DRC-2005-001241 - 0901a06880a3d947

1
INrrnNemoNAL
UneNruu (use)
ConponeuoN
Independence Plaza Suite 950 o l0S0 Seventeenth Street o Denver, CO 80265.303 628 7798 (main) o 303 389 4125 (fax)
Jrme 17,2005
VIA FEDEX
Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake city, uT 841144810
Re: Draft Tailings Management System and Discharge Minimization Technolory
("DMT") PIan Under State of Utah Ground \ilater Discharge Permit No.
UW370004 (the "GWDP") for the White Mesa Uranium Mill '
Dear Mr. Finerfrock:
Enclosed please find a draft White Mesa Mill Tailings Management System and
Discharge Minimization Technology (DMT) Plan (the'?lan'), as required under Part
I.H.l3 ofthe GWDP, for your review and comment.
A number of the DMT requirements under the GWDP are already incorporated into the
Mill's existing Tailings Management System Monitoring PIan under the Mill's State of
Utah Radioactive Materials License No. UTI900479. That existing plan has been
modified and expanded to include the remaining DMT concepts required under the
GWDP. The Plan, as modified, is intended to continue to be a procedure under the
Radioactive Materials License.
If you have any questions or require any further information, please contact the
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undersigned.
Yours truly,
Vice President and General Counscl
Ron Hochstein
Harold Robens
T. Ken MiYoshi
Ron Berg
2
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July -, 2005
Revision: ruSA-2
Page I of27
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AI\D
DISCHARGE MINIMIZATION TECIINOLOGY (DMI")
MOMTORING PLAI\
I. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
;pi;,, for-the wh# Mesa Miu (tt r "Milr') provides procedures for monitoring ofthe tailings cell
;;; as required under State of Utah Radioactive Materials License No. UT1900479 (the
..Radioactive Materials License"), as well as procedures for operati"g Td lluntenance ofmonitoring
equipment and reporting procedures that are,adequate to demonstrate DMT compliance under State
oiUof, Ground ,fuater bisctr-ge Permit No. 37OOO4 for the Mill (the *GWDP')'
This plan is designed as a systematic program for constanl surveillance and documentation of the
;;dt;ithe taiings impoundment syJem including afte itauility, liner inrcgity, and transport
,vrrl-r, as well as rionitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The plan requires daily, ieekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management'
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
on a daily basis, including weekends, all areas connected with the four tailings cells will be
inrp"rt a.- Observationr *itt be made of the current condition of each cell, noting any corrective
action that needs to be taken'
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, excepr on weekends when the shift Foreman will perform ttre weekend tailings
i;$;rii"rr. rr,d Radiation Safety officer *.uy. d"r.,.flate other individuals wittr training, as
described in Section 2.4 below, to Perform the daily tailings inspection.
observations made by the inspector will be recorded on the Daily Inspection Dotafotm(a copy of
which is attached in Appendii e). m" a aily Inspection Data form contains an inspection checklisg
2.1.
Dratl Datc: Junc l7' 2005
White Mesa Mill- Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those r.quiring corrective action. The inspector will place a check by all inspection
items that appear to bL operating properly. Those items Jvhere conditions of potential concern are
observed should be marked with an uX'. A note should accompany the "X" speciffing what ttre
concern is and what corrective measures will resolve the problem. This observation of concem
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell l,2,3,and 4A, Dikes 1,2,3,4A-S, and 4A-W,
*iodn,or",,ent of tailings, effectiveness of dust minimization methods, spray evaporation, e,€lt2
,pill*"y, Cell 3 and 4A liquid pools and associated liquid return equipment, cell leak daection
systems, and the wildlife Ponds.
Operational features of the tailings area are checked for conditions of potential concem. The
fotto*irrg items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active' disposal cell(s), and poolreturn pipeline and pumps'
Daily inspections ofthe tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurrylines from CCD
to th. active tailings cell; SX raffrnate lines that can discharge into Cell I or Cell
3; the pond return line from the tailings area to the Mill; and, lines transporting
pond solutions from one cell to another'
i)
Itraff Darc: Junc 17,2fl)5
Cell l.
Cell2.
Cell3.
