DRC-2010-008445 - 0901a06880bc13a7

DENISOND/I
MINES
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax : 303 389,4125
www.denisonmines.com
Re:
December 20,2010
VIA E.MAIL AND OVERNIGHT DELIVERY
Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
\
State of Utah Division of'Radiation Control ('DRC') Request for lnformation Letter of November 30,
2010 Regarding Reclamation Plan Revision 3.2, Utah Radioactive Materials License UT1900479
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed addendum to the reclamation Plan Revision 3.2 for
White Mesa Mill which are currently pending UDEQ approval. This letter also responds to DRC's Request for
lnformation ('RFl') letter of November 30,2010 requesting additional changes to previously submitted versions
of this document. As requested in the DRC letter, the addendum to Reclamation Plan Revision 3.2 has been
entitled Reclamation Plan Revision 3.2.A. and all changes have been linked to the previously approved version,
Revision 3.1. The information in Revision 3.2.A is being submitted as an addendum to approved Reclamation
Plan Revision 3.1.
Reclamation Plan Revision 3.2.A consists of.
o the contents of approved Revision 3.0 and submittals referred to as Revision 3.1 ,o thecontentsof Revision 3.2 modified as requested by DRC's RFI letterof November30,2010, and. additional material requested in DRC's RFI letter of November 30, 2010.
For ease of comparison, the Addendum Revision 3.2.A has been developed from and all redlined changed
linked to, the approved Revision 3.1. For ease of review, the text sections included in the Addendum have
been provided in both redline/strikeout and blackline ("clean") form, which are provided, respectively, as
Attachments 1 and 2 to this letter. These revisions incorporate all the changes requested in DRC's RFI letter of
November 30, 2010.
Denison requests that UDEQ review and approve the attachments to this letter.
Denison has provided, below, specific responses to each request in DRC's RFI letter. The sections and
numbering of the remainder of this letter follow that of the RFl. Each UDEQ request is shown in italics, below,
followed by Denison's response.
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Letter to Mr. Rusty Lundberg
December 20,2010
Page2
DEQ Comments and Responses
1. The Table of Contents for the Plan needs to be adjusted as a consequence of the subject
Addendum to the existing Reclamation Plan.
Denison Response: The table of contents has been adjusted as indicated in the attachments.
2. On page 1-1 of the redline copy, please retain the last sentence of the second full paragraph
and the list of the facilities to be decommissioned on pages 1-1 through 1-2.
Denison Response: The last sentence and the list of facilities to be decommissioned has been restored to the
text. Three additional items have been added to the list as indicated in the attached addendum.
3. Existing Figure A-5.1-2 in approved Revision 3.1 appears to contain cross secfions and details
which are essenfra/ to be retained in the Reclamation Plan.
a. Therefore, existing Figure A-5.1-2 must somehow be retained and not replaced by the
Addendum.
Denison Response: Figure A-5.1-2 contains the referenced cross sections and details and is attached.
b. ln other elements of the Plan, the existing Figure A-5.1-2, and Figure A-5.1-4 in the
existing plan need to include, as appropriate, the design as wellas fhe assocrafed drawings
for a sub rip+ap tailings filter blanket.
Denison Response: Other elements of the Plan have been revised as indicated in the attached redline
addendum to address the design for the sub rip-rap tailings filter blanket.
4. ln accordance with the subject License Condition 9.11, the Plan needs to describe the use of new
permanent fixtures or facilities that have been installed or are contemplated to be constructed in
conjunction with the reclamation of Cells 4A and 48. We suggesf this be accomplished by referencing
the specific as-built drawings, DMT, and BAT O&M Plans for these facilities.
Denison Response: As requested, the Plan has been revised to address the new facilities associated with the
reclamation of Cell 4A and 48. This has been accomplished by reference to the Cell 4A and 48 Construction
Quality Assurance Reports and the DMT and BAT O&M Plans as indicated in the attached Addendum.
5. Existing Figure 3.2.3-1 is contained in Reclamation Plan 3.1. This figure is a site map of the mill and
ore pad. However, the figure does not reference the distinct boundaries of the ore sforage pad as
provided by a map in the DMT Plan, and as defined by coordinates in Part l.D.3.f of the Ground Water
Discharge Permit. Please incorporate these references in the Plan, or adjust the figure appropriately to
include these boundaries.
Denison Response: Figure 3.2.3-1 has been revised to indicate the boundaries of the ore pad.
6. We request fhat the cover and the text of Reclamation Plan be revised fo sfate that Reclamation
Plan Revision 3.2 is in the form of an Addendum to Reclamation Plan 3.0 and 3.1.
oEN'soJ)//
MINES
Letter to Mr. Rusty Lundberg
December 20,2010
Page 3
Denison Response: The cover has been revised to indicate that the reclamation Plan 3.2.A is an addendum to
reclamation Plan 3.0 and 3.1.
7. Attachment C to the subject Plan included a revised surety estimate that is out-dated. We
acknowledge more recent surety cost estimates provided by DUSA on March 3, August 19,
and October 15,2010. We have a/so mosf recently asked DUSA to modify its 2010 surety
estimate in a November 16,2010 Requesf for lnformation lefter. Therefore, please be advised
that any future DRC approval of Revision 3.2 will not include any approval of the existing
Attachment C.
Denison Response: No response required. Denison acknowledges that existing Attachment C has been
superseded by more recent submittals to DRC.
8. The revised Plan edition of Reclamation Plan Revrslon 3.2 (i.e. the Addendum) will need to be
identified by a unique edition name, but still retain the Reclamation Plan Revision 3.2label,
e.g. "Edition A," or other method for identifying the unique edition.
Denison Response: The revised Plan has been identified as Reclamation Plan Revision 3.2.A.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
DeHrsol.r MrNes (USA) Conp.
C)^L;l--- J*=-/,ltn
r' Jo AnnTischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Centralfiles
DEN!SOJ)//
MINES
DENEOJ)I/
MINES
Dsnison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax : [phone]
wwwdenisonmineg,com
White Mesa Mill Reclamation PIan
Revision 3.2.4
Addend um/Ghanged Pages
for the
White Mesa Mill and
Tailings Management System
December 2010
State of Utahlle.(2) Byproduct Material License #UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
't050 17th Street, Suite 950
Denver, CO, USA 80265
Tel : [phone]
Fax : [phone]
TABLE OF CONTENTS
Page i
Revision 3.24
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Page No.
LISTOFTABTES
LISTOF FIGURES
LIST OF ATTACHMENTS
TISTOFAPPENDICES
REFERENCES
1NTRODUCTtON..................
1.0 SITECHAMCTERISTICS
't_1 CLIMATE 1-5
1-5
1-6
1-6
1-6
'1.1.'l Generallnfluences
1.1.2 Precipitation
1.2 TOPOGMPHY
1.3 ARCHEOLOGICATRESOURCES.
1.3.1 ArcheologicalSites...............
1.3.2 Current Status of Excavation.
,..................... 1 -1 0
.............1-10
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1-13
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Page No.
,.........1-141.4 SURFACE W4T8R..................................
1.4.1 SurfaceWaterDescription....
1.4.2 Surface Water Qualiry
1.5 GROUNDWATER.............................
1-14
1-19
,....................1 -23
Site Description .....................
Geologic Sening............... ..
1.5.2.1 Stratigraphy.........
'1.5.2.2 Local Geologic 5tructure
1.5.3 HydrogeologicSetting
1.6 GEOLOGY
'1.6.'l RegionalGeologr...........
1.5.1
1.5.2 ........................1 -26
1-28
1-30
1.5.3.1 Hydrostratigraphy
1.5.4 ClimatologicalSetting...........
1.5.5 Perched Ground Water Characteristics.............. ..........1-54
1.5.5.1 Perched Water Qualiry 1-60
1-62
1-63
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Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
1.6.7 Blanding Site Geolog,
1.6.1.1
1.6.1.2
1.6.1.3
1.6.2.1
1.6.2.2
1.6.2.3
1.6.2.4
1.6.2.5
1-78
L7A
1 .6.3.2 Pseudostatic Analysis (Seismiciry).................. .......................1-99
1.7 1-100
1-100
1-100
1.7 .1 Terrestrial
1.7.1.1 Flora
1.7.1.2Fauna....................... 1 -1 05
1.7.2 Aquatic8iota.................................................. 1 -1 07
1.8 NATUMLRADIATION
Background..........
Current Monitoring Data........
1.8.2.1 Environmental Radon
1-113
1.6.3
Physiography and Topography
Structure 1-86
Relationship of Earthquakes to Tectonic Structures....... .............................1-90
Potential Earthquake Hazards to Project.............1-96
1.8.1
1.8.2
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2.0
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
1.8.2.3 Vegetation Samples..........1-114
'1.8.2.4 Environmental Air Monitoring and Stack Sampling ................... 1 -1 1 4
1.8.2.6 Surface Water ............................ 1-1 1 6
1.8.2.7 Meteorological Monitoring... .................... 1-'116
EXIST!NG FACILITY
2.'I FACILITYCONSTRUCTIONHISTORY
2.1.1 Mill and Tailings Management Facility z-1
2.2
Operating Periods.............
MillCirc ........................ 2-4
2.3 MONITORING PROGMMS...
2.3.1 MonitoringandReportingUndertheMill'sGWDP.......
Groundwater Monitoring.....
2.2.1
2.2.2
2.2.3
2-2
2-2
2-9
2-9
Deep Aquifer
Seeps and Springs............
Discharge Minimization Technolory and Best Available Technologr
Standards and Monitoring -...-.-.......-.
2.3.1.4.1 General
2.3.1.5 BAT Performance Standards for Cell 44
2.3.1.1
2.3.'.t.2
2.3.1.3
2.3.1.4
,..................... 2-1 3
z-'14
z-15
2-15
2-20
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2.3.1.6
2.3.1.7
2.3.2.1
2.3.2.2
RECTAMATION PLAN
3.2.1
3.2.2
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Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Stormwater Management and 5pill Control Requirements....2-22
2.3.2 Monitoring and lnspections Required Under the License
Environmental Monitoring...
Additional Monitoringand lnspectiOns required Underthe 1icense.....................2-33
3-43.2
LOCATION AND PROPERTY DESCRI PTION...........,..,........
FACILITIES TO BE RECLAIMED
2-24
z-24
nd Equipment. and Other 11e.(2) Byproduct Materia|..............................3-12
.....3-'t5
Tailings and Evaporative Cells ...............3-7
3.2.2.1 Soil Cover Design....................................3-7
3.2.2.2 Celll-1.
3-'11
Cell4/
3-9
3.2.2.4 Cell3...
3.2.2.6 Cell48
3.2.3.'l Mill Building a
3.2.3.2 MillSite...........
3.3 DESTGN CR|TERtA.....................
Regulatory Criteria
Radon Flux Attenuation
................3-1 5
.....................3-1 63.3.1
3.3.2
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3-'t7
3.3.3
3.3.4
3.3.5
3.3.6
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
3-20
F reezefThaw Eval uation 22
Soil Cover Erosion Protection
Slope Stabi lity Analysis
3.3.6.2 Pseudostatic Analysis (Seismicity)................. ........................3-26
3.3.8 Cover Material/Cover Material Volumes.... ................3-27
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TABLE 1 .1-1
TABLE 1.1-2
TABLE 1.3-1
TABLE 1.5-1
LIST OF TABIES
Temperature Means and Extremes at Blanding Utah
(Table 2.1.1 Dames & Moore -Final ES)
Drainage Areas of Project Viciniry and Region.............
(Table 2.6-3 Dames & Moore -Final ES)
Wells Located Within a 5-Mile Radius of the
Precipitation Means and Extremes at Blanding Utah.................. ......... 1-9
(Table 2.1-2 Dames & Moore -Final E5)
Distribution of Recorded Sites According..-......-...........
to Temporal Position
(Table 2.3-2 Dames & Moore -Final E5)
Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Page No.
............................ 1 -8
...............1-',t2
1-18TABLE 1.4-1
White Mesa Uranium Mi11.......
(Table 1.1 Titan)
TABLE 1.5.3.1-1 Propenies of the Dakota,/Burro Canyon Formations,
White Mesa Uranium Mill
(Table 2.1 Titan)
TABLE 1.5.3.1-2 Summary of Hydraulic Properties, White Mesa
Uranium Mill
(Table 2 2 Titan)
TABLE 1 .5.3.2-1 Summary of Borehole Tesrs, 1994 Drilling Program,
White Mesa Proiect, San Juan County, Utah
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1-33
1-39
1-40
1-52
Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
TABLE 1 .5.3.2-2 Results of Laboratory Tests.............
TABLE 1.5.5-1 Monitoring Well and Ground Water Elevation Data,
1-53
White Mesa Uranium Mi11...................
(Table 2.3 Titan)
tlST OF TABTE (continued)
Generalized Stratigraphic Section of Subsurface Rocks
Based on Oil-Well 1ogs..................
(table 2.0-r UMETCO)
.............. 1-59
Page No.
......................... 1-69
TABLE 1.6.1
TABLE 1.6-2
TABLE 1.6-3
TABLE 1.7-1
IABLE1.7-2
TABLE 1.7-3
Generalized Stratigraphic Section of Exposed Rocks
in the Project Vicinity........................... 1-70
(Table 2.6-2 UMETCO)
Modified Mercalli Scale, 1956 Version
(Table 2.6-3 UMETCO)
1-89
Communiry Types and Expanse Within the
ProjectSite 8oundary........ ........ 1-104
(tablez.t-t UMETCo)
Ground Cover for Each Community Within the
Project Site Boundary ...................1-104
Birds Observed in the Viciniry of the White Mesa
(Table 2.7-3 UMETCO)
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.................. 1-107
Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
rABLE1,7.4
TABLE 2.3-1
TABLE 2.3-2
Table 3.3-1
TABLE 5.3.2.1-1
TABLE B-I
Threatened and Endangered Aquatic Species
Occurring in Utah............. ....... 1-'111
(Iable2.7-4 UMETCO)
Groundwater Monitoring Constituents Listed in Table 2 of the GWDP.............. ............................ Z-11
Operational Phase Surface Water Monitoring Program....... ........ 2-33
Average Radon Flux from Tailings Cells 2004-2008...................... ..........................3-19
Placement and Compaction Criteria Reclamation
Cover Materia1s........................ Page A-24
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FIGURE 1.1
FIGURE 1.2
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
LIST OF FIGURES
Page No.
FIGURE 1 .4-1 Drainage Map of the Vicinity of the White Mesa Project.............1-17
(Adapted from Dames & Moore (1978b), Plate 2.6-5)
(Adapted from Dames & Moore (1978b), Plate 2.6-6)
FIGURE 1.+3 Preoperational Water Quality Sampling Stations
in the White Mesa ProjectVicinity............... .........................1-21
(Adapted from Dames & Moore (1978b). Plate 2.6-10)
F|GURE1.5.1 ColoradoPlateauGeologicM"p..................1-27
(Titan Figure 1 .1)
FIGURE 1.5-2 Generalized Stratigraphy of White Mesa
(Titan Figure 1.2)
FIGURE 1.5-3 Ground Water Appropriation Applications Within a
S-Mile Radius.....
(Titan Figure 1.3)
FIGURE 1 .5.3.1-1 Site Plan Map (Showing Cross Sections) ....... .....
(Titan Figure 2.1)
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1-45
FIGURE 1.5.3.1-2 Cross Section A-A' West to East Through White Mesa
Westwater Creek to Corral Canyon
(Titan Figure 2.2)
FIGURE 1.5.3.1-3 Cross Section B-B'North to South Through White Mesa
North of Faciliry to Cottonwood Wash
FIGURE 1.5.5-1 Perched Ground Water Levels..
(Titan Figure 2.4)
FIGURE 1.5.5-2 Saturated Thickness of Perched Water
(Titan Figure 2.5)
FlGURE1.5.5-3 TopographyofBrushyBasin.......................
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White Mesa Mill Reclamation Plan
................... 1 -49
1-57
FIGURE 1.6.1
FIGURE 1.6-2
FIGURE 1.6-3
FIGURE 1.6-4
FIGURE 1.6-5
FIGURE 1.6-6
FIGURE 1.7-1
FIGURE 2.3-1
(Titan Figure 2.6)
Tectonic lndex Map.......
White Mesa Millsite-Geology of Surrounding Area
Seismicity 320km Around Blanding, Utah
Seismicity 200km Around Blanding, Utah..................
Community Types on the White Mesa Project Site
1-68
1-80
1-91
1-92
Seismicity of the Western United States, 1950 to 1979................. .......................1-93
Colorado Lineament ......1-97
1-103
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White Mesa Mill Reclamation Plan
White Mesa Mill Regional Map Showing Land Position .............3-3
White Mesa Mill General Layout Showing Access and
FIGURE 3.2.3-'1 Site Map Showing Locations of Buildings and Tanks 3-12
FIGURE A-2.2.4-1 Sedimentation Basin Detail
FIGURE A-3.3-1 Typical Scanning Path Scoping 5urvey.............
FIGURE 3.1-1
FIGURE 3.2-1
FIGURE A-5.1-4
FIGURE B-1
FIGURE A-3.3-2 Standard Sampling Pattern for Systematic Grid Survey of Soil
FIGURE A-5.1-1 Reclamation Cover Grading Plan for Cells 2 and 3...
FIGURE A-5.1-2 Reclamation Cover and Cross Sections
A-18
A-19
A-24
A-25
A-27RockApron at Base of Toe of Cell Outs1opes...................
Typical Flow Chart for Construction Project.......... .....8-22
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REFERENCES
Abt, S. R., 1987. Engineering and Design of Waste Disposal Systems, Mini-course No. 7: Riprap
Reclamation.
Abt.5.R., J.F., and Wittler., 199. Estimating Flow Through Riprap, lournal of Hydraulic Engineering, v.
May.
Advanced Terra Testing 1996. (Cited in 3.3.2.1)
Agenbroad, L. D. et. al., 1981 . 1980 Excavations in White Mesa, San luan County. Utah.
(Cited in '1.3.2)
Aitken and Berg,1968. (Cited in 3.3.4)
Design for
117, no 5, pp.670-675,
Aki, K., 1979. Characterization of Barriers on an Earthquake Fault. lournal of Geophysical Research, v. 84, PP.
6140-6148. (Cited in 1.6.3.3)
Algermissen,S.T.andPerkins,D.M.. 1976. AProbabilisticEstimateofMaximumAcceleration on Rock in the Contiguous
United States, U. S. Geological Survey Open-File Repon, No.76-416. (Cited in 1.6.3.4)
Anderson,L.W.andMiller,D. G.,1979. QuarternaryFaultMapof Utah,FURGO, lnc.
Arabasa W. 1., Smith, R. 8., and Richins, W. D., eds., 1 979. Earthquake Studies in Utah 1850 to
the University of Utah Seismograph Starions, Department of Geologr and Geophysics.
Bonilla, M. G., Mark, R. K., and Lienkaemper, 1.1..1984. Statistical RelationsAmong Earthquake
1978, Special Publication of
Magnitude, Surface
Rupture Length, and Surface Fault Displacement, Bulletin of the Seismological Society of America, v. 74, No. 6, pp.
2379-2411.
Brill, K. G. and Nuttli, O. W., 1983. Seismiciry of the Colorado Lineament, Geologr,v. 11,pp.2O-2a. (Cited in 1.6'3.3)
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White Mesa Mill Reclamation Plan
Case, f . E. and loesting, H.R.,1972. Regional Geophysical lnvestigations in the Central Plateau. U. 5. Geological Survey
Professional Paper 736. (Cited in 1.6.3.3)
Casjens, L. A. et. al., 1980. Archeological Excavations on White Mesa, San luan Counry, Utah. 1 979; Volumes I through lV;
lune, 1980. (Cited in 1.3.2)
Cater, F. W., 1970. Geolory of the Salt Anticline Region in Southwestern Colorado. U. 5. Geological Survey,
Professional Paper 637. (Cited in 1.6.3.3)
Chen and Associates, lnc., 1978. Soil Properry Study, Earth Lined Tailings Retention Cells, White
Project, Blanding Utah.
Chen and Associates, |nc.,1979. Soil Properry 5tudy, Proposed Tailings Retention Cells, White Mesa
Blanding Utah.
Chen and Associates, lnc., 1987. (Cited in 3.3.2.1,3.3.6)
Cook, K. L. and 5mith, R. 8., 1967. Seismiciry in Utah, 1 850 Through lune 1965. Bull. Seism. Soc.
Uranium Project,
Am.. v. 57, pp.
689-718. (Cited in 1.6.3.3)
Coulter, H. W., Waldron, H. H., and Devine, l. F.,1973. Seismic and Geologic Siting Considerations for Nuclear Facilities,
Proceedings, Fifth World Conference on Eanhquake Engineering, Rome, Paper 302. (Cited in 1.6.3.4)
Craig. L. C., et. al., 1955. Stratigraphy of the Morrison and Related Formations, Colorado Plateau
Preliminary Report. U.5. Geological Survey Bulletin 1009-E, pp. 125-168. (Cited in 1.6.2.2)
Dames and Moore, 1978, "Environmental Report, White Mesa Uranium Project, San luan Counry.
for Enerry Fuels Nuclear, lnc.. lanuary. (Cited in 1.5, 1.5.3.1, 1.5.5, 1.7.1.1)
Dames and Moore, 1978a. Site Selection and Design Study - Tailing Retention and Mill Facilities,
Region.
Utah."Prepared
Uranium Project, lanuary'17, 197 8.
Dames and Moore, 1978b. Environmental Report, White Mesa Uranium Project, San luan County, Utah. lanuary 20,
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Uranium
White Mesa
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1978, revised May 15, 1978. (Cited in Section 1.0,1.4.1,1.4.2,1.6.3.4,'l'.7.1.1,1.7.1.2, 'l.7.2,AttachmentA)
D'Appolonia Consulting Engineers. lnc., 1981, Letter Report, "Assessment of the Water Supply System, White Mesa Project,
Blanding. Utah." Prepared for Energr Fuels Nuclear, lnc., February. (Cited in 1.5, 1.5.3.1)
D'Appolonia Consulting Engineers, |nc.,1979. Engineer's Report, Tailings Management System,
Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, lnc., 1981a. Engineer's Report,Second Phase Design - Cell 3
Management System. White Mesa Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, lnc., 1981 b. Letter Report, Leak Detection System Evaluation,
Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, lnc., 1982c. Letter Report - Groundwater Monitoring Program
Uranium Project, Blanding, Utah.
