursuant to the Division of Radiation Control's ("DRC's") March 5, 2015 letter, regarding the 4Ih Quarter
2014 DMT Performance Standards Monitoring Report, Energy Fuels Resources (USA) Inc. ("EFRI") is
submitting a revised DMT Plan for DRC review. As requested in the DRC March 5, 2015 letter,
references to Roberts Pond have been removed from the DMT Plan because Roberts Pond has been
removed from service. The final excavation report for Roberts Pond was submitted to DRC under
separate cover. A redline strikeout version and clean version of the DMT Plan are attached for your
convenience.
Please contact me if you have any additional questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
v- o / (/
REDLINE
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 12.23
Mav 2014April 2015
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
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WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. INTRODUCTION 3
1.1. Background 3
2. DAILY TAILINGS INSPECTIONS 4
2.1. Daily Inspection 4
3. WEEKLY TAILINGS AND DMT INSPECTION 5
3.1. Weekly Tailings Inspections 5
Northing 9
Easting 9
3.2. Weekly Feedstock Storage Area Inspections 12
4. ANNUAL EVALUATIONS 12
4.1. Freeboard Limits 12
4.2. Annual Leak Detection Fluid Samples 13
4.3. Annual Inspection of the Decontamination Pads 13
5. 5.0 Inspection of the Ammonium Sulfate Cover Area 13
6. OTHER INSPECTIONS 14
7. REPORTING REQUIREMENTS 14
7.1. DMT Reports 14
ATTACHMENTS
Attachment A Forms
Attachment B Feedstock Storage Area
Attachment C Tables
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1. INTRODUCTION
This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
White Mesa Mill's (the "Mill's") Groundwater Discharge Permit ("GWDP") Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT 1900479 (the "RML") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the Mill's Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation ofthe
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
| systems, as well as monitoring of water levels in Roberts Pond and the feedstock storage areas at the
Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill's Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill's Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill's Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
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to be managed, inspected and enforced under the requirements of the RML.
This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1,2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1, 2, 3, 4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-l to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2. lq).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
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(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell's LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1, 2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-l of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill's environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
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volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
For Cells 1, 2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C ofthe
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table 1A and 1B (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe.. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
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(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5618.73 fmsl), and made to the nearest 0.01 foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5618.73 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11, 2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi) No process liquids shall be allowed to be discharged into Cell 2;
(vii) If at any time the most recent average annual head in the Cell 2 slimes drain is found
to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 4A, and 4B and Roberts Pond are to be taken by
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survey on a weekly basis. The beach area in Cell 4B with the maximum elevation is to be
taken by survey on a monthly basis when beaches are first observed, as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee (the
"Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii) The Reference Points for Cells 1, Cell 4A, and 4B, and Roberts Pond are known
points established by professional survey. For Cell 1 and Roberts Pond, the
Reference Point is a wooden stake with a metal disk on it located on the southeast
corner of Cell 1. The elevation of the metal disk (the "Reference Point Elevation")
for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level ("FMSL"). For
Cell 4A and 4B, the Reference Point is a piece of stamped metal monument located
next to the transformer on the south side of Cell 4A and 4B. The elevation at the top
of this piece of rebar (the Reference Point Elevation for Cell 4A and 4B) is 5600.49
fmsl. The Surveyor will set up the Survey Instalment in a location where both the
applicable Reference Point and pond surface are visible.
(iv) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1/Roberts Pond Reference Point on the top of the rebar on the
Cell 4A and 4B Reference Point. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established a
level reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1, Cell 4A, or Cell 4B, er
Roberts Pond, _or the area of the beach in Cell 4B with the highest elevation, as the
case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
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I. Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
II. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
m. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
4AA Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northing Easting
Roberts Pond 323,011 2,579,697
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
B. Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
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elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
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any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill's maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
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3T2-I Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3T^T3.2. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
Freeboard Limits
4A-A-. Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0 feet above mean sea
level, as specified in the GWDP.
