DRC-2006-001221 - 0901a068808550e9

Co-ExecutiveBecretary
Utah Water Quality Board
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Permit No. UGW370004
STATE OF UTAH
DMISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALITY BOARD
SALT LAKE CMY, LITAH 84114-4870
GROUND WATER DISCHARGE PERMIT
In corapliancc with the piovisions of the Utah Water Quality Act, Title 19, Chapter -5, Utah Code
Annotated 1953, as amended, the Act,
International Uranium OSA) Corporation
Independence Plaza, Suite 950
1050 17th Street
Denver, Colorado 80265
is granted a ground water discharge permit for the operation of a uranium milling and tailings
disposal facility located approximately 6 miles south of Blanding, Utah. The facility is located
on a tract of land in Sections 28,29,32, and 33, fownship 37 South, Range 22Bas,t, Salt I.ake
Base and Meridian, San Juan County, Utah.
The permit is based on representations made by the Permittee and other information contained in
the administrative record. It is the responsibility of the Permittee to read and understand all
provisions of this permit.
The milling and tailings disposal facility shall be operated and revised in accordance with
conditions set forth in the permit and the Utah Ground Water Quality Protection Regulations.
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This permit shall become ettect;ue 7t*nl I%IQL
This permit shall expire MA&!._E-.2OlQ.
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Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS ............ ........... 1A. GnouNnWArERCressrrcerroN............... .................. 1B. BacrcnoulroWnrsnQuelrrv... ............... 1C. Penrwr Lnnrs .........21. Ground Water Compliance Limits.... ......22. Tailings Cell Operations........... ..............23. Prohibited Discharges ...........2D. DscruncB Mn'uvuzeuoN Tecm{orocy SreNoARD........... .......... g
1. DMT Design Standards for Existing Tailings Cells 2, and 3......... ............... g2. Existing Tailings Cell Construction Authorized ..... 103. Existing Facility DMT Performance Standards................ ........ 104. Best Available Technology Requirements for New Construction................................ 115. Definition of 11e.(2) Wasre ..................126. Closed Cell Performance Requirements .................127. Facility Reclamation Requirements........... ..-..........128. Stormwater Management and Spill Control Requirements.......... ..............12E. Gnoulto Weren CotwrnNcE AND Tecrworocy PBnronuaNcn Mowrronnqc............. 131. Routine Groundwater Compliance Monitoring............... ......... 132. Groundwater Head Monitoring .............143. Groundwater Monitoring:Well Design and Construction Criteria................................ 144. Monitoring Procedures for Wells.. ........ 145. White Mesa Seep and Spring Monitoring ............... 156. DMT Performance Standard Monitoring ................ 157. On-site Chemicals Inventory.. ............... 168. Tailings Cell Wastewater Quality Monitoring ........ 16F. RpponrnrcRrqum.nunNTs........... ............ 161. Routine Groundwater Monitoring Reports ............. 162. Routine DMT Performance Standard Monitoring Reports..... .................... 173. DMT Performance Upset Reports..... ....174. Other Information .""............175. Groundwater Monitoring Well As-Built Reports ..................... 176. White Mesa Seep and Spring Monitoring Reporrs ................... lg7. Chemicals Inventory Report ................. 1g8. Tailings Cell Wastewater Quality Reports..... ......... lg9. Revised Hydrogeologic Report ............. 1gG. OurorCorwrreNcEsrATus.. .................. 1g1. Accelerated Monitoring Status........ ...... lg2. Violation of Permit Limits .................... 193. Failure to Maintain DMT Required by Permit.. ....". 194. Facility Out of Compliance Status ........205. Accelerated Monitoring Status for New Wells .......20H. CorprmNcE ScrGDUr-E Rrqummmlrrs. .............. .....2O1. Installation of New Groundwater Monitoring Wells ....."..........202. Revised Hydrogeologic Report .............213. Background Ground Water Quality Report: Existing We11s........ ."..."........214. Background Groundwater Quality Report: New Monitoring wells ..".......225. Tailings Cells Wastewater Quality Sampling P1an.......... "........236. Monitoring Well Remedial Construction and Repair Work Plan and Report ........."....23
7 . Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report....... ......".....24
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8. white Mesa Seeps and Springs Sampling work plan and Report....... .......249. On-site Chemicals Inventory Report...... .................2410. Infiltration and Contaminant Transport Modeling Work Plan and Report...... .........2511. Plan forEvaluation of Deep SupplyWell WW-2............... ....................2612. DMT Monitoring P1an......... .............2613. Tailings cell 4A contaminant Removar Schedule and Report ..............2614. Tailings Cell 4A Redesign and Reconstruction ....................2715. Contingency Plan ............2716. Stormwater Best Management Practices plan ......... .............2717. Roberts Pond As-Built Report ..........2g18. Tetrahydrofuran Demonstration Study work plan and Report....... ........2g
PART tr. REPORTING REQUIREMENTS.... ....2gA. RgpREssNterrvE SAIvIpLtr{c ..-.2gB. ANaryucer h.ocrounBs. .............. .........2gC. PSNALTmS ponTalvppnwc............... ........2gD. RsponrhrcorMoxrronwcRBsu_rs .......2gE. CorwueNcs Scrmourns ............... ...........2gF. ApomoNar Moxrronnqc By rr{E psRr[rrEE ............29G. Rrconns Con'rnr.rrs. ...............2gH. Rrrexrrox orRrconos................ ............2gI. NoucrorNoNcorwrreNcpReponrtrrc............... .....30J. Ornen NoNcotwueNcr Rsponrnlc............... ........... 30K. INsprcrroNANDENTRy ...........30
PART m. COMPLIANCE RESPONSIBILITIES........... ...... 31A. Dury ro Corwry .................... 31B. PrNerrmsroRVrorerroNsorprnrwrCouprrroNs............... .....31C. NrroroHerroRRBoucpAcmrrryNoreDrrnNsE............. ..... 3lD. DuryroMrucers ..................31E. Pnoprn OprnenoN eNp MenrrENANCE....... .............. 3l
PART ry. GENERAL REQUIRErVIENTS.......... ..................32A. PremNrpCueNcns .................32B. Avncperrp NoNcorwtreNcE................ ...................32C. PsRN[rAcnoNs.... ..................32D. DuryroRreppry............... ....32E. Dury ro PRovns IuronuauoN ............ ....................32F. Orrmn lNronuauoN............. ....................32G. SrcNerony Rlqum.nvmNTs ........... ...........32H. PeNerrres ron FersrrcATroN orReponrs............... ................... 33I. Av^q,nesLrry opRppoRrs................ ........ 33J. PRopnnryRrcHrs ...................33K. SrvnRannrry ........33L. TneNsrnns ............33M. Srerel.ews ..........34N. RsopnNEn Pnovrs1oNs................ ..............34
List of Tables
Table 1. Ground Water Classification ........... ......... I
Table 2. Groundwater Compliance Limits............... ................3
Table 3. DMT Engineering Design and Specifications ........... g
Table 4. Feedstock Storage Area Coordinates ......... .............. 1l
Table 5. Groundwater Monitoring Repoting Schedule... ...... 16
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Part I
permit No. UGW370004
PAR.T I. SPECIFIC PERMIT CONDITIONS
A. GnornnWarrn ClessmcerloN - the ground water classification of the shallow aquifer
under the tailings facility has been determined on a well-by-well basis, as defined in Table l,
below:
l) Based on historic total dissolved solids (TDS) rlata provided by IUC forperiod between October, 1979 and May, 1999. Average
concentrations calculated by Utah Division of Radiatim Control (DRC) saff in a November 29, 1999 memorandum.
2) Based on average ofDRC split sarnples collecEd from the IUC facility benrecn May, 1999 and Septcmber, 2002.
3) Number of IUC or DRC samples used in the evaluation of average TDS concentsations.
4) Classificatioa of IUC well MW-19 based on the conservatively lower IUC data.
5) Welts MW-20.and MW-22 are not poiot of compliance monitoring wells, but instead are groundwater head monito,ring wells as per part I.8.2.6) Well MW-26 was originally named TW4-15 and was insalled as a part of a recent chloroform contaminant investigation at the facility. Under
this Permit, MW-26 is defined as a Point of Compliance (POC) well for the ailings cells (see Pan I.E.l) .
7) well Tw4-16'was installed as a part of a recent chlorofomr investigation at the facility, and has been included in the permit as groundwater
headmonitoringwe[(PartLE.2). GroundwaterclassificationprovidedherebasedonaverageofboththelUCandDRCdaa(2samples).
8) Well MW-32 was originally named ?xN+17 and was installed as a part of a rccetrt chlorofonn contaminant investigation at rhe facitity. Underftis Permit it is included as a PIOC well for the railings cells in part I.E.l.
B. Becrcno{rND WersR Quarrrv - background groundwater quality will be determined on a
well-by-well basis, as defined by the mean plus second standard deviation concentration.
AfterExecutive Secretary approval of the Background Groundwater Quality Reports required
by Part I.H.3 and 4, this permit will be re-opened and Table 2 revised to define background
concentrations and groundwater compliance limits for all required contaminants.
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Table l. Ground Water Classification
Class II Groundwater Class III Groundwater
Well ID Averase TDS (meA)
Well ID
Averaqe TDS (mpll)
IUC Data DRC Data IUC Data DRC Data ("
Avg.
Conc.(l)
No. of
Data(3)
Avg.
Conc.@)
No. of
DataG)
Avg.
Conc.(l)
No. of
Data(o
Avg.
Conc.@)
No. of
Data(3)
Historic IUC Monitoring Wells
MW-l t-276 68 r.268 4 MW-2 3,031 67 3,103 4
MW-5 2,081 69 2,068 4 MW-3 5,2W 67 5.289 4
MW-lt t-834 50 2.039 4 MW-12 3,939 50 3,756 4
MW-I8 2,545 9 2.61t 4 MW-14 3.582 30 ].589 4
MW-19(",2,697 9 3,120 4 MW-15 3,855 30 3.847 4
MW-20(,,2,977 I nla 0 MW-17 4,539 l1 4,542 4
NfiN-22r')5,105 I nla 0
Beqq4.t IUC Monitoring Wells
MW-26("3,120 I 3.206 I
TW4-16r"2,930 I 3,430 I
MW-32(o)3.190 I 3,650 I
Foohotes:
Part I
Prnrvrrl;nrrs - the permittee shall compty with the forowing r"ir"ffi:$fo
ucw370o04
l. Ground Water Compliance Limits - contaminant concentrations measured in each
monitoring well shall not exceed the Ground Water Compliance Limits (GWCL) definedin Table 2, below. Ground water quality at the site must at all times meet all the
applicable GWQS and ad hoc GWQS defined in R317-6 even though this permit does not
require monitoring for each specific contaminant.
2- Tailings Cell Operations - only ll.e.(2) by-product material authorized by Utah
Radioactive Materials License No. UT-2300478 (hereafter License) shalibe discharged toor disposed of in the tailings ponds.
l. Prohibited Discharges - discharge of other compounds such as paints, used oil,
antifreeze, pesticides, or any other contaminant not defined as ie.(2) material is
prohibited.
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Part I
Permit No. UGW37OOO4
D. Dlscuenar lv{nmruATroN Tucrryorocy STANDARD - the tailings disposal facility must be
built and operated according to the following Discharge Minimization Technology (DMT)
standards:
l. DMT Design Standards for Existing Tailings Cells 1, 2, and 3 - shall be based on existing
construction as described by design and construction information provided by the
Permittee, as summarized in Table 3 below for Tailings Cells 1,2, and3:
l) D'Appolonia Cmsultiug Engrneers, Inc., June, 199, "Engineers Reprt Tailings Mamgemetrt System White Mesa Uranium hoject
Blaoding, Utah Energy Fuels Nuclear, Inc. Denver, Colmado", unpubHshed consultants reporq approximately 50 pp., 2 figurcs, 16 sheets, 2
appendices.
D'Appolmia Consulting Engineen, Inc., February, 1982, "Constuction Re,port Initial Phase - Tailings Mauageme.nt System White Mesa
Uranium Project Blanding, Utah Euergy Fuels Nucleat Inc. Denver, Colorado", unpublished consultatrts rcport approxirnately 7 pp., 6 tables,
13 figures, 4 appendices.
D'Appolonia Cousulting Eogineers, Inc., May, 1981, "Engineer's Report Second Phase Design - Cell 3 Tailings Management SysEm White
Mesa Uraaium Project Blanding, Utah Energy Fuels Nuclear, hc. Denver, Colmado'', unpublished consultents reput, approximately 20 pp., I
figure,5 shees, 3 appendices.
Energy Fuels Nuclear, Inc., March, 1983, 'Consruction Report Second Phase Tailings Maqagement System White M€sa Uranium Project
Energy Fuels Nuclear, Inc.", uupublished compauy repor! l8 pp., 3 tables,4 figures, 5 appendices.
a) Tailings Cell I - consisting of the following major design elements:
Cross-valley Dike and East Dike - constructed on the south side of the pond of
native granular materials with a 3:1. slope, a 20-foot crest width, and a crest
elevation of about 5,620 ft above mean sea level (amsl). A dike of similar design
was constructed on the east margin of the pond, which forms a continuous earthen
structure with the south dike. The remaining interior slopes arc cut-slopes at 3:l
grade.
Liner System - including a single 30 mil PVC flexible membrane liner (FI\[)
constructed of solvent welded seams on a prepared sub-base. Top elevation of the
FML liner was 5,618.5 ft amsl on both the south dike and the north cut-slope. A
protective soil cover layer was constructed immediately over the FML with a
thickness of l2-inches on the cell floor and 18-inches on the interior sideslope.
Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch
thick layer of crushed sandstone was prepared and rolled smooth as a FML sub-
base layer. Beneath this underlay, native sandstone and other foundation
materials were graded to drain to a single low point near the upstream toe of the
south cross-valley dike. Inside this layer, an east-west oriented pipe was installed
Table 3. DMT neering Desisn and Specifications
Tailings
Cell
Repon
Tvoe Eneineerine Report Desisn Fisures
Construction
Soecifications
Cell I Design June, 1979 D'Appolonia
Consultins Ensineers. Inc (1)
Appendix A, Sheets 2,4,8,
9,12-15
Appendix B
Cell2 Design Iune, 1979 D'Appolonia
Consultins Eneineers. Inc (l)Appendix A, Sheets 2,4,'7-
10, 12-15
Appendix B
As-Built February, I 982 D'Appolonia
Consultine Ensineers. Inc (2)
Figures 1,2, and l1 N/A
Cell3 Design May, 1981D'Appolonia
Consultins Ensineers. Inc €)
Sheets 2-5 Appendix B
As-Built March, 1983 E:rergy Fuels
Nuclear.Inc. (a)
Figures l-4 N/A
Footnotes:
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Part I
Permit No. UGW370004
to gather fluids at the upstream toe of the cross-valley dike.
b) Tailings cell2 - which consists of the following major design elements:
l) Cross-valley Dike - constructed at the south margin of Cell 2 of native granular
materials with a 3:1 slope, a 20-foot crest width, and crest elevation of about
5,615 ft amsl. The east and west interior slopes consist of cut-slopes with a 3:l
grade. The Cell 1 south dike forms the north margin of Cell 2, with a crest
elevation of 5,620 ft amsl.
2) Linet System - includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prcparcd sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell 2 is 5,615.0 ft and 5,613.5 ft amsl
on the north and south dikes, respectively. Said Cell2EML liner is independent
of all other disposal cell FML liners. Immediately above the FML, a nominal 12-
inch (cell floor) to l8-inch (inside sideslope) soil protective blanket was
constructed of native sands from on-site excavated soils.
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch
thick layer of crushed sandstone was prepared and rolled smooth as a FML sub-
base layer. Beneath this underlay, native sandstone and other foundation
materials were graded to drain to a single low point near the upstream toe of the
south cross-valley dike. Inside this layer, an east-west oriented pipe was installed
to gather fluids at the upstream toe of the cross-valley dike.
4) Slimes Drain Collection System immediately above the FML a nominal l2-inch
thick protective blanket layer was constructed of native silty-sandy soil. On top of
this protective blanket, a network of 1.S-inch PVC perforated pipe laterals was
installed on a grid spacing interval of about 50-feet. These pipelaterals gravity
drain to a 3-inch diameter perforated PVC collector pipe which also drains toward
the south dike and is accessed from the ground surface via a24-inch diameter,
vertical non-perforated IpPE access pipe. Each run of lateral drainpipe and
collector piping was covered with a 12 to l8-inch thick berm of native granular
filter material. At cell closure, leachate head inside the pipe network ,ritt U"
removed via a submersible pump installed inside the 24-inch diameter IIDpE
access pipe.
c) Tailings cell 3 - consisting of the following major design elements:
l) Cross-valley Dike - constructed at the south margin of Cell 3 of native granular
materials with a 3:l slope, a 20-foot crest width, and a crest elevation of 5,610 ft
amsl. The east and west interior slopes consist of cut-slopes with a 3:1 grade.
The Cell 2 south dike forms the north margin of Cell 3, with a crest elevation of
5,615 ft amsl.
2) Linet System - includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell 3 is 5,613.5 ft and 5,608.5 ft amsl
on the north and south dikes, respectively. Said Cell 3 FML liner is independent
of all other disposal cell FML liners.
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch
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Part I
Permit No. UGW370004
thick layer of crushed sandstone was preparcd and rolled smooth as a FML sub-
base layer. Beneath this underlay, native sandstone and other foundation
materials were graded to drain to a single low point near the upstream toe of the
south cross-valley dike. krside this layer, an east-west oriented pipe was installed
to gather fluids at the upstream toe of the cross-valley dike.
4) Slimes Drain Collection Layer and System - immediately above the FML, a
nominal l2-inch (cell floor) to l8-inch (inside sideslope) soil protective blanket
was constructed of native sands from on-site excavated soils (707o) and dewatered
and cyclone separated tailings sands from the mill (307o). On top of this
protective blanket, a network of 3-inch PVC perforated pipe laterals was installed
on approximately 5O-foot centers. This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a l2-inch diameter, inclined IIDPE access
pipe. Each run of the 3-inch lateral drainpipe And collector pipe was covered with
a 12 to l8-inch thick berm of native granular filter media. At cell closure,
leachate head inside the pipe network will be removed via a submersible pump
installed inside the l2-inch diameter inclined access pipe.
Existing Tailings Cell Construction Authorized - tailings disposal authorized by this
permit is limited to those existing tailings cells defined in Table 3 and Part I.D.l, above.
Authorized operation and maximum disposal capacity in each of the existing tailings cells
shall not exceed the levels authorized by the License. Under no circumstances shall the
freeboard be less than three (3) feet, as measured from the top of the FML. Any
modification by the Permittee to any approved engineering design parameter at these
existing tailings cells shall require prior Executive Secretary approval, modification of
this Permit, and issuance of a construction permit.
Existing Facility DMT Performance Standards - the Permittee shall operate and maintain
certain mill site facilities and the existing tailings disposal cells to minimize the potential
for wastewater release to groundwater and the environment, including, but not limited to
the following'additional DMT compliance measures:
a) DMT Monitoring Wells at Tailings Cell 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 Umit established in
Table 2 of this Permit.
b) Tailings Cells 2 and 3 - including the following performance criteria:
l) Slimes Drain Maximum Allowable Head - the Permittee shall at all times
maintain the average wastewater head in the slimes drain access pipe to be as low
as reasonably achievable in each tailings disposal cell, in accordance with a DMT
Monitoring Plan approved by the Executive Secretary pursuant to Part I.H.13 of
this Permit. For Cell 3, this requirement shall apply after initiation of de-watering
operations.
2) Maximum Tailings Waste Solids Elevation - upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation of the tailings waste solids
does not exceed the top of the FML liner.
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c)
d)
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Part I
Permit No. UGW37OO04
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.
Roberts Pond -the Permittee shall operate this wastewater pond so as to provide a
minimum 2-foot freeboard at all times. Under no circumstances shall the water level
in the pond exceed an elevati on of 5,624 feet amsl. In the event that the wastewater
elevation exceeds this maximum level, the Permittee shall remove the excess
wastewater and place it into containment in Tailings Cell 1 within 72 hours of
discovery. At ttle time of mill site closure, the Permittee shall reclaim and
decommission the Roberts Pond in compliance the final Reclamation Plan approved
under the License (hereafter Reclamation Plan).
Feedstock Storage Area -open-air or bulk storage of all feedstock materials at the
facility awaiting mill processing shali be limited to the eastern ponion of the mill site
area described in Table 4, below. Storage of feedstock materials at the facility outside
this area, shall be performed and maintained only in closed, water-tight containers.
At the time of mill site closure, the Pernrittee shall reclaim and decommission the
Feedstock Storage Area in compliance with an approved Reclamation Plan.
Table ates (l)
Fmhote: I ) lpprffi ginning from the €xtreme northeast comer atrd progressing
4. Feedstock Storage Area Coorcltn
Corner Northins (ft)Eastine (ft)
Northeast 323,595 2,580,925
Southeast 322.140 2.580.920
Southwest 322,140 2.580.420
West I 322.815 2.580-410
West 2 323,O40 2.580,085
West 3 323,120 2,580,085
West 4 323,315 2,580,285
West 5 323,415 2,579,990
Northwest 323,600 2.579.990
State Plane Coddinates beginning from the
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clo"k*ire around the feedstock area (from 6/2?01 IUC Response, Attachment I( Site Topographic Map'
Revised June, 2fi)1.)
e) Mill Site Chemical Reagent Storage - for all chemical reagents stored at existing
storage facilities and held for use in the milling process, the Permittee shall provide
secondary containment to capture and contain all volumes of reagen(s) that might be
released at any individual storage area. Response to spills, cleanup thereof, and
required reporting shall comply with the provisions of an approved Emergency
Response Plan as found in an approved Stormwater Best Management Practices Plan,
stipulated by Parts I.D.8 and I.H.17 of this Permit. For any new construction of
reagent storage facilities, said secondary containment and control shall prevent any
contact of the spilled or otherwise released reagent or product with the ground
surface.
4. Best Available Technology Requirements for New Construction - any construction,
modification, or operation of new waste or wastewater disposal, treatment, or storage
facilities shall require submittal of engineering design plans and specifications, and prior
Executive Secretary review and approval. All engineering plans or specifications
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submitted shall demonstrate compliance with all Best Available Technology requirements
stipulated bythe Utah Ground Water Quality Protection Regulations (UAC R317-6).
Upon Executive Secretary approval, a Construction Permit may be issued, and this Permit
may be re-opened and modified to include any necessary requirements.
Definition of 1le.(2) Waste - for purposes of this Permit , lle.(2) waste is defined as: "...
tailings or wastes produced by the extraction or concentration of uranium or thorium from
any ore processed primarily for its source material content", as defined in Section f 1e.(2)
of the U.S. Atomic Energy Act of '1,954, as amended; which includes other process related
wastes and waste streams described by a March 7,2003 NRC letter from Paul H. Lohaus
to William J. Sinclair.
Closed Cell Performance Requirements - before reclamation and closure of any tailings
disposal cell, the Permittee shall ensure that the final design, construction, and operation
of the cover system at each tailings cell will comply with all requiremerrts of an approved
Reclamation Plan, and will for a period of not less than 200 years meet the following
minimum performance requirements:
Minimize infiltration of precipitation or other surface water into the tailings,
including, but not limited to the radon barier, and
Prevent the accumulation of leachate head within the tailings waste layer that could
rise above or over-top the maximum FML liner elevation internal to any disposal cell,
i.e. create a "bathtub" effect.
Ensure that groundwater quality at the compliance monitoring wells does not exceed
the Ground Water Quality Standards or Ground Water Compliance Limits specified in
Part I.C.l and Table 2 of this Permit.
Facility Reclamation Requirements - upon commencement of decommissioning, the
Permittee shall reclaim the mill site and all related facilities, stabilize the tailings cells,
and construct a cover system over the tailings cells in compliance with all engineering
design and specifications in an approved Reclamation Plan. The Executive Secretary
reseryes the right to require modifications of the Reclamation Plan for purposes of
compliance with the Utah Ground Water Quality Protection Regulations, including but
not limited to containment and control of contaminants, or discharges, or potential
discharges to Waters of the State.
Stormwater Management and Spill Control Requirements - the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with an approved Stormwater Best Management Practices Plan, purcuant to
Part I.H.l7 of the Permit. Said plan shall include provisions to adequately:
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 R3l7-6-6.3(G) and R317-6-6.4(C),
Prevent, control and contain spills of stored reagents or other chemicals at the mill
site,
c) Cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery,
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d) Report reagent spills or other releases at the mill site to the Executive Secretary in
accordance with UAC 19-5-114.
Reconstruction of stormwater management and/or chemical reagent storage facilities,
existing at the time of original Permit issuance, may be required by the Executive
Secretary after occurrence of a major spill or catastrophic failure, pursuant to Part tV.N.3
of this Permit.
E. GnouNo.Wlrrn CotwrreNcE AND TEcnxorocy PERFoRMANCE Mor.rroRn\G - beginning
with the effective date and lasting through the term of this permit or as stated in an approved
closure plan, the Permittee shall sample groundwater monitoring wells, monitor groundwater
levels, monitor water levels of process solutions, and monitor ura rc"p records of the
operation of the facility, as follows:
l. Routine Groundwater Cornpliance Monitoring - the Permittee shall monitor upgradient,
lateral gradient, and downgradient ground water monitoring wells completed in the
shallow aquifer in the vicinity of all potential discharge sources that could affect local
groundwater conditions at the facility, as follows:
a) Quarterly Monitoring - the Permittee shall monitor on a quarterly basis all monitoring
wells listed in Table 2 of this Permit where local groundwater average linear velocity
has been found by the Executive Secretary to be equal to or greater than l0 feeUyear.
For purposes of this Permit, quarterly monitoring is required at the following wells:
1) Upgradient Wells: none
2) Lateral or Downgradient Wells: MW-I1, MW-14, MW-26 (formerly TW4-15),
and MW-32 (formerly TW4-17).
b) Semi-annual Monitoring - the Permittee shall monitgr on a semi-annual basis all
monitoring wells listed in Table 2 of this Permit where local groundwater average
linear velocity has been found by the Executive Secretary to 6e less than l0 feet/year.
For purposes of this Permit, semi-annual monitoring is required at the following
wells:
l) Upgradient Wells: Nf\V-l, MW-18, and MW-19,
2) lateralor Downgradient Wells: MW-2, MW-3, MW-5, MW-12, MW-15, and
MW_17,
c) Compliance Monitoring Parameters - all groundwater samples collected shall be
nalyzed for the following parameters:
1) Field Parameters -depth to groundwater, pH, temperature, and specific
conductance.
2) LaboratoryParameters
i. GWCL Parameters - all contaminants specified in Table2.
General Inorganics -+hloride, sulfate, carbonate, bicarbonate, sodium,
potassium, magnesium, calcium, and total anions and cations.
d) Special Provisions for Groundwater Monitoring - the Permittee shall ensure that all
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groundwater monitoring conducted and reported complies with the following
requirements:
1) Depth to Groundwater Measurements - shall always be made to the nearest 0.01
foot.
Minimum Detection Limits - all groundwater quality analyses reported shall have
a minimum detection limit or reporting limit that is less than its respective Ground
Water Compliance Limit concentration defined in Table 2.
Gross Alpha Counting Variance - all gross alpha analysis reported shall have a
counting variance that is equal to or less than 20vo of the reported activity
concentration.
2. Groundwater Head Monitoring - on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.1, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers:
a) Pointof ComplianceWells-identifiedinTable 2and,PartI.E.1 of thispermit,
b) Piezometers - P-1, P-2,P-3,P-4,P-5.
c) Existing Monitoring Wells - MW-20 andNNV-22.
d) Contaminant Investigation Wells: any well required by the Executive Secretary as a
part of a contaminant investigation or groundwater corrective action, and
e) Any other wells or piezometers required by the Executive Secretary.
3- Groundwater Monitoring Well Design and Construction Criteria - all new groundwater
monitoring wells installed at the facility shall comply with the following design and
construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other
potential origin of groundwater pollution,
Screened and completed in the shallow aquifer,
Designed and constructed in compliance with UAC R317-6-6.3(I)(6), including the
EPA RCRA Ground Water Monitoring Technical Enforcement Guidance Document,
1986, OSWER-9950.1.
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
4. Monitoring Procedures for Wells - beginning with the date of Permit issuance, all
monitoring shall be conducted by the Permittee in conformance with the following
procedures:
a) Sampling - grab samples shall be taken of the ground water, only after adequate
removal or purging of standing water within the well casing has been performed.
b) Sampling Plan - all sampling shall be conducted to ensure collection of representative
samples, and reliability and validity of groundwater monitoring data. All
groundwater sampling shall be conducted in accordance with the currently approved
Groundwater Monitoring Quality Assurance plan.
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Laboratory Approval - all analyses shall be performed by a laboratory certified by the
State of Utah to perform the tests required.
Damage to Monitoring Wells - if any monitor well is damaged or is otherwise
rendered inadequate for its intended pu{pose, the Permittee shall notify the Executive
Secretary in writing within five days of discovery.