Cell4,A'.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 and Cell 4A liquid pools and associated liquid return
equipment.
presence of wildlife and/or domesticated animals in the tailings area' including
waterfowl and bunowing animal habitations.
Spray evaporation Pumps and lines.
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b)
c)
d)
e)
f)
s)
h)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, section 3.1, Appendix E
Revision: ruSA-2
Pryle3 of27
July -, 2005
i)
k)
r)
m)
n)
o)
p)
Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tuitirrgr inspectiorq general surface conditions witl be evaluated for
the following: l) areas of tailings subject to blowing and/or wind movement"2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if waranted, and will be used to direct dust
Observation of flow and operational status ofthe dust controVspray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells l, 3,
and 44.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily lnspection Data fotm
An estimate of flow for active tailings slurry and SX line(s)'
An estimate of flow in the solution return line(s).
Daily measurements in the leak detection system (LDS) sumps of the tailings
cels witt be made when warranted by changes in the solution level of the
respective leak ddection sYstem.
The trigger for further action when evaluating the measurements in any of the
leak deiection systems is a gain of more.than'12 inches in 24 hours. If this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
Whenever the leak detection system punp is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Coniition I I .3.8 througtr I I .3.E of the Mill's Radioactive Materials License, to
detemrine whether or not the flow rate into the leak detection systemis in excess
of the License Conditions.
DrrftDatc: Junc 17,2005
White Mesa Mill - Standard Operating Proccdures
Book I l: Environmental Protection Manual, section 3.1, Appendix E
July -, 2005
q) An estimate ofthe percentage of the tailings beach surface area and solutionpool
area is made, including estimates of solutions, oover areas, and tailings sands for
Cells 3 and 4A'
Items (a), (m), (n), and (o) are to be done only when the Mill is operating' when the Mll is down,
these items cannot be Performed'
2.2.Daily Operations InsPection
During Mill operation, the Shift Foreman, or other person with thetraining specified in Section 2.4
u.ro*,i"rignated by the Radiation safety officer, will perform an inspection ofthe tailings line and
oifing, u"i ^tl"asionce
per shift, P"Ing close attentiol for nopnlial lSks and to the {ischarges
fr;[" pipelines. observations by th" Lrp""tor will be recorded on the appropriate line on the
oi"rit"s i'orr*rr's Daily lrupeciionform
2.3. Dailv OPerations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above,a Mill employee will patnol
,il, "iiilg, area at least twice per shift during Mill operations to ensure that there ane no obvious
safety oriperational issues, ru"h * leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notifi the.Radiatioa Safety offiq
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred'
2.4. Trainine
All individuals performing inspections described in Sections 2.1 and 2.2 abouemusthave Tailings
Management System training-as s.et out in the Tailings lnspection Trainilq procedure, which is
"n".rrZa
as Apiendix B. 1liis training will include a training pack explaining the procedure for
p.rror*i"g th. inrp.rtion and addressing inspection items to be observed. In addition" each
individual, after revie*ing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. TailingsEmergencies
Inspectors will notiff the Radiation Safety Offrcer and/or Mill management immediately if, during
ir,.i, inrprrtion, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings "-.rg.n.y. Until relieved by the Environmental or Radiation Technician or
Radiation Sufrty Officer, inspectors will have the authority to direct resources during tailings
ernergencies.
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Draff Darc: Junc l?,2005
White Mesa Mill - Standard Operating Procodures
Book I I : Environmentat Protection Manual, section 3. I , Appendix E
Rcvision: ruSA-2
PqcS of27
July -, 2005
Any major catastrophic events or conditions pertaining !o the tailings area should be reported
immeaiately to the Naiu Na*uger or the Radiation safety officer, one ofwhom will notiff corporate
rrr*"g"-#. If dam failure occurs, notiff your supervisorand the Mill Manager immediately. The
rrrirr rft*"ger will then notiff corporate Managernent, MSHA (303-231-5465), and the state of
Utah, Division of Dam Safety (801-538-7200)'
3. WEEKLY TAILINGS AND DMT INSPECTION .
3.1. Weeklv Tailines Inspections
Weeklytailings inspections are to be conducted bythe Radiation SafetyDeparffient and includethe
following:
a) Leak Detection Slstems
' Each tailings cell's leak detection system shall be checked weeklyto determine
whether it iI wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leak detection system is measured by use of a
pipe ttrat is removed from the system which will indicate the presence of
solutions in the LDS system. Cell 4A has a blow tube, which has been meastFed
and marked. Once solutions have been identified by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasementandthemeasurements
are extracted from the marked tubing.
