DRC-2008-002421 - 0901a068809b24cd

Oonbon ltrml (U8A) Corp.
IUJO l70r 3tre0 Sulb l!0
Dcnvrr, CO t0:Lt
u3A
Tol :303 tl&l?9t
Fu : 303 3tt-.tt25
www.de nbgnninracom
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Deursor,r MrNES (USA) CoRp.
Steven D. Landau
Manager, Environmental Affairs
cc: Ron F. Hochstein
Harold Roberts
David Frydenlund
David Turk
DENlsOJY/
,YIINES
April 14,2008
VIA FEDERAL EXPRESS
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4850
Re:White Mesa Uranium Mil! Groundwater Discharge Permit UGW370004
P arl 1.H.21-Transm ittal of Dru m med Feedstock Ma na gement Procedu re
Dear Mr. Finerfrock:
ln accordance with the Part 1.H.21 of the above-captioned Groundwater Discharge Permit please find
enclosed the Mill's procedure for the storage of drummed feedstock at locations other than the
feedstock storage area.
lf you should have any questions regarding this procedure please contact me.
Yours Very Truly,
Drummed Feedstock Management Procedure
1.0 Purpose
The purpose of this procedure is to assure that storage of feedstock material is conducted
in a manner so as to preclude the release of Mill feed material to the environment.
2.0 Scope
Feed materials delivered to the White Mesa Mill must be stored in a manner which
preludes the release of the materials to the environment. In the case of bulk materials,
such as unrefined natural ores and alternate feeds delivered in inter-modal containers,
these materials are offloaded from the truck or shipping container directly onto the
approved ore pad where migration of material is precluded by the pads design and
operating procedures (i.e. low permeability pad material, dust control procedures and
limited stockpile height). tn addition to these bulk shipments, some materials are received
in "super sacks" which are necessarily offloaded to the ore pad due the fact that the sacks
can be compromised during the offloading process and, as such, should be stored on the
designed ore storage pad. However, certain feeds are received in drums which serve to
effectively contain the material during storage and, as such, are amenable for storage at
locations other than the ore pad. It is the intent of this procedure to describe the
precautions utilized for drummed feed storage in order to assure that the containerized
materials are not released to the environment.
Procedure
Storage Location
Drummed feeds are stored at locations adjacent to the ore pad and which have
been selected to avoid impact by site drainage and/or pooling. Prior to storage,
planks or pallets are placed beneath the drum storage locations in order to raise
the container from the ground surface and avoid corrosion from water which may
accumulate during precipitation events (despite site selection) and from rusting
due to soil moisture when drums are stored directly on the ground.
Drum Inspection
All drums received at the White Mesa Mill are inspected to determine drum
integrity prior to placing the drum into storage. Each drum will be observed on
all sides for damage or leakage of contents. Dented drums are acceptable if the
dent is not located near a seam or when the dent is not accompanied by a damage
crease on the drum surface. Drums damaged by dents near the seam, crease
damaged drums or drums that have been otherwise compromised during shipment
are re-packed or placed in over-pack drums prior to storage. Drums which are not
damaged are moved directly for placement at the storage location.
3.0
3.1
3.2
J.J Storage Protocol
In accordance with MSHA requirements, drum storage must be implemented is
such a manner as to limit the potential for a drum to tip or fall onto a worker.
Accordingly, drums are not stored in rows with spaces between drums to
eliminate the possibility of a drum falling on and trapping an individual within the
drum rows. In addition, MSHA allows storage of stacked drums but limits drum
stacks to three drums in height due to stability concerns. Given these
considerations, Denison stores drums without spaces between rows and limits
drum stack height to three drums high. while the drums are being placed in a
stacked configuration, care is taken to tip drums against each other andtoward the
center of the storage location as a means of assuring stability of the drum storage
perimeter.
Storage Area Inspections
The drum storage area will be inspected on a monthly basis (and after significant
precipitation events) in order to assure that the stored drums remain intact, that
standing water has not accumulated and to assure that materials are not migrating
from the storage area.
3.4
Dl/o=tli'8ll
April 14,2008
VIA FEDERAL EXPRESS
Mr. Dane L. Finerfrock
Executive Secretary
Utin R"oiation Control Board
5il; ;i Ut"ri oepariment of Environmental Quality
168 North 1950 West
slit t-at<e city, ur 84114-4850
Re: white Mesa uranium Mill Groundnrater Discharge Permit ucw370004
part 1.H.2 1 -Transmittal of orumri"J F""Gtock -Management Procedure
Dear Mr. Finerfrock:
ln accordance with the part l.H.21of the above-captioned Groundwater Discharoe Permit please find
encrosed the Mi1,s procedure for the'-siJrli" oiiirrr;Jf;il;d;i. at locaiions other than the
feedstock storage area.
lf you should have any questions regarding this procedure please contact me'
Yours Very TrulY,
Donbon illnr {U3A) Cotp
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DenYtr, CO t02at
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Dertsott Mlles (USA) ConP.
Steven D. Landau
Minaget, Environmental Affairs
cc: Ron F. Hochstein
Harold Roberts
David Frydenlund
David Turk
1.0 Pumose
The purpose of this procedure is to assure that storage of feedstock material is conductedin a manner so as to preclude the release of Mill feeimaterial to the enyironment.
2.0 Scope
Feed materials delivered to the white Mesa Mill must be stored in a manner whichpreludes the release of the materials to the environment. In the case of bulk materials,such as unrefined nafural ores and alternate feeds delivered in inter-modal containers,these materials are offloaded from th^e truck or shipping container directly onto theapproved ore pad where migration of material is piectuaed by the pua.- a"rign urraoperating procedures-(i.e. low permeability pad ,nuioiul, dust lontroipro""a*es andlimited stockpile height). In addition to thesl rirrt rnip-""ts, some materials are receivedin "super sacks" *1"! are necessarily offloaded to the ore pad due the fact that the sackscan be compromised during the offloading process and, as such, should be stored on thedesigned ore storage pad. However, cert;il feeds are ieceived in drums which serve toeffectively contain the-material during storage and, as such, are amenable for storage atlocations other than-the ore pad. i is G intent of this procedure to describe theprecautions utilized for drummed feed storage in order to assure that the containerizedmaterials are not released to the environment.