Field Monitoring Equipment Calibration and Records - immediately prior to each
monitoring event, the Permittee shall calibrate all field monitoring equipment in
accordance with the respective manufacturer's procedures and guidelines. The
Permittee shall make and preserve on-site written records of such equipment
calibration in accordance with Part tr.G and H of this Permit. Said records shall
identify the manufacturer's and model number of each piece of field equipment used
and calibration.
5. White Mesa Seep and Spring Monitoring - after approval of the report required by part
I.H.9, this Permit may be modified to require annual monitoring of selected seeps or
springs on White Mesa.
DMT Performance Standard Monitoring - after approval of the DMT Monitoring plan
required by Part I.H.13, thePermittee shall perform technology performance monitoring
to determine if DMT is effective in minimizing and controlling the release of
contaminants pursuant to the provisions of Parts I.D.1 and I.D.3 of this permit,
but not limited to the following activities:
including,
weekly Tailings wastewater Pool Elevation Monitoring: cells 1 and 3 - the
Permittee shall monitor and record weekly the elevation of wastewater in Tailings
Cells 1 and 3 to ensure compliance with the maximum wastewater elevation criteria
mandated by Condition 10.3 of the License.' Said measurements shall be made from a
wastewater level gauge or elevation survey.
Weekly Slimes Drain Water Level Monitoring: Cells 2 and,3 - the Permittee shall
monitor and record weekly the depth to wastewater in the slimes drain access pipes at
Tailings Cells 2 and 3 to determine maximum and minimum fluid head before and
after a pumping cycle, respectively. The permittee shall designate, operate, and
maintain one water level measuring point at the centerline of the slimes drain access
pipe at each tailings cell. For Cell 3 this requirement shall apply upon initiation of
tailings de-watering operations.
Weekly Wastewater Irvel Monitoring: Roberts Pond - the Permittee shall monitor
and record weekly wastewater levels at the Roberts Pond to determine compliance
with the DMT operations standards in Part I.D.3. Said measurements shall be made
from a wastewater level gauge or an elevation survey pursuant to I.H.13.
Weekly Feedstock Storage Area Inspection - the Permittee shall develop a Standard
Operating Procedure for the License and inspect the Feedstock Storage Areas to:
Confirm the bulk feedstock materials are maintained within the approved
Feedstock Storage Area defined by Table 4, and
Verify that all alternate feedstock materials located outside the Feedstock Area
defined in Table 4, are maintained within water-tight containers.
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On-site Chemicals Inventory - the Permittee shall monitor and maintain a current
inventory of all chemicals used at the facility at rates equal to or greater than 100 kilyr.
Said inventory shall be maintained on-site, and shall include, but is not limited to:
a) Identification of chemicals used in the milling process and the on-site laboratory,
b) Determination of volume and mass of each raw chemical currently held in storage at
the facility.
Tailings Cell Wastewater Quality Monitoring - on an annual basis, the Permittee shall
collect wastewater quality samples from each wastewater source at each tailings cell at
the facility, including, but not limited to: surface impounded wastewaters, and slimes
drain wastewaters. All such sampling shall be conducted in August of each calendar year
in compliance with the approved Tailings Cell Wastewater Quality Sampling Plan
required by Part I.H.5 of this Permit. The Permittee shall also provide at least a 30-day
notice in advance of the annual sampling event, so as to allow the Executive Secretary to
collect split samples of the various tailings cells wastewater sources.
F. Rsponrhlc Rnqurnrwlrrs - The following reporting procedures for routine and compliance
reports must be met.
1. Routine Groundwater Monitoring Reports - the Permittee shall furnish the Executive
Secretary quarterly monitoring reports of field and laboratory analyses of all well
monitoring and samples described in Parts I.E.1, I.8.2,I.8.4, and I.E.6 of this Permit.
Reports shall be submitted according to the following schedule:
Table 5. Groundwater Moni Scheduleton
Quarter Period Due Date
First January - March June I
Second Anril - June September I
Third Julv - September December I
Founh October - December March I
Failure to submit the reports by the due date shall be deemed as noncompliance with this
permit. Said monitoring reports shall include, but are not limited to, the following
minimum information:
a) Field Data Sheets - or copies thereof that provide the following: well narne, date and
time of well purging, date and time of well sampling, type and condition of well
pump, depth to groundwater before purging and sampling, calculated well casing
volume, volume of water purged before sampling, volume of water collected for
analysis, types of sample containers and preservatives.
b) Laboratory Results - or copies thereof that provide the following: date and time
sampled, date received by laboratory, and for each parameter analyzed, the following
information: laboratory result or concentration, units of measurement, minimum
detection limit or reporting limit, analytical method, date of analysis, counting error
for radiologic analyses, total cations and anions for inorganic analysis.
c) Water Table Contour Map - which provides the location and identity of all wells
sampled that quarter, the measured groundwater elevation at each well measured in
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feet above mean sea level, and isocontour lines to delineate groundwater flow
directions observed during the quarterly sampling event.
Quality Assurance Evaluation and Data Validation - including a written description
and findings of all quality assurance and data validation efforts conducted by the
Permittee in compliance with the Groundwater Monitoring euality Assurante plan.
Said report shall verify the accuracy and reliability of the groundwater quality
compliance data, after evaluation of sample collection techniques and equipment,
sample handling and preservation, analytical methods used, etc.
Electronic Data Files and Format - in addition to written results required for every
sampling report, the Permittee shall provide an electronic copy of all laboratory
results for groundwater quality monitoring conducted. Said electronic files shall
consist of Comma Separated Values (CSV) format, or as otherwise approved by theExecutive Secretary.
2. Routine DMT Performance Standard Monitoring Reports - the permittee shall provide
quarterly monitoring reports of all DMT performance standard monitoring required byPat I.E.6 of this Permit. Said monitoring shall be conducted in compliance with an
approved DMT Monitoring:Plan, pursuant to Part LH.13 of this permit. Said monitoring
reports and results shall be submitted to the Executive Secretary on the schedule provide-d
in Table 5, above, and shall at a minimum include the following information:
a) Summary table of weekly wastewater pool elevation
and the Roberts Pond. Units of reporting shall be in
monitoring at Tailings Cells 1, 3,
feet above mean sea level.
b) Summary table of weekly slimes drain water level monitoring conducted at Tailings
Cells 2 and 3. Said summary shall include, but is not limited to down-slope depth towater level inside the slimes drain access pipe, as measured from one watir level
measuring point at the centerline of the pipe.
DMT Performance Upset Reports - the Permittee shall report any non-compliance with
the DMT performance criteria of Part I.D in accordance with the requiremeirts of part
I.G.3 of this Permit.
Other Information - when the Permittee becomes aware of a failure to submit any relevant
facts in the permit application or submittal of incorrect information in a permit
application or in any report to the Executive Secretary, the Permittee shall submit such
facts or information within 10 days of discovery.
Groundwater Monitoring Wetl As-Built Reports - as-built reports for new groundwater
monitoring wells shall be submitted for Executive Secretary approval, and at a minimumwill include the following information:
a) Geologic Logs - that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs shall be prepared by a
Professional Geologist licensed by the state of utah, or otherwise approved
beforehand by the Executive Secretary.
b) Well Completion Diagram - that detail all physical attributes of the well construction,
including:
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1) Total depth and diameters of boring,
2) Depth, type, diameter, and physical properties of well casing and screen, including
well screen slot size,
3) Depth intervals, type and physical properties of annular filterpack and seal
materials used,
4) Design, type, diameter, and construction of protective surface casing,
5) Survey coordinates prepared by a State of Utah licensed engineer or land
surveyor, including horizontal coordinates and elevation of water level measuring
point, as measured to the nearest 0.01 foot.
c) Aquifer Permeability Data - including slug test, aquifer pump test or other hydraulic
analysis to determine local aquifer hydraulic conductivity in each well.
6. White Mesa Seep and Spring Monitoring Reports - after approval of the work plan and
report required by Pan I.H.9, this Permit may be modified to require annual monitoring
and reporting of selected seeps or springs on White Mesa.
7 . Chemicals Inventory Report - at the time of Permit renewal the Permittee shall submit a
report to update the facilities chemical inventory report required by Part I.H.10. Said
report shall provide all inventory information gathered pursuant to Part I.8.7.
8. Tailings Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part I.E.8 shall be reported to the Executive Secretary with the 3'd
Quarter groundwater quality report due on December 1 of each calendar year. Said report
shall include all information required by Part I.F.1(a), (b), (d), and (e) of this Permit.
g. Revised Hydrogeologic Report - pursuant to Part IV.D of this Permit, and at least 180
days prior to Permit expiration, the Permittee shall submit for Executive Secretary
approval a revised hydrogeologic report for the facility and surrounding area. Said report
shall provide a comprehensive update and evaluation of:
a) Local hydrogeologic conditions in the shallow aquifer, including, but not limited to:
local geologic conditions; time relationships and distribution of shallow aquifer head
measurements from facility wells and piezometers; local groundwater flow directions;
and distribution of aquifer permeability and average linear groundwater velocity
across the site, and
b) Well specific groundwater quality conditions measured at facility monitoring wells
for all groundwater monitoring parameters required by this Permit, including, but not
limited to: temporal contaminant concentrations and trends from each monitoring
well; statistical tests for normality of each contaminant and well, including univariate
or equivalent tests; calculation of the mean concentration and standard deviation for
each well and contaminant.
Our orCorwueNce STRTUS
1. Accelerated Monitoring Status - is required if the concentration of a pollutant in any
compliance monitoring sample exceeds a GWCL in Table 2 of the Permit;the facility
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shall then:
Notify the Executive Secretary in writing within 30 days of receipt of data; and
Immediately initiate accelerated sampling of the pollutant as follows:
1) Quarterly Baseline Monitoring wells - for wells defined by Part I.E.1(a) the
Permittee shall initiate monthly monitoring,
2) Semi-annual Baseline Monitoring Wells - for wells defined by Part I.E.l(b) the
Permittee shall initi ate quarterly monitoring.
Said accelerated monitoring shall continue at the frequencies defined above until the
compliance status of the facility can be determined by the Executive Secretary.
2. Violation of Permit Umits - out-of-compliance status exists when:
The concentration of a pollutant in two consecutive samples from a compliance
monitoring point exceed:
1) A GWCL in Table 2 of this Permit, and;
2) The reported ground water concentration for that pollutant exceeds the mean by
two standard deviations. For purposes of this Permit, the standard deviation and
mean will be calculated using values for the ground water pollutant at each
individual compliance monitoring point or well; or
The concentration value of any pollutant in two or more consecutive samples is
statistically significantly higher than the applicable permit limit. The statistical
significance shall be determined using the statistical methods described in Statistical
Methods for Evaluating Ground Water Monitoring Data from Hazardous Waste
Facilities, Vol. 53, No. 196 of the Federal Register, Oct. 11, 1988.
3. Failure to Maintain DMT Required by Permit
Permittee to Provide Information - in the event that the Permittee fails to maintain
DMT or otherwise fails to meet DMT standards as required by the permit, the
Permittee shall submit to the Executive Secretary a notification and description of the
failure according to R317-6-6.16(C)(1). Notification shall be given orally within24
hours of the Permittee's discovery of the failure of DMT, and shall be followed up by
written notification, including the information necessary to make a determination
under R317-6-6.16(C)(2), within five days of the Permittee's discovery of the failure
of best available technology.
The Executive Secretary shall use the information provided under R317-6-6.16.C(1)
and any additional information provided by the Permittee to determine whether to
initiate a compliance action against the Permittee for violation of permit conditions.
A compliance action shall not be initiated, if the Executive Secretary determines that
the Permittee has met the standards for an affirmative defense, as specified in R317-6-
6.16(cX3).
Affirmative Defense - in the event a compliance action is initiated against the
Permittee for violation of permit conditions relating to best available technology or
DMT, the Permittee may affirmatively defend against that action by demonstrating
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the following:
1) The Permittee submitted notification according to R317-6-6.13;
2) The failure was not intentional or caused by the Permittee's negligence, either in
action or in failure to act
3) The Permittee has taken adequate measures to meet permit conditions in a timely
manner or has submitted to the Executive Secretary, for the Executive Secretary's
approval, an adequate plan and schedule for meeting permit conditions; and
4) The provisions of UCA 19-5-107 have not been violated.
4. Facility Out of Compliance Status - if the facility is out of compliance, the following is
required:
a) The Permittee shall notify the Executive Secretary of the out of compliance status
within 24 hours after detection of that status, followed by a written notice within 5
days of the detection.
b) The Permittee shall continue accelerated sampling pursuant to Part I.G.l, unless the
Executive Secretary determines that other periodic sampling is appropriate, until the
facility is brought into compliance.
The Permittee shall prepare and submit within 30 days to the Executive Secretary a
plan and a time schedule for assessment of the sources, extent and potential
dispersion of the contamination, and an evaluation of potential remedial action to
restore and maintain ground water quality to insure that permit limits will not be
exceeded at the compliance monitoring point and that DMT will be reestablished.
The Executive Secretary may require immediate implementation of the contingency
plan to be submitted pursuant to Part I.H.16, in order to regain and maintain
compliance with the permit limit standards at the compliance monitoring point or to
reestablish DMT as defined in the permit.
e) Where it is infeasible to reestablish DMT as defined in the permit, the permittee may
propose an alternative DMT for approval by the Executive secretary.
5. Accelerated Monitoring Status for New Wells - any new compliance monitoring well
installed by the Permittee after issuance of this Permit, will be designated a compliance
monitoring point, and subject to the requirements of Part I.G of this Permit, after
submittal and Executive Secretary approval of the Background Groundwater euality
Report required by Parr LH.4 of this Permit.
H. ColvpI-IaNcE SCffiDULE RrqummmNTS. The Permittee will comply with the schedules as
described and summarized below:
l. Installation of New Groundwater Monitoring Wells - within 30 days of issuance of this
Permit, the Permittee shall submit a plan for the installation of new monitoring wells for
Executive Secretary approval. Said plan shall include the following information:
a) Tailings Cell I DMT Wells -one (1) hydraulically upgradient well and two (2)
hydraulically downgradient wells that comply with the provisions of Part I.E"3 of this
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Permit, and the well location map submitted by the Permittee on April 16,2004.
b) New Compliance Monitoring Wells for Tailings Cells 2 and 3 -an adequate number
and location of monitoring wells to ensure:
1) Early detection of tailings cell contamination of shallow groundwater from
Tailings Cells 2 and 3. The number and location of these wells shall conform to
the provisions of Part I.E.3, and the well location map submitted by the Permittee
on April 16,2004, and
2) Discrete monitoring of each individual disposal cell. For Cell}this shall mean
installation of three (3) monitoring wells on the shared dike between Cells 2 and
3, as per the well location map submitted by the Permittee on April 16,2004.
c) New well design and construction details that comply with Part I.E.3 of this Permit.
On or before May 1, 2005, the Permittee shall complete installation of all new monitoring
wells in accordance with said plan and any conditions of approval. The Permittee shall
provide at least a7-day notice to allow the Executive Secretary to observe all drilling and
well installation activities related to this plan.
Revised Hydrogeologic Report - within 60 days of completion of the well installations
required by Part I.H.1, the Permittee shall submit a revised hydrogeologic report for
Executive Secretary approval that includes:
a) Monitoring well as built report for each well that complies with the information
requirements of Part I.F.5.
b) Hydrogeologic data from each new well, including but not limited to: depth and
elevation of groundwater level, and aquifer test results to determine local
permeability.
c) Comprehensive hydrogeologic evaluation of the facility that includes both new data
collected during or as a result of the new monitoring well installation required by Part
I.H.1, and all existing hydrogeologic information available for the site.
d) Aquifer test results to determine local hydraulic conductivity and other aquifer
properties at existing well MW-32 (formerly TW4-17).
e) Average linear groundwater velocity calculated for each well, based on well specific
hydraulic conductivity, hydraulic gradient, and effective aquifer porosity.
If after review of this report, the Executive Secretary determines that additional
monitoring wells are required to adequately monitor the facility, the Permit will be re-
opened and modified to require all necessary improvements pursuant to Part tV.N.3.
Background Ground Water Quality Report: Existing Wells - within 90 days of issuance
of this Permit, the Permittee shall submit a Background Ground Water Quality Report for
all existing monitoring wells at the facility for Executive Secretary approval. Said report
shall include:
a) All available groundwater quality data for all existing monitoring wells at the facility.
b) A quality assurance evaluation and data validation of the existing and historic on-site
groundwater quality data that on a well-by-well and contaminant specific basis:
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Identifies,justifies, and/or culls any zero concentration values reported,
Determines the adequacy of minimum detection limits used, particularly with
respect to the corresponding GWQS for each contaminant,
Adequately addresses any special statistical needs for management of data sets
with a large proportion of non-detectable values,
Determines the adequacy of laboratory and analytical methods used,
Determines the consistency of laboratory units of reporting,
Evaluates and justifies internal consistency between specific and composite types
of groundwater quality analysis (e.g. major ions and TDS),
Identifies and justifies any groundwater concentration outliers,
Tests the selected groundwater quality data for each individual well and
contaminant for normality, and justifies the use of parametric or non-parametric
statistical methods for each.
c) An examination and justification of any temporal and/or spatial groundwater quality
concentration phenome[a, that shall include, but are not limited to:
1) Any long term or apparently increasing contaminant concentration trends found in
any existing monitoring wells,
2) Any long term or apparently increasing contaminant concentration ratios observed
in existing monitoring wells.
3) Any contaminant concentrations that appear to exceed their corresponding
GWQS.
d) Determination of descriptive statistics for each individual well and contaminant found
in Table 2 of this Permit.
Upon approval of this report, the Executive Secretary will re-open this Permit and modify
the Ground Water Compliance Limits in Table 2, above to account for natural variations
in groundwater quality, not caused by current or historic operations at the facility.
4. Background Groundwater Quality Report: New Monitoring Wells - within 30 days of
installation of the new monitoring wells required by Part I.H.1 of this Permit, the
Permittee shall implement a quarterly groundwater quality sampling program for all new
monitoring wells. Said sampling shall comply with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part I.E.l,
b) Well monitoring procedure requirements of Part I.8.4, and
c) Quarterly reporting requirements of Part I.F.1.
After completion of eight (8) consecutive quarters of groundwater sampling and analysis
of the new monitoring wells, the Permittee shall submit a Background Groundwater
Quality Report for the new wells for Executive Secretary review and approval. The
content of this report shall comply with the information requirements of Part I.H.3 of this
Permit. Said report shall be submitted for Executive Secretary approval no later than
June 1, 2007 . After approval of this report, the Executive Secretary will re-open this
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Permit and establish Groundwater Compliance Limits in Table 2 for the new monitoring
wells.
Tailings Cells Wastewater Quality Sampling Plan - within 150 days of issuance of this
Permit, the Permittee shall submit a plan for tailings cell wastewater sampling and
analysis for Executive Secretary approval. The purpose of this plan and associated report
shall be to characterize the source term quality of all tailings cell wastewaters, including,
but not limited to: impounded wastewaters or process waters in the tailings cells, and
wastewater or leachates collected by internal slimes drains. Said plan shall include, but is
not limited to:
a) Collection of samples from each wastewater source at each tailings cell, including
wastewater impoundments, slimes drains, etc.
b) Complete analysis for both field and laboratory parameters required by Part I.E.l(d),
and all detectable volatile organic contaminants by EpA Method 82608.
c) Detailed description of all sampling methods and sample preservation techniques to
be employed.
d) Use of standardized analytical methods.
e) Analysis by a State of Utah certified environmental laboratory.
0 30 day advance notice of each annual sampling event to allow the Executive Secretary
to collect split samples of all tailings cell wastewater sources.
After approval of the plan, the Permittee shall implement the plan pursuant to the
requirements of Parts I.E.8 and I.F.8. After approval of this plan, the Executive Secretary
may re-open and modify this Permit to incorporate the provisions of the approved plan.
Monitoring Well Remedial Construction and Repair Work Plan and Report - within 30
days of issuance of this Permit, the Permittee shall submit a work plan and schedule for
the following remedial construction activities for selected monitoring wells at the facility.
Within 60 days of completion of these activities, the Permittee shall submit a report for
Executive Secretary approval, including:
a) Well Development - the Permittee shall develop existing wells at the facility so that
they produce clear groundwater, including wells: Mw-5, Mw-l1, Mw-r8, Mw-19,
MW-26, TW4-16, and MW-32. Said well development will ensure that groundwater
clarity conforms to the EPA RCRA TEGD requirements found in Part I.E.3(c) of this
Permit to the extent reasonably achievable.
b) Protective Surface Casings: Wells and Piezometers - the Permittee shall install steel
surface casings to protect the currently exposed PVC well and piezometer casings,
including: Piezometers P-1, P-2,P-3, P-4, and P-5; and wells Mw-26 and MW-32.
Each steel casing installed shall:
1) Allow ready water level measurement at each piezometer,
2) Not interfere or disturb the existing water level measuring point, and
3) Provide security and control access to the piezometer.
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Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report - within 150
days of issuance of this Permit, the Permittee shall verify the depth to the upper contact of
the Brushy Basin Member of the Morrison Formation in the immediate vicinity of well
MW-3. The Permittee shall provide at least 14 days notice and allow the Executive
Secretary to observe all field activities related to said verification. In the event that the
Executive Secretary determines the well screen has been inadequately constructed, the
Permittee shall retrofit, reconstruct, or replace monitoring well MW-3 in accordance with
a plan and schedule approved by the Executive Secretary.
White Mesa Seeps and Springs Sampling Work Plan and Report - within 180 days of
issuance of this Permit, the Permittee shall submit a plan for Executive Secretary
approval of groundwater sampling and analysis of all seeps and springs found
downgradient or lateral gradient from the tailings cells on White Mesa. Said plan shall
include, but is not limited to:
a) Location of all seeps and springs to be sampled, including maps and surveyed
coordinates (physical location, and elevation),
b) Detailed description of sampling methods and equipment,
c) Determination of field parameters or measurements that will be made,
Description of sample preservation methods,
Determination of the laboratory analyical methods and the environmental laboratory
that will perform the analysis.
0 Sampling and analysis of all ground water compliance parameters found on Table 2 of
this Permit, including analysis of volatile and semi-volatile organic compounds by
EPA SW-846 methods 8260 and8270.
Within 180 days of approval of the plan, the Permittee shall complete said sampling and
analysis, and submit a final report for Executive Secretary approval. Said report shall: 1)
document the sampling project, 2) transmit copies of all field measurements and
laboratory results, 3) provide a water table contour map that includes water table
elevations of all the wells at the facility and the elevations of the phreatic surfaces
observed at each of the seeps and springs sampled, and 4) provide an evaluation and
interpretation of the groundwater quality data collected. The Permittee shall also provide
at least 15 days notice to allow the Executive Secretary to collect split groundwater
quality samples of the seeps and springs.
9. On-site Chemicals Inventory Report - the Permittee shall complete a historical review,
and conduct an inventory of all chemical compounds or reagents stored, used, or currently
in use at the facility. Said report shall include:
a) Identification of all chemicals used in the milling and milling related processes at
White Mesa.
b) Determination of the total volumes currently in use and historically used, as data is
available.
Said report shall be submitted for Executive Secretary approval within 90 days of
issuance of this Permit. At the time of Permit renewal, the Permittee shall submit an
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Permit No. UGW370004
updated inventory report pursuant to Part I.F.7.
l0.Infiltration and Contaminant Transport Modeling Work Plan and Report - the Permittee
shall submit for Executive Secretary approval an infiltration and contaminant transport
modeling report that demonstrates the long-term ability of the tailings cells cover system
to adequately contain and control tailings contaminants and protect nearby groundwater
quality of the uppermost aquifer. Said report shall demonstrate how the tailings cell
engineering design and specifications will comply with the minimum performance
requirements of Part I.D.6 of this Permit. Within 180 days of Permit issuance, the
Permittee shall submit a work plan for Executive Secretary approval, that:
a) Identifies all applicable and pertinent historic studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance.
b) Determines all information necessary for infiltration and contaminant transport
modeling, including but not limited to representative input values for vadose zone and
aquifer soil-water partitioning (IQ) coefficients, tailings source term concentrations,
tailings waste leach rates, vadose zone and aquifer groundwater velocities, vadose
zone and aquifer dispersivity, contaminant half-life or other rates of decay, etc. In the
event that any required information is not currently available, the Permittee may select
conservative assumptions for use in the required infiltration and contaminant
transport models. Otherwise, the Permittee shall identify how information will be
collected that is representative of actual field conditions, and a timetable by which
said information will be submitted forExecutive secretary approval.
c) Identifies all computer models that will be used to simulate long-term performance of
the tailings cells cover system. All predictive models used shall be publicly available
computer codes that adequately represent field characteristics at the tailings disposal
site.
d) Determines the conceptual model to be used and justifies why it is representative or
conservative of actual field conditions at the site. Said conceptual model will identify
the physical domain(s) and geometries to be simulated including the tailings cell
design and construction, all boundary and initial conditions to be assigned in the
model(s), and the shallow aquifer locations where future potential contaminant
concentrations will be predicted.
e) Justifies how the infiltration and contaminant transport problem has been adequately
conceptualized and planned to demonstrate compliance with the requirements of Part
I.D.6 of this Permit.
Within 180 days after approval of the modeling work plan, the Permittee shall complete
all modeling in accordance with the approved work plan and submit a final report for
Executive Secretary approval. In the final report, the Permittee may include supplemental
information to justify modification of certain Permit requirements, including, but not
limited to: the number and types of groundwater compliance monitoring parameters,
tailings cell cover system engineering design and construction specifications, tailings cell
operational requirements, etc. Upon Executive Secretary approval of the final infiltration
and contaminant transport report, the Reclamation Plan may be modified to accommodate
necessary changes to protect public health and the environment.
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1 1. Plan for Evaluation of Deep Supply Well WW-2 - within 1 year from issuance of this
Permit, the Permittee shall submit for Executive Secretary approval a plan for evaluation
of the annular casing seal in water supply well W-W-2. The objective of this plan is to
ensure adequate well casing and annular seals, in compliance with the regulations of the
Utah State Engineer (UAC R655-4-9), with special emphasis on creating both a physical
barrier and hydraulic isolation between the shallow unconfined and the deep confined
aquifers. After approval of the plan, the Permittee shall completely execute all provisions
of the plan on or before decommissioning of the White Mesa mill.
12. DMT Monitoring Plan - within 90 days of issuance of this Permit, the Permittee shall
submit a Facility DMT Monitoring Plan for Executive Secretary approval. The purpose
of said plan shall be to provide adequate design and construction of DMT monitoring
equipment, adequate equipment operation and maintenance procedures to monitor DMT
compliance with the requirements of Parts I.D.l and I.D.3; adequate DMT monitoring
procedures in compliance with Parts I.E.6; and adequate DMT reporting procedures in
compliance with Parts I.F.2 and I.F.3 of this Permit. Said plan shall include, but is not
limited to:
a) Design and constructionof a wastewater pool elevation gauge to be installed at each
tailings cell, or procedures and equipment needed for completion of periodic
wastewater elevation surveys.
b) Designation of a water level measuring point on the slimes drain access pipe at both
Tailings Cells 2 and 3.
c) Based on historical consffuction information and actual measurements, determine the
down-slope depth for the lowest point on the FML found at or near the base of the
slimes drain access pipes for both Cells 2 and 3.
d) Determination of an average allowable wastewater head in the slimes drain layers at
both Cells 2 and 3 that is as low as reasonably achievable.
e) Design and construction of a water level gauge, or procedures and equipment needed
for completion of periodic elevation surveys at the Robens Pond to measure
wastewater levels above the lowest point on the pond's FML.
0 Procedures for monitoring the Feedstock Storage Area to determine appropriate
location of feedstock storage, and water-tight condition of containerized feedstocks.
g) Weekly monitoring and record keeping to determine compliance with Parts I"D.3, and
I.E.6.
Within 30 days of approval of said plan, the Permittee shall complete installation and
make operational all equipment required to comply with this Permit. After approval of
said plan the Executive Secretary may re-open and modify this Permit to incorporate any
additional equipment, operation, and maintenance procedures needed for DMT
monitoring.
13. Tailings Cell4A Contaminant Removal Schedule and Report - within 90 days of
issuance of this Permit, the Permittee shall submit for Executive Secretary approval a
schedule for completion of removal of waste, wastewater, slimes drain material, existing
FML liners, underlying leak detection system materials, and any contaminated subsoils
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under Tailings Cell 4A, including periodic progress reports. The purpose of this workshall be to recover, remove all contaminated materials and to disptse of these materials inTailings Cell 3. Within 60 days of completion of contaminant rernoval from TailingsCell 44, the Permittee shall submit a report for Executive Secretary approval.
14' Tailings Cell 44 Redesign and Reconstruction - after contaminant removal pursuant toPat I'H.14, and prior to any new construction including, but not limited to: ioundations,sub-base materials, liners, or leak detection systems at existing Tailings Cell 4A, thePermittee shall:
Submit engineering design plans and specifications that demonstrate how the newconstruction will comply with the requirements of the Utah Water euality Act, allrules and regulations promulgated thereunder, and the Best Availabfu Technologyrequirements mandated by part I.D.4 of this permit.
Secure prior Executive Secretary approval and issuance of a construction permit.Thereafter, this Permit may be re-opened and modified to reflect the new design andconstruction specifications, and any related operations, monitoring, or reportirigrequirements necessary.