D'Appolonia Consulting, Engineers, lnc., 1982d. Lener Report - Additional Analysis Tailings Cover
White Mesa Uranium Project, Blanding, Utah.
White Mesa
Tailings
White Mesa
White Mesa
D'Appolonia Consulting Engineers, lnc., 1982, "Construction Report. lnitial Phase - Tailings Management System, White
Mesa Uranium Project, Blanding, Utah." Prepared for Energr Fuels Nuclear, lnc., February. (Cited in 1 .5. 1 .5.3.1)
D'Appolonia Consulting Engineers, lnc., 1982a. Construction Report, lnitial Phase - Tailings
Mesa Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, lnc., 1982b. Monitoring Plan - lnitial Phase - Tailings
Mesa Uranium Project, Blanding, Utah.
Management System, White
Management System - White
Design Revisions
D'Appolonia Consulting Engineers, lnc.,1984, "Engineer's Report, Geotechnical Site Evaluation, Farley Project, Garfield
Counry, Utah." Prepared for Atlas Minerals, Moab, Utah, lune. (Cited in 1.5)
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Page iv
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Eardly, A. 1., 1958. Physiography of Southeastern Utah in lntermountain Association Petroleum Geologists
Guidebook, 9th Annual Field Conference, Geologr of the Paradox Basin, pp. 10-1 5. (Cited in 1 .6.1 .1)
Energr Fuels Nuclear, lnc., 1983
Uranium Project.
Construction Report - Second Phase Tailings Management System,White Mesa
Enerry Fuels Nuclear, lnc. Semi-annual Effluent Repon, White Mesa Mill, SUA-1358, Docket No
December 1995) and (anuary through lune 1 996). (Cited in 1 .0, 1 .5, 1 .5.5.1. 3.3.2.2)
Environmenral Protection Agenq,1994. (Cited in 3.3.1, 3.3.3)
Feltis, R. D., 1966. Water from Bedrock in the Colorado Plateau of Utah, Utah State Engineer
Grose, L. f ., 1972. Tectonics, in Geologic Atlas of the Rocky Mountain Region Rocky Mountain
Geologists, Denver, Colorado, pp. 35-aa. (Cited ln 1.6.1.3)
40-8681, (Jrly
Technical Publication No. 15
Association
Hadsell,F.A., 1968. HistoryofEarthquakesinColorado,inHollister, l.S.andWeimer,R. 1.,eds., Geophysical and
Geological Studies of the Relationships Between the Denver Earthquakes and the Rocky Mountain Arsenal Well,
ColoradoSchool MinesQuarterly,v.63,No. 1,pp.57-72. (Citedin 1.6.2.3,1.6.3.3)
Haynes, D.D., Vogel, 1.D., and Wyant, D.G.,1972, "Geology, Structure and Uranium Deposits of the Cortez Quadrangle,
Colorado and Utah." U.S. Geological Survey, Miscellaneous lnvestigation Series, Map, l-629, May. (Cited in 1.5.2,
1.5.3.1, 1.6.2.2)
Hermann, R. 8., Dewey, l. W., and Park, S. F., 1980. The Dulce. New Mexico, Earthquake of lanuary
Seismological Society of America Bulletin, v. 70, No. 6,pp.2171-2183. (Cited in 1.6)
1975. An Unusual Northeast-trending Fracture Zone and its Relation to Basement Wrench Faulting in Nonhern
Paradox Basin, Utah and Colorado, Four Corners Geological Society 8th Field Conference Guidebook. Durango.
Colorado, pp.217-223. (Cited in 1.6.3.3)
Huff. L. D., and Lesure, F. G., 1965. Geologr and Uranium Deposits of Montezuma Canyon Area,
N:\Reclamation Plan\Reclamarion Plan 3.2.a in progress 12.17.10\REFERiNCES 3.2.A clean.doq
San luan County,
Page v
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Utah, U.5. GeologicalSurvey Bulletin 1190,102 p. (Cited in '1.6.2.2)
Hunt, C. 8., 1956. Cenozoic Geolory of the Colorado Plateau: U. S. G.5. Professional Paper,279
Hydro-Engineering, 1991, "Ground Water Hydrologr at the White Mesa Tailings Facility."
Minerals Corporation, Blanding, Utah, July.
Prepared Umetco
,lohnson, H.5., f r., and Thordarson, W., 1966. Uranium Deposits of the Moab, Monticello, White Canyon, and
Monument Valley Districts, Utah and Arizona, U. S. Geological Survey Bulletin 1222-H,53 p. (Cited in 1.6.1.3,
1.6.2.2)
Keend, W. E., 1969. Quaternary Geologr of the Grand and Battlement Mesa Area, Colorado: U.S.G.S. Professional Paper,
617.
Kelley.V. C., 1955. Regional Tectonics of the Colorado Plateau and Relationship to the Origin and
Uranium, New Mexico University Publication Geolory No. 5, 120 p. (Cited in 1.6.1 .3)
Kelley, V. C., 1956. (Cited in 1 .6.1 .3)
Kelley. V.C., 1958, "Tectonics of the Region of the Paradox Basin." ln lntermountain fusociation Petroleum
Geoloqists Guidebook, 9th Annual Field Conference, Geologr of the Paradox Basin, p. 31-38.
Distribution of
Evaluation,ColoradoKirkham, R. M. and Rogers. W. P., 1981 . Earthquake Potential in Colorado, A Preliminary
Geological Survey. Bulletin 43. (Cited in 1.6.3.3)
Krinitzsky, E. L. and Chang, F. K.,1975. State-of-the-Art forAssessing Earthquake Hazards in the United States,
Earthquake lntensity and the Selection of Ground Motions for Seismic Design, Miscellaneous Paper 5-73-1, Report 4,
September 1975,U. S. Army Engineer Waterways Experiment Station, CE. Vicksburg Mississippi.
Larson, E. E., et. a|.,1975. Late Cenozoic Basic Volcanism in Northwestern Colorado and its lmplications Concerning
Tectonics and the Colorado River System in Cenozoic History of Southern Rocky Mountains: Geological Sociery of
America, Memoir 144.
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Page vi
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White Mesa Mill Reclamation Plan
Lawrence Livermore National Laboratory, 1994. Seismic Hrzard Analsis of Title ll Reclamation Plans; U. 5. Nuclear
Regulatory Commission.
Lindsay, L. M. W., 1978. Archeological Test Excavations on White Mesa, San Juan County, Southeastern Utah. (Cited
in 1.3.2)
MITRE Software Corporation, GSLOPE Computer Software Package.
National Oceanic and Atmospheric Administrarion (NOM), 1977. Probable Maximum Precipitation Estimates,
Colorado River and Great Basin Drainages. Hydrometerological Repon (HMR) No.49.
National Oceanic and Atmospheric Administration (NOM), 1988. Computer Printout of Earthquake File Record for
320 km Radius of Blanding, Utah. U. S. Department of Commerce, National Geophysical Data Center, Boulder,
Colorado. (Cited in 1.6.3.4,1.7)
Nielson, A. 5.,'1979. Additional Archeological Test Excavations and lnventory on White Mesa, San luan Counry,
Southeastern Utah. (Ched in 1.3.2)
NUREG 1623,2OO2. Design of erosion Protection for Long-Term stabilization, Final Report, September.
NUREG/CR-1081, March 1980. Characterization of Uranium Tailings Cover Materials for Radon Flux Reduction.
NUREG/CR-26 42,lune 1982. Longterm Survivabiliry of Riprap for Armoring Uranium Mill Tailings and Covers: A
Literature Review.
NUREG/CR-2684, August 1982. Rock Riprap Design Methods and Their Applicabiliry to Long- term Protection of Uranium
Mill Tailings lmpoundments.
NUREG/CR-3027, March 1983. Overland Erosion of Uranium Mill Tailings lmpoundments Physical Processes and
Computational Methods.
NUREG/CR-3061, November 1983. Survivability o{Ancient Man-made Mounds: lmplications for Uranium Mill
N\Reclamation Plan\Reclamation Plan 3.2.a in progress'l 2.1 7.10\REFERENCES 3.2.A clean.doq
Tailings lmpoundment.
NUREG/CR-31 99, October 1 983.
Earthen Cover Materials.
NUREG/CR-3397, October 1 983.
lmpoundments.
NUREG/CR-3533, February 1 984.
N U REG/CR-367 4, March 1984.
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Guidance for Disposal of Uranium Mill Tailings: Long-term Stabilization of
Design Considerations for Long-term Stabilization of Uranium Mill Tailings
Radon Attenuation Handbook for Uranium Mill Tailings Cover Design
Designing Vegetation Covers for Long-term Stabilization of Uranium Mill Tailings.
NUREG/CR-37 47 , May 1985. The Selection and Testing of Rock for Armoring Uranium Tailings lmpoundments.
NUREG/CR-3972, December 1984. Settlement of U rani u m Mill Tailings Piles.
NUREG/CR-4075, May 1985. Designing Protective Covers for Uranium MillTailings Piles: A Review.
NUREG/CR-4087, February, 1985. Measurements of Uranium Mill Tailings Consolidation Characteristics.
NUREG/CR-4323, lanuary 1986. The Protection of Uranium Tailings lmpoundments against Overland Erosion.
NUREG/CR-4403, November 1985. 5ummary of the Waste Management Programs at Uranium Recovery Facilities
as They Relate to the 40 CFR Part192 Standards.
NUREG/CR-4480, September 1986. Erosion Protection of Uranium Tailings lmpoundment.
NUREG/CR-4504, March 1986. Long-term Surveillance and Monitoring of Decommissioned Uranium Processing Sites
and Tailings Piles.
NUREG/CR-4520, April 1986. Predictive Geochemical Modeling of Contaminant Concentrations
Columns and in Plumes Migrating from Uranium Mill Tailings Waste lmpoundments.
N:\Reclamation Plan\Reclamation Plan 3.2.a in progress'12.17.10\REFERTNCES 3.2.A clean doq
Laboratory
NUREG/CR-4620, lune, 1986. Methodologies for Evaluating Long-Term Stabilization Designs of
Tailings lmpoundments, l. D. Nelson, S. R. Abt., et. al. (Cited in 3.3.1. 3.5.5, Attachment A)
NUREG/CR-4651, May 1987. Development of Riprap Design Criteria by Riprap Testing in Flumes:
3.3.1, 3.3.5, Anachment A)
Nuttli, O. W.,1979. 5tate-of-the-Art for Assessing Earthquake Hazards in the United States, Part
Roger and Associates Engineering Company, 1988. Radiological Properties Letters to C. O. Sealy
dated March 4 and May 9, 1988. (Cited in 3.3.2.1)
Rogers and Associates, 1996. (Cited in 3.3.2.1)
Schroeder, P. R., l. M. Morgan. T. M. Walski, and A. C. Gibson, 19B9. "Technical Resource
Evaluation of Landfill Performance (HELP) Model, Version ll," U.5. Environmental Protection Agency
Seed, H. B. And ldriss, l. M., 1982. Ground Motions and 5oils Liquefaction During Earthquakes,
Engi neering Research lnstitute. Berkeley, Cal iforn ia.
Shoemaker, E. M., 1954. Structural Features of Southeastern Utah and Adjacent Pans of Colorado,
Arizona. Utah Geological Society Guidebook to the Geologr of Utah, No. 9, pp. 48-69.
Shoemaker, E.M., 1956, "Structural Features of the Colorado Plateau and Their Relation to Uranium
Geological Survey Professional Paper 300, p. 155-168. (Cited in 1.6.1.3)
Phase l. (Cited in
of Sustained Maximum Ground Acceleration and Velociry to Earthquake lntensiry and Magnitude, with Errata Sheet of
fanuary 11,1982; U. 5. Army Engineers Waterwals Experiment Station, Vicksburg, P. O. No. DACW39-78-C-OO72,67
p. with Two Appendices and 2 p. Errata.
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Uranium Mill
16: The Relation
from R. Y. Eowser
Document, The Hydrologic
Eanhquake
New Mexico, and
(Cited in 1.6.1.3)
Deposits." U.S.
Simon,R.8.,1972. Seismiciry,inMallory,W.W.,and Others,eds.GeologicAtlasof theRocky Mountain Region, Rocky
Mountain fusociation of Geologists, pp. aB-51.
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Page ix
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Slemmons, D.8.,1977 . State-of-the-An for Assessing Earthquake Hazards in the United States,Part 6, Faults and
Earthquake Magnitude, with an Appendix on Geomorphic Features of Active Fault Zones, U. 5. Army Engineer
Waterways Experiment Station, Vicksburg, Contract No. DACW39-76-C-0009, 129 p. plus 37 p. Appendix.
5mith, R. 8.,1978. Seismicity, Crustal Structure, and lntraplate Tectonics of the Western
Tectonics and Regional Geophysics of the Western Cordillera. Smith, R. B. and
Geological Sociery of America, pp.'111-144. (Cited in 1.6.3.3)
5mith. S., 1981. Long-Term Stabiliry at Union Carbide's Tailings Piles in Uravan, Colorado.
Stephenson, D.,1979. Rockfill in Hydraulic Engineering, Developments in Geotechnical
Scientific Publishing Company, pp. 50-60. See NUREG 4620.
Stokes, W. 1., 1954. Stratigraphy of the Southeastern Utah Uranium Region, Utah Geological
Geologr of Utah, No. 9, pp. 16-47.
Cordillera, in Cenozoic
Eaton, G. P., eds, Memoir 152,
Engineering, 27, Elsevier
Society Guidebook to the
Guidebook to the Geologr of
October 1995. (Cited in
Deposits, Utah
Stokes, W. L.,1967. A Survey of Southeastern Utah Uranium Districts. Utah Geological Sociery
Utah, No. 21, pp.1-11. (Cited in 1 .6.2.2)
Tellco Environmental, 1995. Neshaps Radon Flux Measurement Program, White Mesa Mill,
I ntroduction)
Thompson. K.C.,1967. Structural Features of Southeastern Utah and Their Relations to Uranium
Geological Society Guidebook to the Geology of Utah, No. 21, pp. 23-31 . (Cited in 1 .6.1 .3)
Thordarson, 1966. (Cited in 1.6.1.3, 1.6.2.2)
Titan Environmental Corporation, 1994. (Cited in 1.0)
Titan Environmental Corporation, 1 994a
in lntroduction, '1.5)
Hydrogeologic Evaluation of White Mesa Uranium Mill,luly 1994. (Cited
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TitanEnvironmental Corporation. 1994b. Pointsof Compliance,WhiteMesaUraniumMill, September1994. (Cited in
lntroduction, 1.5)
Titan Environmental Corporation, 1996. Tailings Cover Design.White Mesa Mill, October 1996
lntroduction, 1.6.3)
Trifunac, M. D. and Brady. A. G. On the Correlation of Seismic lntensiry Scales with the Peaks of Recorded
Ground Motion, Seismological Sociery of America Bulletin,V.65, Feb. 1975,pp.139-162. (Cited in 1.6.3.4)
Umetco, 1987. Umetco Minerals Corporation SUA-1358: Docket No.40-8681, License Condition 48, White
Mill, Utah, Letter From R. K. f ones to U. 5. Nuclear Regulatory Commission dated November 30, 1987.
Strong
Umetco Minerals Corporation, 1992, "Ground Water Study, White Mesa Mill. Blanding, Utah."
No.40-8681. (Cited in 1.5.3.1,1.5.5)
United States Geological Survey, 1970. (Cited in 1.6)
U.5. Department of Energr, '1988. (Cited in 3.3.1, 3.3.4)
5. Nuclear Regulatory Commission, 1977. Regulatory Guide 3.1 1. Design, Construction, and
Embankment Retention Systems for Uranium Mills, Revision 2,1977.
U.S. Department of Enerry, 1993, "Environmental Assessment of Remedial Action at the Slick Rock Uranium Mill
Tailings Sites. Slick Rock, Colorado." UMTM Project Office, Albuquerque, New Mexico, February. (Cited in
1.s.3)
U. 5. Geological Survey. (Cited in 1.5)
U. S. Geological Survey, 1970. (Cited in 1.6.2.3)
License SUA 1358, Docket
lnspection of
U. S. Nuclear Regulatory Commission. Regulatory Guide 3.64, Task WM 503-4, Calculation of Radon Flux Attenuation
Earthen Uranium MillTailings Covers. (Cited in 3.3.2.1)
by
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U.s.NuclearRegulatoryCommission, 1979. Final Environmental Statement-WhiteMesa Uranium
NUREG-0556. (Cited in Section 1 .0, 1 .3.1, 1 .4, 1 .4.2)
U. S. Nuclear Regulatory Commission, 1980. (Cited in 3.3.1)
Project,
U.S.NuclearRegulatoryCommission, 1984. GuidelinesforDecontaminationofFacilitiesand Equipment Prior to Release
for Unrestricted Use or Termination of Licenses for Byproduct or Source Materials. (Cited in lntroduction)
U. S. Nuclear Regulatory Commission, 1985. Standard Review Plan for UMTM Title I Mill
Plans, Division of Waste Management.
Tailings - Remedial Action
u.s Nuclear Regulatory Commission, 1987a. URFO:TTO, Docket No.40-8681,040086817405,
Minerals Corporation (. S. Hamrick) from F. F. Hawkins dated lanuary 26,1987.
U.5. Nuclear Regulatory Commission, 1989. (Cited in 3.3.1,3.3.2)
U. 5. Nuclear Regulatory Commission, 1990. (Cited in 3.3.5, Anachment A)
University of Utah Seismograph Stations, 1988. Computer List of Earthquakes within 320 km of
Depanment of Geolory and Geophysics, University of Utah. Salt Lake City.
von Hake, C. A.,1977. Earthquake History of Utah, Earthquake lnformation Bulletin 9, pp. 48-51
Warner, L. A., 1978. The Colorado Lineament, A Middle Precambrian Wrench Fault System, Geological
N:\Reclamation Plan\Reclamation Plan 3.2.a in progress 1 2.1 7.10\REFERENCES 3.2.A tlean.doq
Letter to Umetco
10. Letter to
Blanding Utah,
(Cited in 1.6.2.3)
of
U. S. Nuclear Regulatory Commission, 1987b. 10 CFR 40, Appendix A.
U.5. Nuclear Regulatory Commission. 1987c. URFO:GRK, Docket No.40-8681, Letter to Umetco Minerals
Corporation from E. F. Hawkins dated October 21,1987.
U.5. NuclearRegulatoryCommission, 1988. DocketNo.40-8681 5UA-1358,AmendmentNo.
Umetco Minerals Corporation dated lanuary B, 1988, from R. Dale Smith.
Sociery
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America Bulletin.v. 89,pp.161-171. (Cited in 1.6.3.3)
Williams. P.L.,1964. Geolory,Structure. and Uranium Deposits of the Moab Quadrangle, Colorado and Utah, U. S.
Geologic Survey Map, l-360.
Witkind, 1.1.,1964. Geologr of the Abajo Mountains Area, San luan Counry, Utah, U. S. Geological Survey,
Professional Paper 453. (Cited in 1.6.1.3, 1.6.2,1.6.2.2)
Woodward-Clyde Consultans,'1982. Geologic Characterization Repon of the Paradox Basin Study Region, Utah Study
Areas, ONWI-Z9O,v.1, Prepared for Office of Nuclear Waste lsolation, Banelle Memorial lnstitute.
Wong. l. G., 1981 . Seismological Evaluation of the Colorado Lineament in the lntermountain Region (abs.), Eanhquake
Notes, v. 53, pp. 33-34. (Cited in 1.6.3.3)
Wong l. G., 1984. Seismiciry of the Paradox Basin and the Colorado Plateau lnterior, ONWI-492, Prepared for the
Office of Nuclear Wasre lsolation, Battelle Memorial lnstitute. (Cited in 1 .6.3.3)
Zoback, M. D. and Zoback" M. 1.. 1980. State of Stress in the Conterminous United States, fournal of Geophysical
Research, v. 85, pp. 61 13-61 56. (Cited in 1 .6.3.3)
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INTRODUCTION
This reclamation Plan (the "plan") has been prepared by Denison Mines (USA) Corp. ("Denison"),
for Denison's White Mesa Uranium Mill (the "Mill"), located approximately 6.0 miles south of
Blanding, Utah. The Plan presents Denison's plans and estimated costs for the reclamation of the
Mill's tailings Cells I ,2,3,4A and 48, and for decommissioning of the Mill and Mill site.
Summarv of Plan
The uranium and vanadium processing areas of the mill, including all equipment, structures and
support facilities will be decommissioned and disposed of in tailings or buried on site as
appropriate. All equipment, including tankage and piping; agitation; process control
instrumentation and switchgears; and contaminated structures; will be cut up, removed, and buried
in tailings prior to final cover placement. Concrete structures and foundations will be demolished
and removed or covered with soil as appropriate. These decommissioned areas would include,
but not be limited to, the following:
' Coarse ore bin and associated equipment, conveyors and structures.
' Grind circuit including semi-autogenous grind (SAG) mill, screens, pumps and cyclones.
. Three pre-leach tanks to the east of the mill building, including all associated tankage,
agitation equipment, pumps, and piping.
. Seven leach tanks inside the main mill building, including all associated agitation
equipment, pumps and piping.
' Counter-current decantation (CCD) circuit including all thickeners and equipment, pumps
and piping.
' Uranium precipitation circuit, including all thickeners, pumps and piping.
' Two yellowcake dryers and all mechanical and electrical support equipment, including
uranium packaging equipment.
. Clarifiers to the west of the mill building including the preleach thickener and claricone.
' Boiler and all ancillary equipment and buildings.
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' Entire vanadium precipitation, drying, and fusion circuit.