3.0 Procedure
3.1 Storage Location
Drummed feeds are stored at locations adjacent to the ore pad and which havebeen selected to avoid impact by site drainage and/or pooling. prior to storage,planks or pallets are placed beneath the druil storage locations in order to raisethe container from the ground surface and avoid corrosion from water which mayaccumulate dl""g precipitation events (despite site selection) and from rustingdue to soil moisture when drums are stored directry on the ground.
3.2 Drum Inspection
All drums received at the white Mesa Mill are inspected to determine drumintegrity prior to placing the drum into storage. Each drum will be observed onall sides for damage or leakage of contents. bented drums are acceptable if thedent is not located near a seam or when the dent is not accompanied by a damagecrease on the drum surface. Drums damaged by dents near the .Ju*, creasedamaged drums or drums that have been othiwise compromised during shipmentare re-packed or placed in over-pack drums prior to storage. Drums which are notdamaged are moved directly for placement at the storage location.
J.J Storage Protocol
In accordance with ylHA requirementl druT storage must be implemented issuch a manner as to rimit the potenti{ fu, , d*; ;iip or fa, onto a worker.Accordingly, drums are not stored.in rows ;il;;es between drums toeliminate the possibility of a drum falling on and;;pd;r, individuar within thedrum rows' In addition, MSHA allows storage or siackJa drums but limits drumstacks to three drums in height due. to stability concerns. Given theseconsiderations, Denison stores J*-r without .p";; iJr*."n rows and rimitsdrum stack height to three.drums high. while tt" o*,n. are being praced in astacked configuration, care is taken tJtip orumr rgr*i "".r, other and toward the
;:ffi|j."e storage location as a meiuls of assuri"ngrt"tilitv of the a** ,toiug"
Storage Area Inspections
The drum storage area will be inspected on amonthly basis (and after significantprecipitation events) in order to alssure that the ,tor"a-a**s remain intact, that
il#|n: #;ffi;t accumulated and to assure tt"tl"t*iur, *".,oirnffing
3.4
JON M. HUNTSMAN, JR
Govemor
GARY HERBERT
Lieutenanl Gwernor
State of Utatl
Department of
Environmental QualitY
Dianne R' Nielson, Ph.D.
. Executive Director
DIVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
I
:
t
December 1,2006
Mr. David C. FrYdenlund
Vice President and General Counsel
International Uranium Corporation
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
White Mesa Uranium Mill Ground Water Monitoring Quality Assurance Plan
(QAP), Ground water Discharge Permit No. UGW370004 (Permit) - Approval
oitt " eAp, Revision 1.0 and Minor Permit Modification No. 4.
Dear Mr. FrYdenlund:
The Division of Radiation Control (DRC) has reviewed Revision I of the QAP that was
submitted on Novemb er ZO,2006. The submitted QAP is in response to a Confirmatory Action
Letter issued by DRC dated April 12, 2006 and a Unresolved Issues and Request for
Modifications io the QAP letter issued by the DRC dated october 10, 2006' Based on our
review we have approved Revision I of the QAP'
Based on this approval, minor modifications were made to the Permit in Part I.E'(4Xb) and (e),
and Part I.H.6 was taken out. These changes to pages in the Table of contents, 14 and 15, and
ii tt.ougt 2g of the permit are shown in iedline-strikeout format, see attached pages. A final
version a:nd replacement pages for the Permit (Table of Contents and pages 14 through 28) are
also attached.
168 Norrh 1950 west. po Box 1,14850. Salt kke City, uT 841l4-4850. phone [phone] 'fax [phone]
T.D.D. (801 ) 53 6441 4' www.deq'utah'gov
CERTIFIED MAIL
Page2
We request that you carefully read the QAP and the minor modifications to the Permit to ensure
compliance. If you have any questions regarding the QAP, please contact Dean Henderson at
(S01) 536-0046. Thank you for your cooperation in this matter.
Sincerely,Jxry
Dane L Finerfrock
Co-Executive SecretarY
DCH:dh
Attachments (redline and final versions of the Permit, Table of Contents and pages 14 though 28)
F/../qAlrupr-rr,.Oo"
Redline-Strikeout
Version
Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS ............ ........... I
A. Gnoulro Wnrm. ClessrrcerloN.......... ....................... I
B. Becrcnouxo Werrn Querrrv... ............... I
C. hnrwrl*r'rs .........2
l. Ground Water Compliance Limits.... ......2
2. Tailings Cell Operations.......... ...............2
3. Prohibited Discharges ...........2
D. DscnlRcpMnurr,rzeuoNTscHl.iorocv SreNoARD........... .......... 8
l. DMT Design Standards forExisting Tailings Cells 2, and 3......... ............... 8
2. Existing Tailings Cell Construction Authorized......... .............. 10
3. Existing Facility DMT Performance Standards................ ........ l0
4. Best Available Technology Requirements for New Construction .............. I I
5. Definition of I le.(2) Waste ..................l2
6. Closed Cell Performance Requirements .................12
7. Facility Reclamation Requirements........... .............12
8. Stormwater Management and Spill Control Requirements.......... ..............12
E. Gnouuo Wersn CormnNcE AND TrcuNor-ocy PSRFoRMANCE Mol.rtoRtrltc............. 13
1. Routine Groundwater Compliance Monitoring............. ........... 13
2. Groundwater Head Monitoring ............. 14
3. Groundwater Monitoring Well Design and Construction Criteria................................ 14
4. Monitoring Procedures for Wells.. ........l4
5. White Mesa Seep and Spring Monitoring ............... 15
6. DMT Performance Standard Monitoring ................ 15
7. On-site Chemicals Inventory.. ............... 16