15. Contingency Plan - within 180 days of issuance of this Permit, the permittee shall submita Contingency Plan for Executive Secretary approval that provides a detailed list ofactions the Permittee will take to regain compliance with permit limits and DMTrequirements defined in Parts I.C and I.D of this Permit. At a minimum, the ContingencyPlan will include, but is not limited to measures to resolve the following general
categories of non-compliance :
Groundwater Contamination - as shown by any contaminant concentrations incompliance monitoring wells that exceed their respective groundwater compliancelimit found in Part LC.l and Table 2 of this permii.
Mill Discharge Violations - including unauthorized discharge or release of prohibited
contaminants to the tailings cells, pursuant to partr.c.z andl.c.3; and
c) DMT Violations - which include several types of non-compliance, including but notlimited to:
1) Excess tailings cell wastewater pool elevation above the maximum elevations
mandated by Part I.D.3;
2) Excess head in the Tailings Cells 2 and,3 slimes drain system, pursuant to part
I.D.3 and as defined by the DMT Monitoring plan in part I.H.13; and
3) Excess elevation for tailings solids as required by part I.D.3.
After approval of the Contingency Plan, the Executive Secretary may re-open and modifythis Permit to include any new requirements therefrom.
16. Stormwater Best Management Practices Plan - within 180 days of permit issuance thePermittee shall submit a final Stormwater Best Management Practices plan for Executive
Secretary approval. Said plan shall comply with the requirements of part I.D.g of thispermit. Upon Executive Secretary approval, the Permittee shall immediately implement
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all provisions of said plan.
17. Roberts Pond As-Built Report - within 90 days of issuance of this Permit, the Permittee
shall submit for Executive Secretary review and approval a As-Built Report for the
Roberts Pond. Said report shall document:
a) All contaminant removal and re-construction activities completed by the Permittee in
2002,
b) Engineering drawings and specifications to adequately describe and verify the recent
reconstruction efforts.
After review of this report, the Executive Secretary may require modification of the
Reclamation Plan in order to provide adequate demolition and decontamination of the
Roberts Pond at the time of facility closure, and to protect public health and the
environment.
18. Tetrahydrofuran Demonstration Study Work Plan and Report - within 30 days of
issuance of this Permit, the Permittee shall submit a work plan to examine and determine
the root cause of continuing tetrahydrofuran (T[IF) contamination identified in several
existing monitoring wells at the facility, including but not limited to wells: MW-l, MW-
2, MW-3, MW-5, and MW-12. Said plan shall be submitted for Executive Secretary
approval, and shall include collection of direct evidence to verify the source and extent of
TIIF contamination in the aquifer. Such work shall include field and laboratory studies to
determine if the TIIF contamination is localized near each individual well casing and/or
screen, or if it is more broadly distributed across the shallow aquifer.
The Permittee shall complete said studies outlined by the approved plan and submit a
final report for Executive Secretary approval within 90 days of issuance of this Permit.
The Permittee shall provide at least a 30-day notice of any fieldwork related to this plan,
to allow the Executive Secretary to observe all field activities and split any groundwater
quality samples related to this demonstration.
In the event that the Executive Secretary determines that the TIIF concentrations found in
local groundwater are not the result of either historic or current facility operations, this
Permit will be re-opened and Table 2 modified by removing TIf as a GWCL parameter.
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PART tr. REPORTING REQIJIREMENTS
RspREsrNTerrvE Srumwc. Samples taken in compliance with the monitoring requirements
established under Part I shall be representative of the monitored activity.
ANeryncar Pnocsur-rnns. Water sample analysis must be conducted according to test
procedures specified underUAC R317-6-6.3.12 unless othertestprocedures have been specified
in this permit.
kNarrres ron Tervprnxa. The Act provides that any person who falsifies, tampers with, or
knowingly renders inaccurate, any monitoring device or method required to be maintained under
this permii shall, upon conviction, be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not more than six months per violation, or by both'
RsBonnrqc oF MoMToRrNc Rrsurrs" Monitoring results ohtainerl dunng reporting periods
specified in the permit, shall be submitted to the Executive Secretary, Utah Division of Water
{uality at the following address no later than the date specified following the completed
reponing period:
Attention: Compliance and Monitoring Program
State of Utah
Division of Water QualitY
Department of Environmental Quality
Salt Lake CitY, Utah 84114-4870
The quarterly due dates for reporting are: June l, September 1, December 1, and March 1.
CotgnNcE SCIfiDr.I-ES. Reports of compliance or noncompliance with, or any progress
reports on interim and final requirements contained in any Compliance Schedule of this permit
shall be submitted no later than 14 days following each schedule date.
Aopmouar Morqtonwc By rIrE Prnrvrrrrs. If the permittee monitors any pollutant more
frequently than required by this permit, using approved test procedurel as specified in this
permit, the results of tt ir monitoring shall be included in the calculation anil reporting of the data
submitted. Such increased frequency shall also be indicated.
G. RgCORDS CONIENTS.
1. Records of monitoring information shall include:
The date, exact place, and time of sampling, observations' or measurements:
The individual(s) who performed the sampling, observations, or measurements;
The date(s) and time(s) analyses were performed;
The name of the certified laboratory which performed the analyses;
The analyical techniques or methods used; and,
The results of such analyses.
H. RrrsN-11oN oF Rrconos. The permittee shall retain records of all monitoring information,
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including all calibration and maintenance records and copies of all repo{s required. by this
permit, and records of all data used to complete the application for this permit, for a period of at
ieast five years from the date of the sample, measurement, report or application. This period may
be extended by request of the Executive Secretary at any time.
The permittee shall verbally report any noncompliance which may endanger public health or
the environment as ,oon u, possible, Lut no later than 24 hours from the time the permittee
first became aware of the circumstances. The report shall be made to the u.tatr Department of
Environmental euality 24 hour number, [phone], or to the Division of Water Quality,
GroundWaterprotection Section at [phone], duringnormal businesshours (8:00 am
- 5:00 pm Mountain Time).
A.written submission shall-also be provided to the Executive Secretary within five days of
the time that the permittee becomes aware of the circumstances. The written submission
shall contain:
A description of the noncompliance and its cause;
The period of noncompliance, including exact dates and times;
The estimated time noncompliance is expected to continue if it has not been corrected;
and,
d) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncomPliance.
3. Reports shall be submitted to the addresses in Part tr.D, Reporting of Monitoring Results'
Orrrn NoNcorwuaNcs RrponrNc. Instances of noncompiiance not required to be reported
within 5 days, shall be reported at the time that monitoring reports for Part tr.D are submitted'
IxspectoN eNo Exrny. The permittee shall allow the Executive Secretary, or an authorized
+p***.,ive, upon the presentation of credentials and other documents as may be required by
law, to:
l. Enter upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of the permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this Permit;
Inspect at reasonable times any facilities, equipment (including monitoring and control
"luiprn"n,),
practices, or operations regulated or required under this permit; and,
Sample or monitor at reasonable times, for the purpose of assuring pernrit compliance or as
otherwise authorized by the Act, any substances or parameters at any location'
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PART M. COMPLTANCE RESPONSIBILITIES
Dury ro CoMpLy. The permittee must comply with all conditions of this permit. Any permit
noncompliance constitutes a violation of the Act and is grounds for enforcement action; for
permit termination, revocation and re-issuance, or modification; or for denial of a permit renewal
application. The permittee shall give advance notice to the Executive Secretary of the Division
of Water Quality of any planned changes in the permitted facility or activity which may result in
noncompliance with permit requirements.
PrNarrres FoR VIoLATToNS oF PERMIT CoNomoNs. The Act provides that any person who
violates a permit condition implementing provisions of the Act is subject to a civil penalty not to
exceed $10,000 per day of such violation. Any person who willfully or negligently violates
permit conditions is subject to a fine not exceeding $25,000 per day of violation. Any person
convicted under Section 19-5-115 of the Act a second time shall be punished by a fine not
exceeding $50,000 per day. Nothing in this permit shall be construed to relieve the permittee of
the civil or criminal penalties for noncompliance.
Nrro ro Harr oR Rroucr Acmrrry Nor A DEFENSE. It shall not be a defense for a permittee in
an enforcement action that it would have been necessary to halt or reduce the permitted activity
in order to maintain compliance with the conditions of this permit.
Drrry To MmcAre. The permittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
koprn Opnnauou Ar{D MAtr[Er\ANcE. The permittee shall at all times properly operate and
maintain all facilities and systems of treatment andcontrol (andrelated appurtenances) which are
installed or used by the permittee to achieve compliance with the conditions of this permit.
Proper operation and maintenance also includes adequate laboratory controls and quality
assurance procedures. This provision requires the operation of back-up or auxiliary facilities or
similar systems which are installed by a permittee only when the operation is necessary to
achieve compliance with the conditions of the permit.
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PART TV. GENERAL REQI.JIREMENTS
A. praNr.nD CHANcES. The permittee shall give notice to the Executive secretary as soon as
possible of any prurn"o physical alteration-s or additions to the permitted facility' Notice is
ffirea when-the alteration or addition could significantly change the nature of the facility or
increase the quantity of pollutants discharged'
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ANucrperroNoNcorwrr6Nce. The permittee shall give advancenotice of anyplannedchanges
i;;;;tted facility or activity which may result in noncompliance with permit requirements.
PBrurr ACTTONS. This permit may be modified, revoked and reissued, or terminated for cause'
The filing of a requesiuy ttre permittee for apermit modification, revocation and re-issuance' or
termination, or a notifirutio, brptanned changes or anticipated noncompliance, does not stay any
permit condition.
Drrry ro REAppLy. If the permittee wishes to continue an activity regulated by this permit after
the expiration date of this permit, the permittee must apply for and obtain a new permit' The
uppfi.r,ion should be subrnitted at leasl 180 days before the expiration date of this permit'
DuryropnovIDEINFioRMATroN. The permittee shall furnish to the Executive Secretary, within
a reasonable time, any information which the Executive Secretary may request to determine
whether cause exists for modifying, revoking and reissuing, or terminating this permit' or to
determine compriance with this p"r-ir, Thl permittee shall also furnish to the Executive
Secretary, upon request, copies of records required to be kept by this permit'
F. ourn INFpRMATIoN. when the permittee becomes aware that it failed to submit any relevant
facts in a permit application, or rub-itt"d incorrect information in a permit application or any
rcport to tire g*ouiir" Secretar/, it shall promptly submit s,ch facts or information'
G. StcN^ronyRreunrrmrvrs. All applications, reports orinformation submittedtotheExecutive
Secretary shall be signed and certified'
1. All permit applications shall be signed as follows: :
a)Foracorporation:byaresponsiblecorporateofficer;
b) For a partnership or sole proprietorship: by a general partner or the proprietor'
respectively.
c) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official'
2. All reports required by the permit and other information requested by the Executive Secretary
shall be signed by a person described above or by a duly authorized representative ofthat
person.epersonlsaautyauthorizedrepresentativeonlyit
The authori zationis made in writing by a person described above and submitted to the
Executive Secretary, and,
The authorization specified either an individual or a position having responsibility for the
overall operation oi,f,. regulated facility or activity, such as the position of plant
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Permit No. UGW370004
manager, operator of a well or a well field, superintendent, position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the cbmpany. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.)
3. Changes to Authorization. ff an authori zation under Part IV.G.2. is no longer accurate
because a different individual or position has responsibility for the overall operation of the
facility, a new authorization satisfying the requirements of Part w.G.2 must be submitted to
the Executive Secretary prior to or together with any reports, information, orapplications to
be signed by an authorized representative.
4. Certification. Any person signing a document under this section shall make the following
certification:
"I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations. "
H. krr.tALTEs FoR FelsmcenoN oF REPoRTs. The Act provides that any person who knowingly
makes any false statement, representation, or certification in any record or other document
submitted or required to be maintained under this permit, including monitoring reports or reports
of compliance or noncompliance shall, upon conviction be punished by a fine of not more than
$10,000perviolation, orbyimprisonment fornotmorethan six months perviolation, orbyboth.
I. Avarenrrrv onRrponrs. Except for data determined to be confidential by the permittee, all
reports prepared in accordance with the terms of this permit shall be available for public
inspection at the offices of the Executive Secretary. As required by the Act, permit applications,
permits, effluent data, and ground water quality data shall not be considered confidential.
J. kopBnrv fucnrs. The issuance of this permit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations.
K. SrvrnasIUTY. The provisions of this permit are severable, and if any provision of this permit,
or the application of any provision of this permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this permit, shall not
be affected thereby.
L. TRaNsrrns. This permit may be automatically transferred to a new permittee if:
l. The current permittee notifies the Executive Secretary at least 30 days in advance of the
proposed transfer date;
2. The notice includes a written agreement between the existing and new permittee containing a
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Part IV
Permit No. UGW37W4
specific date for transfer of permit responsibility, coverage, and liability between them; and,
3. The Executive Secretary does not notify the existing permittee and the proposed new
permittee of his or her intent to modify, or revoke and reissue the permit. If this notice is not
received, the transfer is effective on the date specified in the agrcement mentioned in
paragraph 2 above.
M. Srarr Lews. Nothing in this permit shall be construed to preclude the institution of any legal
action orrelieve the permittee from anyresponsibilities,liabilities, penalties establishedpursuant
to any applicable state law or regulation under authority preserved by Section 19-5-1 15 of the
Act.
N. ReopnNrn h.ovrsroNs. This permit may be reopened and modified (following propr
administrative procedures) to include the appropriate limitations and compliance schedule; if
necessary, if one or more of the following events occuts:
1. If new ground water standards are adopted by the Board, the permit may be reopened and
modified to extendthe terms of the permit orto include pollutants coveredbynew standards.
The permittee may apply for a variance under the conditions outlined in R317-6-6.4(D).
2. Changes have been determined in background ground water quality.
3. The Executive Secretary determines permit modification is necessary to protect human health
or the environment.
LBM:lm
F:/.../IUCgwPemit2h.doc
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DRAFT
Utah Division of Radiation Control
Ground Water Quality Discharge permit
Statement of Basis
For a
Uranium Milling Facility
At White Mesa, South of Blanding, Utah
Owned and Operated by
International Uranium (USA) Corporation
Independen ce plaza, Suite 950
1050 17th Street
Denver, Colorado 80265
December 1,2004
Purpose
The purpose of this Statement of Basis (SOB) is to describe technical and regulatory basis to
proposed permit requirements found in a Ground Water Quality Discharge Permit No.
UGW370004, (hereafter Permit) for the International Uranium (USA) Corporation (hereafter
IUC) uranium mill facility located about six miles south of Blanding, Utah on White Mesa in
Sections 28,29,32, and 33, Township 37 South, Range 22Bast, Salt Lake Base and Meridian,
San Juan County, Utah.
Introduction and Historv
The White Mesa uranium mill was constructed in 1979-1980 and licensed under federal
regulations by the Nuclear Regulatory Commission (NRC), Source Material License SUA-1358
(hereafter NRC License). Initially, the facility consisted of the mill works and one tailings
disposal cell, Cell 2, which was completed in May, 1980 (2182D'Appolonia Consulting
Engineers Report, p. 3-l). In June, 1981 construction of a wastewater storage pond, Cell l, was
completed (ibid., p. l-1). Conskuction of a second tailings cell, Cell 3, was completed in
September,l9S2 (3/83 Energy Fuels Nuclear Report, p.l-2). Finally, tailings disposal Cell4A
was completed in January, 1990 (5128199 IUC Groundwater Information Report, p. A-11).
However, Cell 44 has not been used yet for tailings disposal, but instead foistorage of raffinate
(personal communication, Mr. Harold Roberts).
Groundwater at White Mesa is primarily found in two aquifers: a shallow unconfined or perched
aquifer, and a deep underlying confined aquifer. The shallow aquifer is found almost entirely in
the Cretaceous-age Burro Canyon Formation, where groundwater is perched on top of the
underlying Jurassic-age Brushy Basin Member of the Morrison Formation. The Brushy Basin
Member is about 200 - 400 feet thick and consists of low permeability shale and mudstone in the
Blanding area (Hintze, p. 200). At White Mesa, IUC estimates that the Brushy Basin member is
about 295 feet thick (7 194 Titan Environmental Report, Fig. 1 .2). From information provided by
IUC, the geologic contact between these two formations is found at a depth of about 78 to I49
feet below ground surface (bgs, see 9/6102IUC map submittal). The waier table in the perched
aquifer is found at shallower depths, and discharges to seeps and springs along the margin of
White Mesa. Upgradient of the mill site, the perched aquifer is used for drinking water, stock
I
Statement of Basis DRAFT December 1,2004
watering, and irrigation. Downgradient of the mill site, the perched aquifer supports stock
watering and some wildlife habitat.
The deep confined aquifer under White Mesa is found in the Entrada and underlying Navajo
Sandstones. IUC estimates the top of the Entrada Sandstone at the site is found at a depth of
more than 1,150 feet bgs (Tlg4TiianEnvironmental Report, Fig. 2.3). This deep aquifer is
hydraulically isolated from the shallow perched aqulfl by at least two (2) shale members of the
Morrison Formation, including the Brushy Basin l-295 feet thickl and the Recapture [- 120 feet
thickl Members (ibia., nig. l.i). Other formations are also found between the perched and deep
confined aquiferi, that also include many layers of thin shale interbeds that contribute to
hydraulic isolation of these two groundwater systems, including: the Morrison Formation
festwater Canyon [- 60 feet thick], and Salt Wash [- 105 feet thick] Members, and the
Summerville normation [- 100 feeittrictl (ibid.). Artesian groundwater conditions found in the
deep Entrada/I.{avajo Sandstone aquifer also reinforce this concept of hydraulic isolation from
the shallow perched system. Regionally, the deep confined aquifer is the primary drinking water
supply, and must be piotected from pollution sources. A few miles south of the mill site the Ute
Mountain Ute comrnunity depends on this deep confined aquifer for drinking water supply.
Between 1979 and 1997 the initial groundwater monitoring program approved by NRC for the
facility examined up to 13 wells and 20 different chemical and radiological contaminants; largely
collected o, u qrru.t.rly basis. ln lggT , after examination of the historical data, the NRC reduced
the monitoring program to six (6) point of compliance (POC) wells in the perched aquifer, all
found a short distarice south of raitlngs Cells 3 and 4,{. These include IUC wells MW-5, MW-
11, MW-12, MW-14, MW-15, and MW-I7. Atthe same time the NRC reduced the number of
analytical parameters to four (4) contaminants that the NRC considered dependable indicators of
tailings ceil leakage: chloride, nickel, potassium, and uranium. This is the same quarterly
moniioring program recently used by IUC to demonstrate compliance with its NRC License'
Under the NRC approved progpm IUC uses an intra-well control chart method to determine
compliance. This methodiompares recent groundwater quality results in each individual PoC
weliwith a control limit for each analyte. In practice, control limits are calculated individually
for each monitoring well and analyte, based on historical or background data that has not been
altered or influenc.a uy the activiiy in question (EPA, February, 1989, pp.7-l andT-L2).
Determination of non-compliance o"c.rir when a recent concentration exceeds its individual
control limit on the controf chart (ibid. ,7-5). Information provided by IUC shows that control
limits were established under the NRC License for four analytes: chloride, nickel, potassium,
and uranium (glg4TitanEnvironmental Report, Appendix B). Since 1979,the Mill has not
received any violation under its NRC approved groundwater monitoring program. To verify this
apparent compliance, the Executive Secietary has required submittal of an historical Background
dround Watei euality Report, pursuant to Part I.H.3 of the Permit.
In May, lggg IUC and the utah Division of Radiation control (DRC) commenced an annual
split sampling program for groundwater monitoring wells at the White Mesa facility. This
program *u. .o*ir.hensivi in that it included all monitoring wells at the facility completed in
it "-rtrutto* aquifer (not just pOC wells), and a large number of groundwater contaminants,
including: heavy 111rtutr, nutrients, general chemistry analytes, radiologics, and volatile organic
compounds (VOCs).
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Statement of Basis DRAFT December 1,2004
During the May, 1999 split sampling event excess chloroform concentrations were discovered in
monitoring well MW-4, which is not a NRC POC well, found along the eastern margin of the
site. Because these concentrations were above the State Ground Water Quality Standard
(GWQS), the DRC initiated enforcement action against IUC on August 23,1999 thru issuance of
a Groundwater Corrective Action Order, which required completion of: l) a contaminant
investigation report to define and bound the contaminant plume, and 2) a groundwater corrective
action plan to clean it up. Repeated groundwater sampling by both IUC and DRC have
confirmed the presence of chloroform in concentrations that exceed the State GWQS along the
eastern margin of the site in wells that appear to be upgradient or cross-gradient from the tailings
cells. Other VOC contaminants have also been detected in these samples. After installation of
20 new monitoring wells at the site, groundwater studies appear to have defined the eastern and
southern boundaries of the chlbroform plume. IUC believes the source of this contamination
was caused by laboratory wastewater disposal activities that pre-dated mill operation. While the
exact number and location of all the potential chloroform sources is still not yet resolved, an
experimental long-term pump test was initiated in April, 2003 to investigate one possible cleanup
methodology.
While the contaminant investigation and groundwater remediation plan are not yet complete, the
DRC believes that additional time is available to resolve these requirements based on the
following factors: 1) hydraulic isolation found between the shallow and deep confined aquifers,
2) the large horizontal distance and the long groundwater travel times between the existing
groundwater contamination on site and the seeps and springs where the shallow aquifer
discharges at the edge of White Mesa, and 3) lack of human exposure for these shallow aquifer
contaminants along this travel path. Upon completion of the contaminant investigation and
before approval of the groundwater remediation plan, the DRC will provide a public comment
period and hearing to inform the local community of the planned cleanup actions and receive
comments thereon.
With all this as a backdrop, the NRC delegated its uranium mill regulatory program to the State
of Utah, effective August 16,2004. As a result, the DRC is the primary regulatory authority for
the IUC White Mesa mill for both radioactive materials and groundwater protection. Shortly, the
existing NRC Source Materials License will be converted to a State Radioactive Materials
License (RML). tn this process, this proposed Permit will replace the groundwater protection
provisions of the NRC Source Materials License.
After review of the existing design, construction, and operation of the IUC facility; and after
consideration of the requirements in both the Utah Water Quality Act (Utah Code Annotated l9-
5) and the Ground Water Quality Protection Regulations (Utah Administrative Code R317-6),
the DRC has determined that a number of changes and enhancements are required in order to
meet State requirements for groundwater protection. These changes are discussed in detail
below.
Maior Permit Requirements
1. Groundwater Classification (Part I.A and Table 1) - was assigned by the Executive
Secretary on a well-by-well basis after review of groundwater quality characteristics for
the shallow aquifer at the IUC White Mesa site. A well-by-well approach was selected
by the Executive Secretary in order to acknowledge the spatial variability of groundwater
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Statement of Basis DRAFT December 1,2004
ffil'#.?lii:jyf,r;'Ji?,,ffi1ffifi:ru1il"f,",1T*1il"ff-::;ll"-T,?ithe
sharrow I
classification at the IUC facility are discussed below:
TDS Backeround Concentrations - the Executive Secretary has established a
general policy that allows groundwater classification to be based on a statistical
construct of the mean total dissolved solids (TDS) concentration plus the second
standard deviation (X+2o). Using a well-by-well approach, this X+2o value
would be derived from available data from each individual well. Inherent in this
approach is the assumption that the TDS data used for this basis is composed
solely of data representative of background or natural conditions at the site, and
not groundwater quality altered by the facility in question.
In determination of the background TDS concentrations, the Executive Secretary
typically considers concentration trend or time series analysis. Spatial analysis of
the data may also be considered to evaluate proximity of the reported
concentrations to possible contamination sources. lncreasing contaminant trends
in individual wells, spatial contaminant distribution pattems, and other statistical
considerations may be used to identify the presence of man-caused groundwater
pollution at the site. These types of evaluations are especially important at
existing facilities that pre-dated the 1989 promulgation of the GWQP rules; such
as the IUC White Mesa site.
Evaluations of this kind will be submitted shortlyby IUC in the Background
Groundwater Quality Report (Part I.H.3), and reviewed by the Executive
Secretary. Pending this submittal, the Executive Secretary has decided to base the
well-by-well groundwater classification on the average TDS concentration
available, and omit any consideration of concentration variance. This approach is
conservative, in that it will result in a generally lower concentration basis for the
classification decision. At some fufure date, when such evaluations are available
and found acceptable by the Executive Secretaty, the background TDS
concentrations will be revised, and the Permit re-opened and modified, pursuant
to Part fV.N.2 or 3 of the Permit.
Impact of Historic Wildlife Pond Recharge (Local Groundwater Mounds) - IUC
has demonstrated that four (4) existing wildlife ponds at the White Mesa facility
discharge water to the shallow aquifer, that in turn has created two (2) local
groundwater mounds; one (l) each at the Northern and Southern Wildlife Ponds
(see l0/15/02 IUC submittal, water level map). The existence of these
groundwater mounds has been confirmed by the Executive Secretary thru both
independent water level measurements and preparation of a water table contour
map for the White Mesa facility for the September,2002 split sampling event (see
Attachment 1, below).
The quality of water maintained in these wildlife ponds is likely high, in that it is
derived from Recapture Reservoir. Water from this reservoir is conveyed to the
IUC facility via a buried pipeline, where part of the supply is used in milling
operations, and another part is diverted to the wildlife ponds to support aquatic
life and habitat for migrating waterfowl (personal communication, Mr. Harold
Roberts, IUC). No lining system was constructed under any of the wildlife ponds
(ibid.). As a result, the wildlife ponds provide a nearly constant source of high
quality recharge to the shallow aquifer at the site. Therefore, it is possible that
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Statement of Basis DRAFT December 1,2004
this recharge has significantly improved localized water quality conditions in the
shallow aquifer; thereby encouraging a wide variability in quality conditions.
This and other sources of water quality variation give rise to the need for well-by-
well protection of groundwater quality at this site.
C. TDS Basis for Classification - one key element in determination of groundwater
class is the TDS content of the groundwater, as outlined in the GWQP Rules, see
Utah Administrative Code (UAC), R317-6-3. Groundwater quality data collected
by both IUC and the DRC show the shallow aquifer at White Mesa has a highly
variable total dissolved solids (TDS) content, rangrng from about 600 to over
5,300 mg/l (see Attachment 2, below).
Using all available TDS data, and after calculation of average TDS concentration
for 33 wells including both POC and temporary wells, the Executive Secretary
determined that 16 wells at the facility appear to exhibit Class II or drinking water
quality groundwater. Seventeen (17) other wells appear to exhibit Class III or
limited use groundwater at the site. For details, see Attachment2, below.
Close review of the available data shows that the historical IUC data, the recent
IUC split sampling data, andthe corresponding DRC split sample results are
largely comparable, with a few exceptions. In the case of historical IUC well
MW-19, the IUC historical TDS data (10179 thru 5/99) produced an average TDS
that was significantly lower than the average TDS based on the recent DRC or
IUC split sampling data (5199 thru9102). Because the older IUC data are
conservatively lower, the Executive Secretary chose to rely on the older IUC TDS
data to determine groundwater class for well MW-19.
D. GWOS Basis for Classification - another key element in determination of
groundwater class is the presence of naturally occurring contaminants in
concentrations that exceed their respective GWQS. [n such cases, the Executive
Secretary has cause to downgrade aquifer classification from Class II to Class III
(see UAC R317-6-3.6). Historic IUC data and more recent split sampling data
suggest that several groundwater contaminants may be found with concentrations
above their respective GWQS in a number of wells at the site. These wells and
parameters from recent split sampling are summarizedinAttachment 3, below.
Some of these wells with excess contaminant concentrations are associated with
the on-going chloroform investigation at the east margin of the site (see 8123199
Ground Water Corrective Action Order). With regard to historic excess
concentrations found at the site, the NRC previously deemed these to be of natural
origin. While some or all of these excess concentrations may be natural, the
Executive Secretary has not yet fully evaluated the available data.
For this and other reasons, the Executive Secretary has required IUC to evaluate
groundwater quality data from the existing wells on site, and prepare and submit
for approval a Background Groundwater Quality Report, in Part I.H.3 of the
Permit. After review and approval of this report the Executive Secretary may
determine the origin of these excess contaminant concentrations, and an
appropriate groundwater classification(s) for the White Mesa facility.
Backeround Ground Water Oualitv (Part I.B. I.H.3. and I.H.4) - a significant amount of
historic groundwater quality data has been collected by IUC for many wells at the
facility. In some cases, these data extend back about 25 years to September,1979.
Statement of Basis DRAFT December 1,2004
However, the Executive Secretary has not yet completed an evaluation of the historic
IUC data, particularly with regards to data quality, and quality assurance issues. Such an
examination needs to include, but is not limited to: justification of any zero
concentration values reported, adequacy of minimum detection limits provided
(particularly with respect to the corresponding GWQS), adequacy of laboratory and
analytical methods used, consistency of laboratory units of reporting, internal consistency
between specific and composite types of analysis (e.g. major ions and TDS),
identification and justification of concentration outliers, and implications of concentration
trends (both temporal and spatial).