' All external tankage not included in the above list including: reagent tanks for the storage
of acid, ammonia, kerosene, water, or dry chemicals; and the vanadium oxidation circuit.
' Uranium and vanadium solvent extraction (SX) circuit including all SX and reagent
tankage, mixers and settlers, pumps, and piping.
' SX building.
' Mill building.
' Office building.
' Shop and warehouse building.
' Sample plant building.
Alternate Feed Circuit
Truck Shop
Temporary Storage Building
The sequence of demolition would proceed so as to allow the maximum use of support areas of the
facility, such as the office and shop areas. Any uncontaminated or decontaminated equipment to
be considered for salvage will be released in accordance with the United States Nuclear
Regulatory Commission ('NRC") document, guidance and in compliance with the conditions of
the Mill's State of Utah Radioactive Materials License No. UT1900479 (the "License"). As with
the equipment for disposal, any contaminated soils from the Mill and surrounding areas and any
ore or feed material on the Mill site will be disposed of in the tailings facilities in accordance with
Section 4.0 of Attachment A, Plans and Specifications.
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beThe estimated reclamation costs for surety are set out in Attachment C. Attachment C
reviewed and updated on a yearly basis.
Plan Oreanization
General site characteristics pertinent to this Plan are contained in Section 1.0. Descriptions of
the facility construction, operations and monitoring are given in Section 2.0. The current
environmental monitoring program is described in Section 2.3. Seismic risk was assessed in
Section 1.6.3.
The Plan itself, including descriptions of facilities to be reclaimed and design criteria, is presented
in Section 3.0. Section 3.0 Attachments A through H are the Plans and Specifications, Quality
Plan for Construction Activities, Cost Estimates, and supplemental testing and design details.
Supporting documents, which have been reproduced as appendices for ease of review, include:
Semi-Annual Effluent Reports (January through June, 2008), (June through
December, 2008) and (January through June 2009) for the Mill, which have been
submitted previously on November 24,2009;
Site hydrogeology and Estimation of Groundwater Travel Times in the Perched
Zone White Mesa Uranium Mill Site Near Blanding, Utah, August 27, 2009,
prepared by Hydro Geo Chem, [nc. (the *2009 HGC Report), submitted previously
on November 24,2009;
The Mill's Stormwater Besl Management Practices Plan, Revision 1.3: June 12,
2008, submitted previously on November 24,2009;
Tailings Cover Design, White Mesa Mill, October 1996. submitted previously on
November 24,2009;
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National Emissions Standards .fbr Hazardous Air Pollutants Radon Flux
Measurement Program, White Mesa Mill Site, 2008. Tellco Environmental,
submitted previously on November 24,2009; and
o Semi-Annual Monitoring Report July I - December 31, 2008 and Annual
Monitoring Summaryfor 2008, White Mesa Mill Meteorological Station, January
20,2009 McVehil-Monnett Associates, Inc., submitted previously on November
24,2009.
AsrequiredbyPartI.H.ll oftheMill'sStateofUtahGroundWaterDischargePermitNo.
UGW370004 (the "GWDP"), Denison is in the process of completing an infiltration and
contamination transport model of the final tailings cover system to demonstrate the
long-term ability of the coverto protect nearby groundwater quality. Upon review of such
modeling, the executive Secretary of the State of Utah radiation Control Board (the
"Executive Secretary") will determine if changes to the cover system as set out in the Plan
are needed to ensure compliance with the performance criteria contained in Part I.D.8 of
the GWDP. Although the modeling has not been completed, modeling results to date
suggest that some changes to the final cover design as set out in the Plan will be needed.
However, as the details of such re-design have not been finalized at this time, the approved
2000 cover design and basis will continue to be used for this version of the Plan. This
Plan will be amended in the future to incorporate any changes to the design of the tailings
cover system that result from the current modeling effort.
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2.0 EXISTING FACILITY
The following sections describe the construction history of the Mill; the Mill and Mill tailings
management facilities; Mill operations including the Mill circuit and tailings managemen! and
both operational and environmental monitoring.
2.1 Facility Construction History
The Mill is a uranium/vanadium mill that was developed in the late 1970's by Energy Fuels
Nuclear, Inc. (EFN) as an outlet for the many small mines that are located in the Colorado Plateau
and for the possibility of milling Arizona Strip ores. At the time of its construction, it was
anticipated that high uranium prices would stimulate ore production. However, prices started to
decline about the same time as Mill operations commenced.
As uranium prices fell, producers in the region were affected and mine output declined. After
about two and one-half years, the Mill ceased ore processing operations altogether, began solution
recycle, and entered a total shutdown phase. In 1984, a majority ownership interest was acquired
by Union Carbide Corporation's ("UCC") Metals Division which later became Umetco Minerals
Corporation ("Umetco"), a wholly-owned subsidiary of UCC. This partnership continued until
May 26,1994 when EFN reassumed complete ownership. [n May of 1997, Denison (then named
Intemational Uranium (USA) Corporation) and its affiliates purchased the assets of EFN and is the
current owner of the facility. Throughout this Plan, the names Denison and IUSA are used
interchangeably.
2.1.1 Mill and Tailings Management Facility
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The Source Materials License Application for the White Mesa Mill was submitted to NRC on
February 8, 1978. Between that date and the date the first ore was fed to the mill gizzly on May
6, 1980, several actions were taken including: increasing mill design capacity, permit issuance
from the United States Environmental Protection Agency ("EPA") and the State of Utah,
archeological clearance for the Mill and tailings areas, and an NRC pre-operational inspection on
May 5, 1980.
Construction on the tailings area began on August l, 1978 with the movement of earth from the
area of Cell 2. Cell 2 was completed on May 4, 1980, Cell I on June 29, 1981, and Cell 3 on
September 2,1982. In January of 1990 an additional cell, designated Cell 4,A., was completed and
initially used solely for solution storage and evaporation. Cell 4A was only used for a short
period of time and then taken out of service because of concerns about the synthetic lining system.
IN 2007, Cell 4A, was retrofitted with a new State of Utah approved lining system and was put
back into service in October of 2008. Cell 48 construction was authorized by License
Amendment No. 4, issued on June 17,2010, and the cell is currently under construction.
The Cell 44. and 48 design and operational details are more specifically described in the following
documents, hereby incorporated by reference:
Cell44. Construction Quality Assurance Report, July 2008
Cell48 Construction Quality Assurance Report, November 2010
Discharge Minimization technology Monitoring Plan, Revision 11, and Best Available
Technology Operatins and Maintenance Plan revision 2, November 12, 2010 (under
review).
2.2 Facility Operations
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In the following subsections, an overview of mill operations and operating periods are followed by
descriptions of the operations of the mill circuit and tailings management facilities.
2.2.1 Operating Periods
The Mill was operated by EFN from the initial start-up date of May 6, 1980 until the cessation of
operations in 1983. Umetco, as per agreement between the parties, became the operator of record
on January l, 1984. The Mill was shut down during all of 1984. The Mill operated at least part
of each year from 1985 through 1990. Mill operations again ceased during the years of 1991
through 1994. EFN reacquired sole ownership on May 26, 1994 and the mill operated again
during 1995 and 1996. After acquisition of the Mill by Denison and its affiliates several local
mines were restarted and the Mill processed conventional ores during 1999 and early 2000. With
the resurgence in uranium and vanadium process in 2003, Denison reopened several area mines
and again began processing uranium and vanadium ores in April of 2008. Mill operations were
suspended in 2009, and resumed in March of 2010. Typical employment figures for the Mill are
I l0 during uranium-only operations and 140 during uraniurn/vanadium operations.
Commencing in the early 1990's through today, the Mill has processed alternate feed materials
from time to time when the Mill has been processing conventional ores. Altemate feed materials
are uranium-bearing materials other than conventionally-mined uranium ores. The Mill installed
an altemate feed circuit in 2009 that allows the Mill to process certain alternate feed materials
simultaneously with conventional ores.
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2.2.2 Mill Circuit
While originally designed for a capacity of 1,500 dry tons per day (dtpd.), the Mill capacity was
boosted to the present rated design of 1980 dtpd. prior to commissioning.
The mill uses an atmospheric hot acid leach followed by counter current decantation ("CCD").
This in tum is followed by a clarification stage which precedes the solvent extraction ("SX")
circuit. Kerosene containing iso-decanol and tertiary amines extract the uranium and vanadium
from the aqueous solution in the SX circuit. Salt and soda ash are then used to strip the uranium
and vanadium from the organic phase.
After extraction of the uranium values from the aqueous solution in SX, uranium is precipitated
with anhydrous ammonia, dissolved, and re-precipitated to improve product quality. The
resulting precipitate is then washed and dewatered using centrifuges to produce a final product
called "yellowcake." The yellowcake is dried in a multiple hearth dryer and packaged in drums
weighing approximately 800 to 1,000 lbs. for shipping to converters.
After the uranium values are stripped from the pregnant solution in SX, the vanadium values are
transferred to tertiary amines contained in kerosene and concentrated into an intermediate product
called vanadium product liquor ("VPL"). An intermediate product, ammonium metavanadate
("AMV"), is precipitated from the VPL using ammonium sulfate in batch precipitators. The
AMV is then filtered on a belt filter and, if necessary, dried. Normally, the AMV cake is fed to
fusion furnaces when it is converted to the mill's primary vanadium product, VzOs tech flake,
commonly called "black flake."
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The same basic process steps used for the recovery of uranium from conventional ores are used for
the recovery of uranium from altemate feed materials, with some variations depending on the
particular altemate feed material.
The mill processed 1,511,544 tons of ore and other materials from May 6, 1980 to February 4,
1983. During the second operational period from October l, 1985 through December 7,1987,
7,023,393 tons of conventional ore were processed. During the third operational period from July
1988 through November 1990, 1,015,032 tons of conventional ore were processed. During the
fourth operational period from August 1995 through January 1996,203,317 tons of conventional
ore were processed. In the fifth operational period from May 1996 through September 1996, the
Mill processed 3,868 tons of calcium fluoride alternate feed material. From 1997 to early 1999,,
the Mill processed 58,403 tons from several additional feed stocks.
With rising uranium prices in the late 1990's, company mines were reopened in 1997, and 87,250
tons of conventional ore were processed in 1999 arrd early 2000. In 2002 and 2003, the Mill
processed 266,690 tons of alternate feed material from government cleanup projects. An
additional 40,866 tons of alternate feed materials were processed in 2007. From April 2008
through May 2009 the Mill processed an additional 184,795 tons of conventional ore.
Inception to date material processed through May 2009 totals 4,128,468 tons. This total is for all
processing periods combined.
2.2.3 Tailings Management Facilities
Tailings produced by the mill typically contain 30 percent moisture by weight, have an in-place
dry density of 86.3 pounds per cubic foot (Cell 2),have asize distribution with a predominant -325 [F"r .
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mesh size fraction, and have a high acid and flocculent content. Tailings from alternate feed
materials that are similar physically to conventional ores, which comprise most of the tons of
alternate feed materials processed to date at the Mill, are similar to the tailings for conventional
ores. Tailings from some of the higher grade, lower volume alternate feed materials may vary
somewhat from the tailings from conventional ores, primarily in moisture and density content.
The tailings facilities at White Mesa currently consist of four cells as follows:
Cell 1, constructed with a 30-millimeter (ml) PVC earthen-covered liner, is used for the
evaporation of process solution (Cell I was previously referred to as Cell 1-1, but is
now referred to as Cell 1);
Cell2,constructed with a 30-millimeter (ml) PVC earthen-covered liner, is used for the
storage of barren tailings sands. This Cell is full and has been partially reclaimed;
Cell 3, constructed with a 3O-millimeter (ml) PVC earthen-covered liner, is used for the
storage of barren tailings sands and solutions. This cell is partially filled and has been
partially reclaimed; and
Cell44, constructed with a geosynthetic clay liner, a 60 Millimeter (mil) HDPE liner, a
300 mil HDPE geonet drainage layer, a second 60 mil HDPE liner, and a slimes drain
network over the entire cell bottom. This cell was placed into service in October of
2008.
Cell 48, will be constructed with a geosynthetic clay liner, a 60 Millimeter (mil) HDPE
liner, a 300 mil HDPE geonet drainage layer, a second 60 mil HDPE liner, and a slimes
drain network over the entire cell bottom. This cell will be constructed during the
201 0 construction season.
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Total estimated design capacity of Cells 2,3, and 4,A' is approximately six million (mm) tons.
Figures 1 .5-4 and 1.5-5 show the locations of the tailings cells.
Denison has submitted an application to the Executive Secretary to amend the License and GWDP
to authorize the construction of tailings Cell 4B, which will be located adjacent to Cell 4,A. and will
provide approximately two million additional tons of tailings capacity. That application was
approved by the Executive Secretary on June 17 , 2010.
2. 2. 3. I Tailings Management
Constructed in shallow valleys or swale areas, the lined tailings facilities provide storage below the
existing grade and reduce potential exposure. Because the cells are separate and distinct,
individual tailings cells may be reclaimed as they are filled to capacity. This phased reclamation
approach minimizes the amount of tailings exposed at any given time and reduces potential
exposure to a minimum.
Slurry disposal has taken place in Cells 2, 3 and 4,A.. Tailings placement in Cell 2 and Cell 3 was
accomplished by means of the final grade method, described below.
The final grade method used in Cell 2 and Cell 3 calls for the slurry to be discharged until the
tailings surface comes up to final grade. The discharge points are set up in the east end of the cell
and the final grade surface is advanced to the slimes pool area. Coarse tailings sand from the
discharge points are graded into low areas to reach the final disposal elevation. When the slimes
pool is reached, the discharge points are then moved to the west end of the cell and worked back to f F._r"
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the middle. An advantage to using the final grade method is that maximum beach stability is
achieved bV (1) allowing water to drain from the sands to the maximum extent, and (2) allowing
coarse sand deposition to help provide stable beaches. Another advantage is that radon release
and dust prevention measures (through the placement of the initial layer of the final cover) are
applied as expeditiously as possible.
Slurry disposal in Cell 4A is from several pre-determined discharge points located around the
north and east sides of the cell. Slurry discharge is only allowed on skid pads, or protective
HDPE sheets, to prevent damage to the synthetic lining system. Once tailings solids have reach
the maximum elevation around the perimeter of the cell, discharge points can be moved toward the
interior of the cell. Slurry disposal in Cell 48 will be conducted in the same manner as Cell 4A.
2. 2. 3. 2 Liquid Management
As a zero-discharge facility, the White Mesa Mill must evaporate all of the liquids utilized during
processing. This evaporation takes place in three (3) areas:
Cell l, which is used for solutions only;
Cell 3, in which tailings and solutions exist;
Cell 44, in which tailings and solutions exist, and
Cell48 after construction is complete.
The original engineering design indicated a net water gain into the cells would occur during Mill
operations. As anticipated, this has been proven to be the case. In addition to natural
evaporation, spray systems have been used at various times to enhance evaporative rates and for
dust control. To minimize the net water gain, solutions are recycled from the active tailings cells ft""*
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to the maximum extent possible. Solutions from Cells l, 3, and 4A are brought back to the CCD
circuit where metallurgical benefit can be realized. Cell 4E} will be operated in the same manner
as Cell 44. Recycle to other parts of the mill circuit are not feasible due to the acid content of the
solution.
2.3 Monitoring Programs
Operational monitoring is defined as those monitoring activities that take place only during
operations. This is contrasted with environmental monitoring, which is performed whether or not
the mill is in operation.
2.3.1 Monitoring and Reporting Under the Mill's GWDP
2. 3. 1. I Ground-vvater Monitoring
a) Plugged and Excluded Wells
Wells MW-6, MW-7, and MW-8 were plugged because they were in the area of Cell 3, as was
MW-13, in the Cell4,{ area. Wells MW-9 and MW-10 are dry and have been excluded from the
monitoring program. MW-16 is dry and has been plugged as part of the tailings Cell 48
construction.
b) Groundwater Monitoring at the Mill Prior to Issuance of the GWDP
At the time of renewal of the License by NRC in March, 1997 and up until issuance of the GWDP
in March 2005, the Mill implemented a groundwater detection monitoring progrzlm to ensure
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compliance to 10 CFR Part 40, Appendix A, in accordance with the provisions of the License.
The detection monitoring program was in accordance with the report entitled, Points of
Compliance, White Mesa Uranium Mill,prepared by Titan Environmental Corporation, submitted
by letter to the NRC dated October 5,1994 (Titan, 1994b). Under that program, the Mill sampled
monitoring wells MW-5, MW-l1, MW-12, MW-14, MW-15 and MW-17, on a quarterly basis.
Samples were analyzed for chloride, potassium, nickel and uranium, and the results of such
sampling were included in the Mill's Semi-Annual Effluent Monitoring Reports that were filed
with the NRC up until August 2004 and with the DRC subsequent thereto.
Between 1979 and 1997,the Mill monitored up to 20 constituents in up to 13 wells. That program
was changed to the Points of Compliance Programin 1997 because NRC had concluded that:
o The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer; and
o The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
c) Issuance of the GWDP
On March 8, 2005, the Executive Secretary issued the GWDP, which includes a groundwater
monitoring program that supersedes and replaces the groundwater monitoring requirements set out
in the License. Groundwater monitoring under the GWDP commenced in March 2005, the
results of which are included in the Mill's Quarterly Groundwater Monitoring Reporls that are
filed with the Executive Secretary.
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The current groundwater monitoring program at the Mill under the GWDP consists of monitoring
at 22 point of compliance monitoring wells: MW-l, MW-2, MW-3, MW-3A, MW-5, MW-I1,
MW-12, MW-14, MW-I5, MW-l7, MW-I8, MW-19, MW-23, MW-24, MW-25, MW-26,
MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32. The locations of these wells are
indicated on Figure 1.5-2.
Part I.E.l.(c) of the GWDP requires that each point of compliance well must be sampled for the
following constituents:
Table 2.3-1
Groundwater Monitoring Constituents Listed in Table 2 of the GWDP
Nutrients:
Ammonia (as N)
Nitrate & Nitrite (as N)
Heavy Metals:
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
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Uranium
Vanadium
Zinc
Radiologics:
Gross Alpha
Volatile Organic Compounds:
Acetone
Benzene
2-Butanone (MEK)
Carbon Tetrachloride
Chloroform
Chloromethane
Dichloromethane
Naphthalene
Tetrahydrofuran
Toluene
Xylenes (total)
Others:
Field pH (S.U.)
Fluoride
Chloride
Sulfate
TDS
Further, Part I.E.l.(c) of the GWDP, requires that, in addition to pH, the following field parameters
must also be monitored:
o Depth to groundwater
o Temperature
o Tubidityr
o Specrtic conductance, fF*ln"
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and that, in addition to chloride and sulfate, the following general organics must also be monitored:
o Carbonate, bicarbonate, sodium, potassium, magnesium, calcium, and total anions and
cations.
Sample frequency depends on the speed of ground water flow in the vicinity of each well. Parts
I.E.1(a) and (b) of the GWDP provide that quarterly monitoring is required for all wells where
local groundwater average linear velocity has been found by the Executive Secretary to be equal to
or greater than 10 feetlyear, and semi-annual monitoring is required where the local groundwater
average linear velocity has been found by the Executive Secretary to be less than l0 feetlyear.
Based on these criteria, quarterly monitoring is required at MW-l1, MW-14, MW-25, MW-26,
MW-30 and MW-31, and semi-annual monitoring is required at MW-1, MW-2, MW-3, MW-3A,
MW-5, MW-12, MW-l5, MW-17, MW-18. MW-19, MW-23, MW-24, MW-27, MW-28, MW-29
and MW-32.
2.3.1.2 Deep Aquifer
The culinary well (one of the supply wells) is completed in the Navajo aquifer, at a depth of
approximately 1,800 feet below the ground surface. Due to the fact that the deep confined aquifer
at the site is hydraulically isolated fiom the shallow perched aquifer, no monitoring of the deep
aquifer is required under the GWDP.
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2.3.1.3 Seeps and Springs
Pursuant to Part I.H.8 of the GWDP, Denison has a Sampling Plan for Seeps and Springs in the
Vicinity of the Wite Mesa Uranium Mill,Revision: 0, March 17,2009 (the "SSSP") that requires
the Mill to perform groundwater sampling and analysis of all seeps and springs found
downgradient or lateral gradient from the tailings cells.
Under the SSSP, seeps and springs sampling is conducted on an annual basis between May I and
July 15 of each year, to the extent sufficient water is available for sampling, at five identified seeps
and springs near the Mill. The sampling locations were selected to correspond with those seeps
and springs sampled for the initial Mill site characterization performed in the 1978 ER, plus
additional sites located by Denison, the BLM and Ute Mountain Ute Indian Tribe representatives.
Samples are analyzed for all ground water monitoring parameters found in Table 2.3-l above.
The laboratory procedures utilized to conduct the analyses of the sampled parameters are those
utilized for groundwater sampling. In addition to these laboratory parameters, the pH,
temperature and conductivity of each sample will be measured and recorded in the field.
Laboratories selected by Denison to perform analyses of seeps and springs samples will be
required to be certified by the State of Utah in accordance with UAC R317-6-6.12.A.
The seeps and springs sampling events will be subject to the Mill's QAP, unless otherwise
specifically modified by the SSSP to meet the specific needs of this type of sampling.
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2.3.1.4 Discharge Minimization Technolopg,, and Best Available Technologt Stondards and
Monitoring
2.3.1.4.1 General
Part I.D. of the GWDP sets out a number of Discharge Minimization Technology ("DMT") and
Best Available Technology ("BAT") standards that must be followed. Part t.E. ofthe GWDP sets
out the Ground Water Compliance and Technology Performance Monitoring requirements, to
ensure that the DMT and BAT standards are met. These provisions of the GWDP, along with the
White Mesa Mill Tailings Management System and Discharge Minimization (DlvtT) Monitoring
Plan, 9108 Revision: Denison-6 (the "DMT Plan"), the Cell 4Aand 48 BAT Monitoring,
Operations and Maintenonce Plan R.evision 2.0 (under review) and other plans and progftlms
developed pursuant to such Parts of the GWDP, set out the methods and procedures for inspections
of the facility operations and for detecting failure of the system.