8. Tailings Cell Wastewater Quality Monitoring ........ 16
F. RrponrnrcRreum.rrren-rs................ ....... 16
1. Routine Groundwater Monitoring Reports ............. 16
2. Routine DMT Performance Standard Monitoring Reports..... .................... 17
3. DMT Performance Upset Reports..... ....17
4. Other Information ...............l7
5. Groundwater Monitoring Well As-Built Reports ..................... l7
6. White Mesa Seep and Spring Monitoring Reports ................... l8
7. Chemicals Inventory Report ................. 18
8. Tailings Cell Wastewater Quality Reports..... ......... l8
G. Our or CorwI-reNcr Srerus.. .................. 18
1. Accelerated Monitoring Status..... ......... 18
2. Violation of Permit Limits .................... 19
3. Failure to Maintain DMT Required by Permit.. ...... 19
4. Facility Out of Compliance Status ........20
5. Accelerated Monitoring Status for New Wells .......20
H. CorwI-rlNcE SclrEDuLE Rreum.rwNTs. .......... .........20
l. Installation of New GroundwaterMonitoringWells ................20
2. Revised Hydrogeologic Report .............21
3. Background Ground Water Quality Report: Existing We11s........ ..............21
4. Background Groundwater Quality Report: New Monitoring Wells .......-..22
5. Tailings Cells Wastewater Quality Sampling PIan.......... .........23
6. Gretsndwater Menitefing Quality Assuranee P14n,,,,,.,,.,,,,,,.,,,r,,,,,,,,,,,,,,,,.,,,,,,,,,,,,,,.,,,,,,,,
@. Monitoring Well Remedial Construction and Repair Work Plan and Report ..............23
78. Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report...................24
oo89. White Mesa Seeps and Springs Sampling Work Plan and Report....... .......24
9{e. On-site Chemicals Inventory Report...... .............25
1q+. Infiltration and Contaminant Transport Modeling Work Plan and Report...............25
lLZ. Plan forEvaluation of Deep Supply Well WW-2............... ....................26
lZ3. DMT Monitoring P1an.......... ............26
114. Tailings Cell4A, Contaminant Removal Schedule and Report ..............27
lg5. Tailings Cell4A Redesign and Reconstruction ....................27
156. Contingency Plan ............27
lgl. Stormwater Best Management Practices Plan ....28
lZ8. Roberts Pond As-Built Report ..........28
199. Tetrahydrofuran Demonstration Study Work Plan and Report....... ........28
PART tr. REPORTING REQIIIREIvIENTS.......... ................29
A. RrpnssrvrervE SAMpLING............... .......29
B. ANlrvucerPnocrounrs................ ........29
C. PSNALTIES FoR TAMpERING............... ........29D. RsponrhrcoFMoNrroRrNcRssulrs... ....29E. CorwueNcr Scrcpur:s................ ..........29
F. ApomoNeI- Mourronwc BY Tm hruu:rrrr ............29G. Rrconos CoNren"rs. ...............29H. RrrerrnoN orRrconps................ ............29
I. Noucs oFNoNCoMpLIANcT RrpoRrn1c............... ..... 30
J. Oumn NoNcoupuANcE REpoRTING.......... ................ 30K. INspncuoN euo Exrnv ........... 30
PART M. COMPLIANCE RESPONSIBILITIES ................. 3I
A. Dury ro CotwI.v .................... 31
B. PrNalrms roR VrolerroNs or hrutr CoNomoNS ......... . ..... . .. . . 3 1
C. Nrrp ro Harr oR Rrpucr Acrrvrrv Nor e DBTTNSE ............. ..... 3l
D. Drrrv ro MrucerE.............. ...................... 3l
E. Pnoprn OprReuoN eNo Men-reNANCE...... ............... 3l
PART rV. GENERAL REQUIREMENTS ..........32
A. Plemwn CHeNcrs .................32
B. Ax'ncparsoNoNcolvpLIANcE......... ........32
C. Pentwr AcnoNs... ...................32
D. DurvroREAPPLy............... ....32
E. Dury ro PRovnB IxronuaroN ............ ....................32
F. Ornsn hronuenoN............. ....................32
G. SrcNeroRv Rreum,rwx-rs............... .......32
H. PeNer-rres roR FRrsmcATroN or RrpoRrs ............... ................... 33I. Avan esLny oFREpoRTS.............. .......... 33
J. PRoprRrvRrcHrs ...................33
K. SrvsRABLmy............... ...........33
L. TRaNsrrRs ............33
M. Srarrl-aws ..........34
N. Rroprusn PRovrsroxs................ ..............34
List of Tables
Table l. Ground Water Classification ............. ....... I
rabre 2. Groundwater Comprianc. Li-;;;:::.:::::.::::.:.:::::.:::.:............ .........3
Table 3. DMT Engineering Design and Specifications ........... 8
Table 4. Feedstock Storage Area Coordinates ..... l1
Table 5. Groundwater Monitoring Reporting Schedule... ...... 16
1l
Part I
Permit No. UGW370004
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.
2) 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.
3) Gross Alpha Counting Variance - all gross alpha analysis reported shall have a
counting variance that is equal to or less than 2O7o 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.l, the Perminee shall measure depth to
groundwater in the following wells and/or piezometers:
a) Point of Compliance Wells - identified in Table 2 and Part I.E.1 of this Permit,
b) Piezometers - P-L,P-},P-3, P-4, P-5.
c) Existing Monitoring Wells - MW-20 andTvlY{-ZZ.
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 gr.oundwater pollution,
b) Screened and completed in the shallow aquifer,
c) Designed and constructed in compliance with UAC R317-6-6.3(IX6), 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 an the currengy
approvedGroundwaterMonitoringQualityAssurancePlan-@
t4
Part I
Permit No. UGW370004
thie+ermit.
c)LaboratoryApproval-allanalysesshallbeperformedbyalaboratorycertifiedbythe
State of Utah to perform the tests required'
d) Damage to Monitoring wells - if any monitor well is damaged or is otherwise
rendered inadequate fIr its intended purpose, the Permittee shall notify the Executive
Secretary in writing within five days of discovery'
and calibrated.