During the review conducted to date, several groundwater quality issues came to the
attention of the Executive Secretary that also need to be addressed and resolved by the
Permittee in the Background Groundwater Quality Report. Some of these issues, include
the following:
A. Several Contaminants Recently Found to Exceed Respective GWQS - recent
DRC split-sampling of groundwater at the IUC facility has found that several
contaminants exceeded their respective GWQS during one or more of the four (4)
split sampling events conducted by the DRC between May, 1999 and September,
2002. With regards to those wells considered for tailings cell monitoring, the
contaminants with excess concentrations include the following (see Attachment 3,
below):
l) Manganese (MW-3, MW-14, MW-32 [formerly TW4-17])
2) Nitrate (MW-4),
3) Selenium (MW-l, MW-4, MW-l5, MW-l7), and
4) Uranium (MW-3, MW-4, MW-14, MW-15, MW-17, and MW-18).
The exceedances found in well MW-4 appear to be related to the chloroform
contamination. While the remaining exceedances may be due to natural causes,
the Executive Secretary has not fully evaluated the available data, and has
therefore required IUC to perform this evaluation.
B. Lone-Term Increasing Uranium Trend: Downsradient Wells - while recent
groundwater quality data from the last l8-months suggests a stable or decreasing
trend, the long-term uranium concentrations for the last l l to 15 years indicate an
increasing trend exists in three (3) downgradient wells at the IUC facility,
including: Mw-14, Mw-15, and MW-17 (Attachment 4, below). IUC believes
that the cause for these increasing uranium trends is due to geochemical changes
brought on by the effects of the groundwater mound created by the nearby
wildlife ponds. While evidence to substantiate this has yet to be provided to and
approved by the Executive Secretary, the exact cause for these long-term
increasing trends is currently unknown, and may be due to a variety of factors that
deserve further study and explanation.
C. Downeradient Uranium Spatial Concentration Hieh - the same three (3)
downgradient wells that exhibit a long term increasing uranium trend are also
found near a spatial concentration high, located downgradient of Tailings Cell4A.
A fourth well, MW-3 is also found inside this concentration high and exceeds the
State GWQS (30 ug/l). For details, see the uranium isoconcentration map based
on September,2002 DRC split sampling results in Attachment 5, below (DRC
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Statement of Basis DRAFT December 1,2004
art - the GWQP Rules provide for the
1"j::lyr111orctg.""d water Protectior LEek (GwPis) to be used as early-warningindicators of impending groundwater pollution. Under this approa"rr, ."-prirlr." i,determined after comparison of groundwater quality monitoring ,.ruit, wiitr ttre GWpLsin each well and for each parameter. said GWpLs are set in the permit afterdetermination that the particular contaminant is detectable in groundw atet atthe facility,its corresponding Gw_es, and its analytical Minimum Detect[n Limit (MDL). Asprovided in the GWQP Rules, these GWPLs are calculated as outlined in Table l, below.
Because background groundwater quality at the IUC facility has not yet been approved,the Executive Secretary cannot determine if any contaminant is naturally occufrng andtherefore detectable or undetectable for purposes of selecting GWpLs in each well.Consequently, the Executive Secretary *itt-iritiatty assign the GWpLs as if they were
map U238-9-02.srf). As shown there, well MW-14 represents the maximumuranium concentration during the September,2002split sampling event (56.7ugll). It is interesting to note that the average linear groundwater velocity(hereafter velocity) found in well MW-14 is one of the highest on site, 62feet/year (10/t9104 Hydro Geo Chem,Inc [HGC] Report, Table l). Furthermore,well MW-14 appears to be located on an uppur.rt prif.ora groundwater flowpath found between it and well MW-I1 which hasihe highei velocity at the site,135 feet/year (ibid., and Attachment L2,DRC groundwater velocity ctntour mapgwflowrate.srf, below).
Two other uranium concentration high points exist at the White Mesa site whereuranium exceeds the State GWQS, including IUC wellsTw4-lg and TW4-l l (seeAttachment :,-Dlc mapU23g_9-02b.srf). However, these two wells appear to beassociated with the chloroform contamination plume.
The cause for the uranium concentration highs found downgradient of Cell 44 and itscoincidence with an apparent preferred groundwater flow path is unknown at this time,and may be due to a variety of factors that deserve further study. These observations andothers indicate that great care must be taken by the Executive Secretary in determinationof background groundwater quality for the compliance monitoring weils at the site; inorder to ensure that any GWCL established by Fermit has not been affected by historicfacility operations. As a result, a detailed evaluation of these and other gro.rrri waterquality concems was added to the Permit ln Part I.H.3 (Background Gro'undwater eualityReport). After submittal of this report and resolution oithese and other groundwaterquality issues, an agreement can be reached regarding descriptive groundwater qualitystatistics and determination of background ground*ui", quality at the IUC facility. Atthat point, the Permit will be re-opened andhe background groundwater concentrationsand related compliance limits modified, see discussion below.
Because Part I.H.1 of the Permit calls for installation of several new monitoring wellsgound the tailings cells, background groundwater quaiity will also need to be Jeterminedfor these monitoring points. To this end, Part I.H.4 was created to require IUC to collectat least eight (8) quarters of groundwater quality data, and submit a second report forExecutive Secretary approval to establish background groundwater quality for the.ewells' Upon approval of this report, the Executive Secietary will re-open the permit andestablish groundwater classifications, background ground water quality concentrations,and compliance limits, as appropriate and uutrro.irea by part IV.N.2 and 3.
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Statement of Basis DRAFT December 1,2004
..undetectable". After submittal and Executive Secretary approval of the existing well
Background Ground Water Quality Report, pursuant to Part I.H.3, the Permit can be re-
op.r.d and the GWPLs modified, see discussion below. Accordingly, the GWPLs set
toaay in Table 2 of the Permit were calculated by use of the classification factors, being
0.25 and0.5 times the GWQS for Class II and III groundwater respectively.
Table l. General Ground Water Protection Level Determinations
1) BG = background concentratron
2) MDL = minimum detection limit
During a meeting of August 12,2003,IUC staff expressed a concern with this approach
in that it does not recognize spatial variability of groundwater quality in the aquifer.
Accordingly, IUC asked the Executive Secretary to downgrade the aquifer classifications
for the Wttit" Mesa Facility, from Class II to Class III, in order to ensure that a large
enough factor is used in determination of the GWPL, so that natural temporal variations
in grJundwater quality at each well do not cause unnecessary non-compliance under the
permit. At the treart of ttris concern is the need to avoid false positive violations of the
GWpLs assigned under the Permit; unnecessary groundwater monitoring and analytical
costs; unneeded enforcement efforts; and undue public concem.
The Executive Secretary acknowledges these "on""*J, and in an effort to address them
has arrived at an alternative approach to groundwater quality compliance that will
recognize natural variations and still protect the groundwater resource. This approach
incofoorates the use of Ground Water Compliance Limits (GWCL) on a well-by-well
basis, instead of GWPLs. Under the GWQP Rules, groundwater quality compliance is
determined in a step-wise fashion, as follows [see UAC R317-6-6.16(4) and (B)]:
A. Accelerated Monitorine IUAC R3l7-6-6.16(A)l - if the concentration of a
"ortr*irrart i, ury ra*ple exceeds the Permit limit, then the Permittee is required
to initiate more frequent groundwater quality monitoring to determine the
compliance status of the facility. Because this section generically refers to a
"p"r-it limit" and not specifically to the GWPLs defined in UAC R317-6-4, the
Executive Secretary has the latitude to use another basis to determine a maximum
contaminant concentration for groundwater quality compliance purposes at a
permitted facility.
This maximum contaminant concentration is referred to in the IUC Permit as a
Ground Water Compliance Limit (GWCL), and will be defined as the mean
concentration plus the second standard deviation (X+2o). This GWCL will be
defined on a well-by-well basis for each key indicator parameter required for
groundwater quality monitoring at the IUC facility. On a statistical basis, and
after collection of a sufficient number of samples, the Xt2o concentration
corresponds to the 95Yorrypex confidence limit; which equates to a2.5o/o (0.025)
probability of any parameter in any well falsely exceeding its GWCL during any
given samPling event.
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Groundwater
Class
TDS
Limit
Groundwater Protection Levels
Undetectable Contaminant
(ereatest ofl
Detectable Contaminant
(ereatest of;
tr 1.25 * BG u 0.25 * GWOS MDL (''1.25 * BG 0.25 * GWQS
m 1.25 * BG 0.5 * GWQS MDL 1.5 * BG 0.5 * GWOS
Footnotes:
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B. Non-Comoliance Status [UAC R3l7-6-6.16(8)] - the IUC facility will be
considered to be out of compliance when two (2) consecutive groundwater quality
samples exceed the respective GWCL (X+2o concentration) for each well and
contaminant in question. On a statistical basis, and after collection of a sufficient
number of samples, this equates to a 0.062% (0.0252) probability that any given
well and parameter will twice, consecutively, falsely exceed its respective
GWCLl.
Pursuant to these considerations, Table 2 of the Permit has been structured to provide the
mean concentration, the standard deviation, and the GWCL (X+2o) for each compliance
monitoring well and monitoring parameter required at the facility. The Executive
Secretary believes that this approach will protect the local groundwater resource, in thatit: 1) recognizes the heterogeneity in groundwater quality apparent at the White Mesa
site by assigning GWCLs on a well-by-well and contaminant specific basis, and2) allows
for natural temporal variation in the groundwater quality by use of the x+2o
concentration limit.
It is important to note that the X+2o concentration for each compliance monitoring well
and contaminant must be based on the natural variance of groundwater quality atthat
location, and not on concentrations that have been altered by man thru pollution. This
issue is especially important for facilities that pre-existed the GWQP Rules, which were
adopted in 1989. For this reason, the Permit requires IUC to prepare and submit for
approval a Background Groundwater Quality Report for existing monitoring wells at the
facility (see Part I.H.3). After review and approval of this report, the Executive Secretary
will determine the mean concentration, standard deviation, and X+2o GWCL for each
well and contaminant listed in the Permit. In the meantime, the Executive Secretary has
set the GWCL concentrations in Table 2 of this Permit as the GWPL concentrations
determined by the formulas outlined in Table l, above. Three (3) exceptions to this
include chloride, sulfate, and TDS, which have no corresponding GWQS and therefore
require pre-determination of background concentratiorts for each parameter and well.
Consequently, the GWCL for these three (3) parameters will be determined later after
approval of the Background Groundwater Quality Report required by Part I.H.3 of thePermit. The Executive Secretary recognizes that the fractions approach used to set the
GWCLs in this Permit does not account for natural variations in groundwater quality.
Hence, false positives in the groundwater monitoring data may occur until the
Background Groundwater Quality Report, required by Part I.H.3 is submitted, approved
by the Executive Secretary and the GWCLs re-established in the permit.
Number and Twes of GWCL Parameters (Permit Table 2) - the process of selecting the
groundwater quality monitoring parameters for the permit included examination of
several technical factors. Each of these is discussed below.
A. Feedstock Materials - one source of contaminants that may be discharged from
the White Mesa facility is the number and type of contaminants that might occur
in feedstock materials processed at the mill. During early operation of the White
Mesa mill, it is anticipated that uranium ores were primarily derived from two (2)
main sources: strata-bound deposits of the Colorado Plateau region, and solution
breccia pipe deposits from the Arizona Strip. Natural contaminants known to
I The Executive Secretary recognizes that this probability for a false positive result applies to a given parameter in agiven well, and that the probability for false positives is higher when considering a group of wel-ls thai are sampled
for collection of parameters in the same monitoring event.
9
Statement of Basis DRAFT
Ore Contaminants Near White Mesa (l)
December 1,2004
B.
occur in these uranium ore deposits have been determined by the U.S'
Environmental Protection Agency (EPA), as summarized in Table 2, below (EPA,
1995, p. l1). From this research it appears that 12 metals are common to the
uranium ores processed by the IUC White Mesa facility. Consequently, all of
these metals have been listed in Table 2 of the Permit as groundwater compliance
monitoring parameters.
Table 2. Reported L ramum
Ore Source Known Contaminants
Colorado Plateau
(strata-bound)
Arsenic Lead Silver
Chromium Molybdenum Vanadium
Cobalt Nickel Zinc
Copper Selenium
Arizona Strip (solution
breccia pipes)
Coooer sulfides Lead sulfides
Iron sulfides Zinc sulfides
l) Data from EPA.995.p. ll
Other contaminants may also have been added to the tailings waste via processing
of alternate feedstocks authorized by the u.S. Nuclear Regulatory commission
(NRC). However, any evaluation made to date by the Executive Secretary
iegarding the number or types of contaminants that might be present in these
alternate feed materials has not been considered here for inclusion as groundwater
compliance monitoring parameters.
process Reagents - another source of contaminants that could be discharged to
groundwater from the facility include mill process reagents. Information
f,rovided by EPA for acid leach processing at conventional uranium mills has
Leen combined with process information from IUC in Table 3, below. Quantities
of reagents actually used by IUC at the White Mesa mill are listed in Table 3 in
bold face t1pe. Daily volumes of reagents actually used by IUC are summarized
and ranked in Table 4, below. From this information it is clear that the tailings
wastewater disposed at the IUC White Mesa mill should have an extremely low
pH, and contain significant quantities of sodium, chloride, ammonia, and
kerosene.
Source Term Abundance - some limited historic wastewater quality sampling and
,"rb." h* b*" done at the IUC White Mesa tailings cells. Some of this work
included pre-construction laboratory bench top testing by IUC to estimate the
possible contaminants that might be discharged in the tailings wastewater. The
i.tRC ulro published other estimates of expected tailings wastewater chemistry.
Several historical samples of the tailings effluent have been collected and
analyzedbyboth the NRC and IUC to determine the chemical properties of the
tailings wastewater for a limited number of parameters (see Attachment 6, below).
Little information is available regarding organic contaminants in the tailings
effluent. All information available to the DRC is summarized in Table 5, below.
C.
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Table 3 S
DRAFT December 1,2004
Footnotes:
I ) For additional information on common acid leach circuit processes at conventional uranium mills, see EpA, 1995 , pp . 22-25 .2) Total daily pounds used of each reagent at the IUC white' Mesa uranium mill is listed in brackets il, as provide d in the 5l2g/99IUC report, p. A-8' Table A-1 and the 1/30/78 Dames and Moore Report, p. 3,-5 and Plates 3.2-1 (uranium milling iiocess), 3.2-2 (copper recovery), and,3.2-3(vanadiumrecovery). Bothofthesedocumentsdetailuseofmanganeseoxidelio,0oolb/dayliiihreep.o"".rrt"pr,including: l)uraniumoreoxidation, 2) uranium leaching and clarification, and 3) copp"r .eior"ry (eaching). Howevir, use ofmanganese oxide was listed in theseoriginal mill documents as an option in case the preferred oxidizer, sodium chloriie, was not available or was not economic. History ofthe millshows that concems about price or availability of sodium chlorate never materialized, hence manganese oxide was never used in any ofthesethree process (personal communication, Mr. Harold Roberts, llll5t}4).3) Also known as tlre uraniferous ion stabilization step (EpA, 1995,pp.22_25).4) Total "organic" used daily = 1,680 lb/day, ofwhich kerosene is reported to be 95% (ibid.). DRC staffthen assumed that remainder ofthe"organic" used in the solvent extraction circuit = amine type compounds used for anionic solvent extraction in the kerosene carrier (g4 lb/day).5) IUC reports only ammonia (NH3) used in the yellowcaketrecipitation step [5l28l99IUC report, p. A-g, Table A-l and l/30/7g Dames and MooreReport, p. 3-5 and Plate 3.2-l (uranium milling process)]. However, on." in un aqueous ro.m, *," ammonia likely occurs as ammonia hydroxidein solution.
6) Copper recovery was once envisioned for the White Mesa mill (l/30/78 Dames and Moore Report, pp. 3-6 and 7, and plate 3.2-2), however itwas never implemented (personal communication, Mr. Harold Roberts, 10/15/04).7) Vanadium recovery information for White Mesa mill from 1/30/78 Dames and I\.ioore Report, pp. 3-7 to 10, and plate 3.2-3.
Table Rankin4. Ranklng of Reported White Mesa Mill
Reagent
Daily Consumption
(lb/dav)
Sulfuric acid (H,SO,)392,000
Chlorides (NaCl)15,000
Soda Ash (Na2COr)10,000
Sodium chlorate (NaClO.,)6,000
Ammonia 2,000
Kerosene 1,596
Flocculants 600
Amines (uranium extraction solvent)84
u White Mesa M ling Processes and Added.
Process Step Actua and Potential Contaminants Added
Uranium
Milling
Operations (l)
Ore Oxidation Sodium chlorate (NaClOr)
[6.0001b/davl (2)
Uranium
Leaching and
Clarification (3)
Sulturic acid (H2SOa)
[392,000|b/day] (2)
Flocculants [600 lb/day] (z)
Solvent
Extraction
Secondary amines with
aliphatic side chains [84
lb/davl (a)
High molecular weight tri-alkyl
amines
Quaternary ammonium
compounds
Kerosene [1,596 lb/davl (o)Tributvl phosohate modifier Long chain alcohols
Pregnant Liquor
Strinpine
Chlorides (NaCl) [15,000
tb/dayl e)Sulfates
Yellowcake
Precioitation
Ammonia hydroxide
(NH3OH) [2,000 lb/davl (s)
Sodium hydroxide (NaOH)
Copper
Recoverv (6)
Vanadium
Recovery (7)
Redox / pH
Adiustment
Sodium chlorate (NaClO3)
[6,000 lb/davl (2)
Solvent
Extraction
Kerosene [,596 lb/day] (a)Secondary amines with aliphatic
side chains [84 lb/davl (a)
Pregnant Liquor
Stripping
Soda Ash (Na2CO3)
solution [10,000 cwes o)
tb/davl @)
Vanadium
Precioitation
Ammonia hydroxide
(NIHIOH) [2,000 lb/davl (5)
i From Table 3, above.
September, 1980 - March, 2003
IUC / NRC Tailings Wastewater
1980 NRC
Generic
EIS
Estimate(2)
(me/L)
1979 rrJC
Bench-top
Estimate(l)Std. Dev.
(me/L)
3,130.65
64,913.9
t48.18
I15.40
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Wastewaterof Estimated and Measured IUC TailiTable 5.
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State
GWQS
(me/L)
1979IUC
Bench-top
Estimate(l)
(me/L)
I98O NRC
Generic
EIS
Estimate@)
(me/L)
September, 1980 - March, 2003
IUC / NRC Tailings Wastewater Samples(3)
Reported Concentrations Avg/
GWQS
Ratio
Min.
(mg/L)
Max.
(me/L)
Average
(ms/L)
Std. Dev.
(me/L)
Sample
CountContaminant
Sodium N/a 4,900 200 1,40c 10,00c 5,808.7 3,072.10 19
Strontium 4 3.6 t4 7.0 4.74 4 1.8
Ihallium 0.002 0.7 45 16.0 20.54 8 7,988.1Iin22,000 <5 5 5 #DIV/O!3
Iitanium 150 6.5 33.3 19.1 ll.7c t2 0.13
Uranium 0.03 2.5 5.0 r54 93.C 41.20 t7 3,120.6
Vanadium 0.06 240 0.1 l3f 51(263.1 r I l.9l t7 4,385.3Zinc59t805(l30c 640.6 598.48 5 128.1
Zirconium 2.3 38.5 12.2 12.00 t4
Rldiolosics bCilL)
Gross Alpha l5 2s0.00c 14,000 189,000 120,493 50,345.1 l5 8,032.9
Gross Beta 74 116,000 68,942 35,918.8 l5 #DIV/O!
Lead-210 2.0 680 20,700 3,385 4,660.1 t7 1,692.6
Thorium-230 l8 3,650 76,640 21,748 15,394.8 l8 1.208.2
Thorium-232 l6 49 t2t 87 )1 A t2 5.4
Polonium-210 t.c 1,410 1,410 1,410 1,410
Radium-226 4C 1,69C 1,027 497.2 t5
Radium-228 1.9 1.9 1.9 #DIV/O!
Iotal Radium 5 42 1,70c 942 553.2 t9 188.4
Selected VOCs fus/l)
Acetone 700 28 514 192 278.4 J 0.3
Benzene 5 <5 <5 2
2-butanone (MEK)4,00[lt 1 5.13 r 3.38 2.13 J 0.003
Carbon Disulf,rde 70c I6 t6 l6 #DIV/O!I 0.02
Carbon tetrachloride 5 <5 <5 <5 2
hloroform 7Q (.16.84 10.28 5.77 J 0.15
I , l -Dichloroethane ola <5 <5 <5 2
1,2-Dichloroethane 5 <5 <5 5 2
Dichloromethane 5 l0 ll l0.s 0.71 2 2.1
Tetrahydrofuran 46 n-a n-a 1-a n-a n-a n-a
Toluene 1,000 <5 6.25 s.62 2
Vinyl ctrloride 2 l0 l0 l0 2
Xylene (total)10,00c 5 <5 5 2
Sel et'tecl Semi-VOCs tus/l )
Benzo(a)pyrene 0.2 <10 <10 <10 2l
Bis(2-ethylhexyl)phthalate 6,0 I I I J 0.2
3hrysene 48 <10 <10 10 2
Diethyl phthalate 5,000 <10 l8.l l8. t J 0.004
Dimethylphthalate Nia 2.7 2.7 2.7 J
Di-n-butylphthalate 70c 1.08 1.08 l.0t J 0.002
Fluoranthene 28C <10 <10 t0 2
Z-Methylnaphthalene 4 l0 <10 <10 2
Naphthalene 100 2.44 2.44 2.44 J 0.024
Phenol 4,000 l0 38.4 38.4 J 0.01
Footnotes:1) From May, 1979 NRC Final Environmental Statement, p. 3-11, Table 3.1. Original concentrations reported in units of gm/liteq converted here to mg/liter.2) From September, 1980 NRC Final Generic EIS, p. M-5, Table M.3. Original concentrations reported in units of ugAiter; converted here to mg/I.3) Based on samples collected by IUC and the U.S. NRC between September, 1980 and March, 2003. For details see Attachment 6, below.
l3
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From this information it appears that the pre-construction laboratory testing
under-estimated the actual concentration of several contaminants that would
accumulate over time in the tailings wastewater, including: ammonia, chloride,
fluoride, TDS, arsenic, cadmium, iron,lead, mercury, sodium, uranium,
vanadium, and zinc. [n some cases these estimates under-predicted the average
measured concentrations by 3-orders of magnitude, e.g., mercury, molybdenum,
uranium, and vanadium. Other pre-construction estimates over-predicted the
average measured concentrations, including: silica, barium, calcium, manganese,
and gross alpha. These concentration differences are indicative of either
variaUitity olthe feedstocks input to the White Mesa mill, the variability of the
milling pio".s itself, and/or recycling of process fluids from Cell 1 back into the
milling proc.s combined with the effects of seasonal evaporation. In order to
better define the tailings wastewater source term concentrations and
characteristics, the Executive Secretary has added a requirement to the Permit in
Part I.8.8 to mandate periodic sampling and analysis of this wastewater.
Review of the available data shows that many of the tailings wastewater
contaminants have had an average concentration that was 50-times greater or
more than the corresponding GWQS, including (see bold values in Table 5,
above): ammonia (N), 16 heavy metals (arsenic, beryllium, cadmium, chromium,
cobalq copper, iron,lead, manganese, mercury, molybdenum, nickel, thallium,
uranium, vanadium, and zinc), fluoride, gross alpha, lead-2 1 0, thorium-2 3 0,
polonium-210, and total radium. Of these, ammonia has been introduced as a
ieagent in the milling process. Of the 16 heavy metals, 1l appear to be derived
from ttre Colorado Plateau ore feedstocks, including: arsenic, chromium, cobalt,
copper, iron,lead, molybdenum, nickel, uranium, vanadium, and zinc (see Table
2, above). Manganese is also a coflrmon contaminant in Colorado Plateau ores
(rersonal communication, Mr. Harold Roberts, 10/18/04). The beryllium,
Jadmium, fluoride, mercury, and thallium concentrations seen in the IUC tailings
wastewater in excess of 5O-times the respective GWQS, appear to be derived
from Arizona Strip ores and altemate feed materials (ibid.). Based on their
elevated source term concentrations, all of these contaminants should be
considered as potential groundwater monitoring parameters for the White Mesa
facility.
As for organic contaminants that might be found in the tailings wastewater, ..,
kerosenels probably the most significant in terms of IUC's reported daily mill
consumption, about 1,600 lblday, see Tables 3 and 4, above. Kerosene is a
mixture of many petroleum distillates, generally composed of hydrocarbons in the
range of Ce to Cro (Risher and Rhodes, p. 105). Researchers who have studied
"rrriro*.ntal releases of kerosene to gfoundwater have recommended use of
several groundwater monitoring parameters, including: benzene, toluene, xylenes
(ortho, meta, and para), ethylbenzene, naphthalene, etc (Thomas and Delfino, p,
96). These VOCs generally constitute the most soluble components of kerosene
(Deutsch and Longmire, chp. 10, p. l9). of these compounds, all have been
detected in groundwater at IUC in the area associated with the on-going
chloroform investigation, with the exception of ethylbenzene, see discussion
below. It is also important to note that these and other aromatic hydrocarbons
commonly comprise about l0-20%of the total content of kerosene, (Risher and
Rhodes, p. 105). On its own merits, naphthalene has been found to constitute
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Statement of Basis DRAFT December 1,2004
about 3% of kerosene by volume (ibid., p. 107). Based on this information, the
Executive Secretary has decided to add four (4) of these VoCs as groundwater
monitoring and compliance parameters in Table 2 of the Permit: benzene,
toluene, xylenes (total), and naphthalene.
contaminant Mobility- during selection of the groundwater monitoring
parameters to be required by the Permit, it is important to consider a
contaminant's ability to travel in a groundwater environment. For most
contaminants this is controlled by its soil-water partitioning (IQ) coefficient.
Ideally these IQ values are determined independently for each Permitted facility,
using laboratory or field-scale tests with site-specific groundwater and soils
and/or aquifer materials. [n cases where site-specific IQ information is not
available, the Executive Secretary has set a precedence of using the lowest Ie
values available in the literature to represent the site in question. A summary of
literature I(a values is found in Attachments 7 and 8, below.
Anionic contaminants - anions generally exhibit very low I(6 values and
need to be considered as groundwater monitoring parameters at the IUC
facility. These anions include: chloride, fluoride, and sulfate. chloride is
currently a groundwater monitoring parameter required under the NRC
license, and has been included as a compliance monitoring parameter in
Table 2 of the Permit.
Fluoride, as mentioned above, has been found in the tailings wastewater
with an average concentration that is more than 400-times its respective
GWQS, and therefore is also included as a GWCL parameter.
Sulfate is a blproduct of the large daily volumes of sulfuric acid used in
the uranium leaching stage of milling (see Table 3, above, and EPA, 1995,
p.22). As a parent contaminant, sulfuric acid is the most predominant
reagent used in the mill where it is consumed at a rate of 392,000 lb/day
(see Table 4, above). Accordingly, sulfate is extremely abundant in the
IUC tailings wastewater with an average concentration of almost 65,000
mgll (see Attachment 6, below). At this average level, sulfate is more than
l4-times more abundant in the tailings wastewater than chloride, which
has been a historical groundwater monitoring parameter under the NRC
license.
Heavy Metals - of the heavy metals known to exist in uranium ores, all
were found to have a lowest literature I(a value of less than2.0llkg, with
the exception of lead @.5lkg) and vanadium (50l/kg), see Attachment 7,
below. However, after consideration of the high acid conditions found in
the tailings wastewater, with an average pH of 1.83, all these heavy metals
could easily stay in solution and not partition on aquifer materials. To
date, no information has been provided by IUC regarding site-specific Ka
data for White Mesa soils and rock. Neither has any quantitative, site-
specific information been submitted regarding the bulk or trace mineral
composition of soils and bedrock at the site that could provide buffering
capacity for any low-pH tailings solutions. Consequently, the Executive
Secretary believes it is not appropriate to eliminate any of the uranium ore
related heavy metals as groundwater compliance monitoring parameters.
Therefore, 14 ore related metals were included in the Permit as GWCL
Statement of Basis I
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DRAFT December I,2004
parameters, including: arsenic, chromium, cobalt, copper, iron, lead,
manganese, molybdenum, nickel, selenium, silver, uranium, vanadium,
andzinc.
Four (4) other heavy metals found in the IUC tailings wastewater appear
to be derived from Aizona Strip ores and altemate feed materials,
including: beryllium, cadmium, mercury, and thallium. All four (a) of
these metals have average tailings wastewater concentrations in excess of
50-times the respective GWQS, ranging between 126-times (beryllium) to
7,988-times (thallium), see Attachment 6, below. Literature low IQ values
for these four (4)metals also vary widely, ranging from 0.0 l/kg (thallium)
to 3221/kg (mercury). Again, based on the high acid environment known
to exist in the tailings wastewater and the unknown buffering potential
expected in the subsurface formations, the Executive Secretary believes it
prudent to include all of these four (4) metals as GWCL parameters in the
Permit (Table 2).
In the future, IUC may provide additional site specific information
regarding contaminant K6 values, and soil and aquifer geochemical
composition and buffering capacity information as a part of the
contaminant transport modeling report required by Part I.H.1 1. After
review and approval of this supporting information and the report, the
Executive Secretary will re-evaluate the need to retain all heavy metals
listed above as GWCL Parameters.