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| 4T2T4. 1. Annual Leak Detection Fluid Samples
Pursuant to Part I.E. 10(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
| 4T3T4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
5. 5.0 Inspection of the Ammonium Sulfate Cover Area
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1/8 inch separation (width) or any significant deterioration or damage of the concrete
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pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7.1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3.1(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3.1(d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2 (Weekly Inspection of Solution
Levels in Roberts Pond), 3.3 3.2(Weekly Feedstock Storage Area Inspections) 5.0
(Inspection of the Ammonium Sulfate Cover Area [for 8 quarters including any
repairs required, and repairs completed]);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
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Page 15 of 24
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
e) With respect to the annual inspection (after the completion of 8 quarterly
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
f) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
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Page 16 of 24
ATTACHMENT A
FORMS
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Page 17 of 24
ATTACHMENT A-l
DAILY INSPECTION DATA
Inspector:,
DateiT
Accompanied by:
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked
Wet _Dry Wet -Dry Wet -Dry Wet .Dry
Checked
Wet -Dry
Initial level.
Final
level
Initial level.
Final
level
Initial level.
Final
level
Initial level.
Final
level
Initial level.
Final
level
Gal, pumped. Gal, pumped. Gal, pumped. Gal, pumped. Gal, pumped.
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-l)
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Page 18 of 24
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date: Inspectors:
1. Pond and Beach
elevations (msl, ft)
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation 5597_
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
5555.14
2. Leak Detection Systems
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (u)Pond Solution Elevation
(b)FML Bottom Elevation 5612.3
(c)Dcpth of Water above FML ((a) (b))
Observation:
New Decon Pad, Portal New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
An!
_wet dry _wet dry _wet dry
If wet, Record liquid
level:
_Ft to Liquid _Ft to Liquid _Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
I White Mesa Mill - Discharge Minimization Technology Monitoring Plan 5/M4/15 Revision: EFRI 12.33
Page 19 of 24
ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no:
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No:
Comments:
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Page 20 of 24
Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes: No:
Comments:
| Is there free-any evidence of breakage, spillage or leakage?
Yes: No:
Comments:
Other comments:
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Page 21 of 24
ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? Yes No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due
September 1 of each calendar year.
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Page 22 of 24
ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the asphalt surface? Yes No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
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Page 23 of 24
ATTACHMENT B
FEEDSTOCK STORAGE AREA
n
\
o MJ
r i <
0 G
LZJ HE
S
N wHrreMWAK*!
F—ditocfc 8towpe Area
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Page 24 of 24
ATTACHMENT C
TABLES
Table IA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Calculated Action leakage Rate
( gallons / acre / day)
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet)
10
15
20
25
30
35
37
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Head above Liner System (feet)
10
15
20
25
30
35
37
Calculated Action leakage Rate
( gallons / acre / day )
211.40
317.00
369.90
422.70
475.60
528.40
570.00
581.20
CLEAN
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 12.3
April 2015
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12.3
Page 2 of 23
WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. INTRODUCTION 3
1.1. Background 3
2. DAILY TAILINGS INSPECTIONS 4
2.1. Daily Inspection 4
3. WEEKLY TAILINGS AND DMT INSPECTION 5
3.1. Weekly Tailings Inspections 5
Northing 9
Easting 9
3.2. Weekly Feedstock Storage Area Inspections 12
4. ANNUAL EVALUATIONS 12
4.1. Annual Leak Detection Fluid Samples 12
4.2. Annual Inspection of the Decontamination Pads 12
5. 5.0 Inspection of the Ammonium Sulfate Cover Area 13
6. OTHER INSPECTIONS 13
7. REPORTING REQUIREMENTS 13
7.1. DMT Reports 14
ATTACHMENTS
Attachment A Forms
Attachment B Feedstock Storage Area
Attachment C Tables
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12.3
Page 3 of 23
1. INTRODUCTION
This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
White Mesa Mill's (the "Mill's") Groundwater Discharge Permit ("GWDP") Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT1900479 (the "RML") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the Mill's Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of the feedstock storage areas at the Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill's Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill's Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill's Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12 3
Page 4 of 23
This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1,2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1, 2, 3,4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safely Officer (RSO) or his designee is responsible for performing these daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-1 to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2. lq).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12.3
Page 5 of 23
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell's LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1,2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-l of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill's environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision- EFRI 12.3
Page 6 of 23
For Cells 1,2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C ofthe
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table 1A and IB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom ofthe
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe.. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
White Mesa Mil! - Discharge Minimization Technology Monitoring Plan 4/15 Revision- EFRI 12 3
Page 7 of 23
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5618.73 fmsl), and made to the nearest 0.01 foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5618.73 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11,2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi) No process liquids shall be allowed to be discharged into Cell 2;
(vii) If at any time the most recent average annual head in the Cell 2 slimes drain is found
to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 4A, and 4B are to be taken by survey on a weekly
basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a
monthly basis when beaches are first observed, as follows:
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Page 8 of 23
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee (the
"Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii) The Reference Points for Cells 1, Cell 4A, and 4B, are known points established by
professional survey. For Cell 1, the Reference Point is a wooden stake with a metal
disk on it located on the southeast comer of Cell 1. The elevation of the metal disk
(the "Reference Point Elevation") for Cell 1 is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 4A and 4B, the Reference Point is a piece of stamped metal
monument located next to the transformer on the south side of Cell 4A and 4B. The
elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A
and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a
location where both the applicable Reference Point and pond surface are visible.