5. White Mesa Seep and Spring Monitoring - after approval of the report required by Part
I.H.9, this Permii may Ue.JOifl"A to require annual monitoring of selected seeps or
springs on White Mesa.
6. DMT Performance Standard Monitoring - after approval of the DMT Monitoring Plan
required by Part I.H.13, the Permittee sf,all perform technology performance monitoring
to determine if DMT is effective in minimiiing and controlling the release of
contaminants pursuant to the provisions of Parts I.D.1 and I'D'3 of this Permit' including'
but not limited to the following activities:
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 lrvel Monitoring: Cells 2 an!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 Wastewaterlrvel 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'
d) 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
ii. verify that all alternate feedstock materials located outside the Feedstock Area
r5
a)
b)
c)
o
Part I
Permi t No. UGW370O04
defined in Table 4, aremaintained within water-tight containers.
7.on-siteChemicalslnventory-thePermitteeshallmonitorandmaintainacurrent
inventory of all chemicals used at the facility at rates equal to or greater-tan 100 kg/yr'
Said inventof shall be maintained on-site, and shall include' but is not limited to:
a)Identificationofchemicalsusedinthemillingprocessandtheon-sitelaboratory,
b) Determination of volume and mass of each raw chemical currently held in storage at
the facility.
S.TailingsCellWastewaterQualityMonitoring-onanannualbasis'thePermitteeshall
collect wastewater quality ,-u-pI", from each wastewater source at each tailings cell at
the facility, including, but not limited to: surface impounded wastewaters' and slimes
drainwastewaters.AllsuchsamplingshallbeconductedinAugustofeachcalendaryear
in complianr. *i,t the approveahaiingt Cell Wastewater Quality Sampling Plan
required by Part t.H.5 ofltris Permit. The Permittee shall also provide at least a 30-day
noticeinadvanceoftheannualsamplingevent,soaStoallowtheExecutiveSecretaryto
collect split samples of the various tailings cells wastewater sources'
F. RrpoRrnrc REQUR.EI'G.*S - 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 .Jportt of field and laboratory analyses of all well
monitoring and samples described in Parts I'E.1, I.F.'},I'E'4, and I'E'6 of this Permit'
Reports snltt ue submitted according to the following schedule:
Table Schedule5. Groundwater Monitori
Ouarter Period Due Date
First January - March June 1
Second April - June Seotember I
Third July - September December I
Fourth October - Decembel March I
Failure to submit the reports by the due date shall be deemed as noncompliance with this
pr""i, Said monitorini r"ports shall include, but are not limited to' the following
minimum information:
Field Data Sheets - or copies thereof that provide the following: well name' date and
time of well purging, date and time of weli sampling, type and condition of well
pump, depth to groundwater before purging and sampling' calculated well casing
volume, volume of water purged Uefo.e sampling, volume of water collected for
analysis, types of sample containers and preservatives'
Laboratory Results - or copies thereof that provide the following: date andtime
sampled, date received by iaboratory, and for each parametet analyzed' the following
information: laboratory iesult or concentration, units of measurement' minimum
detection limit or r.poning limit, analyical method, date of analysis' counting error
ior radiologic analyses, toial cations and anions for inorganic analysis'
a)
b)
l6
o
Part I
Permi
Water Table Contour Map - which provides the location and identity of all wells
sampled that quarter, the measured groundwater elevation at each well measured in
feet above mean sea level, and isocontour lines to delineate gfoundwater 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 Quality Assurance Plan'
Said report shall verify the accuracl and reliability of the groundwater quality
compliance data, after evaluation of sample collection techniques and equipment,
,urrrpt"handlingandpreservation,analyticalmethodsused'etc'
Erectronic 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 Jtp*'""a Values (CSV) format, or as otherwise approved by the
Executive SecretarY.
z. Routine DMT performance Standard Monitoring Reports - the Permittee shall provide
quarterly rnonito.ing reports of all DMT performance standard monitoring required by
parr I.8.6 of this peirii. Said monitorin! shall be corducted in compliance with an
approved DMT Monitoring Plan, pursuuit ,o Part I'H'13 of this Permit' Said monitoring
reports and results shall be submitted to the Executive Secretary on the schedule provided
in Table 5, above, and shall at a minimum include the following information:
c)
d)
e)
t No. UGW370004
monitoring at Tailings Cells 1, 3,
feet above mean sea level'
3.
4.
a) Summary table of weekly wastewater pool elevation
and the Roberts Pond' Units of reporting shall be in
b) Summary table of weekly slimes drain water level monitoring conducted at Tailings
Cells2and3.Saidsummaryshallinclude,butisnotlimitedtodown-slopedepthto
water level inside the slimes drain access pipe, as measured from one water level
measuring point at the centerline of the pipe'
DMT Performance Upset Reports - the Permittee shall report any non-compliance with
the DMT performancl criteria of Part I.D in accordance with the requirements 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 uppfi.Oi* or submittal of incorrect information in a permit
application or in any rrpoa to the Executive Secretary, the Permittee shall submit such
facts o. information within 10 days of discovery'
Groundwater Monitoring well As-Built Reports - as-built reports for new groundwater
monitoring wells shall b"e submitted for Executive Secretary approval, and at a minimum
will 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 oeotogist licensed by the stut" of Utah, or otherwise approved
beforehand by the Executive Secretary'
5.
t7
t No. UGW370004
b) Well Completion Diagram - that detail all physical attributes of the well construction,
including:
l) 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,
and construction of protective surface casing,
o
Part I
Permi
Survey coordinates prepared by a State of Utah licensed engineer or land
.,r.rryo., 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 determinl local aquifer hydraulic conductivity in each well'
White Mesa Seep and Spring Monitoring Reports - after approval of the work plan and
report required by Part r.rr.g, this Permit may be modified to require annual monitoring
and reporting of selected seeps or springs on White Mesa'
Chemicals Inventory Report - at the time of Permit renewal the Permittee shall submit a
report to update the faciiities chemical inventory report required by Part I'H'10' Said
report shali provide all inventory information gathered pursuant to Part l'E'7 '
Tailings Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part LE.8 shall be reported to the Executive secretary with the 3'd
Quarter groundwater quality report due on December I of each calendar year' Said report
shalt lnctuae all information required by Part I.F.l(a), (b), (d), and (e) of this Permit'
Revised Hydroge6logic Report - pursuant to Part IV.D of this Permit, and at least 180
days prior io permit expiratlon, the Permittee shall submit for Executive Secretary
apprwat a revised hydiogeologic report for the facility and surrounding area. Said report
sial provide a comprehensive update and evaluation of:
Local hydrogeologic conditions in the shallow aquifer, including, but not limited to:
local geologi" .onditions; time relationships and distribution of shallow aquifer head
*.urur"*"nts from facility wells and piezometers; local groundwater flow directions;
and distribution of aquifer permeability and average linear groundwater velocity
across the site, and
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.