Volatile Oreanics in Tailinss Wastewater - at least five (5) volatile
organic contaminants (VOC) have been found in the tailings wastewater,
including acetone, 2-butanone (methyl ethyl ketone or MEK), chloroform,
naphthalene, and toluene (see Attachment 6, below). None of these
contaminants exceeded their respective GWQS. However, relatively
significant concentrations of acetone were detected.
The possible source term for naphthalene and toluene may be the large
daily volumes of kerosene used in the solvent extraction circuit, see Tables
3 and 4 above. Research by others has found that aromatic hydrocarbons,
such as benzene and related compounds (toluene, xylenes, etc.),
commonly constitute lO-20% of kerosene fuel oil (Risher and Rhodes, p.
105). By itself, naphthalene has also been found to constitute about 3%o of
kerosene by volume (ibid., p. 107). Naphthalene and toluene have also
been found to have low IQ values, 0.398 and 0.009 LlKg,respectively (see
Attachment 8). These data support the use of naphthalene and toluene as
groundwater compliance monitoring parameters under the Permit.
As for the remaining tailings wastewater VOCs, the source term may be
wastewater from the mill's on-site laboratory, which began operation in
lg77,but did not begin to discharge to Tailings cell 1 until June, 1980
(9l3)l9g IUC Report, p. 6). These remaining VOC's also have very low
literature Ka values of 0.001, 0.015, and0.024 L/Kg for acetone,2-
butanone, and chloroform, respectively.
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unfortunately, the IUC voc data in question is not considered
representative of actual field wastewater conditions in the tailings disposalcells, for several reasons, including
13 volatile compoundshave been found in detectabl" .orr"ert ution in IUC groundwater since
a)siqgle Sample - the data available is derived from only I samplecollected from the slimes drain, and may not be representative ofconcentrations in all the tailings cells over the opeiating history ofthe facility (see Attachment 6, page 2),
unknown sample Date - no sample date was provided for the IUCsample. consequently, it is difficult to know just when in thehistory of the facility the sample was collected, and
Missine Sample Information - no information was availableregarding how the sample was collected, preserved, and analyzed.
Based on this lack of source term characteization, the Executive Secretarytook a conservative approach and has required all five (5) of these voc,sas GWCL parameters in Table 2 of the permit. Furthermore, a compliance
schedule item has been added to the permit to require IUC to bettercharacteize the tailings wastewater quality conditions, see parts I.E.g andI.H.s.
b)
c)
May,1999, see Attachment 9, below. Of these, 12 w:ereorganic
compounds including: six (6) chlorinated solvents, five (5jpetroleumdistillates, and one (l) non-chlorinated organic solvent ftetrarrvarofuran).of these 12 vocs, all appear to have v".y lo* Ie values, rurrgirg from0.009 (tetrahydrofuran) to 0.39g (naphthalene) L/I(g, andwould thereforebe very mobile in a groundwater environment, see Attachment g.
consequently, if any of these contaminants have potential to be foundwastewaters generated at the IUC facility, they should be considered asGWCL parameters under the permit.
a)chlorinated Solvents - the source term for the chlorinated solvents
may have been pre-operational laboratory wastewaters dischargedto septic tank leachfields at the mill site. Since about June, lggl
these wastewaters have been discharged to Tailings cett t. orthese six (6) chlorinated solvents, thrie (3) have b-een found withgroundwater concentrations that exceed their respective GWeS,including: chloroform, carbon tetrachlorid", urrd di.hloromethane
(see Attachments 3 and 10, below). In order to ensure an adequatecharacteization is completed and to better coordinate groundwater
monitoring for both the tailings cells and the chloroforir
investigation, all three of these chlorinated voCs were included asgroundwater monitoring parameters in Table 2 of the permit.
Peholeum Distillates - for the five (5) petroleum distillates
detected in site groundwater, all are aromatic hydrocarbons, withfour (4) derivatives ofbenzene (benzene, toluene, xylene, and1,2,4-timethylbenzene), and one ( I ) polynuclear- artmatic(naphthalene). As discussed above, the source term for these
b)
Statement of Basis DRAFT December 1,2004 I
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c)
compoundsmaybesmallquantitiesofkerosenefoundin
laboiatory wastewater discharged historically to septic tank
leachfields . Largequantities of kerosene are also used in the mill's
solvent extraction circuit and are discharged to the tailings cells.
ofthesefive(5),onlyone(l),benzene,hasbeenfoundinexcess
of its 5 ug/l GWQS (sde Attachment 10, below). For reasons
discussed'above, toluene, and naphthalene were added to the
Permit as groundwater monitoring parameters' However' because
benzene aid xylene are also related to kerosene, and have been
detected in groundwater at the facility; these compounds have also
been added as GWCL parameters in Table 2 of the Permit. For the
time being 1,2,4-trimethylbenzene was omitted as a monitoring
parameter. However, should it be necessary it can be added to the
i'ermit later under provisions found in Part IV'N'3'
Tetrahydrofuran - detectable concentrations of tetrahydrofuran
(THF) h"r" b*" found in four (4) wells at the facility, including
,rp graAi.nt well MW-l, and downgradient wells MW-2, MW-3'
ura-lrtW-t2 (see Attachment 10, below). Two (2) "f9::: wells
have THF concentrations that exceed the State GWQS (46 ryll),
including upgradient well MW-l and downgradient well MW-3
(ibid.). ifr. tt"o (2) other downgradient wells, MW-2 and MW-I2'
"*rtiuit.a detectable THF concentrations that did not exceed the
GWQS.
As a part of the chloroform contaminant investigation, DRC staff
asked IUC to evaluate possible sources of THF at the facility
(ll22l02DRC Request for Additional tnformation, p' 3) In
,"rpon*", IUC claimed that this organic solvent may have been
derived from PVC glues and solvents used during construction of
the PVC well casings found in several monitoring wells at the
facility (l2l2ol02IUC Letter ,p.2). This claim appears consistent
with the occurrence of THF in both up and downgradient wells.
However, further evaluation is required to determine why three (3)
other IUC wells installed at the same time do not exhibit detectable
THF concentrations, including lateral gradient well MW-4' and
downgradient wells MW-5, and MW-l1'
THF is a contaminant of concem, in that one of its major use is as
aGrignardreagentinthesynthesisofmotorfuels(National
Libraly of MeJicine [NLM] Hazardous Substances Data Bank).
Therefore, it may be possible that THF is a trace contaminant in
petroleum products such as kerosene, which is used in large
quantities ut ttr" white Mesa mill (see Table 3, above). Further,
tgF nur unique chemical properties in that it is soluble in both
water and hydrocarbons. Be.a,r.e it has a high water solubility,
THF may be a very mobile groundwater contaminant'
DuringpreparationofthePermit,IUCofferedto:1)continue
monit[.ing THF in all the monitoring wells at the facility, 2)
include trtr as part of the routine tailings wastewater sampling
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a)
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five (5)
bis(2-
and analysis, 3) submit a work plan for additional study and 4)
complete the study and report the results thereof to resolve this
issue. Accordingly, a condition has been added to the permit,s
compliance schedule in Part I.H.l9. If after review and approval
of this report, the Executive Secretary determines that THF is not a
result of mill operations, then the permit will be re-opened andmodified to remove it as a groundwater compliance monitoring
parameter (Table 2).
- IUC has detectedsemi-voc contaminants in tailings cell wastewater, including:
ethylhexyl)phalate; diethyl phthalate; dimethylphthalate; di-n-
butylphthalate; and phenol (see Attachment 6, 6elow). Four (4) of thesecompounds may be mobile in groundwater environments, based on their
estimated I(6 values, including: diethyl phthalate (0.07 LlKg);
dimethylphthalate (0. 04 LlKg); di-n-butylphthalate (0. I 6 L/Kg); andphenol (0.016 L/Kg), see Attachment 8, below. However, none of thesesemi-voc contaminants were included as compliance monitoring
parameters in the Permit, for the following reasons:
Several VOC contaminants have already been proposed as
compliance monitoring parameters that have lowei I(a values than
the semi-voc parameters in question. Examples of these include,
but are not limited to: acetone, chloromethane, dichloromethane,
and toluene. consequently, these voc parameters should be
detected at the compliance monitoring well before any arrival of
the semi-VOC contaminants.
Focusing on the voc contaminants will streamline groundwater
monitoring efforts and reduce associated sampling and analysis
costs for both IUC and the Executive Secretary,
The Executive Secretary can add new compliance monitoring
parameters at any time, if needed to protect human health and the
environment, pursuant to Part fV.N.3 of the permit.
semi-vocs Found in. Site Groundwater - only one (l) split sampling
event included analysis of semi-voc parameters, May, iqqq. nuring tti.
event which was conducted as apart of the chloroform investigation,-only
one (1) semi-voc contaminant was detected in the IUC set ofgroundwater samples at the white Mesa facility, including: Bis(2-
ethylhexyl)phthalate. Unfortunately, a problem with a laboratory blank
forced the DRC to discount all its split sample results for this paiameter.
Follow-up sampling for semi-vocs was not undertaken by DRC staff,primarily because the voc contaminants detected are known to generally
be much more mobile in groundwater environments. The Executive
Secretary will continue with this approach to semi-voC contaminants as
compliance monitoring parameters under the permit.
- the transformations or decay ofcontaminants that would alter the physical properties or reduce the concentrationof contaminants found in the tailings wastewater is another key consideration in
Statement of Basis I
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DRAFT December 1,2004
selection of contaminants for gfoundwater monitoring. In cases where a
contaminant is transformed to a reaction or decay product, it may be preferable to
monitor groundwater quality for the degradation products instead of the parent
contaminant. several tuilirrgr wastewater contaminants were examined with
respect to their persistence in groundwater environments. Each of these
parameters are discussed below:
follows:
NH3 (asN) GWQS : NH3 GWQS * Atomic Weieht of N
Atomic Weight of NH3: 30 mg/l * 14.0067 I U4.0067 + 3 * 1.0079)l: 30 mg/l * 14.0067 I 17.0304
= 24.67 mg/I, round to 25 mgll.
Nitrate and Nitrite - both of these compounds are oxidation or degradation
p--6".t. "f ui"r"*ia, which is one of the top six (6) reagents added
during the milling process (see Table 4, above). As anions, both nitrate
and nitrite ut ,.udily mobile in groundwater environments. For these
reasons, Nitrate + Nitrite (as N) was added to the list of groundwater
compliance monitoring parameters in Table 2 of the Permit.
Chloroform Dauehters - chloroform has been found both in the tailings
@hment 6) and in shallow groundwater primarily in
the area of the chloroform investigation (see Attachment 3) at the site' As
a result, the Executive Secretary has added this volatile organic compound
iVOCI io the list of required groundwater monitoring parameters in Table
) of the Permit. Undeianaerobic conditions, chloroform is degraded to
dichloromethane (or methylene chloride) and then to chloromethane (see
pankow and cherry, p. 80). Both of these daughter products have low soil
I(a values of 0.10 and 0.06 LlKg,respectively (see Attachment 8). For
th"r. ,"urons, all three (3) of these VOCs have been required for
groundwater monitoring at the facility after addition to Table 2 of the
Permit.
Detectability - the ability of common environmental laboratory equipment and
t""h""l"gy t" detect andquantiff contaminant concentrations in groundwater is
another iiiportant issue to consider when selecting parameters for groundwater
compliance monitoring. Executive Secretary review has found that standardized,
EPA approved laboratory methods are available to provide minimum detection
limits ihat are lower than the GWQS discussed below for each compliance
monitoring parameter.
2) - the Executive Secretary has
ffiffiffiFfor each of the grorrrrd*ut.r compliance monitoring parameters listed
in Table 2 of the permit. The source or reference for each of these contaminant's GWQS
is discussed below.
Nutrients and Inorqanics
A. Ammonia (as N) -the25 ug/lad-hoc GWQS found in Table 2 of the Permit was
derived tomTO ug/l EPA final drinking water lifetime health advisory (LHA)
for ammonia (NH3)lsee EPA, Summer, 2002,p. 8]. This value was then
converted to an equivalent concentration for ammonia as nitrogen (NH3 as N), as
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Statement of Basis
C.
Metals
D.
DRAFT December 1,2004
Fluoride - the 4.0 mg/l value is a promulgated Gwes under the utah GwepRules found in UAC R3l7-6-2,Table l.
- the l0 mg/l GWeS comes directly from the UtahGWQP Rules found in UAC R3I7-6-2,Table l.
Arsentq- the 50 ugll Gwes comes from the utah GWep Rules found in uACR3r7-6-2, Table l. However, the EpA drinking water fiiral maximum
concentration limit (MCL) has been recently changed to l0 ug/l (see EpA,Summer, 2002,p. 8). At some point in the future, the Executive becretary mayre-open,the Permit and revise this GWeS accordingly, pursuant to part IV.N.1.
Thallium - all of these GWeS come rrom th" utah cw@Rules found in uAiR3l7-6-2, Table 1.
cobalt and Iron - the ad-hoc GWeS for these two (2) metals, 730 and I 1,000ug/I, respectively, were derived from the tap water concentration limits found inthe EPA Region 3 Superfund Risk Based concenhation (RBC) Table. This EpAreference is available on the Internet at
Mansanese - the 800-ug/l ad-hoc Gwes was derived from an ad-hoc drinkingwater LHA provided by EpA Region g (see ll4/00 EpA Region g letter, p. t)Ilnturn, this LHA was based on the most current reference dose (RfD) in the BpaIntegrated Risk Information System (IRIS) database.
Molybdenum and Nickel - the ad-hoc GWeS of 40 and 100 ugll, respectively,were derived from EpA final LHA for these metals (see EpA, Eummlr,200i,'p.8).
Uraniqrr-r - the 30 ug/l ad-hoc Gwes was derived from a final EpA drinkingwater MCL (see EPA, Surnmer, 2002,p. g). This MCL was re-affirmed bylhe
G.
united States court of Appeals on February 25,2003 (see District of columbiCircuit, Docket No. 01-1028, etc, p.49).
vanadium - an ad-hoc GWeS of 60 ug/l was calculated by DRC staff with theassistance of Mr. Bob Benson, EPA Region 8 drinking *ui.. toxicologist using anEPA RfD for vanadium pentoxide (vzos) ot9 uglkgliay (see Tllglg6rJtahDepartment of Environmental euality tDEe] InformationNeeds Summary, Tablel, Footnote 5).
Zinc - the 5,000 ug/1 ad-hoc Gwes comes directly from the Utah GWep Rulesfound in UAC R3l7-6-2, Table 1. However, the final EpA drinking waLr LHAis currently 2,000 ug/l (see EpA, summer,2002,p. 9). consequently, the
Ex_e,cutive Secretary at some point may re-open the permit ana aa3usi the zincGWQS accordingly, pursuant to part tV.N.l.
Radioloqics
L' Gross Alpha - this 15 pCi/l GWQS is directly from the Utah GWep Rules foundin UAC R3t7-6-2, Table l.
Statement of Basis
VOC Contaminants
DRAFT
T
December 1,2004
total) - the GWQS values
M.Acetone - the 0.7 mg/l (700 ug/l) ad hoc GWQS was derived from lifetime health
,drtr"ry calculationiby UtahbWQ staff, with the assistance of Mr' Bob Benson'
Bpe negion 8 Drinking wut., Program Toxicologist. For additional details, see
the Augist 8,Igg|O1rliq Report (pp. 3-5 and Attachment l)' This 700 ug/l value
was based on an orul e*pirure..f.t"n." dose (RfD) from the EPA Integrated
Risk Information System (IRIS) database of 0.1 mgfi<flday. This same ad hoc
GWQS has been used at another I le.(2) waste disposal facility in Utah'
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Fi3l7-6-2,Table l.
2-Butanone (MEK). Chloromethane (Methvl Chloride).and Naphthalene - these
EPA drinking water LHA for 2-butanone [4
-Jf * 4,00d udll; chloromethane [0.03 mg/l or 30 ug/l]; and naphthalene [0'l
*In o. 1 00 ug/ll , see EPA, Summer, 2002 (yry ' 2, 5 , and 6) '
Chloroform -previously the Executive Secretary relied on an EPA drinking water
MCL f", t"tuf t it utornlthanes, which includes chloroform and 3 other VOC
contaminants, to establish an ad hoc GWQS for chloroform (0.8 mg/l)' However,
recently DRi staff became aware of a new and discrete chloroform RfD
established in the EPA IRIS database. with the help of EPA Region 8 toxicology
staff, an ad hoc drinking water LHA of 0.7 ug/l was established for chlorofolm on
the basis of the .o-porird's non-cancer risk (see 5129103 EPA memorandum)'
Later this value *ur'upp.ored for use at the IUC White Mesa facility by the Utah
DWQ $ee 6112103 DWQ Memorandum)'
Dichloromethane (Methylene chloride) - this ad hoc GWQS was derived from a
E*l EPA dtirki"g water MCL (see EPA, Summer, 2002,p'3)'
Tetrahydrofuran - the 0.046 mgl @6 ug/l) ad hoc GWQS for tetrahydrofuran
(THfibrs"d;n an ad hoc EFA Region 8 drinking water LHA (see 8124199
iee ifegion 8 memorandum). [n tum, the EPA ad hoc LHA was based on a
frovisioial oral cancer slop factor of 7.68-3 mglkflday From calculations
provided by EPA Region d, thr." values of cancer risk and corresponding THF
concentrations were Ietermined, as summarized in Table 6, below' After review
of these data, the Executive Secretary has determined that the mid-range value, 46
ug/l, is appropriate as an ad hoc THF GWQS for the IUC White Mesa site, based
on the following findings:1) ffi;l['*:[:X"Tlffi:".'i'i,o,1,h*n"u.,* I
qualitY), and
Water - review of nearby groundwater
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ur. t u. rtro*, that no existing gtoundwater supply wells or springs are
currently found downgradient of the IUC facility on white Mesa that
22
exclusively use the shallow aquifer for drinking water'
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Table 6. Summary of Tetrahydrofuran
Cancer Risk And GW Concentrations
Cancer Risk
THF Concentration (r)
(me/l)(ue/l)
l:10,000 0.46 ms,/l 460
l:100.000 0.046 46
1:1.000.000 0.0046 4.6
Frcm 8/24199 EPA Region 8 memorandum by Robert Benson.
Future Monitorine Wells (Permit Table 2 and Part I.H.1) - recent water table contour
maps of the shallow aquifer have identified a significant westerly component to
groundwater flow at the White Mesa facility, see Attachment l, below. This change ingroundwater flow directions appears to be the result of wildlife pond seepage and
groundwater mounding discussed above. As a consequence, new grounawater
monitoring wells are necessary at the IUC facility, particularly along the western margin
of the tailings cells. New wells are also needed for Discharge Minimization Technology(DMT) purposes that provide discrete monitoring of each tailings cell, as discussed
below. During meetings in August, 2003 and February, 2}04,IUC proposed the
installation of these new groundwater monitoring wells near the tailingi cells, as
summarized in Table 7. Later,IUC submitted a map to confirm the locations of these
new wells, see Attachment I l, below:
able o IUC Moni Well Locations
Well ID Approximate Location
MW-23 Near southwest corner of Tailines Cell 3
MW-24 Near southwest corner of Tailinss Cell I
MW-25 Near southeast corner of Tailines Cell 3
MW-26 Near northeast corner of Tailings Cell2
(existing chloroform investisation well TW4- I 5)
MW-27 Near northeast corner of Tailines Cell 1
MW-28 Near mid-point of south dike at Tailinss Cell 1
MW-29, MW-
30. and MW-31
Spaced approximately equidistant on south dike of
Tailings Cell2
MW-32 Near southeast corner of Tailings Cell2
(existing chloroform investigation well TW4- I 7)
These general locations were found acceptable. If after review of the hydrogeologic
report required by Part I.H.2 of the Permit, the Executive Secretary determines additional
information is needed, IUC will be asked to provide more information. The short 60-day
compliance schedule for IUC to install the new wells after Executive Secretary upp.ouuf
of the plan was set in order to expedite both the collection of groundwater quality
information from these new wells, and preparation and submittal of the new well
Background Groundwater Quality Report (part I.H.4).
7.
Statement of Basis DRAFT December 1,2004
Revised Hydroeeoloeic Report (Part I.H.2) - after installation of the new monitoring
@i, it *ill be important to evaluate the new hydrogeologic
information collected, and consider it in context with existing information collected to
date at the facility. [n order to ensure evaluation is done and easily tracked by both IUC
and DRC, the Executive Secretary added this requirement to Part I.H.2. At a minimum,
the following types of hydrogeologic information will be included in the Revised
Hydrogeologic RePort:
Monitoring Well As-Built Information - including geologic logs, well completion
diagrams, ind aquifer hydraulic analysis as required by Part I.F.5 of the Permit,
Revised structural contour Map - of the geologic contact between the Brushy
Basin Member of the Morrison Formation, and the overlying Burro Canyon
Formation.
Aquifer Saturated Thickness Map - including a contour map to illustrate the local
distribution of the thickness of the perched aquifer.
Water Table Contour Map - based on groundwater elevation measurements of all
wells and piezometers at the site to illustrate local groundwater flow directions.
Historic Aquifer Permeability Data - aquifer permeability data collected from the
new monitoring wells needs to be evaluated in context with existing slug and./or
aquifer pump test analysis to determine if any preferred groundwater flow
pathways exist.
Multi-well Aquifer Test Results - long-term any new multi-well aquifer testing
done to determine local hydraulic properties, including permeability, needs to be
included. One purpose of this testing would include determination if any
preferred direciions of groundwater flow exist at the facility, i.e', aquifer
permeability heterogeneity and anisotropy. -
Aquifer permeability Distribution Map - based on all reliable and representative
aquifer permeability available to date, IUC will provide a contour map to
illustrate the distribution of permeability of the perched aquifer at the site.
If after review of the Revised Hydrogeologic Report it is determined that additional
information is needed, the Executive Secretary will ask IUC to provide it'
added to the Permit to confirm that only 11e.(2) byproduct
material, including various wastes listed by NRC, may be disposed of in the Mill's
Mi Au
Corr.t*.ti,on Gurtr t-p.t und Z) -information providedby IUC shows that Tailings Cells
t,2., u"al *"r" .onrt*"t"d more than 20 years ago, as summarized in Table 8, below:
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Tabl
After review of the existing design and construction and consultation with the DWe, theExecutive Secretary has determined that the Discharge Minimization Technology 1Dfraf)required under the GWQP Rules [uAC R3r7-6-6.4(cX3)] for IUC disposal cJls l, 2,
and 3 that pre-dated the 1989 GWQP Rules will be defined by the currint or existing
disposal cell construction, with a few modifications. This approach is reasonable,
practical, and acceptable for the following reasons:
Existine conditions - Tailings Cells l, 2, and,3 have been in existence in their
current state for more than 20 years. Over the course of this time, a significant
amount of tailings have been disposed in Cells 2 and,3.
Current Staee in Desiqn Life - Tailings Cell2 has nearly reached its maximum
waste height and capacity, in that temporary soil cover has been advanced over
99.8% of the disposal cell. As a result, the remaining disposal capacity in Cell 2
is only about 5,000 dry tons out of 2,35 2,000 dry tons ofiotal design capacity
(personal communication Harold Roberts, IUC) . At Tailings cell 3, about el%
of the total design capacity has already been used (1,g25,000 o:ut of 2,7 25, 000
dry tons total), and temporary soil cover has been advanced over about 40%o of thecell (ibid.).
Retrofit Construction Impractical - due to the ddvanced age of the disposal Cells
2 and 3 and their near-full capacity, little can be done to retrofit, re-construct, or
modify the under liner systems.
The improvements required under DMT for Tailings Cells 1,2 and3 will focus on
changes in monitoring requirements, and on improvements to facility closure, if needed.
The goal for these changes is to ensure that potential wastewater losses are minimized
and local groundwater quality is protected. These changes include:
D. Improved Groundwater Monitorins - improvements to the existing monitoring
well network are needed to meet the following performance goals:
Early Detection - the ability to detect a release as early as practicable is
important, and is accomplished by locating wells immediately adjacent to
and downgradient of each disposal cell. To satisfy this requirement the
Executive Secretary has required three new DMT monitoring wells (MW-
24,}dw-27, and MW-28) be installed immediately adjacent to cell 1, see
Part I.H.1.
Discrete Monitorine - the ability to individually monitor each disposal cell
at the facility is also important to allow the Executive Secretary to pin
point the source of any groundwater contamination that might be detected.
The DMT monitoring wells required for cell I in part I.H.l will help meet
of
A.
B.
C.
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2)
e 6. summary ot l'arlrngs Cell Completion Dates
Tailings
Cell Completion Date Reference
I June 29, 1981 5/28/99AJC Groundwater Information Report, p. A-11
2 Mav 3. 1980
3 September 15,1982 3/83 Energy Fuels Nuclear Construction Report. p. l-2
4A November 30, 1989 VOqIfC Construction Report, p. 1
Statement of Basis DRAFT December 1,2004
this requirement. Also, IUC will be required to install three (3) additional
monitoing wells between Cell 2 and3 to allow discrete monitoring of
Cell2 (MW-29, MW-30, and MW-31).
- changes to disposal
efforts to minimize potential seepage losses, and
thereby improve protection of local groundwater quality are also important'
Related requiremints for monitoring are also added to confirm that these changes
are in place and are actively being used by IUC. Examples of some of these
changes include:
- imposed in Part I.D.3 for
Aitings cells and Roberts Pond to require that lUC continue to ensure
that impounded wastes and wastewaters are held and maintained over a
flexible membrane liner (FML)'
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Slimes Drain Maximum Allowable Head - required for Tailings cells 2 arld3
in purt fO:O) to ensure that IUC provides constant pumping efforts to
minimize the accumulation of leachates over the FML, and thereby minimize
potential FML leakage to the foundation and groundwater. This requirement
ias immediately imposed in the Permit for Cell2, because IUC is already
actively dewatering ihat cell. Imposition at Cell 3 was delayed by the
Executive Secretary in response to IUC argUments that premature slimes drain
pumping poses a rist< that ihe layer will plug with sulfate salts during tailings
"e11
opeiation, and not be available for slimes de-watering when IUC is ready
to advance a cover over the tailings cell. Such untimely loss of the slimes
drain layer would gfeatly complicate and delay cover construction, and in tum
increase the overall potential for leachates to be released from the final waste
embankment. Detaiis as to an appropriate average wastewater head in the
slimes drain layer at both cells 2 and 3 are to be proposed by IUC and
approved by the Executive secretary in development of a DMT Monitoring
Plan required by Part I.H. 1 3 of the Permit.
Feedstock Storaee - in order to constrain and minimize potential generation of
*"tu*i*ted stormwater or leachates the Permit requires IUC to continue it
existing practice of [see Part I.D.3(d)]: 1) limiting open air storage of
feedstoci materials to the historical storage area found along the eastem
margin of the mill site (as defined by the survey coordinates found in Permit
Tabl-e 5), and 2) maintaining water-tight containerized storage of feedstock
material found anylvhere else at the IUC facility'
4) Mill Site Reaeent Storaee - is of potential concern for groundwater quality in
the event that reagent storage tank leaks or spills could release contaminants
to site soils or gro-undwater. In an effort to prevent this possible problem, and
provide prope*pill prevention and control, Part I.D.3(e) requires IUC to
iemonstrate thaiit has adequate provisions for spill response, cleanup, and
reporting for reagent storage facilities, and to include these in the Stormwater
Best Manag.-"rrt Practices Plan. Content of this plan is stipulated in Part
I.D.8, and submittal and approval of the plan required under Part I.H.17.
At new facilities, the performance goal for secondary containment should
include prevention of spills from contacting the ground surface' During
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discussion with IUC, the company responded that this was impractical in that
the existing reagent storage facilities had been in existence for decades.
Further, IUC contended that: 1) secondary containment had been designed
and constructed at each of the existing reagent storage facilities, albeit it
earthen lined, 2) any soils affected by spills could be easily excavated and
disposed in the tailings cells should a spill occur, 3) after removal of the soils
affected by major spills, new construction could be completed to replace and
restore the secondary containment; which at that time could meet the new
performance criteria for prevention of ground contact, and 4) any required
improvements for chemical reagent storage should focus on changes to
operational and/or spill response measures, and not on re-design or re-
construction of these facilities. Because the IUC facility is a pre-existing
operation under the Ground Water Quality Protection Regulations, DRC staff
agreed with these arguments, and wrote the requirements of part I.D.3(e)
accordingly. However, should any of the existing reagent storage facilities be
re-built, provisions were added to the Permit to require the higher standard at
re-construction, that being secondary containment that would prevent contact
of any spill with the ground surface.
Evaluation of Tailines cell cover System Desim -rover system design and
construction needs to be evaluated in order to ensure that infiltration into the
tailings waste is minimized and groundwater qualityprotected during the post-
closure period. To this end, Part I.H.ll of the Permit requires IUC to submit an
Infiltration and Contaminant Transport Modeling report for Executive Secretary
review and approval. After review of this report, the Executive Secretary will
determine if any changes are need in the proposed cover system. Minimum cover
system performance criteria are stipulated in part I.D.6 of the permit.