In addition to the programs discussed above, the following additional DMT and BAT performance
standards and associated monitoring are required under Parts I.D and I.E. of the GWDP
b) Tailings Cell Operation
Part I.D.2 of the GWDP provides that authorized operation and maximum disposal capacity in
each of the existing tailings Cells, 1 , 2 and 3 shall not exceed the levels authorized by the License
and that under no circumstances shall the freeboard be less than three feet, as measured from the
top of the flexible membrane liner ("FML"). Part I.E.7(a) of the GWDP requires that the
wastewater pool elevations in Cells I and 3 must be monitored weekly to ensure compliance with [F"r ",,, lrln-
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the maximum wastewater elevation criteria mandated by Condition 10.3 of the License.
Part I.D.2 further provides that any modifications by Denison to any approved engineering design
parameter at these existing tailings cells requires prior Executive Secretary approval, modification
of the GWDP and issuance of a construction permit.
c) Slimes Drain Monitoring
Part I.D.3(bXl) of the GWDP requires that Denison must at all times maintain the average
wastewater head in the slimes drain access pipe to be as low as reasonably achievable (ALARA) in
each tailings disposal cell, in accordance with the approved DMT Plan. Compliance will be
achieved when the average annual wastewater recovery elevation in the slimes drain access pipe,
determined pursuant to the currently approved DMT Plan meets the conditions in Equation 1
specified in Part LD.3(b)(1) of the GWDP.
Part I.E.7(b) of the GWDP requires that Denison must monitor and record monthly the depth to
wastewater in the slimes drain access pipes as described in the currently approved DMT Plan at
Cell2, and upon commencement of de-watering activities, at Cell 3, in order to ensure compliance
with Part I.D.3(b)(l) of the GWDP.
d) Maximum Tailings Waste Solids Elevation
Part I.D.3(c) of the GWDP requires that upon closure of any tailings cell, Denison must ensure that
the maximum elevation of the tailings waste solids does not exceed the top of the FML.
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e) Wastewater Elevation in Roberts Pond
Part I.D.3(e) of the GWDP requires that Roberts Pond be operated so as to provide a minimum
2-foot freeboard at all times, and that under no circumstances will the water level in the pond
exceed an elevation of 5,624 feet above mean sea level. Part I.D.3(e) also provides that in the
event the wastewater elevation exceeds this maximum level, Denison must remove the excess
wastewater and place it into containment in Cell I within 72 hours of discovery.
Part I.E.7(c) of the GWDP requires that the wastewater level in Roberts Pond must be monitored
and recorded weekly, in accordance with the currently approved DMT Plan, to determine
compliance with the DMT operations standard in Part I.D.3(e) of the GWDP;
Inspection of Feedstock Storage Area
Part I.D.3(f) of the GWDP requires that open-air or bulk storage of all feedstock materials at the
Mill facility awaiting Mill processing must be limited to the eastern portion of the Mill site (the
"ore pad") described by the coordinates set out in that Part of the GWDP, and that storage of
feedstock materials at the facility outside of this defined area, must meet the requirements of Pan
I.D.ll of the GWDP. Part I.D.ll requires that Denison must store and manage feedstock
materials outside the defined ore storage pad in accordance with the following minimum
performance requirements :
(i)
(ii)
Feedstock materials will be stored at all times in water-tight containers, and
Aisle ways will be provided at all times to allow visual inspection of each and every
feedstock container, or
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(iii) Each and every feedstock contatner
prior to storage, or
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will be placed inside a water-tight overpack
(iv) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical
requirements:
A. A storage area composed of a hardened engineered surface of asphalt or
concrete, and
B. A storage area designed, constructed, ffid operated in accordance with
engineering plans and specifications approved in advance by the Executive
Secretary. All such engineering plans or specifications submitted shall
demonstrate compliance with Part I.D.4 of the GWDP, and
C.A storage area that provides containment berms to control stormwater run-on
and run-off, and
Stormwater drainage works approved in advance by the Executive Secretary, or
Other storage facilities and means approved in advance by the Executive Secretary.
Part I.E.7(d) of the GWDP requires that Denison conduct weekly inspections of all feedstock
storage areas to:
(i) Confirm that the bulk feedstock materials are maintained within the approved
feedstock storage area specified by Part I.D.3(f) of the GWDP; and
(ii) Verify that all alternate feedstock materials located outside the approved feedstock
storage area are stored in accordance with the requirements found in Part I.D.l I
of the GWDP.
Part I.E.7(0 further provides that Denison must conduct weekly inspections to verify that each
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the requirements of Part I.D.l I of the GWDP.
The Mill's Standard
contained in Section
Operating Procedure under the
3.3 of the DMT Plan.
License for inspection of the Mill's ore pad is
Identification of chemicals used in the milling process and the on-site laboratory;
and
Determination of volume and mass of each raw chemical currently held in storage
at the facility.
g) Monitor and Maintain Inventory of Chemicals
Part I.D.3(g) of the GWDP requires that for all chemical reagents stored at existing storage
facilities and held for use in the milling process, Denison must provide secondary containment to
capture and contain all volumes of reagent(s) that might be released atany individual storage area.
Response to spills, cleanup thereof, and required reporting must comply with the provisions of the
Mill's Emergency Response Plan, which is found in the Mill's Stormwater Best Management
Practices Plan,Revision 1.3; June 12,2008 (a copy of which is included as Appendix C), as
stipulated by Parts I.D.10 and I.H.l6 of the GWDP. Part LD.3(g) further provides that for any
new construction of reagent storage facilities, such secondary containment and control must
prevent any contact of the spilled or otherwise released reagent or product with the ground surface.
Part I.E.9 of the GWDP requires that Denison must monitor and maintain a current inventory of all
chemicals used at the facility at rates equal to or greater than 100 kglyr. This inventory must be
maintained on-site, and must include:
(iii)
(iv)
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2.3.1.5 BAT Performance StandardsJor Oell 4A and 48
a) BAT Operations and Maintenance Plan
Part I.D.6 and Part LD.13 of the GWDP provide that Denison must operate and maintain Cell4,{
and Cell 48, respectively, so as to prevent release of wastewater to groundwater and the
environment in accordance with the Mill's Cell 4A and 48 BAT Monitoring, Operations and
Maintenance Plan, pursuant to Part LH.8 of the GWDP. The Mill's Cell 4A and Cell 4B BAT
Monitoring, Operations and Mainlenance Plan, lll20l0 Revision: Denison 2.0 (under review)
inc ludes the following performance standards :
(i) The fluid head in the leak detection system shall not exceed I foot above the lowest
point in the lower membrane liner;
(ii) The leak detection system maximum allowable daily leak rate shall not exceed
24,160 gallons/day for Cell 44. or 26,145 gallons/day for Cell 48;
(iii) After Denison initiates pumping conditions in the slimes drain layer in Cell 4,{ or
Cell 48, Denison will provide continuous declining fluid heads in the slimes drain
layer, in a manner equivalent to the requirements found in Part I.D.3(b) for Cells 2
and 3; and
Under no circumstances shall the freeboard be less than 3 feet in Cell 4,{ or Cell
48, as measured from the top of the FML.
b) Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan
The Cell 4A and 48 BAT Monitoring, Operations and Maintenance Plan also requires Denison to
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
A.
B.
perform the following monitoring and recordkeeping requirements.
Weekly Leak System (LDS) Monitoring -
C.
Denison must provide continuous operation of the leak detection system
pumping and monitoring equipment, including, but not limited to, the
submersible pump, pump controller, head monitoring, and flow meter
equipment approved by the Executive Secretary. Failure of any pumping or
monitoring equipment not repaired and made fully operational within 24-hours
of discovery shall constitute failure of BAT and a violation of the GWDP;
Denison must measure the fluid head above the lowest point on the secondary
FML by the use of procedures and equipment approved by the Executive
Secretary. Under no circumstance shall fluid head in the leak detection system
sump exceed a 1-foot lcvel above the lowest point in the lower FML on the cell
floor. For purposes of compliance monitoring this 1-foot distance shall equate
to 2.28 feet above the leak detection system transducer;
Denison must measure the volume of all fluids pumped from the leak detection
system. Under no circumstances shall the average daily leak detection system
flow volume exceed 24,160 gallons/day for Cell 4,A' or 26,145 gallons/day for
Cell48; and
D. Denison must operate and maintain wastewater levels to provide a 3-foot
Minimum of vertical freeboard in tailings Cell 4,A. and Cell 4B. Such
measurements must be made to the nearest 0.1 foot.
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White Mesa Mill Reclamation Plan
(ii)Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4A or Cell 4B slimes drain
system, monthly recovery head tests and fluid level measurements will be made in accordance
with the requirements of Parts [.D.3 and I.E.7(b) of the GWDP and any plan approved by the
Executive Secretary.
2.3.1.6 Stormwater Management and Spill Control Requirements
Part I.D.IO of the GWDP requires that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the facility in accordance with the Mill's stormwater
best management practices plan. The Mill's Stormwater Best Management Practices Plan,
Revision /.-J: June 12,2008 (a copy of which is included as Appendix C) includes the following
provisions:
Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R317-6-6.3(G) and R317-6-6.a(C);
Prevent, control and contain spills of stored reagents or other chemicals at the Mill site;
Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
Report reagent spills or other releases at the Mill site to the Executive Secretary in
accordance with UAC l9-5-l14.
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b)
c)
d)
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
2.3.1.7 Tailings and Slimes Drain Sampling
Part I.E.8 of the GWDP requires that, on an annual basis, Denison must collect wastewater quality
samples from each wastewater source at each tailings cell at the facility, including surface
impounded wastewaters, and slimes drain wastewaters, pursuant to the Mill's Tailings and Slimes
Drain Sampling Program, Revision 0, November 20,2008 (the "WQSP"). All such sampling
must be conducted in August of each calendar year.
The purpose ofthe WQSP is to characterize the source term quality of all tailings cell wastewaters,
including impounded wastewaters or process waters in the tailings cells, and wastewater or
leachates collected by internal slimes drains. The WQSP requires:
o Collection of samples from the pond area of each active cell and the slimes drain of each
cell that has commenced de-watering activities;
o Samples of tailings and slimes drain material will be analyzed at an offsite contract
laboratory and subjected to the analytical parameters included in Table 2 of the GWDP
(see Table 2.3-l above) and general inorganics listed in Part LE.l(dx2)(ii) of the GWDP,
as well as semi-volatile organic compounds;
o A detailed description of all sampling methods and sample preservation techniques to be
employed;
The procedures utilized to conduct these analyses will be standard analytical methods
utilized for groundwater sampling and as shown in Section 8.2 of the Mill's QAP;
The contracted laboratory will be certified by the State of Utah in accordance with UAC
R317-6-6.12A; and
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
30-day advance notice of each annual sampling event must be given, to allow the
Executive Secretary to collect split samples of all tailings cell wastewater sources.
The tailings and slimes drain sampling events are subject to the Mill's QAP, unless otherwise
specifically modified by the WQSP to meet the specific needs of this type of sampling.
2.3.2 Monitoring and Inspections Required Under the License
2. 3. 2. I Environmental Monitoring
The environmental monitoring program is designed to assess the effect of Mill process and
disposal operations on the unrestricted environment. Delineation of specific equipment and
procedures is presented in the Mill's Environmental Protection Manual included as Appendix A
to the 2007 License Renewal Application.
c) Ambient Air Monitoring
(i) Ambient Particulate
Airborne radionuclide particulate sampling is performed at five locations, termed BHV-1, BHV-2,
BHV-4, BHV-5 and BHV-6. With the approval of the NRC and effective November, 1995,
BHV-3 was removed from the active air particulate monitoring program. At that time, the Mill
proposed (and NRC determined) that a sufficient air monitoring data base had been compiled at
station BHV-3 to establish a representative airborne particulate radionuclide background for the
Mill. BHV-6 was installed by the Mill at the request of the White Mesa Ute Community. This
station began operation in July of 1999 and provides airbome particulate information in the
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
southerly direction between the Mill and the White Mesa Ute Community. Figure 2.3-l shows
the locations of these air particulate monitoring stations.
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White Mesa Mill Reclamation Plan
lnsert Fig2.3-l locations of air particulate stations
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White Mesa Mill Reclamation Plan
The present sampling system consists of high volume particulate samplers utilizing mass flow
controllers to maintain an air flow rate of approximately 32 standard cubic feet per minute.
Samplers are operated continuously with a goal for on-stream operating period at ninety percent.
Filter rotation is weekly with quarterly site compositing for particulate radionuclide analysis.
Analysis is done for U-natural,Th-230,Ra-226, and Pb-210.
See Section 3.13.1.7(a) of the 2007 ER for a summary of historic monitoring results for airborne
particulate.
(ii)Ambient Radon
With the approval of the NRC, Radon-222 monitoring at the BHV stations was discontinued in
1995, due to the unreliability of monitoring equipment available at that time to detect the new 10
CFR standard of 0.1 pCi/I. From that time until the present, the Mill demonstrated compliance
with the requirements of R313-15-301 by calculation authorizedby the NRC in September 1995
and as contemplated by R313-15-302 (2) (a).
This calculation was performed by use of the MILDOS code for estimating environmental
radiation doses for uranium recovery operations (Strenge and Bender 1981) in 1991 in support of
the Mill's 1997license renewal and more recently in2007 in support of the 2007 License Renewal
Application, by use of the updated MILDOS AREA code (Argonne 1998). The analysis under
both the MILDOS and MILDOS AREA codes assumed the Mill to be processing high grade
Arizona Strip ores at full capacity, and calculated the concentrations of radioactive dust and radon
at individual receptor locations around the Mill. Specifically, the modeling under these codes
assumed the following conditions:
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
730,000 tons ofore per year
Average grade of 0.53% U:Os
Yellowcake production of 4.380 tons of U3Os per /ear (8.8 million pounds U3Os per year).
Based on these conditions, the MILDOS and MILDOS AREA codes calculated the combined total
effective dose equivalent from both air particulate and radon at the current nearest residence
(approximately 1.2 miles north of the Mill), i.e., the individual member of the public likely to
receive the highest dose from Mill operations, as well as at all other receptor locations, to be below
the ALARA goal of 10 mrem/yr for air particulate alone as set out in R3l3-15-l0l(4). Mill
operations are constantly monitored to ensure that operating conditions do not exceed the
conditions assumed in the above calculations. If conditions are within those assumed above,
radon has been calculated to be within regulatory limits. If conditions exceed those assumed
above, then further evaluation will be performed in order to ensure that doses to the public
continue to be within regulatory limits. Mill operations to date have never exceeded the License
conditions assumed above.
In order to determine if detection equipment has improved since 1995, the Mill has, commencing
with the first quarter of 2007 , re-instituted direct measurements of radon at the five air particulate
monitoring locations currently utilized for air particulate sampling. The reliability of this data is
currently under review by Denison.
d)External Radiation
TLD badges, as supplied by Landauer, Inc., or equivalent, are utilized at BHV-1, BHV-2, BHV-3,
BHV-4, BHV-5 and BHV-6 to determine ambient extemal gamma exposures (see Figure 2.3-l).
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White Mesa Mill Reclamation Plan
System quality assurances are determined by placing a duplicate monitor at one site continuously.
Exchanges of TLD badges are on a quarterly basis. Badges consist of a minimum of five TLD
chips. Measurements obtained from location BHV-3 have been designated as background due to
BHV-3's remoteness from the Mill site (BHV-3 is located approximately 3.5 miles west of the
Mill site). For further procedural information see Section 4.3 of the Mill's Environmental
Protection Manual, included as Appendix A to the 2007 License Renewal Application. See
Section 3.13.1.7(c) of the 2007 ER for a summary of historic monitoring results for external
radiation.
e) Soil and Vegetation
(i) Soil Monitoring
Soil samples from the top one centimeter of surface soils are collected annually at each of BHV-1,
BHV-2, BHV-3, BHV-4 and BHV-5 (see Figure 2.3-l). A minimum of two kilograms of soil is
collected per site and analyzed for U-natural andRa-226. For further procedural information see
Section 4.1 of the Mill's Environmental Protection Manual included as Appendix A to the 2007
License Renewal Application. See Section 3.13.1 .7.1 of the2007 ER for a summary of the
historic results for soil monitoring. The 2007 ER concludes that the results of sampling are low,
less than the unrestricted release limits.
(i)Vegetation Monitoring
Forage vegetation samples are collected three times per year from animal grazinglocations to the
northeast (near BHV-I (the meteorological station)), northwest (to the immediate west of the site)
and southwest (by BHV-4) of the Mill site. Samples are obtained during the grazing season, in
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
the late fall, early spring, and in late spring. A minimum of three kilograms of vegetation are
submitted from each site for analysis of Ra-226 and Pb-210. For further procedure information
see Section 4.2 of the Mill's Environmental Protection Manual included as Appendix A to the
2007 License Renewal Application. See Section 3.13.7(d) of the 2007 ER for a summary of the
historic results for vegetation monitoring. The 2007 ER concludes that the most recent results
indicate no increase in uptake of Ra-226 and Pb-210 in vegetation.
d)Meteorological
Meteorological monitoring is done at a site near BHV-I. The sensor and recording equipment are
capable of monitoring wind velocity and direction, from which the stability classification is
calculated. Data integration duration is one-hour with hourly recording of mean speed, mean
wind direction, and mean wind stability (as degrees sigma theta).
The data from the meteorological station is retrieved monthly by down loading onto a Campbell
Scientific data module, or the equivalent. The data module is sent to an independent
meteorological contractor where the module is downloaded to a computer record, and the data is
correlated and presented in a Semi-Annual Meteorological Report.
Monitoring for precipitation consists of a daily
gauge, or the equivalent, installed near the
specifications.
log of precipitation using a standard NOAA rain
administrative office, consistent with NOAA
Windrose data is summarized in a format compatible with MILDOS and UDAD specifications for
40 CFR 190 compliance. For further procedural information see Section 1.3 of the Mill's
Environmentol Protection Manual tncluded as Appendix A to the 2007 License Renewal
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White Mesa Mill Reclamation Plan
Application. A windrose for the site is set out in Figure 1.1-1.
e)Emissions
Stack emission monitoring from yellowcake facilities follows EPA Method 5 procedures and
occurs on a quarterly basis, during operation of the facility. Particulate sampling is analyzed for
Unat on a quarterly basis and for Th-230 , Ra-226, and Pb-210 on a semi-annual basis. Demister
and ore stack emission monitoring follows EPA Method 5 procedure on a semi-annual basis,
during operation of the facility. Particulate samples are analyzed for Unat, Th-230,Ra-226, and
Pb-210. Monitored data includes scrubber system operation levels, process feed levels,
particulate emission concentrations, isokinetic conditions, and radionuclide emission
concentrations. For further procedure information see Section 1.4 of the Mill's Environmental
Protection Manual included as Appendix A to the 2007 License Renewal Application. Historic
stack emission data are summarized in Section 3.13.1.7(e) of the 2007 ER.
Surface Water Monitoring
Surface water monitoring is conducted at
Westwater Canyon and Cottonwood Creek.
two locations adjacent to the Mill facility known as
Samples are obtained annually from Westwater and
quarterly from Cottonwood using grab sampling. For Westwater Creek, samples will be of
sediments if a water sample is not available. Field monitored parameters and laboratory
monitored parameters are listed in Table 2.3-2. For fuither procedural information see Section
2.1 of the Mill's Environmental Protection Manual included as Appendix A to the2007 License
Renewal Application. See Section 3.7.4 of the 2007 ER for a summary of the historic results for
surface water monitoring.
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White Mesa Mill Reclamation Plan
Table2.3-2
Operational Phase Surface Water Monitoring Program
Monitoring Sites
Westwater Creek and Cottonwood Creek
Field Requirements
l. Temperature C;
2. Specific Conductivity umhos at25 C;
3. pH at 25 C,
4. Sample date;
5. Sample ID Code;
Vendor Laboratory Requirements
*Semiannual sample must be taken a minimum of four months apart.
**Annual Westwater Creek sample is analyzed for semi-annual parameters.
Radionuclides and LLDs reported in pCi/ml
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One gallon Unfiltered, Raw and Preserved to
pH<2 with HNOr
Total Dissolved Solids Total Dissolved Solids
Total Susoended Solids Total Suspended Solids
Gross Aloha
Susoended Unat
Dissolved Unat
Susoended Ra-226
Dissolved Ra-226
Susoended Th-230
Dissolved Th-230
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2.3.2.2 Additional Monitoring and Inspeclions Required Under the License
Under the License daily, weekly, and monthly inspection reporting and monitoring are required by
NRC Regulatory Guide 8.31, Information Relevant to Ensuring that Occupational Radiation
Exposures at Uranium Recovery Facilities will be As Low As is Reasonable Achievable, Revision
l, May 2002 ("Reg Guide 8.31"), by Section 2.3 of the Mill's ALARA Program and by the DMT
Plan, over and above the inspections described above that are required under the GWDP. A copy
of the Mill's ALARA Program is included as Appendix I to the 2007 License Renewal
Application.
a)Daily Inspections
Three types of daily inspections are performed at the Mill under the License:
(i) Radiation Staff Inspections
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the Mill's Radiation Safety Officer ("RSO") or
designated health physics technician should conduct a daily walk-through (visual) inspection of all
work and storage areas of the Mill to ensure proper implementation of good radiation safety
procedures, including good housekeeping that would minimize unnecessary contamination.
These inspections are required by Section 2.3.1 of the Mill's ALARA Program, and are
documented and on file in the Mill's Radiation Protection Office.
(ii) OperatingForemanlnspections
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30 CFR Section 56.18002 ofthe Mine Safety and Health Administration regulations requires that a
competent person designated by the operator must examine each working place at least once each
shift for conditions which may adversely affect safety or health. These daily inspections are
documented and on file in the Mill's Radiation Protection Office.