4)
s)
6.
7.
8.
9.
a)
b)
G. Our oF CoMPLIANCE STATUS
t8
O
Part I
Permit
1. Accelerated Monitoring Status - is required if tlr-e concentration of a pollutant in any
compliance monitorinf sample "*.""d, a GWCL in Table 2 of the Permiq the facility
shall then:
No. UGW370004
Notify the Executive Secretary in writing within 30 days of receipt of data; and
Immediately initiate accelerated sampling of the pollutant as follows:
Quarterly Baseline Monitoring Wells - for wells defined by Part I'E'l(a) the
Piermittel shall initi ate monthly monitoring'
Semi-annualBaselineMonitoringWells_forwellsdefinedbyPartl.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 faiitity can be determined by the Executive Secretary'
2.ViolationofPermitLimits-out-of-compliancestatusexistswhen:
a) The concentration of a pollutant in two consecutive samples from a compliance
monitoring Point exceed:
c) Affirmative Defense - in the event a compliance action is initiated against the
t9
A GWCL in Table 2 of this Permit, and;
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 calculaied using^values for the ground water pollutant at each
individual compliance monitoring point or well; or
b) 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 deiermined using the statisticaimethods described in statistical
Methods for Evaluating Ground watJr Monitoring Data from Hazardous Waste
Facilities, vot. j3, No.-tqo of the Federal Register, oct' 11' 1988'
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 orllly within 24
hours of the Permitteels discovery of the failure of DMT, and shall be followed up by
written notification, including the information necessary to make a determination
under R3 t7-6-6. toicjizl, *iit in 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 infonnation provided by the Permittee to determine whether to
initiate a compliance action uguinrt the Permittee for violation of permit conditions'
A compliance action shall noibe initiated, if the Executive Secretary determines that
thePermitteehasmetthestandardsforanaffirmativedefense,asspecifiedinR3lT-6-
6.16(c)(3).
a)
b)
r)
2)
1)
2)
3.
a)
b)
o
Part I
Permi
permittee for violation of permit conditions relating to best available technology or
DMT, the Permittee may affirmatively defend against that action by demonstrating
the following:
1) The Permittee submitted notification according to R317-6-6'13;
The failure was not intentional or caused by the Permittee's negligence, either in
action or in failure to act
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
4. Facility Out of Compliance Status - if the facility
required:
The Permittee shall notify the Executive Secretary of the out of compliance status
within 24 hours after detiction of that status, followed by a written notice within 5
days of the detection'
The Permittee shall continue accelerated sampling pursuant to Part I.G'1, unless the
Executive Secretary determines that other periodic sampling is appropriate' until the
facility is brought into cornpliance'
The Permittee shall prepare and submit within 30 days to the Executive Secretary a
plan and a time schehule for assessment of the sources, extent and potential
iispersion 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 .o-pliun., monitoring point and that DMT will be reestablished'
The Executive Secretary may require immediate implementation of the contingency
plan to be submitteo 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'
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 permit;e 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 Quality
Report required by Part I.H'4 of this Permit'
H. ColplrANCE SCHEDULE RsQunellEtvrs. The Permittee will comply with the schedules as
described and summarized below:
1. Installation of New Groundwater Monitoring wells - within 30 days of issuance of this
permit, the permittee shall submit a plan forthe installation of new monitoring wells for
Executive Secretary approval. Said plan shall include the following information:
2)
3)
t No. UGW370004
been violated.
is out of compliance, the following is
a)
b)
c)
d)
e)
20
a)
b)
Part I
Permit No. uGW370004
Tailings cell 1 DMT Wells -one (1) hydraulically upgradient well and two (2)
hydraulically downgradient wells that comply wiitr the provisions of Part I'E'3 of this
permit, and the welilocation map suumittea-uy the Permittee on April 16, 2004'
New compliance Monitoring wells for Tailings cells 2 and3 -an adequate number
and location of monitoring wells to ensure:
1)
2)
Early detection of tailings cell contamination of shallow groundwater from
iliir;. Cells 2 and 3. ihe 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
Discrete monitoring of each individual disposal cell' For.cell 2 this shall mean
installation or trrree (:) monitoring wells on the shared dike between cells 2 and
3, as per the well tocation map submitted by the Permittee on April |6,2oo4.
c) New well design and construction details that comply with Part I'E'3 of this Permit'
onorbeforeMayl,2005,thePermitteeshallcompleteinstallation:3,:::-::11:ll,';:,iJ;?;ra#.e'*itr, said plan ana any conditions of approval' The Permittee shall
:ll:-^ a,
;,_HJ: ffiffi;:i";;;*io.aloy.,r," r-".*ive Secreiarv to observe au driuing and
well installation activities related to this plan'
2. Revised Hydrogeologic Report - within 60 days of completion of the well installations
required by Part LH.I, the iermittee 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'
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.
comprehensive hydrogeologic evaluation of the facility that includes both new data
collected during o, u, i ,"rult of the new monitoring well installation required by Part
i.H.r, and all eiisting hydrogeologic information available for the site'
d) Aquifer test results to determine local hydraulic conductivity and other aquifer
-/ prop"rti", at existing well MW-32 (formerly TW4-17)'
e) Average linear groundwater velocity calculated for each well' based on well specific
hydraulicconductivity,hydraulicgradient,andeffectiveaquiferporosity.