10. Existing Tailines Cell Desisn / Construction Findines -during review of the existing
tailings cell design and construction the Executive Secretary found that construction
documentation for Tailings Cell 1 is limited to one (l) as-built report dated February,
1982 by D'Appolonia Consulting Engineers (p. 3-1). In this report the as-built
information is limited to only a topographic map of the Cell 1 floor prior to FML
installation (ibid., Fig. l2). Authors of the report state that they were involved in
construction of Cell 2, and that Tailings Cell I construction was done by the previous
White Mesa owner, Energy Fuels Nuclear (EFN). No other Cell I as-built information is
available, nor is there any documentation of any Cell I construction quality assurance /
quality control. DRC field inspections have confirmed the existence of an earthen dike at
the south margin of Cell 1 and a FML liner inside this cell. Without any other
information, the Executive Secretary has assumed that the Cell 1 construction largely
followed the cell's original design found in a June, 1979 D'Appolonia Engineers Report.
From IUC plan maps the Executive Secretary estimated the Cell 1 footprint area to be
about 57 acres.
As for Tailings Cells 2 and 3, as-built reports were found and reviewed by DRC staff;
findings from which are found in a June 27,2000 DRC Memorandum. These reviews
resulted in a summary description of the liner technology for these two (2) disposal cells,
as outlined in Part I.D.l(b) and (c) of the Permit. From IUC plan maps the Executive
Secretary estimated the footprint area to be about 68 and 55 acres for Cells 2 and3,
respectively.
Statement of Basis DRAFT December 1,2004
From this review it appears that the design and construction of all three (3) existing
tailings cells consists of a single PVC FML liner and a limited leak detection system
undeithe primary liner comprised of a single pipe at the toe of the southern dike within a
permeable sand layer that extends across the cell floor. While outdated, this construction
upp"urr to have been common technology for the time (1980-1982). Since then, FML
tec-hnology has greatly advanced both in materials used, designs produced, construction
methodslracticed, and quality assurance / quality control measures applied. Modern
designs include multiplaFMls (e.g., primary, secondary, tertiary, etc), and a leachate
removal system over and multiple leak detection layers under the primary FML' Such
advanced designs provide effective leachate head control at the primary FML, thereby
minimizing lpakage rates and providing sensitive leak detection; and efficient leakage
collection and removal systems. [n cases where facilities have deployed modem waste
containment and leak deiection / control technology, the Executive Secretary has allowed
the leak detection system to be the primary means of compliance determination for the
facility.
However, this is not case for the existing tailings cells at IUC. Therefore, for purposes of
defining the DMT standard for IUC, the Executive Secretary is left with only one option,
that of improving detection of potential tailings cell leakage by installation of discrete
monitoring wells-. To this end,IUC has agreed to install eight (8) new monitoring wells
immediately adjacent to the tailings cells, as follows (see Attachment 11, below):
A. Tailings Cell I - wells MW-24, NNV'27, and MW-28,
B. Tailings Cell 2 -wells MW-29, MW-30, and MW-31, and
C. Tailings Cell 3 - wells MW-23 and MW-25.
@rTailingsCell4AisfoundintwoUmetcoMineralsCorporation
@Jreafter [metco; reports dated August, 1988 and April 10, 1989. Cell 4,{ construction
was completed on or about November 30, 1989, see Table 8, above. Later, IUC
completed an as-built report and submitted it for Executive Secretary review (see 8/00
IUC Tailings Cell44 Construction Report). Review of the engineering design and as-
built reporti , shows that an improvement was made to the leak detection system in Cell
44, coirpared to the older cells, in that a secondary FML was installed immediately
underneath the leak detection piping system. Unfortunately, this secondary FML was
very limited in horizontal extent, in that it was only 2-feet wider than the graded trench
for each leak detection pipe (8/88 Umetco Report, Sheet C4-3). As a result, very large
areas exist between the leak detection pipes where the primary FML has no underlying
membrane to divert leakage to the detection pipe. Consequently, 98% of the Cell 4A
floor area does not have a-secondary FML present to divert leakage to the leak detection
collection pipes (6127 100 DRC memorandum, p. I 0). As a result, the existing design and
construction of this disposal cell could allow a significant volume of leakage to escape
undetected and possibly contaminate underlying groundwater re sources.
However, unlike Cells l, 2, and 3, Cell 4A has a 12-inch clay liner under the primary
FML. Therefore, leakage from the primary FML would necessarily have to penetrate and
escape this clay layer before it could infiltrate the cell foundation and possibly
contaminate underlying groundwater. While this clay liner represents a significant
improvement in facility tuitirrg. cell design, DRC review of the as-built report, referenced
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above, found very little clay liner conskuction quality assurance I quality control
information to substantiate any in-place or field permeability for this clay layer. As a
result, the DRC is unable to quantift the rate of any possible leakage from this clay layer,
or confirm the degree of control this layer may have had on said leichate.
Despite this lack of information, Cell 4,A' has never been used for tailings disposal, but
instead was used only for storage and evaporation of vanadium process solutions (5l2gl1l
IUC Cell4A Leak Detection Report, p. 1). ruC has advised DRC staff that no taiiings
waste or wastewater have been deposited in Cell4,A' since the early 1990's. This lack of
waste disposal, and exposure of the FML to the elements has caused Cell4A to fall into
disrepair over the years. DRC staff site visits between 1995 and 2003 have observed
failure of several FML panels on the interior sideslope; thereby exposing large areas of
the sideslope subsoils. IUC acknowledges this damage and the general airrepuir of Cell
4/^.
In addition, the existing NRC License requires IUC to submit verbal and written reports
when flow rates from the leak detection system exceed I gallon per minute (gpm) iNnC
9123102 License, Condition 11.3(D)1. tn a May 29,2001letter, IUC notified the NRC
that LDS flows at Tailings Cell4A had exceeded the 1.0 gpm rate atCell4A. Based on
these findings, it appears that the FML has failed to control the process fluids maintained
across the floor of Cell 4A, thereby causing reliance on the clay sub-liner to prevent
contact with the underlying sub-soils. Since that time IUC has begun the process of
removing the materials once stored there, in preparation of re-lining the cell prior to re-
use.
The raffinates and salts once stored in Cell 4Amay have similar chemical characteristics
as the uranium raffinate in the Mill, in that the vanadium raffinate is derived from the
outfall of the uranium extraction circuit in the IUC milling process (5/25/gg IUC
Groundwater Information Report, p.A-7 and Figure B-2). Consequently, these fluids
may contain significant concentrations of many contaminants of concem, including: low
pH fluids, heavy metals, uranium, high sulfates and TDS levels, and organic
contaminants.
Considering the FML damage acknowledged by IUC, the general state of disrepair
discussed above, and the lack of tailings solids disposed to date; major improvements in
the design and construction of Cell 4A are warranted prior to re-use of thocell. For this
reason, the existing Cell 44 design and construction were not approved in Part I.D of the
Permit. IUC has also agreed and Part I.H.14 of the Permit has been crafted to require
submiffal of a Cell4A contaminant removal schedule for Executive Secretary approval,
which would include periodic progress reports of said contaminant removal.
Requirements are also provided for IUC to complete removal of all fluids and salts stored
there, the FML liner and LDS layer, and any contaminated underlying clay or sub-soils,
pursuant to Part I.H.14. Furthermore, if IUC desires to reconstruct and re-line Cell44,
the Permit also requires IUC to submit new engineering design and specifications for Cell
44 that meet BAT design and construction requirements, and secure prior approval,
pursuant to Part I.H.l5.
Part - this pond was
originally installed as a part of the initial Mill constru"tion approrr"d by the NRi, and is
located in the western portion of the mill site a short distance east of Cell 1. This pond
was designed as an emergency catchment basin for major tank failure or process upset
from the mill. In May,2002IUC made the decision to clean out the exisiing pond and
Statement of Basis DRAFT December 1,2004
replace the former Hypalon liner with a new High Density Polyethylene (HDPE)
rnembrane. To date, no IUC engineering design or as-built drawings have been provided
for re-construction of the Roberts Pond, but IUC has committed to provide this
information in the near future. A brief description of the FML retrofit construction was
provided in a February LI,}OO4IUC email, details of which are outlined below:
A.
B.
C.
The Roberts Pond is relatively small, less than 0.4 acres in srze.
After 25 years of gervice the Hypalon liner in the Roberts Pond was removed and
replaced with a single membrane, 60 mil HDPE liner'
After removal of the former Hypalon FML, IUC conducted radiological surveys
with.both field instruments and uranium soil sampling and analysis to determine
soil areas with concentrations that were above "background".
Contaminated soils were excavated and moved to the ore storage pad for re-
processing in the mill.
Foundation preparation included gleaning the sub-grade to remove oversize rock,
rolling the sub-grade with a smooth drum roller, raking pond sideslopes to remove
or.rrir" rock oi other material, installation of a geotextile material over the entire
footprint as a protective layer under the FML'
Construction quality assurance / quality control (QA/QC) measures performed
included three (3) destructive tests on FML seams (l per 500 linear feet),
followed by air pressure tests and vacuum box tests where needed.
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Without having reviewed the IUC As-Built report, the Executive Secretary cannot
approve either the design or the construction of the re-built pond. However, the
Executive Secretary hai decided to accept the pond as it is, regulate it under the Permit,
including imposition of DMT monitoring requirements, based on the following findings:
The Roberts Pond is small in size, about 0.4 acres, compared to the
tailings cells, and
The Roberts Pond is used to store intermittent wastewater flows, and
therefore may not be a constant head source
At the time mill site decommissioning, detailed radiologic surveys will be
conducted of the entire atea, andcontaminated soils removed and placed
for disposal in the tailings cells. All of these activities are regulated by the
Executive Secretary under the Radioactive Materials License
Therefore, part I.H.l8 has been added to the Permit's compliance schedule to require
submittal of an As-Built report to document the recent design and re-construction. After
review of this report, the Executive Secretary will determine if additional measures are
necessary to protect public health and the environment. Such changes, if needed, would
be implernented as a-part of the Reclamation Plan required by the License'
Existine Facilitv DMT Operations Standards (Part I.D.3) - in lieu of major engineering
i,severa1newoperationalrequirementswereimposedby
the iermit to minimize the fotential for release of contaminants to the groundwater from
the tailings cells and facilities at the mill site, including:
A. Slimes Drain Maximum Head: Cells 2 and 3 - this performance criteria was
added .o ur io require IUC to install, operate, and maintain automated pump
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control systems inside the slimes drain access pipe for both Tailings Cells 2 and 3.
The intent of this requirement is to ensure that the average wastewater head in this
layer is maintained as low as reasonably achievable, and thereby minimize
leakage from the primary FML. Determination of the wastewater level that meets
this criteria will be made by IUC and approved by the Executive Secretary later asapart of the DMT Monitoring Plan; pursuant to Part I.H.13. Similar head control
requirements have been stipulated by the Executive Secretary for other facilities.
- this requirementIE
applies to all tailings cells at the IUC facility. The utah water eualityRegulations require a minimum 3-foot freeboard for wastewater impoundments
that treat 50,000 gallons or more per day [uAC R3l3-10.3(c;1. ru^c has reported
that the tailings disposal system is expected to average 335 gavmin, which
equates to a daily rate of 482,400 gal/day (5l28l99IUC Groundwater Information
Report, p. A-9). Assuming that this rate is evenly dishibuted between all Cells l,
2, and 3, this flow would equate to a daily rate of 160,g00 gallday/cell, which iswell above the 50,000 gal/day limit established by state rule. As a result, the 3-foot minimum freeboard limit applies to the IUC tailings cells, and such a
requirement was stipulated in Partl.D.2 of the Permit. The Executive Secretary
recognizes that the NRC License already requires IUC to make an annual
determination of the minimum freeboard required at the tailings cells to control
the Potential Maximum Precipitation (PMP). This annual evaluation includes
calculations to determine the necessary freeboard required in the tailings cells to
control any upslope run-off that could impinge on the tailings ur"a, andwould
have to be maintained behind the tailings dikes. Consequently, the State,s 3-foot
freeboard requirement imposed in Part I.D.2 is designed to compliment and not
replace the existing License freeboard requirement.
C.
IUC design and as-built reports it was clerwas clear that Tailings Cells I and2 share a
3 - during review of the
common dike, and Cells 2 and 3 share a dike in common. The construction
originally approved by the NRC and the IUC design and as-built reports provided
show different elevations for the top of the FML liner at both the north and south
sides of each of these intervening dikes. consequently, it appears possible for
waste to be disposed at an elevation where the FML does noi exist. The originalNRC approval stipulated that tailings material was to be deposited only to tf,e topof the FML (personal communication, Mr. Harold Roberts, l0/15/04). To
continue this restriction and prevent unacceptable tailings placement above theFML, an additional performance criteria was added to the bermit to require that
the final tailings waste elevation, before cover system emplacement, always be
below the maximum FML liner elevation in each disposai cell. Although Cell I is
cutrently used for process wastewater storage and not for tailings solids disposal,
this requirement would still apply at Cell I at some future time when undeithe
current NRC approved reclamation plan requires Cell I be used for disposal of
demolition debris from the mill and decommissioning wastes from the mill site.
I.D - as discussed above,
the Executive Secretary has determined it necessary and IUC has agreed to insiall
discrete groundwater monitoring wells around each tailings cell as a means toyti{ythe DMT requirements of the cwep Rures [uAC R317-6-6.4(cX3)].
DMT performance standards stipulated in Part I.D.3(a)(2) of the p..-it i"q-ui..t
Statement of Basis DRAFT December 1,2004
IUC to operate and maintain the tailings cells in such a manner as to prevent
gfoundwater conditions in any nearby wells from exceeding the Groundwater
-ompliance Limits established in Table 2 of the Permit
Roberts pond lPart I.D.3(_c)l - as described above, little documentation has been
pr""rd"d by ruc;garding the design and construction of this mill site
wastewatei catchment pot a. This pond, is about 0-40 acres in size, and found
approximately 180 feei west of the mill building and about 200 feet east of the
ntrtneast corner of Tailings Cell 1 (see 6122101 ruC Response, Attachment K,
Site Topographic Map, Revised 6/01). This wastewater pond apparently receives
periodic nioi ataittage and other wastewaters from the mill, is frequently empty,
ind was re-lined with a new FML in May, 2002'
In order to minimize any seepage release from this wastewater pond, the
Executive Secretary has determined that an appropriate DMT operations standard
would be two-fold:
A stipulation that IUC maintain a minimal wastewater head in this pond
basei on a 2-foot freeboard and a l-foot additional operating limit. Since
the top of FML in this pond is about 5,626 feet above mean sea level (ft
amsl), the maximum operating solution limit in the Roberts Pond was set
in the Permit at 5,624 ft amsl. Because the lowest point on the FML is
found at 5,618 ft amsl, this would allow the pond to be operated with a 5-
foot maximum head, and
At the time of mill site closure IUC will excavate and remove the liner,
berms, and all contaminated subsoils in compliance with an approved final
Reclamation Plan under the Radioactive Materials License (hereinafter
Reclamation Plan). Since the Executive Secretary now has Agreement
State status for uranium mills, the DRC will closely examine
decommissioning of this pond at the appropriate time'
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Feedstock storase Area [Part I.D.3(d) and Table 5l - for new facilities, the
@ apotential discharging facilitymeet BAT requirements.
At otier permitted facilities, BAT for waste storage areas has been defined as
storage or". u hardened concrete or asphalt surface. For existing facilities that
preda:ted the GWQP Rules, less stringent design requirements, called DMT
'standards, are imposed [see UAC R3l7-6-6.4(C)]. For the IUC facility, the
Executive Secretary has decided to define DMT for the feedstock storage area by
restricting the locaiions where this activity can be done, and by requiring that
certain feidstock materials be maintained in watertight containers, as described
below.
1) Restricted Area for Open Air Feedstock Storaee -historically feedstock' materiuls fo. th. mill have been stored under open-air conditions in an
area found along the eastem margin of the mill site. In order to minimize
the potential foigroundwater and surface water pollution at the facility,
the Executive Secretary has decided to restrict feedstock storage to the
existing area, thereby constraining the size and location of these activities
in the future. The Executive Secretary determined that this approach to
DMT is appropriate, not only because the practice has a historical
precedencg but also because IUC has a commitment under the
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Radioactive Materials License to decommission and decontaminate this
area at the time of closure, in accordance with a July 7,2000ILJC
Reclamation Plan. During preparation of the permit, IUC staff explained
that this reclamation plan includes radiologic soil surveys of uranium to
determine the depth to which excavation would be conducted, and
contaminated soils removed and disposed of in the tailings cells.
Although DRC staff has yet to review and evaluate the content the IUC
Reclamation Plan, we anticipate this would be done as a part of the next
License renewal, scheduled for sometime on or near March 3r,2007 .
State plane coordinates for the Feedstock Storage Area are defined in
Table 5 of the Permit, as a means to constrain where open-air storage can
be done. These coordinates were initially estimated by DRC staff from a
June, 2001 IUC topographic map (ibid.), and later refined by IUC in a
February 19,2004 email.
Designation of only one (1) open-air feedstock storage area will also
facilitate IUC and DRC compliance inspections by allowing ready
identification of feedstocks stored at the mill site.
containerized Storaee for Feedstock - during permit preparation it was
agreed that if IUC chose to store feedstock materials anywhere else at the
facility, other than the feedstock storage area defined in permit Table 5,
that this storage would be conducted only in closed, watertight containers.
This more stringent requirement is appropriate in order to protect these
other areas from contamination by contact stormwater runoff or feedstock
leachates that might be generated by open-air storage.
Alternate Feedstock Storaee - IUC will be required to obtain an
amendment to its Radioactive Materials License before it will be
authorized to receive and process any new alternate feed materials. This
allows the Executive Secretary prior opportunity to review each license
amendment application and determine if any special storage precautions
are needed to protect groundwater quality, public health and the
environment.
significant quantities of chemical reagents are stored on the mill site for use in the
uranium milling process. In order to minimize the potential for discharge to
native soils and groundwater, a DMT performance standard was added to this
section of the Permit to require IUC to continue to maintain secondary
containment around exiting storage areas and to require that any new or
replacement storage facilities meet current BAT standards. Resolution of this
requirement should be provided by IUC after submittal of the DMT Monitoring
Plan required by Part I.H.13.
leT .4) - this
section has been added to the Permit to ensure that all new construction, modification, or
operation of waste or wastewater disposal, treatment, or storage facilities requires
submittal of engineering plans and specifications and prior Executive Secretary review
and approval. In these plans and specifications the Permittee is required to demonstrate
how the Best Available Technology (BAT) requirements of the GWQP Rules have been
15.
Statement of Basis DRAFT December 1,2004
met. After Executive Secretary approval a Construction Permit may be issued, and the
Ground Water Discharge Permit modified.
Definition of I le.(2) Waste (Part I.D.5) - this definition was added to the Permit for
p"rpor"r of .turity, as it regards prohibited discharges defined in Part I.C.l(c). The
-Executive
Secretary has determined that constraining the types of contaminants
authorized for disposal is consistent with discharge minimization and groundwater
quality protection. Regulatory definition of l1e.(2) waste is found in Section I le.(2) of
tfre U.S. Atomic Energy'Act, 1954, as amended, and includes "the tailings or wastes
produced by the extraction or concentration of uranium or thoriumfrom any ore
'processed primarily for its source material contenf'. In addition to mill tailings solids
and wastewaters, the NRC considers other process related wastes to also be 11e.(2) by-
product material, including (see 317103 NRC letter):
A. Solid waste from facility office buildings,
C.
Spent chemicals used in ongoing process operations, including laboratory
chemicals used for ore assay,
Virgin chemicals intended for use at the facility, but not consumed in process
operations, including laboratory chemicals intended for use in ore assay,
Non-uranium bearing structural or other debris found in altemate feedstock
materials accepted for on-site processing.
Contaminated groundwater from the on-going chloroform groundwater corrective
action project at the facility. This wastewater has been deemed as 1le.(2) waste
in thatlt originated from on-site disposal of spent laboratory chemicals used for
ore assay.
post-Closure Performance Requirements (Part I.D.6) - currently a Reclamation Plan has
b*" ,ppr"*d by th" NRC under the existing License. Soon the NRC License will be
converted to a State License as a part of the Agreement State transfer process. At the
time of the next License renewal, scheduled for sometime around March, 2007, DRC
staff will re-examine the Reclamation Plan for content and adequacy. New requirements
were added to the Permit at this time to ensure that the final reclamation design provided
adequate performance criteria to protect local groundwater quality. This is appropriate,
as discussed above, in that the cover system design and construction is the only means
available to the Executive Secretary to improve the existing facility and protect
underlying groundwater resources, if determined necessary. These new performance
criteria *itt utro guide the infiltration and contaminant transport modeling to be done
shortly by IUC in response to requirements found in Part I.H.l1. To this end, three (3)
requirements were added to ensure that the cover system for each tailings cell will be
designed and constructed to:
Minimize the infiltration of water into radon barrier and underlying tailings waste,
prevent the accumulation of leachates within the tailings that might create a
bathtub effect and thereby spill over the maximum elevation of the FML inside
any disposal cell; thereby causing a release of contaminants to the environment,
and
protect groundwater quality at the compliance monitoring wells by ensuring that
contaminant concentrations there do not exceed their respective GWQS or GWCL
defined in Part I.C.l and Table2.
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To provide consistency with the performance criteria stipulated by the Executive
Secretary at other 11e.(2) disposal operations, a200-year minimum performance period
was required for all three (3) of these criteria.
- Part I.D.7 has been added to
Permit to provide the Executive Secretary an opportunity to ensure that:
Ihe post-closure performance requirements for the tailings cell cover system in
Part I.D.6 is fully and adequately integrated into the Reclamation Plan. Because
DRC evaluation of this Reclamation Plan will be done at the time of the next
License renewal, scheduled on or around March, 2007 part I.H.l I has been
added to the Permit to require that IUC complete an infiltration and contaminant
tranSport model of the final tailings cell cover system to demonstrate the long-
term ability of the cover to protect nearby groundwater quality. As a part ofthis
cover system performance modeling required by part I.H.l l, the Executive
secretary will determine if changes to cover system are needed to ensure
compliance with the Part I.D.6 performance criteria.
All other facility demolition and decommissioning activities outlined in the
Reclamation Plan will be done in a manner adequate to protect local groundwater
quality. Issues or concerns to be considered and resolved include, but are not
limited to:
1) Identification, isolation, and authorized disposal of any un-used chemical
reagents held in storage at the mill site at the time of closure.
2) Demolition, excavation, removal, and authorized disposal of a[
contaminated man-made structures, including, but not limited to:
buildings, pipes, power lines, tanks, access roads, drain fields, leach fields,
fly-ash disposal ponds, feedstock storage areas, mill site wastewater
storage ponds, solid waste disposal landfills, and all related appurtenances.
3) Excavation, removal, and authorized disposal of all contaminated soils
found anywhere outside of the tailings cells at the facility.
Through this process the Executive Secretary aims to ensure that DMT has been
adequately established for both the final tailings cell cover system and reclamation of the
facility.
and and I.H.lil - one aspect ofDMT is preventing and controlling contaminated stormwater and chemical spills frommill site activities. [n July, 2001 ruC provided the DRC a draft copy of a July 17, 2001
Spill Management Plan. Said plan included a section on stormwater management.
During a meeting in February,2004IUC explained that they had submitted this plan for
NRC approval. IUC also submitted a copy of the plan to DRC on July 17, 2001 and laterprovided a second coPy, which contained additional minor revisions on April 26,2004.
Subsequent DRC research found that the July 17,2001 draft plan had not yet been
approved by the NRC. Currently, DRC staff are in review of this plan and will provide
comments to IUC shortly. With respect to this issue, IUC and DRC reached the
following agreements:
A. IUC is an existing facility under the GWQP Rules. Therefore, the existing
stormwater management system and chemical I rcagent storage facilities would be
accepted "as is" under the permit.
Statement of Basis DRAFT December 1,2004
In the future, any construction of new reagent storage facilities or major re-
construction of existing facilities will meet current BAT design and operation
standards"
Re-construction of reagent storage facilities may be required by the DRC after a
major spill or catastrophic failure of existing storage facilities, pursuant to the
Permit re-opener provisions in Part IV.N.3.
D. IUC will revise both plans submitted to take into account and resolve any
Executive Secretary comments, and re-submit a final Stormwater Management
and Spill Control Plan for approval. The final plan will establish acceptable
operational, maintenance, monitoring, and reporting requirements for stormwater
management and spill prevention and control. The final plan will also provide
speciic actions to prevent, respond to, control, and remediate spills of chemical
reagents at the mill site.
To this end part I.D.8 was added to the Permit to require IUC to conduct its activities in
compliance with an approved Stormwater Management and Spill Control Plan. Part
t.ff.iZ was added to require IUC to submit a final version of this plan for Executive
Secretary approval.
I.E.1) - this section prescribes the
-""rt"""g r"q"""*ents for groundwater monitoring wells at the facility, including
upgradienq downgradient, and lateral gradient wells. Some of the specific requirements
are described below:
-1'l- routine groundwater
q""ttty *""rt"""g is commonly done on a quarterly basis (4-times/year).
Iio*"r"., the Executive Secretary may allow a reduced frequency of routine
groundwater sampling if site specific groundwater conditions warrant [see UAC
F.f tZ-O-0.t6(AXt)1. For certain sites where groundwater velocities have been
found as low as one to two feet per year, the Executive Secretary has approved a
semi-arurual sampling frequency (2-times/year) in order to avoid statistical
problems such as auto-correlation, and allow a better measure of natural
groundwater quality variations.
During preparation of the Permit, IUC submitted a March 25,2004 Hydro Geo
CnemlffC-C) letter and a January 30, 2003 HGC groundwater velocity report
wherein IUC suggested that local groundwater velocity at White Mesa was about
l.l to 2.8 feetlyeir. Detailed DRC review found the January 30, 2003 HGC
analysis to be based on an area between the tailings cells and Ruin Spring, and not
focused on each individual monitoring well at the facility (see9l2ll04 DRC
Memorandum).
on october 15,2004 a conference call was held between DRC staff and
representatives of IUC and HGC. During this call, DRC staff asked that
ad-ditional work be done to determine local groundwater velocity at each
monitoring well at the site, where velocity would be calculated on well specific
hydraulic ionductivity and hydraulic gradient data. On this same date, IUC staff
pioposed that there be two (2) different frequencies of routine groundwater
monitoring at White Mesa, as follows:
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o Semi-annual (2 times/year) where groundwater velocity is less than l0
feet/year, and
o Quarterly (4 times/year) where groundwater velocity is equal to or greater
than 10 feet/year.
Later IUC provided an October 19,2OO4 HGC letter report that revised previous
HGC groundwater velocity calculations by providing well specific values. Afterreview of this HGC report, DRC staff found four (4) tailings wells at the White
\desa facility exhibit local groundwater flow velociiy .quuI to or greater than 10
feetlyea4 including (see I ll23l04 DRC Memorandum, iables I ind2):
o cross-eradient wells: MW-26 (14 feet/year) and Mw-32 (19 feet /year).
Previously these wells were named Tw4-15 and rw4-17, respectivlly, and
o Downeradient wells: MW-l I (135 feet/year)and MW-l 4 (62 feet/year)
All other existing IUC tailings cell monitoring wells were found with local
groundwater velocities of less than l0 feetlyear (ibid.). Based on this
information, the Executive Secretary has agreed to accept IUC,s proposal for two(2) different routine groundwater monitoring scheduler ut th" aci1ty, based on
the following findings:
Areas of high groundwater velocity deserve more frequent sampling in
order to rapidly detect contamination and remediate ilearlier while the
problem is smaller and closer to the source. To do otherwise is not
protective of groundwater quality resources, and serves only to make theproblem more expensive before it is discovered and corrected.
At IUC wells where groundwater velocity is equal to or above l0
feetlyear, groundwater will travel more than 2.5 feetbetween quarterly
sampling events. At the highest velocity tailings well, MW_t f 1t:Sfeetlyear), groundwater at this downgradient location will havel about 34
feet between quarterly sampling events. The Executive Secretary believes
that this provides sufficient reaction time to confirm any contaminant
exceedance and regain control thereof.
At IUC wells where groundwater velocity is less than 10 feetlyear,
groundwater will travel less than 5 feet between each semi-annual
sampling event. At the tailings well with the lowest velocity, Mw-l(0.026 feetlyear) groundwater at this upgradient location wiil travel a very
short distance between each semi-annual sampling event (0.01 feet), and
auto-correlation will likely occur. Despite this statistical drawback, the
Executive Secretary believes that semi-annual sampling at this and other
low velocity locations is protective of the environment.
Above and beyond these baseline frequencies, the permit contains
provisions for accelerated groundwater monitoring to confirm the presence
of groundwater contamination, see part I.G.l . Under these requirements,
IUC is mandated to accelerate its monitoring frequency when any
pollutant in any well exceeds its respective GWCL in Table 2 of the
Permit. For those wells with a semi-annual baseline frequency, quarterly
accelerated monitoring is required. For wells with a quarterly baseline
schedule, monthly accelerated sampling is required. In summ ary, a single
Statement of Basis DRAFT December 1,2004
exceedance in a single well will result in a much higher sampling
frequency in order to confirm the apparent problem, and pursuant to Part
I.G:I, this accelerated monitoring will continue until the Executive
secretary can determine the compliance status of the facility.
If groundwater contamination is detected and confirmed in the future,
tec'hnology is available to control the contamination, and even reverse its
flow and thereby contain it near its source.