(iii)Daily Tailings lnspection
Paragraph 2.2 of the DMT Plan requires that during Mill operation, the Shift Foreman, or other
person with the training specified in paragraph 2.4 of the DMT Plan, designated by the RSO, will
perform an inspection of the tailings line and tailings area at least once per shift, paying close
attention for potential leaks and to the discharges from the pipelines. Observations by the
Inspector are recorded on the appropriate line on the Mill's Daily Inspection Data form.
b) Weekly lnspections
Three types of weekly inspections are perfbrmed at the Mill under the License:
(i) Weekly Inspection of the Mill Forms
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the RSO and the Mill foreman should, and
Section 2.3.2 of the Mill's ALARA Program provides that the RSO and Mill foreman, or their
respective designees, shall conduct a weekly inspection of all Mill areas to observe general
radiation control practices and review required changes in procedures and equipment. Particular
attention is to be focused on areas where potential exposures to personnel might exist and in areas
of operation or locations where contamination is evident.
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White Mesa Mill Reclamation Plan
(ii)Weekly Ore Storage Pad Inspection Forms
Paragraph 3.3 of the DMT Plan requires that weekly feedstock storage area inspections will be
performed by the Radiation Safety Department, to confirm that the bulk feedstock materials are
stored and maintained within the defined area of the ore pad and that all alternate feed materials
located outside the defined ore pad area are maintained within water tight containers. The results
of these inspections are recorded on the Mill's Ore Storage/Sample Plant Weekly Inspection
Report.
(iii) Weekly Tailings and DMT Inspection
Paragraphs 3.1 and 3.2 of the DMT Plan require that weekly inspections of the tailings area and
DMT requirements be performed by the radiation safety department.
c)Monthly Reports
Two types of monthly reports are prepared by Mill staff:
Monthly Radiation Safety Reports
At least monthly, the RSO reviews the results of daily and weekly inspections, including a review
of all monitoring and exposure data for the month and provides to the Mill Manager a monthly
report containing a written summary of the month's significant worker protection activities
(Section 2.3.4 of the Mill's ALARA Program).
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(ii)Monthly Tailings Inspection Reports
Paragraph 4 of the DMT Plan requires that a Monthly Inspection Data form be completed for the
monthly tailings inspection. This inspection is typically performed in the fourth week of each
month and is in lieu of the weekly tailings inspection for that week.
Mill staff also prepares a monthly summary of all daily, weekly, monthly and quarterly tailings
inspections.
d) Quarterly Tailings Inspections
Paragraph 5 of the DMT Plan requires that the RSO or his designee perform a quarterly tailings
inspection.
e)Annual Evaluations
The following annual evaluations are performed under the License, as set out in Section 6 of the
DMT Plan.
(i) Annual Technical Evaluation
An annual technical evaluation of the tailings management system must be performed by a
registered professional engineer (PE), who has experience and training in the area of geotechnical
aspects of retention structures. The technical evaluation includes an on-site inspection of the
tailings management system and a thorough review of all tailings records for the past year. The
Technical Evaluation also includes a review and summary ofthe annual movement monitor survey fpo"*
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(see paragraph (ii) below).
All tailings cells and corresponding dikes are inspected for signs of erosion, subsidence, shrinkage,
and seepage. The drainage ditches are inspected to evaluate surface water control structures.
In the event tailings capacity evaluations were performed for the receipt of altemate feed material
during the year, the capacity evaluation forms and associated calculation sheets will be reviewed to
ensure that the maximum tailings capacity estimate is accurate. The amount of tailings added to
the system since the last evaluation will also be calculated to determine the estimated capacity at
the time of the evaluation.
As discussed above, tailings inspection records consist of daily, weekly, monthly, and quarterly
tailings inspections. These inspection records are evaluated to determine if any freeboard limits
are being approached. Records will also be reviewed to summarize observations of potential
concern. The evaluation also involves discussion with the Environmental and/or Radiation
Technician and the RSO regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings areaare taken. The training of individuals is also
reviewed as a part of the Annual Technical Evaluation.
The registered engineer obtains copies of selected tailings inspections, along with the monthly and
quarterly summaries of observations of concem and the corrective actions taken. These copies are
then included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Directing Dam Safety Engineer, State of Utah, Natural Resources.
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(ii)Annual Movement Monitor Survey
A movement monitor survey is conducted by a licensed surveyor annually in accordance with
Condition 11.3 of the License, approved on June 17,2010. The movement monitor survey
consists of surveying monitors along dikes 4A-S and 4B-S to detect any possible settlement or
movement of the dikes. The data generated from this survey is reviewed and incorporated into
the Annual Technical Evaluation Reporl of the tailings management system.
(iii) Annual Leak Detection Fluid Samples
IntheeventsolutionhasbeendetectedinaleakdetectionsysteminCells l,2or 3,asamplewillbe
collected on an annual basis. This sample will be analyzed according to the conditions set forth in
License Condition 1 1.3.C. The results of the analysis will be reviewed to determine the origin of
the solution.
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3.0 RECLAMATION PLAN
This section provides an overview of the Mill location and property; details the facilities to be
reclaimed; and describes the design criteria applied in this Plan. Reclamation plans and
specifications are presented in Attachment A. Attachment B presents the quality plan for
construction activities. Attachment C presents cost estimates for reclamation. Attachments D
through H present additional material test results and design calculations to support the
reclamation plan.
3.1 Location and Property Description
The White Mesa Mill is located six miles south of Blanding, Utah on US Highway 191 on a parcel
of land encompassing all or part of Sections 21,22,27,28,29,32, and 33 of T37S, P22E, and
Sections 4,5,6,8, 9, and l6 of T38S. R228, Salt Lake Base and Meridian described as follows
(Figure 3.1-1):
The south half of Section 2l; the southeast quarter of the southeast quarter of
Section 22; the northwest quarter of the northwest quarter and lots 1 and 4 of
Section 27 all that part of the southwest quarter of the northwest quarter and the
northwest quarter southwest quarter of Section 27 lying west of Utah State
Highway 163; the northeast quarter of the northwest quarter, the south half of the
northwest quarter, the northeast quarter and the south half of Section 28; the
southeast quarter of the southeast quarter of Section 29; the east half of Section 32
and all of Section 33, Township 37 South, Range 22 East, Salt Lake Base and
Meridian. Lots I through 4, inclusive, the south half of the north half, the
southwest quarter, the west half of the southeast quarter, the west half of the east
half of the southeast quarter and the west half of the east half of the east half of the
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southeast quarter of Section 4; Lots I through 4, inclusive, the south half of the
north half and the south half of Section 5 (all); Lots I and 2, the south half of the
northeast quarter and the south half of Section 6 (Ell2); the northeast quarter of
Section 8; all of Section 9 and all of Section 16, Township 38 South, Range 22Bast,
Salt Lake Base and Meridian. Additonal land is controlled by 46 Mill site claims.
Total land holdings are approximately 5,415 acres..
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INSERT FIGURE 3.1-1
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3.2 Facilities to be Reclaimed
See Figure 3.2-l for a general layout of the mill yard and related facilities and the restricted area
boundary.
3.2.1 Summary of Facilities to be Reclaimed
The facilities to be reclaimed include the following:
o Cell 1 (evaporation). Cell I was previously referred to as Cell I-1. It is now referred to
as Cell 1;
o Cells 2 and3,4A and 48 (tailings);
o Mill buildings and equipment;
o On-site contaminated areas; and
o Off-site contaminated areas (i.e., potential areas affected by windblown tailings).
The reclamation of the above facilities will include the following:
o Placement of contaminated soils, crystals, and synthetic liner material and any
contaminated underlying soils from Cell 1 into tailings Cells 4,A' or 48.
o Placement of a compacted clay liner on a portion of the Cell 1 impoundment area to be
used for disposal of contaminated materials and debris from the Mill site
decommissioning. (the Cell 1 Tailings Area)
o Placement of materials and debris from Mill Decommissioning into tailings Cells 4,{ or 48
or in the Cell 1 Tailings Area;
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Placement of an engineered multi-layer cover over the entire area of Cells2,3,4A and 48
and the Cell I Tailings Area.
Construction of runoffcontrol and diversion channels as necessary;
Reconditioning of Mill and ancillary areas; and
Reclamation of borrow sources.
o
O
o
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INSERT FIGURE 3.2-I
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3.2.2 Tailings and Evaporative Cells
The following subsections describe the cover design and reclamation procedures for Cells1-I,2,3,
4,A. and 48. Complete engineering details and text are presented in the Tailings Cover Design
report, Appendix D, previously submitted. Additional information is provided in Attachments D,
E and F to this submittal.
3.2.2.1 Soil Cover Design
A six-foot thick soil cover to be placed over the uranium tailings and mill decommissioning
materials in the Cell l-l Tailings Area, Cell2, Cell2, Cell 4,A. and Cell 48 was designed using
on-site materials that will contain tailings and radon emissions in compliance with regulations of
the NRC, the State of Utah, and by ref'erence, the EPA. The cover consists of a one-foot thick
layer of clay, available from within the site boundaries (Section 16 or stockpiles on site), below
two feet of random fill (frost barrier). available from stockpiles on site. The clay is underlain by
three feet (minimum) random fill soil (platform fill), also available on site. In addition to the soil
cover, a minimum three-inch (on the cover top) to 8-inch (on the cover slopes) layer of riprap
material will be placed over the compacted random fill to stabilize slopes and provide long-term
erosion resistance (see Attachments D and H for characterization of cover materials).
Uranium tailings soil cover design requirements for regulatory compliance include:
' Attenuate radon flux to an acceptable level (20 picoCuries-per meter squared-per second
[pCi/m2lsec]) (NRC, l9S9) and 40 CFR 61 .250-61.256;
' Minimize infiltration into the reclaimed tailings cells;
' Maintain a design life of up to 1,000 years or to the extent reasonably achievable, and in
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any case for at least 200 years; and
. Provide long-term slope stability and geomorphic durability to withstand erosional forces
of wind, the probable maximum flood event, and a horizontal ground acceleration of 0.1g
due to seismic events.
Several models/analyses were utilized in simulating the soil cover effectiveness: radon flux
attenuation, hydrologic evaluation of inhltration, freezelthaw effects, soil cover erosion
protection, and static and pseudostatic slope stability analyses. These analyses and results are
discussed in detail in Sections 3.3.1 through 3.3.5, and calculations are also shown in the Tailings
Cover Design report, (Appendix D, Attachment E and Attachment F). The soil cover (from top to
the bottom) will consist of: (l) minimum of three inches of riprap material; (2) two feet of
compacted random fill; (3) one foot of compacted clay; and (a) minimum three feet of compacted
random fill soil.
The final grading plan is presented in Section 5, Figure 5.1-1. As indicated on the figures, the top
slope of the soil cover will be constructed at 0.2 percent and the side slopes, as well as transitional
areas between cells, will be graded to five horizontal to one vertical (5H:lV).
A minimum of three feet random fill is located beneath the compacted filI and clay layers (see
cross-sections on Figures 5 . I -2 and 5 . 1 -3 ). The purpose of the fill is to raise the base of the cover
to the desired subgrade elevation. ln many areas, the required fill thickness will be much greater.
However, the models and analyses presented in the Tailings Cover Design report (Appendix D)
were performed conservatively, assuming only a three-foot layer. For modeling purposes, this
lower, random fill layer was considered as part of the soil cover for performing the radon flux
attenuation calculation, as it effectively contributes to the reduction of radon emissions (see
Section 3.3.2). The fill was also evaluated in the slope stability analysis (see Section 3.3.6).
However, it is not defined as part of the soil cover for other design calculations (infiltration,
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freezelthaw, and cover erosion).
3.2.2.2 Cell l-I
Cell 1, used during mill operations solely for evaporation of process liquids, is the northernmost
existing cell and is located immediately west of the mill. It is also the highest cell in elevation, as
the natural topography slopes to the south. The drainage area above and including the cell is 216
acres. This includes drainage from the Mill site.
Cell 1 will be evaporated to dryness. The synthetic liner and raffinate uystals will then be
removed and placed in tailings Cells 4,A. or 48. Any contaminated soils below the liner will be
removed and also placed in the tailings cells. Based on current regulatory criteria, the current
plan calls for excavation of the residual radioactive materials to be designed to ensure that the
concentration of radium-226 in land averaged over any area of 100 square meters does not exceed
the background level by more than:
5 pCilg, averaged over the first l5 cm of soil below the surface, and
l5 pCi/g, averaged over a 15 cm thick layer of soil more than l5 cm below the surface.
A portion of Cell I (i.e., the Cell 1 Tailings Area), adjacent to and running parallel to the
downstream cell dike, will be used for permanent disposal of contaminated materials and debris
from the mill site decommissioning and windblown cleanup. The actual area of Cell 1-l Tailings
Area needed for storage of additional material will depend on the status of Cell 44 and 48 at the
time of final mill decommissioning. A portion of the Mill area decommissioning material may be
placed in Cell4A or 48 if space is available, but for purposes of the reclamation design the entire
quantity of contaminated materials from the Mill site decommissioning is assumed to be placed in
the Cell 1 Tailings Area. This results in approximately l0 acres of the Cell I Tailings Area and
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being utilized for permanent tailings storage. The remaining area of Cell I will then be
breached and converted to a sedimentation basin. All runoff from the Cell l-I Tailings Area, the
Mill area and the area immediately north of Cell 1 will be routed into the sedimentation basin and
will discharge onto the natural ground via the channel located at the southwest corner of the basin.
The channel is designed to accommodate the PMF flood.
The HEC-I model was used to determine the PMF and route the flood through the sedimentation
basin (Attachment G). The peak flow was determined to be 1 ,344 cubic feet per second (cfs). A
20-foot wide channel will discharge the flow to the natural drainage. During the local storm PMF
event, the maximum discharge through the channel will be 1,344 cfs. The entire flood volume
will pass through the discharge channel in approximately four hours.
At peak flow, the velocity in the discharge channel will be 7.45 feet per second (fps). The
maximum flow depth will be 1.45 feet. This will be a bedrock channel and the allowable velocity
for a channel of this type is 8-10 fps, therefore no riprap is required. A free board depth of 0.5 feet
will be maintained for the PMP event.
3.2.2.3 Cell 2
Cell2 will be filled with tailings and covered with a multi-layered engineered cover to a minimum
cover thickness of six feet. The final cover will drain to the south at a 0.2 percent gradient.
The cover will be as described in Section 3.2.2.1above, and will consist of a minimum ofthree feet
of random fill (platform fill), followed by a clay radon barrier of one foot in thickness, and two feet
of upper random fill (frost barrier) for protection of the radon barrier. A minimum of three inches
of rock will be utilized as armor against erosion. Side slopes will be graded to a 5:1 slope and will
have 0.67 feet (8 inches) of rock arnor protection.
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3.2.2.4 Cell 3
Cell 3 will be filled with tailings, debris and contaminated soils and covered with the same
multi-layered engineered cover as Cell 2.
3.2.2.5 Cell 4A
Cell 4,\ will be filled with tailings, debris and contaminated
multi-layered engineered cover as Cell 2 and Cell 3.
3.2.2.6 Cell 48
Cell 48 will be filled with tailings, debris and contaminated
multi-layered engineered cover as Cell 2, Cell3 and Cell 4,A..
3.2.3 Mill Decommissioning
A general layout of the mill area is shown in Figure 3.2.3-1.
soils and covered with the same
soils and covered with the same
3.2.3.1 Mill Building, Equipment, and Other l le.(2) Byproduct Material
The uranium and vanadium sections, including ore reclaim, grinding, pre-leach, leach, CCD, SX,
and precipitation and drying circuits as well as the alternate feed circuit, decontamination pads,
scale house, sample plant, truck shop and all other structures on site will be decommissioned as
follows:
All equipment including instrumentation, process piping, electrical control and switchgear, and
contaminated structures will be removed. Contaminated concrete foundations will be demolished
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and removed or covered with soil as required. Uncontaminated equipment, structures and waste
materials from Mill decommissioning may be disposed of by sale, transfened to other
company-owned facilities, transferred to an appropriate off-site solid waste site, or disposed of in
one of the tailings cells. Contaminated equipment, structures and dry waste materials from Mill
decommissioning, contaminated soils underlying the Mill areas, and ancillary contaminated
materials will be disposed of in tailings Cell 4,A., Cell 4B, or the Cell 1 Tailings Area. All other
11e.(2) byproduct material on site will be disposed of in Cell 44' or Cell 48.
Debris and scrap will have a maximum dimension of 20 feet and a maximum volume of 30 cubic
feet. Material exceeding these limits will be reduced to within the acceptable limits by breaking,
cutting or other approved methods. Empty drums, tanks or other objects having a hollow volume
greater than five cubic feet will be reduced in volume by at least 70 percent. If volume reduction
is not feasible, openings shall be made in the object to allow soils or other approved material to
enter the object.
Debris and scrap will be spread across the designated areas to avoid nesting and to reduce the
volume of voids present in the placed mass. Stockpiled soils, and/or other approved material
shall be placed over and into the scrap in sufficient amounts to fill the voids between the large
pieces and the volume within the hollow pieces to form a coherent mass.
See also Section 3.1 of Attachment A.
The estimated reclamation costs for surety are set out in Attachment C. Attachment C will be
reviewed and updated on a yearly basis.
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INSERT FIGURE 3.2.3.1
LAYOUT OF MILL YARD AND ORE PAD
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3.2.3.2 Mill Site
Contaminated areas on the Mill site will be primarily superficial and includes the ore storage area
and surface contamination of some roads. All ore will have been previously removed from the
ore stockpile area or will be transported and disposed of as contaminated material. All
contaminated materials will be excavated and be disposed in one of the tailings cells. The depth
of excavation will vary depending on the extent of contamination and will be governed by the
criteria in Attachment A, Section 3.2.
Windblown material is defined as Mill-derived contaminants dispersed by wind to surrounding
areas. Windblown contaminated material detected by a gamma survey using the criteria in
Attachment A, Section3.2, will be excavated and disposed in one of the tailings cells.
Disturbed areas will be covered, graded and vegetated as required. The proposed grading plan for
the Mill site and ancillary areas is shown on Figure A-3.2-l in Attachment A.
J.J Design Criteria
As required by Part I.H.l of the GWDP, Denison is in the process of completing an infiltration and
contamination transport model of the final tailings cover system to demonstrate the long-term
ability of the cover to protect nearby groundwater quality. Upon review of such modeling, the
executive Secretary will determine if changes to the cover systems as set outin the iPlan are needed
to ensure compliance with the performance criteria contained in part I.D.8 of the GWDP.
Although the modeling has not been completed, modeling results to date suggest that some
changes to the final cover design as set out in this Plan will be needed. However, as the details of
such re-design have not been finalized at this time, the approved 2000 cover deiagn and basis will
continue to be used for this version of the Plan. This Plan will be amended in the future to
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incorporate any changes to the design of the tailings cover system that result from the current
modeling effort.
The design criteria summaries in this section are adapted from Tailings Cover Design, Mill (Titan,
1996). A copy of the Tailings Cover Design report is included in Appendix D, previously
submitted. It contains all of the calculations used in design discussed in this section. Additional
design information is included in Attachments D through H to this submittal.
3.3.1 Regulatory Criteria
Information contained in 10 CFR Part 20, Appendix A, 10 CFR Part 40, and Appendix A to 10
CFR Part 40 (which are incorporated by reference into UAC R3l3-24-4), and 40 CFR Part 192
was used as criteria in final designs under this Plan. In addition, the following documents also
provided guidance:
o EPA, 1994, The Hydrologic Evaluation of Londfill Performance (HELP) Model, Version
-3, EPA/600/R-94/1 68b, September;
o NRC, 1989, "Regulatory Guide 3.64 (Task WM-503-4) Calculation of Radon Flux
Attenuation by Earthen Uranium Mill Tailings Covers, March;
o NRC, 1980, Final Staff Technical Position Design of Erosion Protection Covers for
Stabilization of Uranium Mill Tailings Sires, August;
o NUREGICR-4620, Nelson, J. D., Abt, S. R., et. al., 1986, Methodologiesfor Evaluating
Long-Term Stabilization Designs of Uranium Mill Tailings Impoundments, June;
o NUREG/CR-4651,1987, Development of Riprap Design Criteria by Riprap Testing in
Flumes: Phase l,May;
o U. S. Department of Energy, 1988, Effect of Freezing and Thawing on UMTRA Covers,
Albuquerque, New Mexico, October; and.
o NUREG 1620,2003, Standard Review Planfor the review of a reclamation Planfor Mill
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Tailings Sites Under Title II o/'the uranium Mill Tailings radiation Control Act of 1978.
As mentioned above, the requirements set out in Part I.D.8 of the GWDP require that the cover
system for each tailings cell will be designed and constructed to meet the following minimum
requirements for a period of not less than 200 years:
Minimize the infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon barrier;
Prevent the accumulation of leachate head within the tailings waste layer that could rise
above or over-top the maximum FML elevation internal to any disposal cell, i.e. create a
"bathtub" effect; and
Ensure that groundwater quality at the compliance monitoring wells deosn ot exceed the
GWQSs or GWCLs specified in Part I.C.1 and table2 of the GWDP.
Upon completion of the Infiltration Analysis, this Plan will be revised as necessary to ensure
compliance with these requirements.
3.3.2 Radon Flux Attenuation
The EPA rules in 40 CFR Part 192 require that a "uranium tailings cover be designed to produce
reasonable assurance that the radon-222 release rate would not exceed 20 pCilmzlsec for a period
of 1,000 years to the extent reasonably achievable and in any case for at least 200 years when
averaged over the disposal area over at least a one year period" (NRC, 1989). NRC regulations
presented in l0 CFR Part 40 (incorporate by reference into UAC R313-24-4) also restrict radon
flux to less than 20 pCilm2lsec. The following sections present the analyses and design for a soil
cover which meets this requirement.