If after review of this report, the Executive Secretary 9tt:Tl:tt:lit39:i::,Xl
monitoring wells are required to adequately monitoi the facility, :T::T:t*1ll3ti"il:ffi;: H;ffi to require all necessary improvements pursuanr to part IV.N.3.
3. Background Ground water Quality Report: Existing wells - within 90 days of issuance
of this permit, the permittee shall suumit a Background Ground water Quality Report for
all existing monitoring wells at the facility for Eiecutive secretary approval' Said report
shall include:
a)Allavai]ablegroundwaterqualitydataforallexistingmonitoringwellsatthefacility.
2l
b)
c)
o
Part I
Permit No. UGW370OO4
b)Aqualityassuranceevaluationanddatavalidationoftheexistingandhistoricon-site
groundwater quality data that on a well-by-well and contaminant specific basis:
l) Identifies, justifies, and/or culls any zero concentration values reported'
2) Determines the adequacy of minimum detection limits used' particularly with
respecttothecorrespondingGWQSforeachcontaminant'
Adequately addresses any special statistical needs for management of data sets
with a large proportion of non-detectable values'
Determinestheadequacyoflaboratoryandanalyticalmethodsused,
Determines the consistency of laboratory units of reporting'
Evaluates and justifies intemal consistency between spllfic 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 olany temporal and/or spatial groundwater quality
concentration phenoir"nu, that shall include, but are not limited to:
1) Any long tefln or apparently increasing contaminant concentration trends found in
anY existing monitoring wells,
Any long term or apparently increasing contaminant concentration ratios observed
in existing monitoring wells'
Anycontaminantconcentrationsthatappeartoexceedtheircorresponding
GWQS.
3)
4)
s)
6)
7)
8)
2)
3)
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 Compiiance 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: NewlVlonitoring Wells - within 30 days of
installation of the new monitoring we'lls required by Part I'H'l of this Permit' the
Permittee sfraff imfiement a quarierly groundwater quality sampling program for all new
monitoring wells. said sampiing stralt comply with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part I.E.1,
b)WellmonitoringprocedurerequirementsofPartl'E'4'and
c) Quarterly reporting requirements of Part I'F'l'
After completion of eight (8) consecutive quarters of groundwater sampling and analysis
of the new monitoringlells, the Permittee-shall submit a Background Groundwater
euality Report for thJ new wells for Executive Secretary review and approval' The
22
o
Part I
Permi t No. UGW370004
content of this report shall comply with the information requirements of Part I'H'3 of this
Permit. Said repirt 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
permit and establish Gioundwater Compliance Limits in Table 2 for the new monitoring
wells.
5. 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 appioval. 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'
for both field and laboratory parameters required by Part I.E.l(d),
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 analyical 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
requir#ents of Partsi.E.8 and I.F.S. After approval of this plan, the Executive Secretary
.uy ,"-op"n and modify this Permit to incorporate the provisions of the approved plan'
. (Reserved)
ff. 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-18, MW-19,
MW-26, TW4-16, and Mw-32. Said well development will ensure that groundwater
23
b) Complete analYsis
and all detectable
o
Part I
Permi
clarity conforms to
Permit to the extent
t No. UGW370004
the EPA RCRA TEGD requirements found in Part I'E'3(c) of this
reasonablY achievable.
SZ.MonitoringWellMW-3Verification,Retrofit,orReconstructionReport-withinl50
days of issuance of this Permit, the Permittee shall verify the depth to the upper contact of
theBrushyBasinMemberoftheMorrisonFormationintheimmediatevicinityofwell
MW-3. The Permittee shall provide at least 14 days notice and allow the Executive
Secretarytoobserveallfieldactivitiesrelatedtosaidverification.Intheeventthatthe
Executive s".r.iury 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'
9&. White Mesa Seeps and Springs Sampling work Plan and Report - within 180 days of
issuance of this permit, the permittei stratt submit a plan for Executive Secretary
approvalofgroundwatersamplingandanalysisofallseepsandspringsfound
downgradien, o, iu,"rul gradient from the taitlngs cells on White Mesa' Said plan shall
include, but is not limited to:
a)Locationofallseepsandspringstobesampled,includingmapsandsurveyed
coordinates (physical location' and elevation)'
b) Detailed description of sampling methods and equipment'
b)ProtectivesurfaceCasings:WellsandPiezometers_thePermitteeshallinstallsteel
surface casings to protect the currently exposedPVC well and piezometer casings'
including: piez#eters p-1, p-2,p3: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'
of field parameters or measurements that will be made'
Description of sample preservation methods'
e) Determination of the laboratory analyical methods and the environmental laboratory
that will Perform the analYsis'
0samplingandanalysisofallgrorlndwatercomplianceparametersfoundonTable2of
this Permit, irrtuJirg analysi-s of volatile and simi-volatile organic compounds by
EPA SW-846 methods 8260 and 8270'
Within 180 days of approval of the plan, the Permittee shall complete said sampling and
analysis, and submii uhnuf report for Executive Secretary approval' Said report shall: 1)
document the sampling proieci, 2) transmit copies of all field measurements and
laboratory results, 3j ff;i.it a water table conlour map that includes water table
elevations of all ttre 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
interpretatio, or th" g;dwater qlrlii datatollected. The Permittee shall also provide
at least l5 days notic"e to allow the-Exeiutive Secretary to collect split groundwater
c)
d)
24
o
Part I
Permi t No. UGW370004
quality samples of the seeps and springs'
+g9. 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
updated inventory report pursuant to Part I'F'7'
l+0. 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 longterm filiJV oll::']11i:^:"11:
#ffi;;;; uirqru,"ry contain and control tailings contaminants and protect nearby
;;;;ffi;;;;ffiry "f the uppermost aquifer' said l:pon'l1ll9:3:istrate how the
;;iil;;.;ii"ngir""ting desien and specificatiols witt ::Ttlv with1T 1'llT:il;il.;;;" ffio"-Jr,, or-purt r.p.o or-tni: p":rt within :19 ryj 1:::17ffi;;;f.h; p"'.-i,,"" shall submit a work plan for Executive secretary approval, that:
Identifies all applicable and pertinent historic studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance.