If suffrcient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be retuned to a
disPosal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered'by the elapsed time since fluid was las
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
insPection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accoidance with paragraph I 1.3 C. ofthe Radioastive Materials
License.
b) Slimes Drain Water Level Monitoring
DraftDar: Junc 17,2(X)5
Cell 3 is an active tailings cell while Cell 2 is partially reclaimed with
White Mesa Mill- Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.l, Appendix E
July _, 2005
approximately 90%o of the surface covered by platform fill. Each cell has a
siimes drain system which aids in dewatering the slimes and sands placed in the
cell. Depth to wastewater in the slimes drain access pipes shall be monitored and
recorded weekly to determine ma:rimum and minimum fluid head before and
after a pumping cycle, respectively. The slimes drains in Cells 2 and 3 are
checked for-defth to solution using the notched area on the center-line of the
access pipe as a reference point and measuring the distance to the wetted end of
the inserted pipe after it has been removed fiom the system. Because Cell 3 is
currently active, no pumping from the slimes drain is authorized. Cell2 has a
pump piaced inside of * u"".rs pipe and at the bottom ofthe slimes pool depth
approiimately one foot above the flexible membrane tiner (flar'): *I*
based on historical construction information, is the lowest point on the FML
found at or near the base ofthe slimes drain access Pipe for Cell2. This pump is
on a timed system, which maintains the liquid level at or near the punrp suction,
which is placed at the lowest point possible in the slimes drain access pipe. This
maintaini the water level as low as is reasonably achievable. The Cell 2 slimes
drain is pumped every fifteen minutes automatically and the pump is checked
weekly to observe that the pumP is operating
llind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed'
d) Tailings llastewater Pool Elevation Monitoring
Solution elevation measurements in Cells I and 3 are to be taken on a weekly
basis using survey equipment that is accurate to 0.1 inches.
e) Summary
In addition, the weeklyinspection should summarize all activities concerningthe
tailings area for that particular week'
Results of the weekly tailings inspection are recorded on the lAeeWy Tailings and DMT Inspection
form. An example of 15. WeeHy Tailings and DMT Inspectionform is provided in Appendix A.
On a weekly basis, solution elevations are to be taken on Roberts Pond. The meastrement is the
depth to soiution level in Roberts Pond offthe end of the pond pump support using a trarlsit and
,rfu"yirrg rod and a reference surveypoint. The Weekly solution level in Roberts Pond is recorded
Drafl Datc: Junc l?,2005
Revision: ruSA-2
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3.2.
White Mesa Mill - Standard Operating Procedurcs , -- -Book I l: Environmental Protection Manual, section 3.1, Appendix E
July -, 2005
on the WeeHy Tailings and DMT Inspectionform'
3.3. Weekly Feedstock Storaee Area lnspections
weekly feedstock storage area inspections will be performed by *r9 r1i$3ti9n f"Fny otpartnent, to
confirm that the bulk feJdstock materials are stored and maintained withinthe defined areadescribed
in the GWDP and that all altemate feedstock located qutside the defined Feedstock Area are
;"i"i"ii.a within water tight containers. The results of this inspection will.be recorded on the
WeeHy Mill Inspection foJ.. Any variance in stored materials from this requirement or observed
i;.k#g ;i;;aL feedstock drums or other containers will be brought to the attention of Mill
Management and promptly rectified'
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety officer or his designee from
the Radiation safetfoepartment and recorded on the Monthly Inspection Dataform, an exarnple of
which is contained in Appendix A. Monthly inspections are to be performed no soonerthan 14 dap
since the last monthly iuilingr inspection and can be conducted concurrently with the quarterly
i6ting, inspection *h"n applicablC. The following items are to be inspected:
a) Tailings Slurry PiPeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness *ill be measured using an ulnasonic device by
.i,t ri,t r iudiutio, safety staffor other trained designees. The critical points of the
pipe include bends, slope changes, valves, T9 jT"dons, which are critical to dike
,t"Uitity. These locations to be monitored will be determinedbythe Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches l, 2 and 3 shall be monitored monthly for sloughingo erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress'
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
d) OversPraY Dust Minimization
Revision: ruSA-2
Prye7 of27
Draff Datc: Junc 17,2fi)5
White Mesa Mill- Standard Operating Procedures
Book I l: Environmentat Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: ruSA-2
Page 8 of27
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning proPerly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediatelY shut-off.