(iv) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and
4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by
gently rocking the rod back and forth until the Surveyor has established a level
reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1, Cell 4A, or Cell 4B, or
the area of the beach in Cell 4B with the highest elevation, as the case may be. These
designated locations, and the methods to be used by the Assistant to consistently use
the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
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Page 9 of 23
A. Pond Surface Measurements
I. Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
H. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
LT. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are:
Northing Easting
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
B. Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
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(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
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to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill's maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision EFRI 12 3
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3.2. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Annual Leak Detection Fluid Samples
Pursuant to Part I.E. 10(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
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b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use ofthe facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
5. 5.0 Inspection of the Ammonium Sulfate Cover Area
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1/8 inch separation (width) or any significant deterioration or damage of the concrete
pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
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7.1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3.1(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3.1(d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
including any repairs required, and repairs completed]);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
e) With respect to the annual inspection (after the completion of 8 quarterly
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
f) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report.
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ATTACHMENT A
FORMS
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ATTACHMENT A-l
DAILY INSPECTION DATA
Inspector:.
Date:
Accompanied by:
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked
Wet .Dry Wet _Dry Wet -Dry Wet .Dry
Checked
Wet _Dry
Initial level.
Final
level
Initial level.
Final
level
Initial level.
Final
level
Initial level.
Final
level
Initial level.
Final
level
Gal, pumped. Gal. pumped_ Gal, pumped. Gal, pumped. Gal. pumped_
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tai
System (Appendix A-l)
ings Management
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ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date: Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation
elevations (msl, ft)
(b) FML Bottom Elevation 5597_
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14_
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
2. Leak Detection Systems
Observation:
New Decon Pad. Portal New Decon Pad. Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
_wet dry _wet dry wet _dry
If wet, Record liquid
level:
_Ft to Liquid _Ft to Liquid _Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
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ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:.
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock matenals stored in the area indicated on the attached diagram:
yes: no:
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No:
Comments:
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision- EFRI 12 3
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Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes: No:
Comments:
Is there any evidence of breakage, spillage or leakage?
Yes- No:
Comments:
Other comments:
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ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
__Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? Yes No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due
September 1 of each calendar year.
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ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
_Yes No
Is there any significant deterioration or damage of the asphalt surface? Yes No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
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ATTACHMENT B
FEEDSTOCK STORAGE AREA
o
o o
n
1]
N
t
WWTEMEflAligr rtar
Foadstoffc 8toMflB Aiaa Map
1&. l "tm i .
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision. EFRI 12.3
Page 23 of 23
ATTACHMENT C
TABLES
Table IA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet)
10
15
20
25
30
35
37
Calculated Action leakage Rate
( gallons / acre / day )
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Calculated Action leakage Rate
( gallons / acre / day )
211.40
317.00
369.90
422.70
475.60
528.40
570.00
581.20
Head above Liner System (feet)
10
15
20
25
30
35
37