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 panitioning (IQ) coefficients, tailings source tern concentrations'
,rifing, waste leacir 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 cuffently available, the Permittee may select
conservative assumptions for use in the required infiltration and contaminant
transport models. dtherwise, 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 for Executive Secretary approval'
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
computeicodes 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 actuaifield 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
mod-el1s), 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
25
a)
b)
c)
o
Part I
Permit
conceptualizedandplannedtodemonstratecompliancewiththerequirementsofPat
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 iinut r"port, thi Permittee may include supplemental
information to jusdfy modification of certainPermit requirements' including' but not
limited to: the nu-b", and types of groundwater compliance monitoring parameters'
tailings cell cover system engineerin! design and construction specifications, tailings cell
operational requirements, etc. Upon-Executive Secretary approval of the final infiltration
and contaminanttransport report;the Reclamation Plan may be modified to accommodate
necessarychangestoprotectpublichealthandtheenvironment.
lIL. PlanforEvaluationof DeepSupplyWellWW-2-within l yearfromissuanceof this
permit, the permittee shall submit for ixecutive secretary approval a plal for evaluation
of the annular casing seal in water supply well WW-2' Jht objective of this plan is to
ensure adequate well casing and anruia.seals, in compliance with the regulations of the
Utah State Engineer (uAC R655-4-g), 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 o.t"ror" decommissioning of the white Mesa mill.
|SZ.DMTMonitoringPlan-withing0daysofissuanceofthisPermit,thePermitteeshall
submit a Facility DtfrT 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 ,"qri*."nts of Parts I.D'l and I'D'3; adequate DMT monitoring
procedures in compliance with P_arts I.E.6; and adequate DMT reporting procedures in
compliance with P^arts I.F.2 and LF.3 of this Permit. said plan shall include' but is not
limited to:
g) Design and construction of a wastewater pool elevation gauge to be installed at each
tailings cell, or procedures and equipment needed for completion of periodic
wastewater elevation surveys'
h) Designation of a water level measuring point on the slimes drain access pipe at both
Tailings Cells 2 and 3'
i)Basedonhistoricalconstructioninformationandactualmeasurements,determinethe
down-slope depth for the lowest point on theIML found at or near the base of the
slimes drain aciess pipes for both Cells 2 and 3'
No. UGW370004
allowable wastewater head in the slimes drain layers at
low as reasonablY achievable.
j) Determination of an average
both Cells 2 and 3 that is as
k) Design and construction of a water level gauge, or procedures and equipment needed
for c6mpletion of periodic elevation surveys at the Roberts Pond to measure
wastewaterlevelsubo,"thelowestpointonthepond'sFML.
I) Procedures for monitoring the
location of feedstock storage,
Feedstock Storage Area to determine appropriate
andwater-tightconditionofcontainerizedfeedstocks.
26
o
Part I
Permi t No. UGW37O0O4
m) 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 Permitto incorporate any
additional equipment, operation, and maintenance procedures needed for DMT
monitoring.
lq. 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
under Tailings Cefi+e, including periodic progless reports' The purpose of this work
shall be to recover, remove all contaminutti *ut.tiult and to dispose of these materials in
Tailings cell 3. within 60 days of completion of contaminant removal from Tailings
Cell 4A, the permittee shall submit a report for Executive Secretary approval'
L5/.. Tailings cell44 Redesign and Reconstruction - after contaminant removal pursuant
to Part I.H.14, and prior to any new construction including, but not limited to:
foundations, sub-base materials, liners, or leak detection systems at existing Tailings Cell
4A, the Permittee shall:
a) Submit engineering design plans and specifications that demonstrate how the new
construction will Jonlpty *itt the requirements of the Utah Water Quality Act' all
rules and regulations iromulgated thereunder, and the Best Available Technology
requiremenis mandated by Part I'D'4 of this Permit'
b) Secure prior Executive Secretary approval and issuance of a construction permit'
Thereafter, this Permit may be rl-openea and modified to reflect the new design and
construction sfecifications, and any related operations, monitoring' or reporting
requirements necessary'
165. Contingency Plan - within 180 days of issuance of this Permit' the Permittee shall
submitaContingencyPlanforExecutiveSecretaryapprovalthatprovidesadetailedlist
of actions the Permitiee will take to regain compliance with Permit limits and DMT
requirements defined in Parts I.C and I-.D of this Permit. At a minimum, the contingency
Plan will include, but is not limited to measures to resolve the following general
categories of non-comPli ance :
Groundwater contamination - as shown by any contaminant concentrations in
compliance monitoring wells that exceed their respective groundwater compliance
limiifound in Part I.C.1 and Table 2 of this Permit'
Mill Discharge Violations - including unauthorized discharge or release of prohibited
contaminants to the tailings cells, pursuant to PartI.C.2 and I'C'3; and
DMT Violations - which include several types of non-compliance, including but not
limited to:
l) Excess tailings cell wastewater pool elevation above the maximum elevations
27
a)
b)
c)
o
Part I
Permit No. UGW3700O4
mandated bY Part I.D.3;
2) Excess head in the Tailings Cells 2 and 3 slimes drain system, pursuant to Part
LD.3 and as defined by the DMT Monitoring Plan in Part I.H.l3; 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 modify
this Permit to include any new requirements therefrom'
tq6. Stormwater Best Management Practices Plan - within 180 days of Permit issuance the
permittee shall submit a final Stormwater Best Management Practices Plan for Executive
Secretary approval. Said plan shall comply with the requirements of Part I.D.8 of this
permit. Upon Executive Secretary approval, the Permittee shall immediately implement
all provisions of said Plan.
1SZ. Roberrs 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
reconstructi on 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.
19E. 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 (Tlf) contamination identified in several
existing monitoring wells at the facility, including but not limited to wells: MW-l,I\dW-
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 THF as a GWCL parameter.