e) Remarlts
A section is included on the Monthly Inspection Data formfor remarks in which
recorlmendations can be made or observations ofconcern can be documented.
l) Summary of Daily, lTeekly and Quarterly Inspections
The monthly inspection will also summarizc the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
tn addition, settlement monitors arc qpically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the RadiatiOn Safety Of,ficer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 daln since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operationsfl\,Iaintenance
Review, a Construction Review and a Summary, as follows:
a) Embanlonent lnsPection
The Embankment inspection involves a visual inspection of the ct€st, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exPosed liner.
b) Operations/Maintenance Review
The Operations/lvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings axea on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
Draft Datc: Junc 17,2005
White Mesa Mill - Standard Operating Procedures
Boof t l: Environmentat Protection Manual' Section 3'l' Appendix E
Juty -,
2005
modificationsmadetothetailingsareaonaquarterlybasis.
d) Summary
The summary will include all major activities or o6servatioN noted around the
tailings area on a quarterly basis'
If any of these conditions are noted, the conditions and corrective measunEs taken should be
documented in the euarterly Inspection iatafotrr. An example ofthe Quarterly Inspection Data
form is provided in APPendix A'
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (pE), who rr"."rp"ri"ri"e and tiarriog in *re area of geotechnical aspects of
retention strucflnes.
'The technical &aluation 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 urra ,r**ury ofthe annual movement monitor s,rvey (see section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ait t "r will be inspected to evaluate surface water control
sfuctures.
In the event tailings capacity evaluations (as per sop pBL-3) were performed for the receipt of
artemate feed materiar during the year, thr rupu"ity evaluation forms and associated calculation
sheets will be reviewed to .ir*. tt at ttre **irnr* 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'
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections'
These inspection records will be evaluatei-to deiermine if any freeboard limits are being
approached. Records wilr also be reviewed to summarize observations of potential concsrn. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety officer regarding acti;ities around the tailings area for the past year. During the
annual inspection, photographs ofthe tailirrg. *r" will be taken' The training ofindividuals will be
reviewed as a part bf tn.-n*ual Technical Evaluation.
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Draft D*c: Junc l?,2005
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual' Section 3'l ' Appendix E
Revision: ruSA-2
Page l0 of27
July -, 2005
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
;illi;;trincluded in the Annual Technical Evaluation Report'
The Annual rechnical Evaluation Report must be submitted by September l$ of everyyearto:
Directing Dam SafetY Engineer
State of Utatr, Natural Resources
1636 West North TemPle, Suite 220
Salt Lake CitY, Utah 841l6-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed:surveyor annually during the second
quarter of each year. The movement monitor rrrriy consists of surveying monitors along dikes 3-s,
4A-w, and 4A-s to d"i"ct any possible settlbmentor movement of the dikes. The data generated
from this survey is reviewed und irr"orporated into the Annual rechnicol Evaluation Report ofthe
tailings management system'
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January t0, 1990 Drainage Reportfor Cells I
and 4A and are stated below:
(i) A liquid marimum elevation of 5,615.4 feet mean sea level in Cell 1.
(ii) A liquid ma:rimum elevation of 5,596.4 feet mean sea level in Cell4A.
b) Tailings Cell 3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated duriry
the next 12 months will be made. This estimate is multiplied by l'5, a
factor of safety, to yield the Morimum Mill Production.
(iii) The Maximum Mill Production is divided by the number oftons required
IhafiDac: Junc 17,2005
White Mesa Mill - Standard Operating Procedus
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July -, 2005
Revision: ruSA-2
Pagc ll of27
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced Pool Area.