IUC owns and controls a large area of land downgradient of the tailings
cells where it can control public access to groundwater. Further, the seeps
and springs found at the edge of White Mesa where the public could be
exposed tlo contaminated groundwater are even more removed from the
taiiings cells. These long distances appeal to provide ample reaction time
to deiect and confirm the presence of contamination, and design and
implement corrective actions to regain control of said releases, should they
occur.
Momtonng raramglgrs Lrart r.D.rt.u,ll - t uLu IIvIU ouu rsuvr@rvrJ
; compliance' The need for laboratory analysis for
I.both field and laboratory parameters are
the Table 2 compliance parameters is self-evident. Certain other groundwater
quality parameteis were added to assist in interpretation of general geochemical
condiiions present in the aquifer, including the major anions and cations. Due to
the limited informatiott uruilubl" and uncertainty in the characterization of the
tailings cells contaminant source terms, a broad suite of VOCs are also required
under the Permit (EPA Method 8260). In general, many VOC parameters may be
key indicators of groundwater pollution, in that they are man-made and are
*ouit" in groundwater environments, see discussion above.
C. Special provisions [Part I.E.l(d)l - during review of the data from several split
*-pting "r"rrt, ,ir." M ay, 1999, certain quality assurance issues have been
identified by the Executive Secretary. In order to ensure that these issues are
resolved in the future, special provisions have been added to the Permit to draw
attention to them.
I.E.2) - certain wells and piezometers exist at the
Well Part I.- in order to Provide an
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I1JC fr4tty th"t ur" **pt.t.a it the shallow aquifer, but are not listed in Table 2 as
compliance monitoring wells for the tailings cells. These include five (5) piezometers
associated with the *it-olif" ponds (p-l thru p-5), two (2) existing wells outside the IUC
restricted area (MW-20 and MW -22), atdseveral wells related to the chloroform
investigation. currently these chloroform investigation wells include Mw-4A, TW4-1
thru T,i/4-14, TW4-16, fW+-tS, and TW4-19, but may change as the investigation and
corrective action project progresses' Depth to groundwater or head monitoring is
required of these *"i1, in ora.r to maximize our understanding of local groundwater flow
directions at the facility. To this end, a requirement was added to do this extra head
monitoring at these existing wells and piezometers at the same frequency as the
ermit requires that a number of new monitoring
wells be installed, see Part I.H.l. To ensure that these new wells are properly located and
compliance monitoring wells.
38
constructed, certain performance criteria have been added to the Permit in this section'
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- this section has been added to the permit
to provide general performance criteria for groundwater sampling. Most important of
these is the requirement that all groundwater monitoring comply rritt a quality assurance(QA) plan, such as will be submitted by IUC for Executive Sicretary upprolrui, pursuant
to Part I.H.6. In order to comply with requirements found in the GWep Rules iUeCR317-6-6.3(I) and (L)1, ruC will need to submit its existing QA plan to ensure ihut it it
consistent with EPA guidance found in the RCRA Ground Water Monitoring Technical
Enforcement Guidance (TEGD) document (EpA, 19g6).
and I.H.9) - as
described below, monitoring of the contact seeps and springs ut tt " rag" of Wrte Mesa
is important because these locations are where the shaliow aquifer discharges, and henceform points of exposure for wildlife and the public for any groundwater contamination
that may be released from the facility. This monitoring wili not replace the compliancewell monitoring required by Part I.E.l, which will provide a much earlier warning of arelease. Instead, the seep and spring monitoring is designed to compliment the IUCmonitoring well data, and confirm that activities at the IUC facility have not adversely
impacted local surface water quality. Under the requirements of tLese two (2) sections of
the Permit this sampling and reporting will be completed on an annual basis.
Determination of those seeps or springs selected for sampling will be completed afterExecutive Secretary approval of the White Mesa Seep and Spring Sampling Report
required by Part I.H.9. Commencement of this annual surface *iter monitoring will thenbegin after modification of the permit accordingly.
DMT 6 and - Part I.E.6 stipulates the24.
monitoring requirements
standards set forth in Part
needed to demonstrate compliance with the DMT performance
LD.2 and 3 of the Permit, as summarized below:
A.Tailines Cell 1 - including weekly wastewater pool level monitoring to determine
compliance with the minimum freeboard requirement in Part 1.D.2. Again, if the
maximum wastewater pool elevation is exceeded, IUC is required to immediatelynotify the Executive Secretary under the provisions of parts I.F.3 and I.G.3.
Quarterly depth to groundwater and groundwater quality sampling and analysis is
also required from three (3) discrete monitoring wells immediately adjacenito
Cell l. DMT compliance is maintained at Cell 1 when the groundwater quality in
these three (3) monitoring wells does not exceed their respeitive GWeS in fa'Ute
2 of the Permit. In the event that any groundwater contaminant in these wells
exceeds a GWQS, IUC will be required to report the non-compliance pursuant to
Parts I.G. I and2. A compliance schedule requirement has been added to part
I.H.l to ensure the DMT monitoring wells are installed properly at cell 1.
Tailines Cells 2 and 3 - including weekly wastewater pool elevation and slimes
drain water level monitoring. DMT compliance is maintained when the water
levels in the wastewater pools and in the slimes drain layers are below their
respective maximums specified in Part l.D-2. In the event that either of these
wastewater levels exceeds the requirements, IUC is required to report them
immediately to the Executive Secretary in accordance *ith Part I.F.3 and I.G.3.
Roberts Pond - including weekly monitoring of wastewater levels in the Roberts
Pond at the mill site to verify that the wastewater head is maintained so as to
provide the minimum 2-foot freeboard required by part I.D.3(c).
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Statement of Basis DRAFT December 1,2004
Feedstock Storase Area - including weekly monitoring to ensure that:
Bulk feedstocks are located and stored only inside the approved Feedstock
Storage Area, and that
Containerized feedstocks located outside the approved Feedstock Storage
Area are maintained in closed, water-tight containers.
In order to ensure that IUC provides appropriate monitoring equipment, and adequate
operation and maintenance procedures for DMT monitoring, a compliance schedule
requirements has been added to Part I.H.l3 to require submittal and approval of a DMT
Monitoring Plan.
and I.F.7 - much of the
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di.""*'ir" above regarding determination of groundwater monitoring parameters rs
intimately related to ttre type of ore or feedstock material being processed, and the types
and conclntrations of chemicals used on-site in the milling process, on-site laboratory,
etc. For this reason, the Executive Secretary has determined it critical to maintain an
inventory of chemicals in storage and used at the facility in order to determine at some
future date the appropriate parameters that should be considered both for characterization
of the tailings cells wastewaters, and for groundwater monitoring parameters.
To this end, monitoring requirements were added to Part I.E.7 to require IUC to maintain
a current chemical inv-ntory on site. The Executive Secretary recognizes that some
chemicals may be used at such a small rate that they do not constitute a potential risk to
groundwater quality. In order to address this issue, an annual consumption rate of 100
fg/y, *ut tp""in"d. Using this provision, IUC need not inventory those compounds
whose annual consumption is less than this amount.
Reporting requirements for this inventory were also added to Part I.F.7, where IUC will
ue requirld to submit a report at the time of Permit renewal, i.e., 180 days before
expiration of the current Permit.
The Executive Secretary has determined it important to establish a baseline inventory of
historical and current chemicals used at the facility. To this end, a new Permit
requirement was added to the Permit's compliance schedule in Part I'H'10'
I.E.
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LFS*"d tHfl - uft"r r*i"* of the historic tailings cell wastewater quality samples
*tt""t"a to Auie by IUC, it appears that IUC's tailings wastewater sampling and analysis
has been focused on process control and not environmental considerations (see
Attachment 6, below). Historically, IUC has not been required to conduct any
comprehensive analysis of this tailings wastewater for environmental purposes.
Consequently, the available data are limited both in the number of samples and
pururn"i..r. iltU" information is also available regarding quality assurance issues for
said sampling and analysis. In light of this situation a new requirement has been added to
the permit to require a comprehensive and routine examination of tailings wastewater
quality for environmental purposes. To facilitate this, a compliance schedule item was
added to part I.H.5 to requireluc to submit a plan for Executive Secretary approval for
routine tailings cell wastiwater monitoring. The purpose of this sampling plan is to
identify the d]stinct sources of tailings wastewater that will be sampled (wastewater pool,
slimes drain, etc), standardize all sampling and analytical procedures, and provide an
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outline for compliance with all related monitoring and reporting requirements in parts
I.E.8 and I.F.8 of the Permit.
This approach of annual sampling assumes that over several years a sufficient number of
samples will be available to adequately describe the average chemical conditions of these
wastewaters.
Further, the approach in Part I.E.8 also specifies that the samples be collected in August,
at the peak of the evaporation season in order to measure the highest contaminant
concentrations in the sybtem.
Other approaches to sampling frequency could have been used, such as: 1) a minimum
number of days of mill operation, 2) sampling after a change in feedstocksprocessed, or
3) multiple samples for each season of the year, etc. However, all of these Lave
drawbacks, in that they: l) ignore the dynamics of local weather conditions which
change from year to year, 2) ignore processing schedule dynamics which are also
variable, 3) require more samples to be collected, 4) mandate tedious monitoring andreporting to document and justifu the frequency used, and 5) result in increased sampling
costs with little apparent benefit. In the end, the Executive Secretary chose a simple
approach of one (l) annual sample from each tailings wastewater source to be collected
when contaminant concentrations should be highest.
The information generated by this routine monitoring will also be helpful in the on-goingchloroform contaminant investigation. In an April 11, 2002 Technical Information
Request, DRC staff asked IUC to fully characteize the contaminants in this wastewater,
and allow the State to collect split samples in this process (ibid., pp. l5-16). The need for
this characterization was discussed with IUC in meetings of eprii-tZ and,i4,2OO2. In
the latter meeting, IUC agreed to sample and, analyze the tailings wastewater for a
comprehensive suite of contaminants, including, but not limited to: metals, VOCs, Semi-vocs, etc. It was also agreed that a sampling plan would be submitted for DRC
approval before sampling began. Later,IUC provided a May 3l,2}02work plan for thissampling. DRC staff reviewed the sampling plan and requested additional information in
a July 3 , 2002 email. Because discussions about the content of this sampling plan are on-going, Part I.H.5 has been added to the Permit to require IUC to submit a tai'iings cellwastewater sampling plan for Executive Secretary approval.
Pending completion of this sampling plan, on August 12,2003IUC voluntarily submiued
results of several grab samples collected from the tailings cells in March, 211i,which aresummarized in Attachment 6, below. Preliminary DRC review shows the following:
IUC samples were collected from impounded wastewaters in Tailings Cells I and
3 and analyzed for a partial list of the analytes previously agreed to in the plan,
including: major ions, nutrients, metals, and radiologics,
No sampling was conducted of impounded wastewater at either Tailings Cells 2
or 44 because no exposed solution was available at the time of sampling (March,
2003),
No samples were collected from the slimes drain layers or leak detection systems
in Cells 2,3, or 4A,
No analysis was made for any voC or Semi-voC contaminants in any sample.
This March,2003IUC data may be used at sometime in the future by the Executive
Secretary in his review of routine monitoring data to be collected under the permit. In
Statement of Basis DRAFT December 1,2004
the meantime, the Permit will require routine monitoring in order that a defensible and
representative characteizationof tailings wastewater quality be completed.
part I.E.8 of the Permit also requires IUC to provide 30-day prior notice, so as to allow
the Executive Secretary an opportunity to collect split samples of these tailings cell
wastewaters. DRC staff intena to periodically conduct such split sampling as a means of
verification of IUC',s tailings wastewater chatacteization.
Reporting requirements in Part I.F.S mandate that IUC report the annual tailings
*urt.*ut-., quality results with the 3'd quarter groundwater monitoring report, due each
year on Decembei 1. This section also requires that the content of these reports be
,i*itu, !o the quarterly groundwater monitoring reports, by providing the field data
sheets, copies oftn" laboratory reports, a quality assurance evaluation and data
validaiion, and reporting in etectronic format, pursuant to Part I'F'l(a), O), (d), and (e)'
- this section was added to
reporting and to detail the types of routine quarterly
groundwater monitorin g datarequired. The schedule provided in Table 6 of the Permit
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illo*. IUC 45 days after the end of each quarter to submit the required information.
Most of the data requirements are self-explanatory, but are specificallylistgd in the
permit to assist tUi in providing complete submittals. The list of required information
will also provide a guidi for the types of information that must be considered in
preparatiin of the Groundwater Monitoring Quality Assurance Plan, required by Part
DMT performance Upset Reports (Part I.F.3) - this requirement was added to the Permit
f"r "lrrifr*tion prrp*"r to distinguish this reporting from the routine DMT performance
reporting to be submitted quarterly under Part I.F.2. Examples of DMT failures that need
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In addition, the Executive Secretary has required the submittal of quarterly water table
contour maps to emphasis the need to understand groundwater flow directions at the
facility. pursuant to Part IV.N.3, these contour maps will allow the Executive Secretary
to require new compliance monitoring wells should it be discovered that groundwater
flow directions have changed.
A section has also been added to require IUC to provide the groundwater quality results
in an electronic format, which will allow the Executive Secretary ready access to the
information and will speed review of the data'
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purt ff : fras been uaa.O to ttr. permit to require quarterly reporting for all monitoring
related to the DMT standards specified in Part I.8.6, including wastewater pool
elevations in all three (3) tailings cells, slimes drain head for Tailings Cells 2 and 3, and a
sunmary table of weekly wastewater levels measured by IUC at the Roberts Pond in the
mill site area.
In the event that IUC discovers an upset condition, where the DMT performance standard
has been violated, they are required to notify the Executive Secretary within 24-hours of
discovery (verbal) uri 5 duytlwri6en; of the problem. Examples of these types of
problems, include, but are not limited to:
Excess wastewater head at any of the tailings cells or the Roberts Pond,
Excess leachate head in the slimes drain layer at Tailings Cells 2 or 3;
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to be reported under this section include, but are not limited to: excess wastewater pool
elevations in Tailings Cellsl, 2,3, andthe Roberts Pond; excess slimes drain leachate
heads at Tailings Cells 2 and 3; bulk feedstock materials stored outside the approved
storage area; and leaking containers of altemate feedstock materials, etc.
Other lnformation (Part I.F.4) - in the event that the Permittee omits information, or
discovers incorrect information was reported, this section provides a timeline by which
IUC must correct or complete the respective repoft.
I.F.5) -this section has been addedto the Permit to provide specific guidelines on what kinds of information are required formonitoring well as built reports. The Executive Secretary deems it necessary to provide
these details, in light of the need for additional monitoring wells at the faciliiy, as
mandated by Part I.H.l of the Permit.
Part of the requirements mandated here require the geologic log for each monitoring well
be prepared by a Professional Geologist licensed by the State. This requirement was
added in order to comply with the recent Professional Geologist Licensing Act, enacted
by the Utah State Legislature in2002, and the attending Professional Geologisi Licensing
Rules (UAC Rl56-76). The requirement that the survey coordinates for each monitoringwell be prepared by a Utah licensed land surveyor or engineer was added to the permit in
order to ensure accuracy for the survey coordinates reported.
- this section of the permit is taken almost
verbatim from the GWQP Rules in UAC R317-6-6.16(A). It requires the permittee to
accelerate the frequency of monitoring in the event that any pollutant in any well exceeds
its corresponding GWCL, as defined in Table 2 of the Permit, and to continue that
accelerated monitoring frequency until such time as the Executive Secretary ca1_
determine the compliance status of the facility. Because semi-annual and quarterly
groundwater monitoring have been defined as the routine frequencies in part I.E.l, this
accelerated monitoring status would require quarterly and monthly groundwater quality
sampling, respectively.
Violation of Permit Limits (Part I.G.2) - this section is taken almost verbatim from theGWQP Rules, found in UAC R317-6-6.16(8).
34. Failu
Rules found in
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Permit
- this section of the Permit is taken almost verbatim from the Gwep
UAC R317-6-6.16(C)
I.H.l6) - general requirements to addressfacility out-of-compliance status are found in Part I.G.4 of the permit, which is taken
almost verbatim from the GWQP Rules (UAC R317-6-6.17). This section of the permit
references the ability of the Executive Secretary to require immediate implementation of
the Contingency Plan to regain and maintain compliance with the permit, should the
Permittee fail to act [see Part I.G.4 (d)]. Such Executive Secretary action is authorized by
the GWQP Rules IUAC R3 I 7-6-6. I 7(A)(4)]. This plan is also required as a part of a
Permit application in the GWQP Rules IUAC R317-6-6.3(N)]. To date, IU0hasn,t
submitted a Contingency Plan for Executive Secretary approval. The overall goal for thisplan is to provide the necessary actions for IUC to re-gain compliance in seveial areas
regulated by the Permit, including: groundwater quality, limitations or prohibitions on
contaminants discharged to the tailings cells, and/or Discharge Minimization Technology
performance standards (e.g. tailings cell solids and wastewater elevations, slimes drain
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operation, etc). For this reason a compliance schedule item in Part I.H.16 has been added
to ttre permit to require IUC to provide a final plan for Executive Secretary approval.
Accelerated Monitorine Status for New Wells (Part I.G.5) - this section was added to the
P"@liancemonitoringofthenewtailingsce1lmonitoringwells
required by Part I.H.1 does not beginuntil after Executive Secretary approval of the
nack$ound Groundwater Quality Report required by Part I.H.4. As a result, IUC will
not be required to accelerate their monitoring frequency, as per Parts I.G.1 (Probable Out-
of-Compliance), or I.G.2 (Out-of-Compliance), until after approval of this report.
- the GWQP Rules require
th"t th" Pr""it application include several information items regarding quality assurance
and quality.otrtrol for groundwater monitoring [UAC R3l7-6-6.3(I) and (L)]. Part of
this riquirlment mandates that groundwater sampling conform to the EPA RCRA
Ground Water Monitoring Technical Enforcement Guidance (TEGD) document (EPA,
1986). prior to the May,leel sptit sampling event, IUC provided a Groundwater Quality
Assurance Project Planto the DRC (3/90 ruC Groundwater QA Project Plan, Rev. 2).
However, thisilan was written for purposes of the NRC radioactive materials license,
and did not specifically rely on the EPA RCRA TEGD (ibid., p. 3). In order to provide
IUC the opportrnity to modiff their existing plan to conform to the State requirements, a
,"* .o-piiur"" scledule item was added to Part I.H.6 of the Permit, which mandates a
revised pian be submitted for Executive Secretary approval. After review and approval
of this modified plan, the permit will be re-opened and modified to require that all future
groundwater sampling comply with the new plan.
I.H.7) - during several
rit"r rrrit. ,"d four (4) split groundwater quality sampling events since May, 1999, DRC
staff have noted the need for remedial construction, maintenance, or repair at several
monitoring wells at the IUC facility, including:
Well Development - 16 of the existing monitoring wells at the IUC facility fail to
pr"d".. "1*t groundwater in confornance with the EPA RCRA TEGD. The
observed groundwater turbidity appears to be the product of incomplete well
developmint, and poses a potential for bias of the groundwater quality analytical
results, particularly for metals and nutrients' Consequently, the Executive
Secretary has determined it necessary to require IUC to develop these wells in
order to ensure they meet the EPA RCRA TEGD turbidity criteria of 5
nephelometric turbidity units (NTU), to the extent reasonably practicable'
Protective Surface Casinss: Piezometers - in response to a DRC request for
"ddtt."rt hydr"geologic information, IUC installed five (5) piezometers at the
White Mesafaciiity in December, 2001 (518102 Hydro Geo Chem Report, p.1)'
While no protectivl steel surface casings were called for in the original approved
installation plan, it is important to protect these piezometers because they are used
for groundwater head monitoring under PartI.E.2. The lack of protective casing
porJr a problem because the l-inch diameter PVC piezometer casings could be
easily bioken by surface activities. Also, PVC is prone to degradation by
ultraviolet light, and could be easily degraded.
In order to ensure that the monitoring wells are properly repaired and developed in a
timely manner these requirements have been added to Part I.H.7.
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during recent
information,
including:
Missine Geolosic Loe - review of the MW-3 well as-built diagram shows that no
geologic log was provided at the time of well installation(7194 Titan
Environmental Report, Appendix A, as-built diagram). consequently, it is
impossible to ascertain if the screened interval was adequately located across the
base of the shallow aquifer, i.e., at or below the upper contact of the Brushy Basin
Member of the Morrison Formation.
Lack of Filter Media - well MW-3 was constructed without any filter media or
sand pack across the screened interval.
Excessivelv Lone Casine Sump - a 9 or lO-foot long non-perforated section of
well casing was constructed at the bottom of this well.
Poor Positionine of Well Screen Apparent - about 2 week after installation of
well MW-3, mill staff found the well to be dry (ibid., Appendix A,9ll4l7g).
However, in late September, 1979 mill staff measured the static water level at a
depth of 83.4 ft (ibid., Appendix 8,9125179). Recent DRC water level
measurements show that the water table surface is found at a similar depth, 83.6
feet below the water level measuring point (ft bmp, 919/02). After consideration
of the well's measuring point stickup , r.95 feet, the September,2oo2 water level
was only about 5.3 feet above the base of the well screen. This well construction
and water table depth poses a problem in that at the IUC purge rate of 2 gallons
per minute (gpm), the well is rapidlypurged dry and IUC is unable to complete
both purging and sample collection in one continuous process.
Arguments have been made by IUC that the well screen in MW-3 was properly set based
on the local geology found there. However, no geologic or geophysical logs exist to
support this assertion. Consequently, the Executive Secretary has determined it
necessary to verify, retrofit or reconstruct this well. Key to this mandate is the
requirement to determine the total saturated thickness of the aquifer at well MW-3, which
will require determination of the depth of the upper contact of the Brushy Basin Member
of the Morrison Formation at this location. This can be done either by geophysical
logging and/or drilling of a confirmation boring in the immediate vicinity of the well.
After determination of the complete saturated thickness of the aquifer at well MW-3, the
Permittee is required to retrofit or re-construct the well to ensure the well screen fully
penetrates the saturation. Thereafter, a new well as-built report must be submitted. After
approval of the replacement well, if needed, the Executive Secretary may require
plugging and abandonment of the former well. The Permittee is also required to provide
at least a7-day notice of all field activities, so as to allow the Executive Secretary to
observe these activities and participate in decisions regarding the fate of well MW-3.
white Mesa Seeps and Sprinss Samplins Report (part I.H.9) - in a February 7,2000
request for information, IUC was asked to provide a hydrogeologic study of the contact
seeps and springs found at the edge of White Mesa (see 217100 DRC Request for
Information, p. 13). The purpose of this study was to establish background groundwater
flow and water quality conditions at these discharge points, and included a request for:
split sampling events and after review of available well MW-3 as-built
DRC staff have found several problems with the construction of this well,
40.
Statement of Basis DRAFT December 1,2004
Land Survey - of the seePs/sPrings,
Water Table Contour Map - of both the IUC monitoring wells and the contact
seeps/springs, and
Groundwater ouality Sampline - and analysis of said seeps/springs.
IUC responded to portions of this request in a September 8, 2000 submittal. Later the
DRC renewed its request for survey coordinates for these seeps and springs in a March
20,ZO1t letter to IUC (3120101 DRC Request for Information, p. 6). Subsequently, IUC
provided survey coordinates for three (3) contact seeps at the edge of White Mesa,
including elevation data (9l7l0l ruC letter, attached spreadsheets).
Subsequently, other parties expressed interest and concern in the groundwater hydrology
and walter quality oflhese seeps and springs at the edge of White Mesa, including the
Moab office of the Bureau of Land Management (BLM), and White Mesa band of the
Ute Mountain Ute Tribe (Ute Tribe). ln June, 2002the DRC proposed a collaboration
between the BLM, Ute Tribe, IUC and DRC to study the hydrogeology of the White
Mesa contact seeps and springs. In subsequent discussions it was agreed that: 1) the Ute
Tribe, with BLM assistance, would complete a detailed reconnaissance of all the seeps
and springs found downgradient of the IUC tailings cells at the edge of White Mesa, 2)
IUC would provide a land survey to accurately locate and determine the elevation of all
the seeps and springs identified by the Ute Tribe, and 3) DRC would provide analytical
services for the groundwater quality samples collected.
Later,on September 20,2002 DRC and Ute Tribe staff conducted a preliminary field
survey of seeps and springs in the area, and located six (6) different discharge points at
the edge of White Mesa, all of which appear to be hydraulically downgradient of the IUC
facitity. These seeps and springs are summarizedinTable 10, below.
2002
Footnotes:
ffin.-tir.a.ompass direction and approximated distance from estimated center of IUC Tailings Cell 1.
During a May 21,2003 conference call between BLM, Ute Tribe, IUC and DRC staff
several otheraspects of this hydrogeologic study were discussed, including: goals and
objectives ofthe study, need for an upgradient reference seep, field and laboratory
parameters to sample and analyze, field sampling equipment and methods, data quality
assurance rrr"ur*r"i needed, and capability for split sampling. At the conclusion of this
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B.
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Table 10. Known White Mesa Perimeter Seeps and Springs as of Septembff
Seep or
Spring
Name
USGS 7.5
Minute
Ouadranqle
Approximate Location Relative to
IUC Tailines Cells (r)
Approximate MaP LocationDirectionDistance (ft)
Entrance
Seeo
BlackMesa
Butte
East 4,700 -300 ft E.,0 ft S., NW Corner,
Sec. 34. T. 37 S., R.22F,.
Westwater
Seep
Black Mesa
Butte
West 5,200 -1,000 ft E., 200 ft S., NW Corner, Sec.
32.T.37 S., R.22E.
Cottonwood
Seep
Black Mesa
Butte
Southwest 9,400 -1,500 ftN,2,200 ftW., SE Corner,
Sec. 31. T.37 S., R.22F,.
Ruin Spring Black Mesa
Butte
Southwest 13,000 -2,200 ft E., 1,200 ft S., NW Corner,
Sec. 8. T. 38 S.. R.228.
Corral Seep Big Bench South 16,200 -300 ft E., 1,200 ft N., SW Corner, Sec.
10. T. 38 S.. R.22 E.
Tank Seep Big Bench Southeast 21,400 -2,300 ft N., 400 ft W., SE Corner, Sec.
15, T. 38 S., R.22 E.
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meeting, the parties agreed to convene again after the Ute Tribe completed its detailed
field survey of White Mesa seep and spring locations. On July l,20}3,the Ute Tribe
reported that the field survey was about half done (7lll03 Ute Tribe email). To date, it is
unknown if the Ute Tribe field survey has been completed.
After all of these considerations, the Executive Secretary has determined it appropriate
for IUC to bear the responsibility forthis study, by adding a Permit requirement for a
White Mesa Seeps and Springs Sampling Report in Part I.H.9. This is done not only to
ensure IUC participation, but to accelerate completion of the study, and provide timely
resolution of concerns held by local citizens and tribal members regarding the potential
for pollution from the tailings cells to adversely affect nearby surface *uG. quality.
A provision has also been added to Part I.H.9 to allow the Executive Secretary to re-open
and modify the Permit after approval of said sampling report, in particular parts I.8.5 andI.F.6. The purpose of this action is to allow the collection of background groundwater
head, flow, and water quality data during the operating life of the facility. This is
important in that these seeps and springs form points of exposure for wildlife and the
public where offsite groundwater contamination could be discharged. By way of
clarification, it is not the Executive Secretary's intent to use this siep and spring
sampling in lieu of compliance monitoring well sampling at the facility. Instead, it is to
be used to complement that data collected from wells at the IUC faciliiy, with the intent
of establishing background water quality conditions at these surface water locations.
Recently IUC initiated its own sampling of Ruin Spring and sampled Cottonwood Spring
on one occasion when water was available. At the time these samples were collected,
these were the only seeps and springs IUC considered to have sufficient flow to allow
sampling. Results of this sampling have yet to be reviewed by the DRC.
and Plan 2\ - after review of
available well completion information, IUC was informed that the construction of a deep
supply well, WW-2,locatedhydraulically upgradient of the mill site, was inadequate, in
that it failed to provide an annular seal that would isolate the deep confined aquifer from
the shallow unconfined aquifer (see 217100 DRC Request for Additional information, pp.
7-9). This same DRC request also asked that this problem be investigated for all other
deep supply wells at the IUC facility (ibid., p. 9). In response IUC agreed to consider
several alternatives for well WW-2 at the time of mill decommissioning (9/3/00 ruC
Response, p.20). To this end, a new condition was added to the Permii in part I.H.12 to
require submittal of a work plan within I year of Permit issuance that would apply to all
the deep supply wells at the facility. This mandate also provides: l) a performance
objective to ensure that both physical and hydraulic barriers are constructed in the deep
supply wells at the time ofplugging and abandonment to prevent hydraulic
communication between the shallow unconfined and the deep confined aquifers, and2) a
requirement that the provisions of the approved plugging and abandorr*ent plan on or
before decommissioning of the uranium mill.
- as described above, the Executive
Secretary in issuance of this Permit has reviewed the existing engineering design and
construction, determined the DMT design and performance standards (Parts I.D.1 and
I.D.3), established DMT monitoring criteria (Part I.E.6), and established DMT reporting
requirements (Part I.F.2). However, the Executive Secretary has not yet had the
opportunity to review and approve the specific activities, procedures, and equipment that
IUC will use to monitor and verify DMT compliance. In order to provide for this
42.