3. 3.2. 1 Predictive Analysis
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The soil cover for the tailings cells at White Mesa Mill was evaluated for attenuation of radon gas
using the digital computer program, RADON, presented in the NRC's Regulatory Guide 3.64
(Task WM 503-4) entitled Calculation of Radon Flux Attenuation by Earthen Uranium Mill
Tailings Covers. The RADON model calculates radon-222 flux attenuation by multi-layered
earthen uranium mill tailings covers, and determines the minimum cover thickness required to
meet NRC and EPA standards. The RADON model uses the following soil properties in the
calculation process:
o Soil layer thickness [centimeters (cm)];
o Soil porosity (percent);
o Density [grams-per-cubic centimeter (gm/cm3)];
o Weight percent moisture (percent);
o Radium activity (picig);
o Radon emanation coefficient (unitless); and
o Diffusion coefficient [square centimeters-per-second (cm2isec)].
Physical and radiological properties for tailings and random fill were analyzed by Chen and
Associates (1987) and Rogers and Associates (1988). Clay physical data from Section l6 was
analyzed by Advanced Terra Testing (1996) and Rogers and Associates (1996). Additional
testing of cover materials was perlormed in April 1999. The test results are included in
Attachment D. See Appendix D, previously submitted, for additional laboratory test results.
The RADON model was performed for the following cover section (from top to bottom):
two feet compacted random fill (frost barrier);
one foot compacted clay; and
a minimum of three feet random fill occupying the freeboard space between the tailings
a
a
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and clay layer (Platform fill)'
The top one foot of the lower random fill, clay layer and two foot upper random fill are compacted
to 95 percent maximum dry density. The top riprap layer was not included as part of the soil
cover for the radon attenuation calculation.
The most current RADON modeling is included in Attachment F.
The results of the RADON modeling exercise, based on two different compaction scenarios, show
that the uranium tailings cover configuration will attenuate radon flux emanating from the tailings
to a level of 18.2 to 19.8 pCi/m2lsec. This number was conservatively calculated as it takes into
account thefreezelthaw effect on the uppermost part (6.8 inches) of the cover (Section 3.3.4).
The soil cover and tailing parameters used to run the RADON model, in addition to the RADON
input and output data files, are presented in Appendix D as part of the Radon Calculation brief (See
Appendix B in the Tailings Cover Design report, previously submitted in its entirety as Appendix
D) and the most current model included as Attachment F to this submittal. Based on the model
results, the soil cover design of six-foot thickness will meet the requirements of 40 CFR Part 192
and 10 CFR Part 40.
3.3.2.2 Empirical Data
Radon gas flux measurements have been made at the White Mesa Mill tailings piles over Cells 2
and 3 (see Appendix D). Cunently Cell 2 is fully covered and Cell 3 is partially covered with
three to four feet of random fill. During the period 2004 through2007, cell2 was only partially
covered with such random fill. Radon flux measurements, averaged over the covered areas, were
as follows (Denison 2004-2008):
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Iable 3.3-1
Average Radon Flux from Tailings Cells 2004-2008
(pCi/m2lsec)
Empirical data suggest that the random fill cover, alone, is currently providing an effective barrier
to radon flux. Thus, the proposed tailings cover configuration, which is thicker, moisture
adjusted, contains a clay layer, and is compacted, is expected to attenuate the radon flux to a level
below that predicted by the RADON model. The field radon flux measurements confirm the
conservatism of the cover design. This conservatism is useful, however, to guarantee compliance
with applicable regulations under long term climatic conditions over the required design life of
200 to 1,000 years.
3.3.3 InfiltrationAnalysis
The tailings ponds at White Mesa Mill are lined with synthetic geomembrane liners which under
certain climatic conditions, could potentially lead to the long-terrn accumulation of water from
infiltration of precipitation. Thereflore, the soil cover was evaluated to estimate the potential
magnitude of infiltration into the capped tailings ponds. The Hydrologic Evaluation of Landfill
Performance (HELP) model, Version 3.0 (EPA, 1994) was used for the analysis. HELP is a quasi
two-dimensional hydrologic model of water movement across, into, through, and out of capped
and lined impoundments. The model utilizes weather, soil, and engineering design data as input
to the model, to account for the eff-ects of surface storage, snowmelt, run-off, infiltration,
evapotranspiration, vegetative growth, soil moisture storage, lateral subsurface drainage, and
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Cell3 10.8 6.2 10.0 8.9 3.r
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unsaturated vertical drainage on the specific design, at the specified location.
The soil cover was evaluated based on a two-foot compacted random fill layer over a one-foot
thick, compacted clay layer. The soil cover layers were modeled based on material placement at a
minimum of 95 percent of the maximum dry density, and within two percent of the optimum
moisture content per American Society for Testing and Materials (ASTM) requirements. The top
riprap layer and the bottom random fill layer were not included as part of the soil cover for
infiltration calculations. These two layers are not playing any role in controlling the infiltration
through the cover material.
The random fill will consist of clayey sands and silts with random amounts of gravel and rock-size
materials. The average hydraulic conductivity of several samples of random fill was calculated,
based on laboratory tests, to be 8.87 x l0-7 cm/sec. The hydraulic conductivity of the clay source
from Section 16 was measured in the laboratory to be 3.7 x 10-8 cm/sec. Geotechnical soil
properties and laboratory data are presented in Appendix D.
Key HELP model input parameters include:
Blanding, Utah, monthly temperature and precipitation data, and HELP model default
solar radiation, and evapotranspiration data from Grand Junction, Colorado. Grand
Junction is located northeast of Blanding in similar climate and elevation;
Soil cover configuration identifying the number of layers, layer types, layer thickness, and
the total covered surface area;
Individual layer material characteristics identiffing saturated hydraulic conductivity,
porosity, wilting point, field capacity, and percent moisture; and
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Soil Conservation Service runoff curve numbers, evaporative zone depth, maximum leaf
area index, and anticipated vegetation quality.
Water balance results, as calculated by the HELP model, indicate that precipitation would either
run off the soil cover or be evaporated. Thus, model simulations predict zero infiltration of
surface water through the soil cover, as designed. These model results are conservative and take
into account thefreezelthaw effects on the uppermost part (6.8 inches) of the cover (See Section
1.3 of the Tailings Cover Design report, Appendix D). The HELP model input and output for the
tailings soil cover are presented in the HELP Model calculation brief included in previously
submitted Appendix D.
As mentioned above, potential infiltration into the tailings cap is currently ebing remodelined in
the Infiltration Analysis. Any changes to this Plan that are required as a result of such remodeling
will be incorporated into a subsequent revision to this Plan.
3.3.4 Freeze/Thaw Evaluation
The tailings soil cover of one foot of compacted clay covered by two feet of random flrll was
evaluated for freezelthaw impacts. Repeated freezelthaw cycles have been shown to increase the
bulk soil permeability by breaking down the compacted soil structure.
The soil cover was evaluated for freezelthaw effects using the modified Berggren equation as
presented in Aitken and Berg (1968) and recommended by the NRC (U.S. Department of Energy,
1988). This evaluation was based on the properties of the random fill and clay soil, and
meteorological data from both Banding, Utah and Grand Junction, Colorado.
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The results of the freezelthaw evaluation indicate that the anticipated maximum depth of frost
penetration on the soil cover would be less than 6.8 inches. Since the random fill layer is two feet
thick, the frost depth would be confined to this layer and would not penetrate into the underlying
clay layer. The performance of the soil cover to attenuate radon gas flux below the prescribed
standards, and to prevent surface water infiltration, would not be compromised. The input data
and results of the freezelthaw evaluation are presented in the Effects of Freezing on Tailings
Covers Calculation brief included as Appendix E in the Tailings Cover Design report, which was
previously submitted as Appendix D.
3.3.5 Soil Cover Erosion Protection
A riprap layer was designed for erosion protection of the tailings soil cover. According to NRC
guidance, the design must be adequate to protect the soil/tailings against exposure and erosion for
200 to 1,000 years (NRC, 1990). Currently, there is no standard industry practice for stabilizing
tailings for 1,000 years. However, by treating the embankment slopes as wide channels, the
hydraulic design principles and practices associated with channel design were used to design
stable slopes that will not erode. Thus, a conservative design based on NRC guidelines was
developed. Engineering details and calculations are summarized in the Erosion Protection
Calculation brief provided in Appendix F in the Tailings Cover Design report, which was
previously submitted as Appendix D.
Riprap cover specifications for the top and side slopes were determined separately as the side
slopes are much steeper than the slope of the top of the cover. The size and thickness of the riprap
on the top of the cover was calculated using the Safety Factor Method (NUREG/CR-4651, 1987),
while the Stephenson Method (NUREG/CR-4651,1987) was used for the side slopes. These
methodologies were chosen based on NRC recommendations (1990).
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By the Safety Factor Method, riprap dimensions for the top slope were calculated in order to
achieve a slope "safety factor" of 1.1 . For the top of the soil cover, with a slope of 0.2 percent, the
Safety Factor Method indicated a median diameter (D5s) riprap of 0.28 inches is required to
stabilize the top slope. However, this dimension must be modified based on the long-term
durability of the specific rock type to be used in construction. The suitability of rock to be used as
a protective cover has been assessed by laboratory tests to determine the physical characteristics of
the rocks (See Attachment H). The North pit source has an over sizing factor of 9.85%. The
riprap sourced from this pit should have a D50 size of at least 0.31 inches and should have an
overall layer thickness of at least three inches on the top of the cover.
Riprap dimensions for the side slopes were calculated using Stephenson Method equations. The
side slopes of the cover are designed at 5H: I V. At this slope, Stephenson's Method indicated the
unmodified riprap Dso of 3.24 inches is required. Again, assuming that the North pit material will
be used, the modified Dso size of the riprap should be at least 3.54 inches with an overall layer
thickness of at least 8 inches.
The potential of erosion damage due to overland flow, sheetflow, and channel scouring on the top
and side slopes of the cover, including the riprap layer, has been evaluated. Overland flow
calculations were performed using site meteorological data, cap design specifications, and
guidelines set by the NRC (NUREG/CR-4620, 1986). These calculations are included in
Appendix F of the Tailings Cover Design report (Appendix D previously submitted). According
to the guidelines, overland flow velocity estimates are to be compared to "permissible velocities,"
which have been suggested by the NRC, to determine the potential for erosion damage. When
calculated, overland flow velocity estimates exceed permissible velocities, additional cover
protection should be considered. The permissible velocity for the tailings cover (including the
riprap layer) is 5.0 to 6.0 feet-per-second (ft./sec.) (NUREG/CR-4620). The overland flow
velocity calculated for the top of the cover is less than 2.0 ft./sec., and the calculated velocity on
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the side slopes is 4.9 ft./sec.
The need for a filter or bedding material beneath the riprap was evaluated using methods presented
in NUREGICR-4620. The function of the filter is to prevent stone penetration into the cover, and
to prevent soil erosion of the cover at the riprap/soil cover interface. The likelihood of soil
erosion at the interface is evaluated by calculating the interstitial flow velocity through the riprap.
lnterstitial velocities were calculated using procedures presented by Abt et al. (1991), which
updates the Leps relationship that is presented in NUREGICP.-4620. Details of these calculations
are presented in Attachment G. The interstitial velocities on the top slope and the toe apron are
sufficiently low that a bedding layer is not necessary. However, the interstitial velocity within the
riprap on the side slopes is within the range of values where bedding is conditionally
recoillmended. Because of the wide ditference in grain size distributions between the riprap and
the random fill, it is recommended that a 6-inch layer of bedding material be placed between these
two materials.
A rock apron will be constructed at the toe of high slopes and in areas where runoff might be
concentrated (See Figure A-5.1-4). The design of the rock aprons is detailed in Attachment G.
3.3.6 Slope Stability Analysis
Static and pseudostatic analyses were performed to establish the stability of the side slopes of the
tailings soil cover. The side slopes are designed at an angle of 5H:lV. Because the side slope
along the southern section of Cell 4,A. is the longest and the ground elevation drops rapidly at its
base, this slope was determined to be critical and is thus the focus of the stability analyses.
The computer software package GSLOPE, developed by MITRE Software Corporation, has been
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used for these analyses to determine the potential for slope failure. GSLOPE applies Bishop's
Method of slices to identify the critical failure surface and calculate a factor of safety (FOS). The
slope geometry and properties of the construction materials and bedrock are input into the model.
These data and drawings are included in the Stability Analysis of Side Slopes Calculation brief
included in Appendix G of the Tailings Cover Design report. For this analysis, competent
bedrock is designated at 10 feet below the lowest point of the foundation [i.e., at a 5,540-foot
elevation above mean sea level (msl)]. 'l'his is a conservative estimate, based on the borehole logs
supplied by Chen and Associates (1979)" which indicate bedrock near the surface.
3. 3.6. 1 Static Analysis
For the static analysis, a Factor of Saf-ety ("FOS") of 1.5 or more was used to indicate an acceptable
level of stability. The calculated FOS is 2.91, which indicates that the slope should be stable
under static conditions. Results of the computer model simulations are included in Appendix G
of the Tailings Cover Design report.
3. 3.6.2 Pseudostatic Analysis (Seismic ity)
The slope stability analysis described above was repeated under pseudostatic conditions in order to
estimate a FOS for the slope when a horizontal ground acceleration of 0.10g is applied. The slope
geometry and material properties used in this analysis are identical to those used in the stability
analysis. A FOS of 1.0 or more was used to indicate an acceptable level of stability under
pseudostatic conditions. The calculated FOS is 1.903, which indicates that the slope should be
stable under dynamic conditions. Details of the analysis and the simulation results are included in
Appendix G of the Tailings Cover Design report.
In June of 1994, Lawrence Livermore National Laboratory ("LLNL") published a report entitled
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Seismic Hazard Analysis of Title II Reclamation Plans, (Lawrence Livermore National
Laboratory, 1994) which included a section on seismic activity in southern Utah. In the LLNL
report, a horizontal ground acceleration of 0.129 was proposed for the White Mesa site. The
evaluations made by LLNL were conservative to account for tectonically active regions that exist,
for example, near Moab, Utah. Although, the LLNL report states that "...[Blanding] is located in
a region known for its scarcity of recorded seismic events," the stability of the cap design slopes
using the LLNL factor was evaluated. The results of a sensitivity analysis reveal that when
considering a horizontal ground acceleration of 0.129, the calculated FOS is 1.778 which is still
above the required value of 1.0, indicating adequate safety under pseudostatic conditions. This
analysis is also included in Appendix G of the Tailings Cover Design report. A probabilistic
seismic risk analysis (See Attachment E) was performed in April 1999 during an evaluation of
cover stability.
3.3.7 Soil Cover-Animal Intrusion
To date, the White Mesa site has experienced only minor problems with burrowing animals. In
the long term, no measures short of continual annihilation of target animals can prevent burrowing.
However, reasonable measures will discourage burrowing including :
' Total cover thickness of at least six-feet;
' Compaction of the upper three feet of soil cover materials to a minimum of 95 percent, and
the lower three feet to 80-90 percent, based on a standard Proctor (ASTM D-698); and
' Riprap placed over the compacted random fill material.
3.3.8 Cover Material/Cover Material Volumes
Construction materials for reclamation will be obtained frorn on-site locations. Fill material will
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be available from the stockpiles that were generated from excavation of the cells for the tailings
facility. If required, additional materials are available locally to the west of the site. A clay
material source, identified in Section 16 at the southern end of the White Mesa Mill site, will be
used to construct the one-foot compacted clay layer. Riprap material will be produced from
off-site sources.
Detailed material quantities calculations are provided in Attachment C, Cost Estimates for
Reclamation of White Mesa Mill Facilities, as part of the volume and costing exercise.
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ATTACHMENT A
PLANS AND SPECIFICATIONS
FOR
RECLAMATION
OF
WHITE MESA FACILITIES
BLANDTNG, UTAH
PREPARED BY
DENTSON MrNES (USA) CORP.
INDEPENDENCE PLAZA
1O5O 17TII STREET, SUITE 950
DENVER, CO 80265
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TABLE OF CONTENTS
Page No.
GENERAL .,........ A-I
CELL I RECLAMATION ... A-I
Scope........ ................. A-l
Removal of Contaminated Materials ............ A-l
2.2.1 Raffinate Crystals ........... A-1
2.2.2 Synthetic Liner......... ....... A-2
2.2.3 Contaminated Soils...... ... A-2
Cell I Tailings Area A-3
2.3.1 General..... ..... A-3
2.3.2 Materials ....... A-3
2.3.3 Borrow Sources .............. A-3
Liner Construction............... ....... A-3
2.4.1 General..... ..... A-3
2.4.2 Placement and Compaction......... ..... A-4
2.4.2.1Methods .............. A-4
2.4.2.2 Moisture and Density Control ................ A-5
2.t
2.2
2.3
2.4
3.0
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TABLE OF CONTENTS (continued)Page
No.
3.3.1 Guidance ""' A-12
3.3.2 General Methodology............. ........ A-12
3.3.3 Scoping Survey...... '...... A-13
3.3.4 Characterization and Remediation Control Surveys..... ...... A-15
3.3.5 Final Survey............... ... A-16
3.3.6 Employee Health and Safety .......... A-16
3.3.7 Environment Monitoring............ .... A-17
3.3.8 Quality Assurance. ........ A-17
PLACEMENT METHODS............ ...... A-20
4.1 Scrap and Debris ..-.- A-20
4.2 Contaminated Soils and Raffinate Crystals................ .- A-21
4.3 Compaction Requirements........... .......'....... A-21
5.0 RECLAMATION CAP - CELLS L2,3, 4A, AND 4B............. ............... A-22
5.1 Earth Cover....... ...... A-22
5.2 Materials ....-............ A-22
5.2.1 Physical Properties. ....... A-22
5.2.2 Borrow Sources .-......-.-. A-29
Cover Construction............... .... A-29
5.3.1 General..... ... A-29
5.3.2 Placement and Compaction......... ... A-30
5.3.2.1Methods ............ A-30
5.3.2.2 Moisture and Density Control ............'. A-31
Monitoring Cover Settlement ... A-32
5.3
5.4
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TABLE OF CONTENTS (continued)Page No.
5.4.1 Temporary Settlement Plates........ .. A-32
5.4.1.1 General..... ......... A-325.4.l.2lnstallation ........ A-32
5.4.1.3 Monitoring Settlement Plates ............... A-33
ROCK PROTECTION .......... ............... A-35
6.1
6.2
6.3
7.0 QUALTTY CONTROL/QUALTTY ASSURANCE............ ..... A-37
7.1 Quality P1an.......... .. A-377.2 Implementation......... ................ A-387.3 Quality Control Procedures ...... A-387.4 Frequency of Quality Control Tests ........ ... A-38
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GENERAL
The specifications presented in this section cover the reclamation of the Mill facilities.
CELL I RECLAMATION
Scope
The reclamation of Cell I (previously referred to as Cell 1-I) consists of evaporating the cell to
dryness, removing raffinate crystals, synthetic liner and any contaminated soils, and constructing
a clay lined area adjacent to and parallel with the existing Cell 1 dike for permanent disposal of
contaminated material and debris from the Mill site decommissioning, referred to as the Cell I
Tailings Area. A sedimentation basin will then be constructed and a drainage channel provided.
2.2 Removal of Contaminated Materials
2.2.1 Raffinate Crystals
Raffinate crystals will be removed from Cell 1 and transported to the tailings cells. tt is
anticipated that the crystals will have a consistency similar to a granular material when brought
to the cells, with large crystal masses being broken down for transport. Placement of the crystals
will be performed as a granular fill, with care being taken to avoid nesting of large sized
material. Voids around large material will be filled with finer material or the crystal mass
broken down by the placing equipment. Actual placement procedures will be evaluated by the
QC officer during construction as crystal materials are brought and placed in the cells.
2.0
2.1
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2.2.2 Synthetic Liner
The PVC liner will be cut up, folded (when necessary), removed from Cell 1, and transported to
the tailings cells. The liner material will be spread as flat as practical over the designated area.
After placement, the liner will be covered as soon as possible with at least one foot of soil,
crystals or other materials for protection against wind, as approved by the QC officer.
2.2.3 Contaminated Soils
The extent of contamination of the Mill site will be determined by a scintillometer survey. If
necessary, a correlation between scintillometer readings and U-nat/Radim-226 concentrations
will be developed. Scintillometer readings can then be used to define cleanup areas and to
monitor the cleanup. Soil sampling will be conducted to confirm that the cleanup results in a
concentration of Radium-226 averaged over any area of 100 square meters that does not exceed
the background level by more than:
5 pCi/g averaged over the first l5 cm of soils below the surface, and
l5 pCi/g averaged over a 15 cm thick layer of soils more than 15 cm below the surface
Where surveys indicate the above criteria have not been achieved, the soil will be removed to
meet the criteria. Soil removed from Cell I will be excavated and transported to the tailings
cells. Placement and compaction will be in accordance with Section 4.0 of these Plans and
Specifications.
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2.3 Cell I Tailinqs Area
2.3.1 General
A clay lined area will be constructed adjacent to and parallel with the existing Cell I dike for
permanent disposal of contaminated material and debris from the Mill site decommissioning (the
Cell 1 Tailings Area). The area will be lined with 12 inches of clay prior to placement of
contaminated materials and installation of the final reclamation cap.
2.3.2 Materials
Clays will have at least 40 percent passing the No. 200 sieve. The minimum liquid limit of these
soils will be 25 and the plasticity index will be 15 or greater. These soils will classifu as CL, SC
or CH materials under the Unified Soil Classification System.
2.3.3 Borrow Sources
Clay will be obtaned from suitable materials stockpiled on site during cell construction or will be
imported from borrow areas located in Section 16, T38S, R228, SLM.
2.4 Liner Construction
2.4.1 General
Placement of clay liner materials will be based on a schedule determined by the availability of
contaminated materials removed from the Mill decommissioning area in order to maintain
optimum moisture content of the clay liner prior to placing of contaminated materials
2.4.2 Placement and Compaction
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2.4.2.1 Methods
Placement of fill will be monitored by a qualified individual with the authority to stop work and
reject material being placed. The full 12 inches of the clay liner fill will be compacted to 95o
maximum dry density per ASTM D 698.