(iv) The PMP Flood Volume Requirement, as per the Januuy 10' 1990 *
Drainage Report, is 123.4 acre feet. " The PMP Flood volune
Requirernent is divided by the Reduced Pool Area to determine the PMP
Freeboard Level.
(v) The Wave Run Up of 0.78 feet (as specified in the Jarucy 10,'1990
Drainage Report)is added to the PMP Freeboard Irvel to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill Cental File.
c) Roberts Pond
The freeboard limit for Roberts Pond is a liquid morimurr elevation of 5,624.0
feet above mean sea level, as specified in the GWDP'
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition ll.3.C. Ttre iesults of the analysis will be reviewed to determine the origin of the
solution.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations shouldbeperformed as
sfecifiea in Seciions 2,3,'4,' s and 6 above. However, additional inspections should be conducted
uh", urry significant storm or significant natural or man-made event occurs'
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthlylnspection Data and
euarterly Inspection'Dati forms included as Appendix A and described in Sections 2,3,4 and 5
,irp".tir"ry,;d the operating Foreman's Daily Inspection and WeeHy Mill lrupectlon forms
described in Sections 2 and3, rlspectively, the following additional reports shall also be prepared:
8.1. Monthlv Tailines Reoorts
Draff Datc: Junc 17, 2fl)5
White Mesa Mill - Standard Operating Procedures
Book I l: Environmentai Protection Manual' Section 3'l ' Appendix E
July -, 2005
Monthly tailings reports are prepared every month and_summariz.ethe previous monthrs activities
around the tailings area. Ii not prrp*"i by the Radiation safety officer, the report shall be
submitted to the Radiation Safety bffi"rr for review. The Mill Manager will review the report as
well before th" ,.port is filed in ttre Mill central File. The report will contain a summary of
observation, of "on".,,l noted on the daily and wegklltailings inspections. corrective m€asures
taken during the month will be docurnentea dorrg wittrthg observations where appropriate. All daily
and weekly tailings
-i-nrp".,io,
forms will be afia;hed to the report. A monthly inspection form will
also be attached. a.;";t;rpection forms will accompany the reporr when applicable. The repon
will be signed and dated Ly the preparer in addition tothe Radiation Safety officer and the Mill
Manager.
8.2. DMT Reoorts
euarterly reports of DMT monitoring activities of all required information required by Part 1'F'2 of
the GWDp relating to the inspecti6ns described in slction 3.ro) (stimes Drain water Irvel
Monitoring), 3.1(d) (Tailings wastewater Pool Elevation Monitoring), 3'2 (Weekly lnspection of
solution Levels in li;;r-pond) and 3.3 (weekly Feedsock Storage Area Inspections) will be
provided to the Executive secretary on the schedule provided in Table 5 of the GWDP'
Revision: ruSA-2
Page 12 of27
Draff Dalc: Juoc 17,2005
White Mesa Mill - Stirndard Operating Proccdurci
tsook I l: Environmental Protection Manuat, Section 3'l' Appendix E
July-,2005
APPENDD( A
FORMS
Rcvision: ruSA-2
Page 13 of27
Draff Duc: Junc 17' 2005
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TATUII{GS SLURRY OISCHANGE LOCATIOII
DITE:
TTISPECTOR:
IIILL
AREA
I
N
I
White Mesa Mill - Standard Operating Procedures Revision: ruSA-2
Book I l: Environmental prorection Manual, Section 3.1, Appendix E Page lE of27
July -, 2005
APPENDD( A (CON[)
TNTERNATIONAL URANIUM (USA) CORPORATION
WEEKLY TAILINGS INSPECTION
Date:Inspectors:
l. Pond elevations (mst,ft) Cell l:
Cell3:
2. Slimes Drain Liquid Levels
Roberts Pond:
Cell l:
Cell3:
Cell4.A:
4. Tailings Area Inspection (Note dispersal of blowing tailings):
CellZ: Pohms
Feet to Liquid
Gallons Pumped
Beginning Level
Ending Level
Gallons Pumped
3. I-eak Detection SYstems
Observation:
Cell I Cell2 Cell3 Cell44
wet dry wet drv wet dryls I-PS wet or dry?wet dry
If wet, Record
liouid level:
_Ft to
Liquid
Ft to
Liouid
' Ftto
Liouid
Ft to
Liouid
lf sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate-
Volume
Flow Rate .