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Statement of Basis DRAFT December 1,2004
opportunity, part I.H.l3 has been added to the Permit. Facilities that need to be
examinea in this plan include, but are not limited to: various wastewater level criteria for
Tailings Cells l, ),3 andthe Roberts Pond; the Feedstock Storage Area restrictions, and
secondary containment for mill site reagent storage'
Relatively short timeframes have been provided in order to accelerate IUC's
implementation of DMT. Provisions have also been included in Part I.H.13 to allow the
Executive Secretary to re-open and modify the Permit, so as to include all necessary
monitoring procedures and equipment.
.H.14) - as discussed above
Part although somewhatTailinqs cell 44 Redesign ancl l(econstrucUon ( raIT r.Ia.l I , - aluruuB[ suurtrw
."d*dr"t *ith th" prwisions of Part I.D.4, this requirement has been added to
emphasize the need for Executive Secretary approval before any re-construction of
tailings Cell44, including: soil foundation or sub-base preparation, liner construction, or
leak detection system construction. This section also allows the Executive Secretary to
re-open and modify the Permit to add any necessary design, construction, operation,
.orrltotirg or reporting requirements for the revised cells'
the GWQPExecutive Secretary -htndtngs Kegarotng rxtsung rasrlty nequueurguls - Lrre \r Yv vr
n rt"r -uraate that G Executive Secretary may issue a Permit for a facility that was
constructed before adoption of the GWQP Rules in 1989, i.e., an "existing" facility, that
certain provisions are met by the applicant, including [UAC R3 l7-6-6'a(Q]:
,,...1. the applicant demonstrates that the applicable class TDS limits, ground
water quality standards and protection levels will be met;
2. the monitoring plan, sampling and reporting requirements are adequate
to determine compliance with applicable requirements;
the Executive Secretary has determined it necessary to require IUC to continue to
compiete its removal of th" contaminated materials and liner system in existing tailings
Cell44. Over the past two (2) years IUC has been removing the raffinates and salts that
have been stored inthe cell, and disposing of them in tailings Cell 3. To ensure that this
process is completed in a timely manner, a requirement has been added to Part I.H.14 to
iequire IUC to submit a contaminant removal schedule for completion of this work for
Executive Secretary approval. This new requirement also mandates periodic progress
reports, and a frnal-completion report that isto be submitted after contaminant removal is
finished, for Executive Secretary approval. It is anticipated that adequate contaminant
removal will include removal of all fluids, any residual salts or solids, the FML liner
system, any underlying LDS, and all contaminated clay sub-liner and any contaminated
sub-soils. b*ing permit preparation, it was agreed that IUC will perform a radiologic
survey and/or uranium laboratory analysis ofthe clay subJiner and ifnecessary any
unaertying soils found under tailings Cell 4A to determine the total extent of any clay
sub-liner or subsoil contamination. This approach is justified, in that under oxidizing or
acidic conditions uranium is expected to by highly mobile in soils. Consequently, the
Executive Secretary believes that uranium soil concentrations can be used as a tracer to
estimate the vertical penetration of contaminants in the raffinates and salts once stored in
Cell4A. No approvut of tn. final contamination removal report will be issued until the
Executive Secretary is satisfied that any contaminants potentially released to the clay sub-
liner or sub-grade soils via the FML leakage discussed above, have been adequately
recovered and placed back into appropriate engineering control.
44.
45.
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Statement of Basis DRAFT December 1,2004
3. the applicant utilizes treatment and discharge minimization technologt
commensurate with plant process design capability and similar or
equivalent to that utilized byfocilities that produce similar products or' services with similar production process technologlt; and,
4. there is no current or anticipated impairment of present andfuture
beneficial uses of the ground water."
After consideration of the above discussion, the Executive Secretarybelieves the GWep
Rule requirements have been or will be met by the provisions of the draft permit, as
described below:
A. Applicable TDS Limits. GWOS. and GWPLs - the draft Permit establishes both
GWQS and GWCLs for all related contaminants known to exist in the tailings
wastewater effluent. On an interim basis, the GWCLs assigned herein were based
on the factoring approach allowed in the GWQP Rules. Later,after completion
and approval of the existing well Background broundwater Quality Report (part
I.H.3), the Executive Secretary will establish a GWCL based on descriptive
statistics (X+2o) for all compliance parameters in Table 2 ineachmonitoringwell' Future compliance monitoring at the facility will verify if IUC continues to
meet these GWCLs at each well. If at sometime, one of more wells exceed its
GV/CL for TDS or any other Table 2 contaminant, enforcement action will be
taken to ensure local groundwater quality is restored.
B. Monitoring Plan. Sampling and Reportins Requirements - groundwater
monitoring at the facility is adequate in that all related contaminants known to
exist in the tailings effluent at elevated concentrations have been selected for
compliance sampling, and respective GWQS and GWCL have been established.
DMT monitoring requirements have also been determined for each potential
contaminant source at the facility. Although a certain number of monitoring wells
need to be installed, and groundwater compliance and DMT monitoring plans
need to be finalized and approved, the Executive Secretary has required th.s"
activities to be completed and the missing plans submitted for approval. Upon
approval of these activities, completion by IUC, and submittal and approval of the
required monitoring plans, the Executive Secretary will re-open and modify the
permit to incorporate all necessary requirements. At that point, the approved
monitoring plans will become enforceable appendices to the Permit, ana th"
Permit will be complete in terms of providing adequate monitoring and reporting.
C. Satisfactory DMT - the review conducted herein has identified those aspects of
existing facility design and construction that do not meet current standards. In
fum, the Permit specifies new monitoring and operational improvements to
minimize the potential for discharge of contaminants to native soils and
groundwater from several potential sources at the facility, including the tailings
cells, wastewater ponds, feedstock storage areas, etc.
D. Impairment of Beneficial Uses of Groundwater -This determination will be made
by the Executive Secretary after IUC completes two major efforts: 1)
Improvements to the existing monitoring well network, including addition of new
wells to provide more discrete and more rapid detection of potential seepage
release from the tailings cells, and establishment of an approved groundwater
monitoring quality assurance plan to enhance reliability of reported monitoring
DRAFTStatement of Basis
Attachments (11)
F:/.../IUCgwpSOB2f.doc
File: IUC Ground Water Permit
LBM:lm
December 1,2004
results, and2) Submittal of a Background Groundwater Quality Report to provide
a compreheniive evaluation of local groundwater quality conditions' After
review of this report, the Executive secretary will re-open the Permit and modiff
the GWCLs to reflect natural groundwater conditions, or may take enforcement
actions as necessary to protect local groundwater quality and all related current or
future beneficial uses oigrdundwater. In either case, a public review and
comment period will be frovided, either for a modified Permit, or at the time of
approval of *y groundwater corrective action plan that may be required'
with regards to possible future groundwater quality impairment, infiltration,
groundiater flow, and contaminant transport modeling will be providedby IUC
io predict future compliance by the facility. The Permit requires that these types
of models be used tolvaluate the existing NRC approved Reclamation Plan for
the facility, and stipulates minimum performance criteria for the same. If the
modelingindicates that these minimum performance criteria will not be met, then:
l. Changes to the tailings cell cover design will be implemented by the
Executive Secretary in the Reclamation Plan under the State License, and
2. The input values to these models will become the design basis for the final
engineiring design, specifications, and construction parameters for the
cover system at the reclaimed facility.
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Statement of Basis DRAFT December 1,2004
References
D'Appolonia Consulting Engineers, Inc., February, 1982, "Construction Report Initial Phase -
Tailings Management System White Mesa Uranium Project Blanding, Utah Energy Fuels
Nuclear Inc. Denver, Colorado", unpublished consultants report, approximately 7 pp., 6
tables, l3 figures,4 appendices.
Dames & Moore, January 30,1978, "Environmental Report White Mesa Uranium Project San
Juan County, Utah for Energy Fuels Nuclear, [nc., unpublished consultants report,
approximately 549 pp., 9 appendices.
Deutsch, W. and P. Longmire, February, 1997,"Practical Applications of Groundwater
Geochemistry", National Ground Water Association seminarproceedings, Denver, CO,
approximately 988 pp.
Energy Fuels Nuclear, Inc., March, 1983, "Construction Report Second Phase Tailings
Management System White Mesa Uranium Project Energy Fuels Nuclear, Inc.",
unpublished company report, l8 pp., 3 tables, 4 figures, 5 appendices.
Hem, J.D., 1985, Study and Interpretation of the Chemical Characteristics of Natural Water", 3'd
Edition, USGS Water Supply Paper 2254,264pp.
Hintze, L.F., 1988, Geoloeic History of Utah, Brigham Young University Geology Studies
Special Publication 7, 202 pp.
Hydro Geo Chem, Inc., May 8, 2002,letter report of as-built details for monitoring wells and
piezometers at the IUC White Mesa uranium mill, unpublished consultants report from
Stewart J. Smith to Michelle Rehmann, includes May 9,2002 hansmittal letter by David
C. Frydenlund of International Uranium Corporation to William J. Sinclair,2 pp.
Hydro Geo Chem, Inc., January 30, 2003,"Site Hydrogeology and Estimation of Groundwater
Travel Times in the Perched Zone White Mesa Uranium Mill Site Near Blanding, (Jtah",
unpublished consultants report, l8 pp., 2 tables, 7 figures.
Hydro Geo Chem, IDC., March 25,2004, untitled letter from Stewart Smith to Harold Roberts, 4
pp.
Hydro Geo Chem, Inc., October 19,2004,letter report from Stewart Smith to Harold Roberts on
well specific groundwater average linear velocity, 3 pp., I table, 2 figures; includes an
October 20,2004International Uranium (USA) Corporation transmittal letter from David
C. Frydenlund to Loren Morton, 1 p.
International Uranium Corporation, March, 1990, "White Mesa Mill's Ground Water QA Project
Plan, Rev. 2", unpublished companyplan, 17 pp, includes February 24,1999 transmittal
letter from Michelle R. Rehmann to William J. Sinclair,2 pp.
International Uranium Corporation, May 28,1999, "Groundwater Information Report White
Mesa Uranium Mill Blanding, Utah", unpublished company report, I l3 pp., l2 tables, 15
figures, 8 attachments.
Statement of Basis DRAFT December 1,2004
Intemational Uranium Corporation, September 30, 1999, "Chloroform Source Assessment
Report", unpublished company report by Michelle Rehmann, 13 pp., 2 figures, and2
appendices.
International Uranium Corporation, August, 2000, "Construction Report Tailings Cell 4A White
Mesa Uranium Mill - Tailings Management System", unpublished company report, 13
pp., 2 fi gures, 12 attaclwrents, 1 4 photographs'
International Uranium Corporation, September 8, 2000, "Groundwater Information Report
Revision Package", unpublished company report, 31 pp., l1 attachments, includes
September 8, 2000 transmittal letter from David C. Frydenlund to William J. Sinclain, 2
pp.
International Uranium Corporation, June 22,2001, "March 20,2001 UDEQ Letter and Request
for Additional Site Hydrogeology Information in Response to IUSA September 8, 2000
Revised Groundwater lnformation Report; Groundwater Discharge Permit for White
Mesa Mill; Followup to May l l, 2001 Letter from David C. Frydenlund to William J.
Sinclair", unpublished company response, 20 pp.,14 attachments'
International Uranium Corporation, July 17,2OOl, "Draft Spill Management Plan, Groundwater
Discharge Permit Application for White Mesa Mill", includes three plans: l) July 17,
2001 Stormwater Best Management Practices Plan, 7 pp.,4 figures, I table, and2
Appendices (Appendix 1: July 17,2001 :Spill Prevention, Control, and Countenneasures
for Chemicals and Petroleum Products", l4pp.,6 tables, 2 figures; and Appendix2:
April 29, 1998 "Emergency Response Plan", l5 pp.,4 exhibits, 2 appendices, I figure, I
table).
Intemational Uranium Corporation, September 7,200l, "Updated Topographic Map,
Groundwater Discharge Permit Application for White Mesa Mill", unpublished company
letter from Harold R. Roberts to William J. Sinclair, 1 p., includes map and 4
spreadsheets.
Intemational Uranium Corporation, May 3l,2002, "Pond Solution Sampling Workplan White
Mesa Uranium Mill Site Near Blanding, IJtah", unpublished company work plan, 4pp.,
includes May 31, 2002 transmittal letter from Michelle Rehmann to William J. Sinclair, 2
pp.
International Uranium Corporation, September 6,2O\2,"Transmittal of Brushy Basin Contour
Map, White Mesa Mill Site Utah DEQ Notice of Violation and Groundwater Corrective
Action Order UDEQ Docket No. UGQ-20-01 of August 23, 1999", transmittal letter (2
pp.) and unpublished company contour map.
Intemational Uranium Corporation, October 15,2\O2,"W.ater Level Map and Resolution of
Increasing Water Levels Observed in MW-4, Utah DEQ Notice of Violation and
Groundwater Corrective Action Order, UDEQ Docket No. UGQ-20-01 of August 23,
lggg",unpublished company submittal, 2pp.,l map, 50 pages of water level data.
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Statement of Basis DRAFT December 1,2004
Intemational Uranium Corporation, December 20,2002, "November,2002 Letter from Utah
Department of Environmental Quality to International Uranium Corporation Regarding
November,200l Split Sampling Results for the White Mesa Uranium Mill", unpublished
company response, 4 pp.,2 attachments.
International Uranium Corporation, August 3l,z}}4,"International Uranium (USA) Corporation
Source Material License No. SUA-1358 White Mesa Mill, Blanding, Utah Semi-Annual
Effluent Monitoring Report for Period January I,2OO4 through June 30, 2004,,,
unpublished company monitoring report, 3 pp., 7 attachments, includes transmittal letter
from Ron Berg to Mr. Dane Finerfrock, 2 pp.
International Uranium Corporation, October 17,2}}3,"September 16,2003 Letter from the Utah
Departrnent of Environmental Quality, Division of Water Quality to International
Uranium (USA) Corporation", unpublished company response, 3 pp., 2 attachments.
uranium corporation, February 19,2004, "Supporting Information for GwDp,,,
correspondence from Harold Roberts to Loren Morton, I p. 3 attachments.
National Library of Medicine,Hazardous Substances Data Bank, part of the Toxnet System,
found on the intemet at: http://toxnet.nlm.nih.gov/.
Pankow, J.F. and J.A. Cherry,1996, Dense Chlorinated Solvents and Other DNApLs in
Groundwater, Waterloo Press, portland, Oregon, 522pp.
Risher, J.F. and S.W. Rhodes, June, 1995, "Toxicological Profile for Fuel Oils", U.S.
Department of Health and Human Services, Public Health Service, Agency for Toxic
Substances and Disease Registry, 231pp.,2 appendices, found on internet at:
www.atsdr.cdc. eov/toxprofi les/tp75-c3.pdf.
Thomas, D. and J.J. Delfino, Fall, 1991, "A Gas Chromatographic / Chemical Indicator
Approach to Assessing Groundwater Contamination by Peholeum products", Ground
Water Monitorine Review, National Ground Water Association, pp. 90-100.
Titan Environmental Corporation, July, 1994, "Hydrogeologic Evaluation of White Mesa
uranium Mill", unpublished consultants report, approximately 5l pp., 5 tables, 19
figures, 7 appendices.
Titan Environmental Corporation, September,1994,"Points of Compliance White Mesa
Uranium Mill", unpublished consultants report, 13 pp., I table, 4 figures, 3 appendices.
Umetco Minerals Corporation, April 10, 1989, "Cell4 Design", unpublished company report,
includes: l) April 10, 1989 letter from Curtis O. Sealy to Edward F. Hawkin., t pp., *itf,
60 pp. of technical response materials, and2) August, 1988 Umetco Minerals
Corporation "Cell 4 Design Tailings Management System", unpublished company report,
17 pp.,2 attachments, and 2 appendices.
Umetco Minerals Corporation and Peel Environmental Services, January, 1993, "Groundwater
Study White Mesa Facility Blanding, IJtah",unpublished company and consultants
report, approximately 54 pp., 5 appendices.
Statement of Basis DRAFT December 1,2004
umetco Minerals corporation, June, lgg4,"Gtoundwater Study 1994 Update White Mesa
Facility Blanding, IJtah", unpublished company report, 51 pp', 6 appendices.
United States Code of Federal Regulations, Title 10, Chapter 1 - Energy, "Domestic Licensing
of Source Material", Part 40 (10 CFR 40), Appendix A "Criteria Relating to the
Operation of Uranium Mills and the Disposition of Tailings or Wastes Produced by the
Extraction or Concentration of Source Material From Ores Processed Primarily for Their
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rm/doc-collections/cfr/.
United States Court of Appeals, District of Columbia Circuit, February 25,2003, Docket Nos'
0l-102g, 0l-103i, 0l-1034, and 01-1037,City of Waukesha; Village of Sussex Water
Commission; Radiation, Science & Health; Nuclear Energy Institute, Inc.; and the
National Mining Association versus Environmental Protection AgencY,49 PP., available
on the lnternet at:2603 and at
united states Environmental Protection Agency, september, 1986, RCRA Ground-water
Monitoring Technical Enforcement Guidance Document, Office of Solid Waste and
Emergency Response, OSWER-9950.1, 208 pp', 3 appendices'
United States Environmental Protection Agency, February, 1989, "statistical Analysis of
Ground-Water Monitoring Data at RCRA Facilities, Interim Final Guidance", Office of
Solid Waste, aPProximatelY 146 PP'
United States Environmental Protection Agency, Jarntary,1995, "Technical Resource Document
Extraction and Beneficiation of Ores and Minerals Volume 5 Uranium", EPA 530-R-94-
032,74 PP., 3 aPPendices.
United States Environmental Protection Agency, Region 8, August 24,1999, "Toxicity of
Tetrahydrofirran", unpublished agency memo from Robert Benson, Ph.D- to Loren
Morton, Utah DEQ, I P., 2 attachments.
United States Environmental Protection Agency, January 4,2}O},technical correspondence
letter from Mr. Robert Benson, EpA Region 8 drinking water program toxicologist to Loren
Morton, Utah Division of Radiation Control,2 pp'
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Health Advisories", EPA 822-R-02-038,12 pp., available on the Intemet at
United States Environmental Protection Agency, Regron 8, May 29,2003, "Lifetime Health
Advisory and Cancer Risk for Chloroform", unpublished agency memorandum from
Robert Benson, Ph.D. to Loren Morton, Utah DEQ ,2 pp'
United States Nuclear Regulatory Commission, May, 1979, "Final Environmental Statement
Related to Operat[n of White Mesa Uranium Project Energy Fuels Nuclear, fnc., Docket
54
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Statement of Basis DRAFT December 1,2004
No. 40-8681", NUREG-0556, Office of Nuclear Material Safety and Safeguards,
approximately 290 pp.
United States Nuclear Regulatory Commission, September, 1980, "Final Generic Environmental
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Vol. III, Office of Nuclear Material Safety and Safeguards, approximately 238 pp.
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No. SUA-I358, Docket No. 040-8681, Amendment No. 22", agency license to
International Uranium Corporation for Uranium Mill at White Mesa, Utah, 1I pp.
United States Nuclear Regulatory Commission, March 7,2003, "Response to Questions in
January 14,2003 Letter from William Sinclair", agency response letter from Paul H.
Lohaus to William J. Sinclair, 3 pp.
Utah Department of Environmental Quality, July 18, 1996, "lnformation Needs Summary for
Atlas Corporation Moab Uranium Mill Ground Water Contaminant Investigation Report
and Ground Water Corrective Action Plan, as found in the Utah Ground Water Quality
Protection Regulations (UAC R317-6-6.1 5),24 pp., found as an attachment to a
September 12,1996 Utah Division of Radiation Control letter from William J. Sinclair
and Don A. Ostler to Richard E. Blubaugh, 6 pp.
Utah Division of Radiation Control, February 7, 2000, "Muy, 1999 ruC Groundwater
Information Report: DRC Request for Additional tnformation Related to Site
Hydrogeology'', unpublished agency request, 2 pp. transmittal leffer, includes Utah
Division of Radiation Control technical information request of February 7, 2000
"Request for Additional lnformation Related to Site Hydrogeolo1t'', 18 pp., 2
attachments.
Utah Division of Radiation Control, J:urire 27,2000, "International Uranium Corporation White
Mesa Uranium Tailings Facility: Engineering Design and As-Built Reports; Staff
Findings, Conclusions, and Recommendations", unpublished agency technical
memorandum, 29 pp., 5 attachments.
Utah Division of Radiation Control, March 20,200l, "September 8, 2000 IUC Revised
Groundwater Information Report: Ground Water Discharge Permit Application for White
Mesa Mill: Request for Additional Site Hydrogeology Information", unpublished agency
request for information, 10 pp., 3 attachments.
Utah Division of Radiation Control, June 7, 200I, "October 4,2000IUC and HGC Investigation
of Elevated Chloroform Concentrations in Perched Groundwater at the White Mesa
Uranium Mill Near Blanding, Utah: August 23,1999 Utah Division of Water Quality
Notice of Violation and Groundwater Corrective Action Order; Docket No. UGW20-01:
Request for Additional Information.", unpublished agency information request, 12 pp., 8
attachments.
Utah Division of Radiation Control, october 26, 200l, "September 21, 2001NRC Draft
Environmental Assessment Regarding Maywood New Jersey FUSRAP Site: IUC White
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Statement of Basis DRAFT December 1,2004
Mesa Uranium Mill Near Blanding, LJtah", unpublished agency comment letter from
William J. Sinclair to Melvyn Leach, U.S. NRC, 5 pp.
Utah Division of Radiation Control, November 15, 2001, o'Recent Meetings and Conference Call
with tnternational Uranium Corporation Regarding Hydrogeologic Conditions at White
MesaMill, October4, 18, and24,2001-,unpublishedagencytechnicalmemorandum, 16
pp., 3 attachments.
Utah Division of Radiation Control, April I l,2002,"November 9,2001IUC Update Report on
Ongoing Chloroform Investigation at White Mesa Uranium Mill; AugustZ3,1999
Division of Water Quality Notice of Violation and Groundwater Corrective Action Order,
Docket No. UGW20-01: Request for Additional Information", unpublished agency
information request, 18 pp., 5 attachments.
Utah Division of Radiation Control, July 3, 2002, "IUC: 5/31102 Tailings Pond Wastewater
Sampling Workplan - DRC Comments", unpublished agency comments, email
transmittal from Loren Morton to Harold Roberts, 2 pp.
Utah Division of Radiation Control, November 22,2002, 'November, 2001 Groundwater Split
Sampling Event at IUC White Mesa Uranium Mill Near Blanding, Utah: Utah DEQ
Request for Additional Information", unpublished agency information request, 4 pp.,7
attachments.
Utah Division of Radiation Control, April 30,2003, "November,2}0l Split Sampling Event at
IUC White Mesa Uranium Mill: DRC Staff Review and Conclusions", unpublished
agency memorandum report, 44 pp.,7 tables, 29 attachments.
Utah Division of Radiation Control, September 16,2003, "December 20,2002IUC Response
Regarding Recent Detection of Tetrahydrofuran Concentrations in Groundwater at the
White Mesa Uranium Mill: Request for Work Plan", unpublished agency information
request, 3 pp., 2 attachments.
Utah Division of Radiation Control, November 12,2003, "October 17 ,2003 IUC Response to
September 16,2003 DRC Request for Work Plan; THF Contamination of Several
Monitoring Wells at White Mesa Uranium Mill: Request for Work Plan", 5 pp, 5
attachments.
Utah Division of Radiation Control, November 26,2003, "IUC: Groundwater Protection Level
Statistics and Accelerated Monitoring Frequency'', email correspondence from Loren
Morton to David Frydenlund,2PP.
Utah Division of Radiation Control, September 2l,2004, "Review of IUC Report - 'Site
Hydrogeology and Estimation of Groundwater Travel Times in the Perched Zone White
Mesa Uranium Mill Site Near Blanding, Utah', January 30, 2003 by Hydro Geo Chem,
Inc.", unpublished agency technical memorandum, 6 PP., 4 figures, 7 tables.
Utah Division of Radiation Control, November 23,2004, "Review of Hydro Geo Chem Inc
Report - Report on Perched Zone Water Movement, White Mesa Uranium Mill Site Near
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Statement of Basis DRAFT December 1,2004
Blanding, Utah, October 20,2004", unpublished agency technical memorandum , 4 pp.,2
tables, 5 figures.
Utah Division of Water Quality, August 8,1994, "Basis for Revised Ground Water Protection
Levels: New Parameters and Revised Shallow Ground Water Quality Statistics",
unpublished staff report, 39 pp., 23 attachments.
Utah Division of Water Quality, August 23,1999, 'Notice of Violation and Groundwater
Corrective Action Order; Docket No. UGW20-01: Request for Additional Information.",
unpublished agency order and information request,12 pp., 8 attachments.
Utah Division of Water Quality, June 12, 2003, "Chloroform Standard for White Mesa Mill
Corrective Action", unpublished agency memorandum from Don Ostler to Bill Sinclair, I
p.
Utah Division of Water Quality, September 16,2003, "December 20,2002IUC Response
Regarding Recent Detection of Tetrahydrofuran Concentrations in Groundwater at the
White Mesa Uranium Mill: Request for Work Plan", unpublished agency information
request from William J. Sinclair to Harold Roberts, 3 pp., 2 attachments.
Ute Mountain Ute Tribe, July l, 2003, "White Mesa Seep Sampling", unpublished tribal email
from Scott Clow to Loren Morton, 2 pp.
DRAFT
ATTACHMENT 1
Utah Division of Radiation Control
Water Table Contour MaPs
For the September,2002 Split Sampling Event
At the IUC White Mesa Uranium Mill
Near Blanding Utah.
DRC Surfer Maps: 9-02h.srf,9-02h-b.sd and 9-02h-c.srf,
and DRC spreadsheet GWHEAD.XLS, tabsheet 9-02
DRAFT
ATTACHMENT 2
Utah Division of Radiation Control
Summary of Shallow Aquifer TDS Concentrations
At the IUC White Mesa Uranium Mill
Near Blanding Utah.
DRC Spreadsheet GWclass.xls, tabsheets Sum, HistSum, and HistSumELI
DRAFT
ATTACHMENT 3
Utah Division of Radiation Control
Summary of IUC Wells and Parameters
That Exceed their Respective GWQS
At the IUC White Mesa Uranium Mill
Near Blanding Utah.
(based on DRC/IUC split sampling results)
DRC spreadsheet GWclass.xls, tabsheet Exceed
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ATTACHMENT 4
Utah Division of Radiation Control
Time Series Concentration Graphs of
Natural Uranium Contamination in
IUC White Mesa Mill
Groundwater Monitoring Wells
MW-14, MW-I5, andMW-17
From August 31,2004IUC Semi-Annual Effluent Monitoring Report,
Groundwater Statistical Analysis by Shewhart-Cusum Method June 30, 2004 Section
DRAFT
ATTACHMENT 5
Utah Division of Radiation Conhol
Shallow Aquifer Uranium 238 Isoconcentration Map
For the September,2002 Groundwater Split Sampling Event at the
IUC White Mesa Uranium Mill Facility
Near Blanding, Utah
DRC Surfer Contour Maps: U238-9-02.srf and U238-9-02b.srf
DRC Excel spreadsheet U-238.x1s, tabsheet 9-02
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DRAFT
ATTACHMENT 6
Utah Division of Radiation Control
Summary of IUC Tailings Cells
Historic Wastewater Quality Data
From the White Mesa Uranium Mill
Near Blanding Utah.
DRC spreadsheet TailsWQ.xls, tabsheet NewSum
DRAFT
ATTACHMENT 7
Utah Division of Radiation Control
Summary of Literature Values for
Soil-Water Partitioning (K6) Coefficients for Metals
DRC spreadsheet I lE2KdSum.xls
Tabsheet: Metals
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DRAFT
ATTACHMENT 8
Utah Division of Radiation Control
Summary of Literature Values for
Organic Carbon Partitioning Coefficients (K*)
Soil-Water Partitioning (Ka) Coefficients for Organics
DRC spreadsheet 1 lE2KdSum.xls
Tabsheet: Org-Koc
DRAFT
ATTACHMENT 9
Utah Division of Radiation Control
Summary of Detectable Organic Contaminants
Found in Utah DRC Split Groundwater Samples
Colleted from the IUC White Mesa Uranium Mill Site
From MaY, 1999 thru SePtember,200?
DRC spreadsheet Splitsum.xls
Tabsheet: Organics
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DRAFT
ATTACHMENT 10
Utah Division of Radiation Control
Summary of Groundwater Quality
Split Sampling Results
For Selected Volatile Organic Contaminants
From the IUC White Mesa Uranium Mill,
May, 1999 thru Septemb er, 2002
DRC spreadsheets: Benzene.xls, CTC.xls, and THF.xls
Tabsheets: HistSum
DRAFT I
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ATTACHMENT 11
April 16,2004
Proposed Groundwater Monitoring Well Location Map
Received by the
Utah Division of Radiation Control
On April 20,2004
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DRAFT
ATTACHMENT 12
Utah Division of Radiation Control
Groundwater Velocity Contour Map
(based on IUC velocity data)
From November 23,2004
Utah Division of Radiation Control
Memorandum, Figure 2