In all layers of the clay liner will be such that the liner will, as far as practicable, be free of
lenses, pockets, streaks or layers of material differing substantially in texture, gradation or
moisture content from the surrounding material. Oversized material will be controlled through
selective excavation of stockpiled material, observation of placement by a qualified individual
with authority to stop work and reject material being placed and by culling oversized material
from the fill.
If the moisture content of any layer of clay liner is outside of the Allowable Placement Moisture
Content specified in Table A-5.3.2.1-1, it will be moistened and/or reworked with a harrow,
scarifier, or other suitable equipment to a sufficient depth to provide relatively uniform moisture
content and a satisfactory bonding surface before the next succeeding layer of clay material is
placed. If the compacted surface of any layer of clay liner material is too wet, due to
precipitation, for proper compaction of the earthfill material to be placed thereon, it will be
reworked with harrow, scarifier or other suitable equipment to reduce the moisture content to the
required level shown in Table 4-5.3.2.1-1. It will then be recompacted to the earthfill
requirements.
No clay material will be placed when either the materials, or the underlying material, is frozen or
when ambient temperatures do not permit the placement or compaction of the materials to the
specified density, without developing frost lenses in the fill.
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2.4.2.2 Moisture and Density Control
As far as practicable, the materials will be brought to the proper moisture content before
placement, or moisture will be added to the material by sprinkling on the fill. Each layer of the
fill will be conditioned so that the moisture content is uniform throughout the layer prior to and
during compaction. The moisture content of the compacted liner material will be within the
limits of standard optimum moisture content as shown in Table A-5.3.2.1-1. Material that is too
dry or too wet to permit bonding of layers during compaction will be rejected and will be
reworked until the moisture content is within the specified limits. Reworking may include
removal, re-harrowing, reconditioning, rerolling, or combinations of these procedures.
Density control of compacted clay will be such that the compacted material represented by
samples having a dry density less than the values shown in Table A-5.3.2.1-l will be rejected.
Such rejected material will be reworked as necessary and rerolled until a dry density equal to or
greater than the percent of its standard Proctor maximum density shown in Table A-5.3.2.1-1.
To determine that the moisture content and dry density requirements of the compacted liner
material are being met, field and laboratory tests will be made at specified intervals taken from
the compacted fills as specified in Section 7.4, "Frequency of Quality Control Tests."
2.5 Sedimentation Basin
Cell 1 will then be breached and constructed as a sedimentation basin. All runoff from the Mill
area and immediately north of the cell will be routed into the sedimentation basin and will
discharge onto the natural ground via the channel located at the southwest corner of the basin.
The channel is designed to accommodate the PMF flood.
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A sedimentation basin will be constructed in Cell I as shown in Figure A-2.2.4-1. Grading will
be performed to promote drainage and proper functioning of the basin. The drainage channel out
of the sedimentation basin will be constructed to the lines and grades as shown.
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INSERT FIGURE A-2.2.4-I
SEDIMENTATION BASIN DETAILS
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MILL DECOMMISSTONTNG
The following subsections detail decommissioning plans for the Mill buildings and equipment;
the Mill site; and windblown contamination.
3.1 Mill
The uranium and vanadium processing areas of the Mill, including all equipment, structures and
support facilities, will be decommissioned and disposed of in tailings or buried on site as
appropriate. All equipment, including tankage and piping, agitation equipment, process control
instrumentation and switchgear, and contaminated structures will be cut up, removed and buried
in tailings prior to final cover placement. Concrete structures and foundations will be
demolished and removed or covered with soil as appropriate. These decommissioned areas
would include, but not be limited to the following:
Coarse ore bin and associated equipment, conveyors and structures.
Grind circuit including semi-autogeneous grind (SAG) Mill, screens, pumps and
cyclones.
The three preleach tanks to the east of the Mill building, including all tankage,
agitation equipment, pumps and piping.
The seven leach tanks inside the main Mill building, including all agitation
equipment, pumps and piping.
The counter-current decantation (CCD) circuit including all thickeners and
equipment, pumps and piping.
Uranium precipitation circuit, including all thickeners, pumps and piping.
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' The two yellow cake dryers and all mechanical and electrical support equipment,
including uranium packaging equipment.
' The clarifiers to the west of the Mill building including the preleach thickener
(PLT) and claricone.
' The boiler and all ancillary equipment and buildings.
' The entire vanadium precipitation, drying and fusion circuit.
' All extemal tankage not included in the previous list including reagent tanks for
the storage of acid, ammonia, kerosene, water, dry chemicals, etc. and the
vanadium oxidation circuit.
' The uranium and vanadium solvent extraction (SX) circuit including all SX and
reagent tankage, mixers and settlers, pumps and piping.
' The SX building.
' The Mill building.
' The Alternate Feed processing circuit
' Decontamination pads
' The office building.
' The shop and warehouse building.
' The sample plant building.
' The Reagent storage building.
The sequence of demolition would proceed so as to allow the maximum use of support areas of
the facility such as the office and shop areas. It is anticipated that all major structures and large
equipment will be demolished with the use of hydraulic shears. These will speed the process,
provide proper sizing of the materials to be placed in tailings, and reduce exposure to radiation
and other safety hazards during the demolition. Any uncontaminated or decontaminated
equipment to be considered for salvage will be released in accordance with the terms of License
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Condition 9.10. As with the equipment for disposal, any contaminated soils from the Mill area
will be disposed of in the tailings facilities in accordance with Section 4.0 of the Specifications.
Mill Site
Contaminated areas on the Mill site will be primarily superficial and include the ore storage area
and surface contamination of some roads. All ore and altemate feed materials will have been
previously removed from the ore stockpile area. All contaminated materials will be excavated
and be disposed in one of the tailings cells in accordance with Section 4.0 of these Plans and
Specifications. The depth of excavation will vary depending on the extent of contamination and
will be based on the criteria in Section 2.2.3 of these Plans and Specifications. All other 1 le.(2)
byproduct materials will be disposed of in the tailings cells.
All ancillary contaminated materials including pipelines will be removed and will be disposed of
by disposal in the tailing cells in accordance with Section 4.0 of these Plans and Specifications.
Disturbed areas will be covered, graded and vegetated as required. The proposed grading plan
for the Mill site and ancillary areas is shown on Figure A-3.2-1.
3.3 WindblownContamination
Windblown contamination is defined as Mill derived contaminants dispersed by the wind to
surrounding areas. The potential areas affected by windblown contamination will be surveyed
using scintillometers taking into account historical operational data from the Semi-annual
Effluent Reports and other guidance such as prevailing wind direction and historical background
data. Areas covered by the existing Mill facilities and ore storage pad, the tailings cells and
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adjacent stockpiles of random fill, clay and topsoil, will be excluded from the survey. Materials
from these areas will be removed in conjunction with final reclamation and decommissioning of
the Mill and tailings cells.
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Insert FIGURE 43.2-l
MILL SITE AND ORE PAD FINAL GRADING PLAN
3.3.1 Guidance
The necessity for remedial actions will be based upon an evaluation prepared by Denison, and
approved by the Executive Secretary, of the potential health hazard presented by any windblown
materials identified. The assessment will be based upon analysis of all pertinent radiometric and
past land use information and will consider the feasibility, cost-effectiveness, and environmental
impact of the proposed remedial activities and final land use. All methods utilized will be
consistent with the guidance contained in NUREG-5849: "Manual for Conducting Radiological
Surveys in Support of License Termination."
3.3.2 General Methodology
The facility cunently monitors soils for the presence of Ra-226, Th-230 and natural uranium,
such results being presented in the second semi-annual effluent report for each year. Guideline
values for these materials will be determined and will form the basis for the cleanup of the Mill
site and surrounding areas. For purposes of determining possible windblown contamination,
areas used for processing of uranium ores as well as the tailings and evaporative facilities will be
excluded from the initial scoping survey, due to their proximity to the uranium recovery
operations. Those areas include:
. The Mill building, including CCD, Pre-Leach Thickener areao uranium drying and
packaging, clarifying, and preleach.
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' The SX building, including reagent storage immediately to the east of the SX
building.
' The altemate feed circuit.
' The ore pad and ore feed areas.
' Tailings Cells No. 2, 3,4A, and 48.
' Evaporation Cell No. 1.
The remaining areas of the Mill will be divided up into two areas for purposes of windblown
determinations:
' The restricted area, less the above areas; and,
' A halo around the restricted area.
Areas within the restricted area, as shown on Figure 3.2-l will be initially surveyed on a 30 x 30
meter grid as described below in Section 3.3.3. The halo around the suspected area of
contamination will also be initially surveyed on a 50 x 50 meter grid using methodologies
described below in Section 3.3.3. Any areas which are found to have elevated activity levels will
be further evaluated as described in Sections 3.3.4 and 3.3.5. Initial surveys of the areas
surrounding the Mill and tailings area have indicated potential windblown contamination only to
the north and east of the Mill ore storage area, and to the southwest of Cell 3, as indicated on
Figure 3.2-1.
3.3.3 Scoping Survey
Areas contaminated through process activities or windblown contamination from the tailings
areas will be remediated to meet applicable cleanup criteria for Ra-226, Th-230 and natural
uranium. Contaminated areas will be remediated such that the residual radionuclides remaining
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on the site, that are distinguishable from background, will not result in a dose that is greater than
that which would result from the radium soil standard (5 pCi/gram above background).
Soil cleanup verification will be accomplished by use of several calibrated beta/gamma
instruments. Multiple instruments will be maintained and calibrated to ensure availability during
Remediation efforts.
Initial soil samples will be chemically analyzed to determine on-site correlation between the
gamma readings and the concentration of radium, thorium and uranium, in the samples. Samples
will be taken from areas known to be contaminated with only processed uranium materials (i.e.
tailings sand and windblown contamination) and areas in which it is suspected that unprocessed
uranium materials (i.e. ore pad and windblown areas downwind of the ore pad) are present. The
actual number of samples used will depend on the correlation of the results between gamma
readings and the Ra-226 concentration. A minimum of 35 samples of windblown tailings
material, and 15 samples of unprocessed ore materials is proposed. Adequate samples will be
taken to ensure that graphs can be developed to adequately project the linear regression lines and
the calculated upper and lower 95 percent confidence levels for each of the instruments. The 95
percent confidence limit will be used for the guideline value for correlation between garnma
readings and radium concentration. Because the unprocessed materials are expected to have
proportionally higher values of uranium in relation to the radium and thorium content, the
correlation to the beta/gamma readings are expected to be different than readings from areas
known to be contaminated with only processed materials. Areas expected to have contamination
from both processed and unprocessed materials will be evaluated on the more conservative
correlation, or will be cleaned to the radium standard which should ensure that the uranium is
removed.
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Radium concentration in the samples should range from25Yo of the guideline value (5 pCi/gram
above background) for the area of interest, through the anticipated upper range of radium
contamination. Background radium concentrations have been gathered over a 16 year period at
sample station BHV-3 located upwind and 5 miles west of the Mill. The radium background
concentration from this sampling is 0.93 pCi/gram. This value will be used as an interim value
for the background concentration. Prior to initiating cleanup of windblown contamination, a
systematic soil sampling program will be conducted in an area within 3 miles of the site, in
geologically similar areas with soil types and soil chemistry similar to the areas to be cleaned, to
determine the average background radium concentration, or concentrations, to be ultimately used
for the cleanup.
An initial scoping survey for windblown contamination will be conducted based on analysis of
all pertinent radiometric and past land use information. The survey will be conducted using
calibrated beta/gamma instruments on a 30 meter by 30 meter grid. Additional surveys will be
conducted in a halo, or buffer zone, around the projected impact area. The survey in the buffer
area will be conducted on a 50 meter by 50 meter grid. Grids where no readings exceed 75Yo of
the guideline value (5 pCi/gram above background) will be classified as unaffected, and will not
require remediation.
The survey will be conducted by walking a path within the grid as shown in Figure 4-3.3-1.
These paths will be designed so that a minimum of l0o/o of the area within the grid sidelines will
be scanned, using an average coverage area for the instrument of one (1) meter wide. The
instrument will be swung from side to side at an elevation of six (6) inches above ground level,
with the rate of coverage maintained within the recommended duration specified by the specific
instrument manufacturer. In no case will the scanning rate be greater than the rate of 0.5 meters
per second (m/sec) specified in NUREG/CR-5849 (NRC, 1992).
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3.3.4 Characterization and Remediation Control Surveys
After the entire subarea has been classified as affected or unaffected, the affected areas will be
further scanned to identiff areas of elevated activity requiring cleanup. Such areas will be
flagged and sufficient soils removed to, at a minimum, meet activity criteria. Following such
remediation, the area will be scanned again to ensure compliance with activity criteria. A
calibrated beta/gamma instrument capable of detecting activity levels of less than or equal to 25
percent of the guideline values will be used to scan all the areas of interest.
3.3.5 Final Survey
After removal of contamination, final surveys will be taken over remediated areas. Final surveys
will be calculated and documented within specific l0 meter by l0 meter grids with sample point
locations as shown in Figure A-3.3.2. Soil samples from l0%o of the surveyed grids will be
chemically analyzed to confirm the initial correlation factors utilized and confirm the success of
cleanup effort for radium, thorium and uranium. Ten (10) percent of the samples chemically
analyzed will be split, with a duplicate sent to an offsite laboratory. Spikes and blanks, equal in
number to 10 percent of the samples that are chemically analyzed, will be processed with the
samples.
3.3.6 Employee Health and Safety
Programs currently in place for monitoring of exposures to employees will remain in effect
throughout the time period during which tailings cell reclamation, Mill decommissioning and
clean up of windblown contamination are conducted. This will include personal monitoring
(frlm badges/TlD's) and the ongoing bioassay program. Access control will be maintained at
the Restricted Area boundary to ensure employees and equipment are released from the site in
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accordance with the current License conditions.
are expected and reclamation activities are not
the current levels.
3.3.7 Environment Monitoring
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In general, no changes to the existing programs
expected to increase exposure potential beyond
Existing environmental monitoring programs will continue during the time period in which
reclamation and decommissioning is conducted. This includes monitoring of surface and
groundwater, airbome particulates, radon, soils and vegetation, according to the existing License
conditions. In general, no changes to the existing programs are expected and reclamation
activities are not expected to increase exposure potential beyond the current levels.
3.3.8 Quality Assurance
At least six (6) months prior to beginning of decommission activities, a detailed Quality
Assurance Plan will be submitted for Executive Secretary approval. The Plan will be in
accordance with NRC Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring
Programs. In general, the Plan will detail Denison's organizational structure and responsibilities,
qualifications of personnel, operating procedures and instructions, record keeping and document
control, and quality control in the sampling procedure and outside laboratory. The Plan will
adopt the existing quality assurance/quality control procedures utilized in compliance with the
existing License.
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Insert Figure A3.3-1
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Insert Figure L3.3-2
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PLACEMENT METHODS
Scrap and Debris
The scrap and debris will have a maximum dimension of 20 feet and a maximum volume of 30
cubic feet. Scrap exceeding these limits will be reduced to within the acceptable limits by
breaking, cutting or other approved methods. Empty drums, tanks or other objects having a
hollow volume greater than five cubic feet will be reduced in volume by at least 70 percent. If
volume reduction is not feasible, openings will be made in the object to allow soils, tailings
and/or other approved materials to enter the object at the time of covering on the tailings cells.
The scrap, after having been reduced in dimension and volume, if required, will be placed on the
tailings cells as directed by the QC officer.
Any scrap placed will be spread across the top of the tailings cells to avoid nesting and to reduce
the volume of voids present in the disposed mass. Stockpiled soils, contaminated soils, tailings
and/or other approved materials will be placed over and into the scrap in sufficient amount to fill
the voids between the large pieces and the volume within the hollow pieces to form a coherent
mass. It is recognized that some voids will remain because of the scrap volume reduction
specified, and because of practical limitations of these procedures. Reasonable effort will be
made to fill the voids. The approval of the Site Manager or a designated representative will be
required for the use of materials other than stockpiled soils, contaminated soils or tailings for the
purpose of filling voids.
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Contaminated Soils and Raffinate Crystals
The various materials will not be concentrated in thick deposits on top of the tailings, but will be
spread over the working surface as much as possible to provide relatively uniform settlement and
consolidation characteristics of the cleanup materials.
4.3 CompactionRequirements
The scrap, contaminated soils and other materials for the first lift will be placed over the existing
tailings surface to a depth of up to four feet thick in a bridging lift to allow access for placing and
compacting equipment. The first lift will be compacted by the tracking of heavy equipment,
such as a Caterpillar D6 Dozer (or equivalent), at least four times prior to the placement of a
subsequent lift. Subsequent layers will not exceed two feet and will be compacted to the same
requirements.
During construction, the compaction requirements for the crystals will be reevaluated based on
field conditions and modified by the Site Manager or a designated representative, with the
agreement of the Executive Secretary.
The contaminated soils and other cleanup materials after the bridging lift will be compacted to at
least 80 percent of standard Proctor maximum density (ASTM D-698).
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RECLAMATION CAP - CELLS 1,2,3,4A AND 48
Earth Cover
A multi-layered earthen cover will be placed over tailings Cells 2,3, 4A and 48 and a portion of
Cell 1 used for disposal of contaminated materials (the Celll Tailings Area). The general
grading plan is shown on Drawing ,4.-5.1-1. Reclamation cover cross-sections are shown on
Drawings A-5.1-2 and 4-5.1-3.
5.2 Materials
5.2.1 Physical Properties
The physical properties of materials for use as cover soils will meet the following:
Random Fill (Platform Fill and Frost Barrier)
These materials will be mixtures of clayey sands and silts with random amounts of gravel and
rock size material. [n the initial bridging lift of the platform fill, rock sizes of up to 213 of the
thickness of the lift will be allowed. On all other random fill lifts, rock sizes will be limited to
213 of the lift thickness, with at least 30 percent of the material finer than 40 sieve. For that
portion passing the No. 40 sieve, these soils will classiff as CL, SC, MC or SM materials under
the Unified Soil Classification System. Oversized material will be controlled through selective
excavation at the stockpiles and through the utilization of a grader, bulldozer or backhoe to cull
oversize from the fill.
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Clay Layer Materials
Clays will have at least 40 percent passing the No. 200 sieve. The minimum liquid limit of these
soils will be 25 and the plasticity index will be l5 or greater. These soils will classifu as CL, SC
or CH materials under the Unified Soil Classification System.
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Insert A5.1-l
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Insert Figure A-5.1-2
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Insert FIGURE A-5.1-3
RECLAMATION COVER CROSS SECTIONS
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Insert Figure A-5.1-4
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5.2.2 Borrow Sources
The sources for soils for the cover materials are as follows:
l.Random Fill (Platform and Frost Barrier) - stockpiles from previous cell
construction activities currently located to the east and west of the tailing
facilities.
Clay - will be from suitable materials stockpiled on site during cell construction
or will be imported from borrow areas located in Section 16, T38S,R22F,, sLM.
3. Rock Armor - will be produced through screening of alluvial gravels located in
deposits I mile north of Blanding, utah; 7 miles north of the Mill site.
5.3 Cover Construction
5.3.1 General
Placement of cover materials will be based on a schedule determined by analysis of settlement
data, piezometer data and equipment mobility considerations. Settlement plates and piezometers
will be installed and monitored in accordance with Section 5.4 of these Plans and Specifications.
2.
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5.3.2 Placement and Compaction
5.3.2.1 Methods
Platform Fill
An initial lift of 3 to 4 feet of random fill will be placed over the tailings surface to form a stable
working platform for subsequent controlled fill placement. This initial lift will be placed by
pushing random fill material or contaminated materials across the tailings in increments, slowly
enough that_the underlying tailings are displaced as liule as possible. Compaction of the initial
lift will be limited to what the weight of the placement equipment provides. The maximum rock
size, as far as practicable, in the initial lift is 213 of the lift thickness. Placement of fill will be
monitored by a qualified individual with the authority to stop work and reject material being
placed. The top surface (top 1.0 feet) of the platform fill will be compacted to 90oZ maximum
dry density per ASTM D 698.
Frost Barrier Fill
Frost barrier fill will be placed above the clay cover in 12- inch lifts, with panicle size limited to
213 of the lift thickness. Frost barrier material will come from the excavation of random fi1l
stockpiles, If oversized material is observed during the excavation of fill material it will be
removed as far as practicable before it is placed in the fill.
In all layers of the cover the distribution and gradation of the materials throughout each fiIl layer
will be such that the f,rll will, as far as practicable, be free of lenses, pockets, streaks or layers of
material differing substantially in texture, gradation or moisture content from the surrounding
material. Nesting of oversized material will be controlled through selective excavation of
stockpiled material, observation of placement by a qualified individual with authority to stop
work and reject material being placed and by culling oversized material from the fill utilizing a
grader. Successive loads of material will be placed on the fill so as to produce the best practical
distribution of material.
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If the compacted surface of any layer of filI is too dry or smooth to bond properly with the layer
of material to be placed thereon, it will be moistened and/or reworked with a harrow, scarifier, or
other suitable equipment to a sufficient depth to provide relatively uniform moisture content and
a satisfactory bonding surface before the next succeeding layer of earthfill is placed. If the
compacted surface of any layer of earthfill in-place is too wet, due to precipitation, for proper
compaction of the earthfill material to be placed thereon, it will be reworked with harrow,
scarifier or other suitable equipment to reduce the moisture content to the required level shown
in Table 5.3.2.1-1. It will then be recompacted to the earthfill requirements.
No material will be placed when either the materials, or the underlying material, is frozen or
when ambient temperatures do not permit the placement or compaction of the materials to the
specified density, without developing frost lenses in the fill.
5.3.2.2 Moisture and Density Control
As far as practicable, the materials will be brought to the proper moisture content before
placement on tailings, or moisture will be added to the material by sprinkling on the earthfill.
Each layer of the fill will be conditioned so that the moisture content is uniform throughout the
layer prior to and during compaction. The moisture content of the compacted fill will be within
the limits of standard optimum moisture content as shown in Table 5.3.2.1-1. Material that is too
dry or too wet to permit bonding of layers during compaction will be rejected and will be
reworked until the moisture content is within the specified limits. Reworking may include
removal, re-harrowing, reconditioning, rerolling, or combinations of these procedures.