Volume
Flow Rate-
Volume
Flow Rate-
Was fluid samPle
collected?
ves no ves no
-
yes no ves no
5. Control Matrods ImPlemented:
DraffDarc: Junc 17,2005
White Mesa MiU - Standard Opcrating Procodurcs'
g; r l: Environmentat Protection Manual, Scction 3.1, Appendix E
July-,2005
Rcvisim: IUSA-2
Pagelg ofTl
6.
7.Contaminated Waste DumP:
8
.,1=
n./r{rr ( /r *'1
Drafl Drr: Jurr 17' 2fl)5
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual' Section 3'l' Appendix E
July -, 2005
Revision: ruSA-2
Pagc 20 of27
APPEI\IDD( A (CONT.)
MONTELY INSPECTION DATA
Inspector:
Date:
1. Slurra PiPeline:
en the Mill is oPerating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Diversion Ditch I
ves no
ves no
ves no
ves no
Diversion Ditch 2
ves noves no
. ves no
ves no
Diversion Ditch 3 Diversion Berm 2
ves noves noves no
-ves no
ves no
]€s-no
Comments:
3. Summary of Activities Around Sedimentation Pond:
Draft Datc: Junc 17,2005
White Mesa Mill- Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3'l' Appendix E
July -, 2005
4. OversPraY Dust Minimization:
Overspray sJstem functionirrg properly: Yes'
overspray carried more than 50 feet from the cell: ],es+no' Ii"yes", was system immediately shut ofl ves-no
Revision: IUSA-2
Page2l of27
Comments:
5. Remarks:
6. Settlement Monitors
Cell2 W2:
Cell2 W3:
Cell2 W4:
Cell2WT-C:Cell4A-Toe: ,
Cell2W3-S:
Cell2El-N:
Cell2El-lSt
-
Cell2El-2S:
Cell2 East:
Cell3-lN:
Cell3-lC:
Cell3-lS:
Cell3-2N:
Cell2W5-Ni
-
1. Summary of Daily, Weekly and Quarterly Inspections:
DrrftDatc: Junc 17,2fi)5
White Mesa Mill - Standard Operating Procedures Revision: ruSA'
Book I l: Environm"J pro,*ion lrianual, Section 3.1, Appendix E Page2? of 27
July -, 2005
APPENDD( A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
I)ate:
8. Embankment InsPection:
g. OperationsMaintenance Review:
10. Construction Activites:
11. Summary:
DraffDalc: June 17'2005
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3'l' Appendix E
July -,
2005
Revision: ruSA-2
Pagc23 of27
APPENDIX B
TAILINGS
"VSPE
CTOR TRAINING
This document provides the training necessary for qualifiing management-designated T.d'I44t^f'I
conducting daily. tailingr iitpt"iolo. fruirring information is presented by the Radiation Safety
officer or designee from ttre Environmental oepartment. Dailytailings inspections are conducted in
accordance with til white Mesa Mill Tailingr M*ug"ment System and Discharge Minimization
Technology (DMT) Monitoring plan. The Ridiation sur.ty o.ffrcer or designee from the Radiation
,safety Departrnent is responsible for performing monthly and quarterly tailings inspections' T3iltnps
inspection forms will be included in the roorthly tailings inspection reports, which summarize the
"oriaitiorrr,
activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether a[ inspection ilems are normar (satisfactory, requiring no
"",l"iil, oat condiiions of potential concern exiit (requiring action). A "check" mark indicates no
action required. r.onJitions of potential concern exist the inspector should mark an "x' in the area
the condition pertains to, note tire condition, and speciff the corrective actiori to be taken. If an
observabre concern is made, it should be noied on th. tailings report "ptJth" corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well'
rnhio events or con o the tailings area should be reportedAny major catastrophic events or conditions pertai-ni"g- 9 i: T]':I:*T3..
immediately to the Naiil r,1*uger or the Radiation safety officer, one of,whom will notiff corporate
Management. If dam failure occurs, notiffyour supervisorand the Mill Manager immediately' The
Mill Manager will then notify corporate Management, MSHA (303-231-5465), and the state of
Utah, Division of Dam Safety (801-538-7200)'
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily t"riinE, inspection form. Refer to Appendix A for an exampre of the daily tailings
inrfr.tion form. rt.Inrp..tion form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp b:le' The pipelinejoints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
DraflDalc: Junc 17' 2fi)5
White Mesa Mill - Standard Operating Procedurcs
g;k f f t Environmentat ProtEction Manual' Section 3't' Appendix E
July --, 2005
inspected for danrage and loss of support. v_alyes are also to be inspected particurarly for
leaks, blocked valJes, and closed ,ulr.t. Points of discharge need to be inspected for
improper location and orientation'
2. OPerational SYstems:
operating systems including water levels, beach liners, and covered areas.are {ems.to P
inspected anJ noted on thi daily inspection forms. Sudden changes in water levels
previously observed or water levis exceeding the operating level of a pond are potential
areas of concem and should be noted. Beach areas that are observed as having cracks, leverc
erosion ", ;il; are also items that require investigation and notation on-daily P*:
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered -;.-il;;riJa also be noted on the daily inspection form-
Cells l, 3 and 4A solution levels are to be monitored closely for conditions nearing
ma:<imum "p.i iiiirr.i*ra for large changes in.the water level since the last inspection'
All pumping activities affgcting ttre iater level will be documented. In Cells 1 and 3, the
pVC liner needs to be monitorej closely for exposed liner, especially after storm events' It is
important to ,or", exposed liner immediut"ly as exposure to sunlight will cause degradation
ofthe pVC liner. Small areas of exposed linir should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. Afterthese conditions
have been noted to the Radiation safety officer, a work order will be written by the
Radiation srfrt officer and tumed into-the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of ttre repairs'
3. Dikes and Embankments:
Inspection items include the slopes and the.crests of each dike' For slopes' areas of concem
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas' and areas of
seepage outbreak. For crests, areas ofconcern are cracks, subsidence, and severe erosion'
when any ofthese conditions are noted, an "X" mark should be placed inthe sectionmarked
for that dike.
tn addition, the dikes, in particular dikes 3, 4A-s and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in a..f, possibly io the liner. Iiany of these conditions exist, the inspection report
should be marked accordinglY'
Revision: ruSA-2
Page24 of27
X'low Rates:
Drafi Datc: Junc 17,2{X)5
White Mesa Mill- Standard Operating Procedures
Book I l: Environrnental Protection Manual, section 3.1, Appendix E
July -, 2005
Revision: ruSA-2
Prye2l of27
presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GpM). Rates need to be determined for slurry lines, pond return, sX-
taiis, and tire spray ,yrt.*. During non-operatfpnal modes, the flow rate coltrmn should be
marked as *O'i Tt.-.u*. holds true whqr the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines hasto-be lade every 4hours during operation ofthe
,oitt.- If possible, the inspection ihould include obserrration of the entire discharge line and
discharge spill point into the bell. If "fill to elevation" flags are in place, the tailings and
U"ifa-"[ is io Ue monitored and controlled so as to not cover the flags
.6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A' Other
observations to be noted include a brief description of present weather conditions, and a
record of uny frecipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings'
The Radiation Safety Deparrment measures precipitation -o-1
a daily basis. Daill
measluements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken'
7. Obserryations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of "orcrrn noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8. NlaP of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where aPPlicable.
l. Cover area
2. Beacl/tailing sands area
3. Solution as it exists
4. PumP lines
Drafi Darc: Junc 17' 2005
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, section 3.1, Appendix E
July -, 2005
Revision: ruSA-2
Page26 of27
5.
6.
7.
Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
Slurry discharge when oPerating
Over spray system when oPerating
9. SafetY Rules:
All safety rules applicable to the mill are applicable when in the tailings area These rules
meet the requiredMSHA regulations for the tailings area. Please pay particular notice to the
following rules:
l. The posted speed limit for the tailings area is l5 mph and should not be exceeded.