Density control of compacted soil will be such that the compacted material represented by
samples having a dry density less than the values shown in Table 5.3.2.1-l will be rejected.
Such rejected material will be reworked as necessary and rerolled until a dry density equal to or
greater than the percent of its standard Proctor maximum density shown in Table 5.3.2.1-1.
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To determine that the moisture content and dry density requirements of the compacted fill are
being met, field and laboratory tests will be made at specified intervals taken from the compacted
fills as specified in Section 7.4, "Frequency of Quality Control Tests."
Monitoring Cover Settlement
5.4.1 Temporary Settlement Plates
5.4.1.1General
Temporary settlement plates will be installed in the tailings Cells. At the time of cell closure, a
monitoring program will be proposed to the Executive Secretary. Data collected will be
analyzed and the reclamation techniques and schedule adjusted accordingly.
5.4.1.2 Installation
At the time of cell closure or during the placement of interim cover temporary settlement plates
will be installed. These temporary settlement plates will consist of a corrosion resistant steel
plate ll4 inch thick and two foot square to which a one inch diameter corrosion resistant monitor
pipe has been welded. The one inch monitor pipe will be surrounded by a three inch diameter
guard pipe which will not be attached to the base plate.
The installation will consist of leveling an areaon the existing surface of the tailings, and placing
the base plate directly on the tailings. A minimum three feet of initial soil or tailings cover will
be placed on the base plate for a minimum radial distance of five feet from the pipe.
5. 4. 1. 3 Monitoring Settlement Plates
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Monitoring of settlement plates will be in accordance with the program submitted to and
approved by the DRC. Settlement observations will be made in accordance with Quality Control
Procedure QC-l6-WM, "Monitoring of Temporary Settlement Plates."
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INSERT TABLE 5,3.2.1-I
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ROCK PROTECTION
General
The side slopes of the reclaimed cover will be protected by rock surfacing. Drawings 5.1-1, 5.1-
2, and 5.1-3 show the location of rock protection with the size, thickness and gradation
requirements for the various side slopes.
A riprap layer was designed for erosion protection of the tailings soil cover. According to NRC
guidance, the design must be adequate to protect the soil/tailings against exposure and erosion
for 200 to 1,000 years (NRC, 1990). Currently, there is no standard industry practice for
stabilizing tailings for 1,000 years. However, by treating the embankment slopes as wide
channels, the hydraulic design principles and practices associated with channel design were used
to design stable slopes that will not erode. Thus, a conservative design based on NRC guidelines
was developed. Engineering details and calculations are summarized in the Tailings Cover
Design report (Appendix D).
Riprap cover specifications for the top and side slopes were determined separately as the side
slopes are much steeper than the slope of the top of the cover. The size and thickness of the
riprap on the top of the cover was calculated using the Safety Factor Method (NUREG/CR-4651,
1987), while the Stephenson Method Q.{UREG/CR-4651 , 1987) was used for the side slopes.
These methodologies were chosen based on NRC recommendations (1990).
By the Safety Factor Method, riprap dimensions for the top slope were calculated in order to
achieve a slope "safety factor" of 1.1. For the top of the soil cover, with a slope of 0.2 percent,
the Safety Factor Method indicated a median diameter (D5e) riprap of 0.28 inches is required to
stabilize the top slope. However, this dimension must be modified based on the long-term
durability of the specific rock type to be used in construction. The suitability of rock to be used
as a protective cover has been assessed by laboratory tests to determine the physical
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characteristics of the rocks. The gravels sourced from pits located north of Blanding require an
oversizing factor of 9.35%. Therefore, riprap created from this source should have a D5s size of
at least 0.306 inches and should have an overall layer thickness of at least three inches on the top
of the cover. From a practical construction standpoint the minimum rock layer thickness may be
up to six (6) inches.
Riprap dimensions for the side slopes were calculated using Stephenson Method equations. The
side slopes of the cover are designed at 5H:lV. At this slope, Stephenson's Method indicated the
unmodified riprap D5s of 3.24 inches is required. Again assuming that the gravel from north of
Blanding will be used, the modified D56 size of the riprap should be at least 3.54 inches with an
overall layer thickness ofat least 8 inches.
Riprap bedding should be placed between the random fill and the riprap on the side slopes. The
bedding should consist of medium sand, and should be placed with a minimum layer thickness of
6 inches.
6.2 Materials
Slope Surface Bedding No. 40 Sieve
Materials utilized for riprap applications will meet the following specifications:
Droo Size
Slope Surface Riprap
Toe Apron Riprap ' 6.4" 'l 12"24"
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Riprap will be supplied to the project from gravel
Riprap will be a screened Product.
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sources located north of the project site.
Riprap quality will be evaluated by methods presented in NUREG1|623 Design of Erosion
protection for Long-Term Stabilization Size adjustment will be made in the riprap for materials
not meeting the quality criteria.
6.3 Placement
Riprap and bedding material will be hauled to the reclaimed surfaces and placed on the surfaces
using belly dump highway trucks and road graders. Riprap and bedding will be dumped by
trucks in windrows and the grader will spread the riprap in a manner to minimize segregation of
the material. Depth of placement will be controlled through the establishment of grade stakes
placed on a 200 x 200 foot grid on the top of the cells and by a 100 x 100 foot grid on the cell
slopes. physical checks of riprap and bedding depth will be accomplished through the use of
hand dug test pits at the center of each grid in addition to monitoring the depth indicated on the
grade stakes. placement of the riprap and bedding will avoid accumulation of riprap or bedding
sizes less than the minimum D56 size and nesting of the larger sized rock. The riprap and
bedding layer will be compacted by at least two passes by aD-7 Dozer (or equivalent) in order to
key the rock for stability.
QUALITY CONTROL/QUAL ITY ASSURANCE
Oualitv Plan
A euality Plan has been developed for construction activities at the Mill. The Quality Plan
includes the following:
1. QC/QA Definitions, Methodology and Activities.
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2.
J.
4.
5.
6.
7.2
Organizational Structure.
Surveys, Inspections, Sampling and Testing.
Changes and Corrective Actions.
Documentation Requirements.
Quality Control Procedures.
Implementation
The Quality Plan will be implemented upon initiation of reclamation work.
7.3 Ouality Control Procedures
Quality control procedures have been developed for reclamation and are presented in Attachment
B of this Reclamation Plan. Procedures will be used for all testing, sampling and inspection
functions.
7.4 Frequency of Ouality Control Tests
The frequency of the quality control tests for earthwork will be as follows:
1. The frequency of the field density and moisture tests will be not less than one test per
1,000 cubic yards (CY) of compacted contaminated material placed and one test per 500
CY of compacted random fill, radon barrier or frost barrier. A minimum of two tests will
be taken for each day that an applicable amount of fill is placed in excess of 150 CY. A
minimum of one test per lift and at least one test for every full shift of compaction
operations will be taken.
Field density/moisture tests will be performed utilizing a nuclear density gauge (ASTM
D-2922 density and ASTM D-3017 moisture content). Correlation tests will be
N:\Reclamation Plan\Reclamation Plan 3.2.a in progress 12. 17. l0\ATTACHMENT A rev3.2clean.docx
2.
Page A-38
Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
performed at a rate of one for every five nuclear gauge tests for compacted contaminated
materials (one_
per 2,500 CY placed) and one for every ten nuclear gauge tests for other compacted
materials (one per 5,000 CY of material placed). Correlation tests will be sand cone tests
(ASTM D-1556) for density determination and oven drying method (ASTM D-2216) for
moisture determination.
Gradation and classification testing will be performed at a minimum of one test per 2,000
CY of upper platform fill and frost barrier placed. A minimum of one test will be
performed for each 1,000 CY of radon barrier material placed. For all materials other
than random fill and contaminated materials, at least one gradation test will be run for
each day of significant material placement (in excess of 150 CY).
Atterberg limits will be determined on materials being placed as radon barrier. Radon
ba:rier material will be tested at a rate of at least once each day of significant material
placement (in excess of 150 CY). Samples should be randomly selected.
Prior to the start of field compaction operations, appropriate laboratory compaction
curves will be obtained for the range of materials to be placed. During construction, one
point Proctor tests will be performed at a frequency of one test per every five field
density tests (one test per 2,500 CY placed). Laboratory compaction curves (based on
complete Proctor tests) will be obtained at a frequency of approximately one for every l0
to 15 field density tests (one lab Proctor test per 5,000 CY to 7,500 CY placed),
depending on the variability of materials being placed.
For riprap and bedding materials, each load of material will be visually checked against
standard piles for gradation prior to transport to the tailings piles.
J.
4.
5.
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Page A-39
Revision 3.2.A
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Prior to delivery of any riprap materials to the site rock durability tests will be performed for
each gradation to be used. Test series for riprap durability will include specific gravity,
absorption, sodium soundness and LA abrasion. During construction
gradations will be performed for each type of riprap and bedding when approximately one-third
(1/3) and two-thirds (213) of the total volume of each type have been produced or delivered. In
addition, test series for rock durability will be performed on any riprap material at this same
time. For any type of riprap where the volume is greater than 30,000 CY, a test series and
gradations will be performed for each additional 10,000 CY of riprap produced or delivered.
N:\Reclamation Plan\Reclamation Plan 3.2.a in progress 12. I 7. l0\A'TTACHMENT A rev3.2clean.docx
ATTACHMENT G
CHANNEL, TOE APRON AND RIP RAP FILTER BLANKET
DESIGN CALCULTIONS
FOR
RECLAMATION
OF
WHITE MESA MILL FACILITIES
BLANDTNG, UTAH
PREPARED BY
DENTSON MrNES (USA) CORP.
lo5o 17'h srREET, SUITE 950
DENVER, COLORADO 80265
December 2010 Revision 3.2.A
ATTACHMENT 7 - RESPONSE TO NRC COMMENTS 7/17198
TABLE OF SIX-HOUR LOCAL PMP RAINFALL DEPTH VS DURATION FOR WHITE MESA MIL
6-Hour Storm Rainfall is 10 inches (ref: Hydrologic Design Report for White Mesa Mill, 1990)
6/1 Hr Ratio for WHITE MESA is 1.22 (Figure 4.7 and Table 4.4, HMR 49)
ONE-HOUR PMP IS.
97.0o/o or
8.20 inches at 5000 ft. elevation
7 95 inches at 5600 ft. elevation (1)
(based on Tabls 6.34, HMR 49)
0
0.25
0.5
0.75
1
2
3
4
5
6
0
74
89
95
100
111
116
119
121
122
0.00
6.07
7.30
7.79
8.20
9.10
9.51
9.75
9.92
10.00
0.00
5.88
7.08
7.55
7.95
8.83
9.22
9.46
9.62
9.70
Plot of data is adaptation of Figure 12 10, HMR 55A, to site rainfall.
(1) Average elevation of site in vicinity of base of cell 4Aeach tanks
TIME DISTRIBUTION OF FIRST ONE HOUR, OR THE ONE-HOUR PMP
(after Table 2.1, NUREG CR 4620)
0
2.5
5
10
15
20
30
45
60
0
0.04
0.08
0.17
0.25
0.33
0.50
0.75
100
0
27.5
45
62
74
82
89
o<
100
2.25
3.69
5.08
6.07
6.72
7.30
7.79
8.20
2.19
3.58
4.93
5.88
6.52
7.08
7.55
7.95
1
I
I
\
l
I
\
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I
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I
i
I
1
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EERq=fri=yft2oE
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=,EEg=
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ATTACHMENT 11 RESPONSES TO NRC COMMENTS 7/17198
RATIONAL METHOD CALCULATION OF PMF PEAK DISCHARGE, VELOCITY, ANO DEPTH TI,IROUGH CELL #1 DISCHARGE CHANNEL
ELEMENT
LENGTH
L
SURFACE
AREA
res
FLOW PAMMETERS IN CELL #1 DISCHARGE CHANNEL AT PEAK PMF DISCHARGE
Sedrock Channel
3edrock Channel
Channel
Botlom
widrh, b
ft
Channsl
Side
Slopes
Channel
Gradient, s
lu?,
Mannrng
Coefl
n
On/l.49's^.
Flow
Depth, y
ft
Crcss Seclion
Area of Flil
a,ft 2
Hydraulic
Radius
R. fi
a(R)^.67 v6locrty
fps
Allowable
P€ak
Volooty
fps
'coE 1970
'100
120
3:1
3:1
0.0100
0.0100
0.025
0.025
226
226
1.62
1.45
169.9
1 80.3
1.54
1.40
226.95
225.46
7.96
7.45
8-10
8-1 0
TTACHMENT 12 TABLE. RESPONSES TO NRC COMMENTS 7/17198
APRON DESIGN TABLE - TAILING CELL EROSION PROTECTION
MESA MILL
FLOW PATH ELEMENT
ELEMENT
LENGTH
L
ft
ELEMENT
wlDTH
ft
GRADiENI
S
ftt1r
ANGLE
degrees
tc
(minimum
E 0 042)
hou6
RAINFALL
W|THIN
tc
rnches
INTENSITY
m./hr
P6k
Unit
Dbcharge
q
cts/ft
d50
rnchs
APRON 10 001 0.57 0.60 729 12.07 180 7.3
]e top cover clement lrngrth 6 2450 ft. This ms used n the calculations for hme of concenvatton and peak uni dFcharge
le outsloPe element length 6 240 ft. ThE ms used in the Elculations for ilme ot concentEnon and peak unit dEcharge
1e d50 tor the outslope Hs calculated per Abt, S.R and Johnson, T L , "Rrprap Desrgn tor ove(optring F|il," ASCE Journal of HydEulic Engtnenng, 1991ledsofortheapron%scalculatedperAbl,S.R.,Johnson,T.L..Thomton.clandTcbant.Sc..'RipEpSizingatT@of EmbankmentSlops,.ASCEJoumal otHydEulEEngtneenng,Juty
EPTH OF SCOUR AT DOWNSTREAM EDGE OF TOE APRON
ll methods used are from Pemberlon, E-L., and J.M. Lara, 1984, "Compuling Degradalion and Local Scou/, Technical Guideline for Bureau of Reclamalion
s = deplh of scour, fl.
= unit discharge, cfs/fl
ethod 1 ds=K'q^o.2,
K = constant, 2.45
q = 1.81 cfsm
ds = 2.82 fl
ethod 2 ds = 0.25 dm
dm = mean waler deplh at design discharge
ds = 0.72 ft.
/llethod3 ds=0.6rdfo
dfo = q^0.666/Fbo^0.333
Fbo = zero bed factor = 1.0 fr/s^2 for fine sand
ds=0.09 fi
ds=0.25rdma
dma = unil cross section of flow = 0.87 fl
ds=0.22 fl
ds = dma'((Vmruc}.1)
Vm = mean velocity = 1.81/0.78 fps
Vc = 0.5 fps
ds=3.17 fl
SCOUR DEPTH =1.30 ft
depth of downstream edge scour barrier
a /2 .1,/ea C ; \ 16 00S\15268\Xts\RouFRON2 .x] s
@ rurwH TECHNICAL MEMORANDUM
TO: Doug Oliver
DATE: January 29,2010
FROM: Roslyn Stern
SUBJECT: Evaluation of need for filter layer on side slopes of Denison's White
Mesa Mill Tailings Cell Cover
DA'LD'T'A A 'EIIET UO',LD
The following evaluation was performed to evaluate the need for a filter layer under the
rock layer on the side slopes of the tailings cells cover for the White Mesa Mill.
Supporting assumptions, calculations, and discussion are provided following the
conclusions and recommendations.
Conclusions and Recommendations
The calculated interstitial velocities on the top slope and the toe apron are sufficiently
low that a bedding layer is not necessary. However, the interstitial velocity within the
erosion protection on the side slopes is within the range of values where bedding is
conditionally recommended. Because of the wide difference in grain size distribution
between the erosion protection and the random fill, it is recommended that a 6-inch layer
(for constructability) of bedding material be placed between these two materials. The
bedding material should be medium sand with the following specifications:
Sieve Size Percent Passing
3 inches 100
No.4 65-100
No.20 20-70No.200 0-5
The need for a rock layer on the sideslopes and underlying filter zone can be evaluated as
part of the detailed cover design. The rock layer on the sideslopes could be replaced with
a rock mulch (gravel-amended topsoii) that has the appropriate median size for erosion
protection. A rock mulch (gravel-amended topsoil) is being proposed for the cover
surface.
3665 JFK Parku;ay TEL [phone]
Suite 206 FAX [phone]
FortCollins,ColoradoB0525 www.mwhglobal.com
@ rurwu TECHNICAL MEMORANDUM
,A'LD'18 ' ,EITEE rOBLD
Supporting Documentation and Discussion
Problem Statement
Evaluate the need for bedding layer between cover soils and erosion protection material
Gock) by estimating interstitial pore velocities using method proposed by Abt et al.
(1991). This evaluation is being completed for the currently permitted rock cover design.
Assumptions
o Reclamation cover, as described in Section3.2.2 of the 2000 Reclamation Plan
(International Uranium Co.p, 2000) consists of six-foot soil cover. The cover
consists, from bottom to top, of a minimum of three feet of random fill (platform
fill), one foot of clay, and two feet of random fill (frost barrier).
o Cells 2 and3 will have final cover placed at a0.2 percent grade, with 5H:1V side
slopes (Section 3.2.2.3).
o Erosion protection on the top surface of the cover will be provided by placing a
minimum of 3 inches of riprap with a median diameter (D5e) of 0.3 inches
(Section 3.3.5) and a D16s of 0.6 inches (Section 6.2 of Attachment A - Plans and
Specifications). The overland flow velocity calculated for the top of the cover is
less than 2.0 ftlsec (Section 3.3.5).
Erosion protection of the side slopes of the cover will be provided by placing a
minimum of 8 inches of riprap with a D56 of 3.5 inches (Section 3.3.5) and a Dles
of 7 inches (Section 6.2 of Attachment A - Plans and Specifications). The
calculated flow velocity on the side slopes is 4.9 ff/sec (Section 3.3.5).
Erosion protection of the toe apron will be provided by placing riprap with a D5s
of 6.4 inches (Section 3.3.5) and a Dlse of l2 inches (Section 6.2 of Attachment
A - Plans and Specifications).
As described in Section 5.2 of Attachment A (Plans and Specifications), the
random fill used as platform fill and frost barrier protection is specified to have at
least 30 percent of the material finer than the number 40 sieve, with a Droo less
than 8 inches.
The peak unit discharge from the tailings cells is 1.8 cfs/ft (Attachment 12 to
Attachment G - Channel and Toe Apron Design Calculations)
3665 JFK Parkvray TEL [phone]a.10
Suite 206 FAX 970 3Zi 9406
FortCollins,Colorado80525 www.mwhglobal.com
@ rurwH
AA'LD'IG A AErTEE flONLD
TECHNICAL MEMORANDUM
Discussion
NUREG-1623, Apperdix D, recommends a filtff or bedding layer be placed under
erosion protection ifinterstitial velocities are greater than I ff/sec, in order to prevent
erosion of the underlying soils. Bedding is not required if interstitial velocities are less
than 0.5 ff/sec, and recommended depending on the characteristics of the underlying soil
if velocities are between 0.5 and 1 ft/sec.
lnterstitial velocities are calculated by procedures presented by Abt et al. (1991) as given
in the following equation. This method updates the Leps (1973) relationship that is
presented in NUREG/CR-4620 Q.Jelson et al. 1986):
v,=0.23(gxD,oxs)o'5
Where:
V; : interstitial velocities (ftls),
G: acceleration of gravity (ft1s2),
Dro : rock diameter at which 10 percent is finer (inches), and
S: gradient in decimal form.
The maximum D1s of the erosion protection is estimated based on D5s required for
erosion protection, assuming the erosion protection will have a coefficient of uniformity
(CU) of 6 and a band width of 5 . B and width refers to the ratio of the minimum and
maximum allowed particle sizes acceptable for any given percent finer designation.
USDA (1994) recorlmends CU to be a maximum of 6 in order to prevent gap-grading of
filters. Table 1 summarizes the results.
3665 JFil Paii:v;a,, TEL [phone]
Suite 206 FAX [phone]
FortCollins,Colorado80525 www.mwhglobal.com
able 1. Results of Beddine Requirernents
Location Top Cover Cover Side Slopes Toe Apron
Minimum D5s
(inches)
0.3 3.5 6.4
Maximum Dro
(inches)
0.35 t.24 3.73
Slooe (%)0.2 20 I
Interstitial Velocity
(fl/s)
0.03 0.65 0.25
,O'LD'IE ' DEI'iEI UODID
@ rurwn TECHNICAL MEMORANDUM
References
Abt, S.R., J.F. Rufl and R.J. Wilter (1991). Estimating Flow Through Riprap, Journal of
Hydraulic Engineering,v. ll7, No. 5, May.
Intemational Uranium (USA) Corp (2000). Reclamation Plan, White Mesa Mill,
Blanding, Utah, Revision 3.0, July.
Johnson, T.L. (2002). Design of Erosion Protection for Long-Term Stabilization,
NUREG-1623, U.S. Nuclear Regulatory Commission (NRC), February.
Nelson, J.D., S.R. Abt, R.L. Volpe, D. van Zyl, N.E. Hinkle, W.P. Staub (1986)
Methodologies for Evaluating Long-Term Stabilization Designs of Uranium Mill tailings
Impoundments, NUREGICR-4620, U.S. Nuclear Regulatory Commission (NRC), June.
U.S. Department of Agriculture (USDA) (1994). Gradation Design of Sand and Gravel
Filters, National Engineering Handbook, Part 633, Chapter 26, October.
3665 JFK Parkway TEL 970 377 S410
Suite 206 FAX [phone]
FortCollins, Colorado80525 www.mwhglobal.com
9.O.-
\-.-gp61p, 6.- g.
7.Or-
Denison Mines (USA) Corp.oEN'soJ)/
,YIINES
FIGURE A-5.1.4
Rock Apron at Base of Toe Cell Outslopes
RECI-AMATION PIAN REVISION 3.2.A