2. No food or drink is permitted in the area'
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at anytime'
5. Only those specifically authorized may operate motor vehicles in the resticted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
Any work performed in which there is a danger of falling or slipping in the cell will
ffiir" rhe use of a safety belt or harness with attended life line and an approved life
ja&et. A portable eyewash must be present.on site as well.
Lyi*" ttre boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be.present on site as well'
Preserryation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
uilings area. Alt wildlife observed should be reported on the Wildlife Report Worksheet
J".inE each shift. Waterfowl seen near the tailings cells should be discouraged fiom landing
by the use of noisemakers.
Certilication:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perforrr daily tailings
inspections. ft. Ruaiutlon Safety Officer authorizes certification. Referto the Certification
Foim, Appendix C. This form should be signed and dated only after a thoroughreview ofthe
tailinis information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
7.
8.
r0.
11.
Drafl Darc: Junc 17,2005
White Mesa Mill- Standard Operating Procedures
Book I l: Environmental Protection Manual' Section 3'l' Appendix E
July --, 2005
Revision: ruSA-2
Page27 of27
I have read the document titled "Tailings Manag"*""l System' White Mesa Mill Tailings
ilil;i;;ing" *a have received in-site iistruction at the tailings system. This instnrction
included document tion orauity tailings inspections, analysis of potential problems (dike
ffi;, trnusual flows), notification procedures and safety'
APPENDX C
CERTIFICATION FORM
Date:
Name:
Signattue
I certiff that the above-named person is quarified to perform the daily inspection of the tailings
system at the White Mesa Mill'
Supervisor
DrEi Dttc: Junc 17,2005
ffiF
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
,o* r. f.MAN, JR.'Govemor
GARYHERBERT
Lieutenant Govemor
o,
Harold Roberts
International Uranium (IUSA) Colporation
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Subject: Roberts Pond As-Built Report Dated June 10, 2005, Groundwater Permit No.
UGW370004: Request for Additional Information
Dear Mr. Roberts,
On November 16, 2005 we had a telephone discussion about the Roberts Pond as-built report and
drawings that have been submitted. In the discussion, you agreed to send me some photos of the
pond works the next time you visited the mill site in early December. What is the status of the
photos?
If you have any questions or comments, please contact me at [phone].re
'Johnathan P. Cook, P.E.
Environmental Engineer
DF/JPC: jc
F:\FACILITIES\IUC - WHffE MESA\Ore Mill Building\Roberts PondU005-12-29l-etter -rob pond asbuilt - final.doc
File: IUC.05.04
December 29,2005
168 North 1950 West. PO Box lzl4850 . Salt Lake City, UT 841 14-4850 . phone [phone] . fax [phone]
T.D.D. (801) 5364414. www.deq.unh gov
. HUNTSMAN, JR
Govemor
GARY HERBERT
Lieutenant Govemor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
TO:
FROM:
DATE:
SUBJECT:
MEMORANDUM
John Cook ,
Dean Henderson [)rl+
December 28,2005
Discharge Minimization Technology (DMT) Monitoring Plan
Ground Water Discharge Permit (Permit)
International Uranium Corporation (IUC)
White Mesa Mill, Blanding, Utah
I have reviewed the ruC DMT Monitoring Plan submitted on June 17, 2005. I found that
the DMT Monitoring Plan did not address and needs to include the following as required in
Part I.H.l3.g) of the Permit:
Part I.D.3.a) DMT Monitoring Wells at Tailings Cell I -at all times the Permittee
shall operate and maintain Tailings Cell I to prevent groundwater quality conditions
in any nearby monitoring well from exceeding any Ground Water Compliance Limit
established in Table 2 of this Permit.
Part I.D.3.b).3) DMT Monitoring Wells - at all times the Permittee shall operate and
maintain Tailings Cells 2 and 3 to prevent groundwater quality conditions in any
nearby monitoring well from exceeding any Ground Water Compliance Limit
established in Table 2 of this Permit.
168 North 1950 West. PO Box 144850. Salt Lake City, UT 841 14-4850. phone [phone]. fax [phone]'7
T.D.D. (801 ) 5364414 . www.deq. utah. gov