28
Final Version and
Replacement Pages for the Permit
Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS ............ ........... 1
A. GnouNp Werrn ClessmcerloN.......... """""""""""' I
B. BecrcnouNoWerenQuerrrv... """""""' I
C. PsnmTlnrn'rs """"'2
Ground Water Compliance Limits.'.. """2
Tailings Cell Operations.......... """""""'2
Prohibited Discharges """""'2
DrscseRcr MnmrnzenoN TecrntolocY STANDARD'.......... """"" 8
DMT Design Standards for Existing Tailings Cells 2, and 3...""" """""""' 8
Existing Tailings Cell Construction Authorized ""' 10
Existing Facility DMT Performance Standards............... """"' l0
Best Available Technology Requirements for New Construction.......'. ..... 11
Definition of 11e.(2) Waste --.-.-."""""' 12
Closed Cell Performance Requirements """"""""' 12
Facility Reclamation Requirements........... """"""' 12
Stormwater Management and Spill Control Requirements .......... .............. L2
Gnouxo WersR CorwlmNCE AND TscrnIoLoGY PERFoRMANCE Molrronnqo............. 13
Routine Groundwater Compliance Monitoring............. """""' 13
Groundwater Head Monitoring """"""' 14
Groundwater Monitoring Well Design and Construction Criteria..'..............'.............. 14
Monitoring Procedures for Wells..' """' 14
White Mesa Seep and Spring Monitoring """""""' 15
DMT Performance Standard Monitoring """""""" 15
On-site Chemicals Inventory.. """""""' 16
Tailings Cell Wastewater Quality Monitoring """" 16
RrponmqcRTQuIREI!8NTS........... .....'.""' 16
Routine Groundwater Monitoring Reports """"""' 16
Routine DMT Performance Standard Monitoring Reports..... ....................17
DMT Performance Upset Reports..... "" 17
Other Information ............... """"""""" 17
Groundwater Monitoring Well As-Built Reports """"""""""' 17
White Mesa Seep and Spring Monitoring Reports .""""""""" 18
Chemicals Inventory Report """"""""' 18
Tailings Cell Wastewater Quality Reports..... """"' 18
Revised Hydrogeologic Report """"""' 18
OurorCotmnNcESTATUS.. ...."''""'""' 18
Accelerated Monitoring Status........ """ 18
Violation of Permit Limits """""""""" 19
Failure to Maintain DMT Required by Permit.' """ 19
Facility Out of Compliance Status """"20
Accelerated Monitoring Status for New Wells *""'20
CorwmNcE ScHEDULE RrQunrwNrs. .......... """"'20
Installation of New GroundwaterMonitoringWells """"""""'20
Revised Hydrogeologic Report """"""'21
Background Ground Water Quality Report: Existing We11s........ """""""2L
Background Groundwater Quality Report: New Monitoring Wells ..........22
Tailings Cells Wastewater Quality Sampling Plan....'..-.. """"'23
Monitoring Well Remedial Construction and Repair Work Plan and Report .'...'........23
Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report....... ---.........24
i
l.
2.
3.
D.
1.
2.-J.
4.
5.
6.
7.
8.
E.
l.
2.
3.
4.
5.
6.
7.
8.
F.
1.
2.
J.
4.
5.
6.
7.
8.
9.
G.
l.
2.
J.
4.
5.
H.
1.
2.
3.
4.
5.
6.
7.
oo8. White Mesa Seeps and Springs Sampling Work Plan and Report....... .......24
g. On-site Chemicals Inventory Report....... """"""""24
10. Infiltration and Contaminant Transport Modeling Work Plan and Report.......-...-..-25
1 1. Plan for Evaluation of Deep Supply Well WW-z.........""" """""""""" 26
12. DMT Monitoring P1an......... """"""'26
13. Tailings cell4A contaminant Removal Schedule and Report ..............26
14. Tailings Cell 4A Redesign and Reconstruction """"""""""27
15. Contingency Plan """"""27
16. Stormwater Best Management Practices Plan ""27
17. Roberts Pond As-Built Report """""28
18. Tetrahydrofuran Demonstration Study Work Plan and Report...... .........28
PART tr. REPORTING REQUIREMENTS............... .-..-..-.-.29
A. RrpnssmirtATrvE SaNpLnIc. """"""""""'29
B. ANervrrcarPnocBounrs.............'. """"'29
C. PTNnTTmsFoRTAMPERING. ""29
D. RrpoRrmcorMorvrroruxcREsulTs """'29
E. CotwrnNcE ScmDULES ............... """""' 29
F. AppmoNel-MoNrronnlcBY TllEPrnrrnrrrr """"""29
G. RBconps Cox'rmrrs. """""""'29
H. RrreI.r[oNoFRECoRDs..............'. """"""'2g
L NoucgoFNoNCoMPLIANCEREPoRTING..............' ""' 30
J. OrrmnNoNcotplIeNCEREPoRTING............... """""' 30
PART m. CoMPLIANCE RESPONSIBILITIES ...........'....' 3l
A. DurvroCoMPLY """""""""" 31
B. PsNerrmsronVIotRTIoNSoFPERMTCot'uruoNs.......'.-..... ""' 31
C. NrroroHnrroRREDUCEAcrrvrrvNorADersNsB """"""""" 31
D. Durv ro Mrncerr """"""""" 31
E. Pnoprn OpBnenoN eNo Men'rrnNANCE....... """"""" 31
PART rV. GENERAL REQUIREMENTS.......... ...-......-.......32
A. Prelri.lsD CrnNces """"""""'32
B. AN'ncrperso NoNcotmlANCE......'.. """"32
C. Ppntwr AcnoNs.... """"""""" 32
D. DurvroRrapplY............... ""32
E. Durv ro kovpp IxronvenoN ....'....'.. """""""""" 32
F. Oumn Ir.r'onuanoN............. """"""""""32
G. SrcNeronv ReQunmmNTS........... """""'32
H. PeNerrms noR FaI-smcATIoN or Rrponrs -.............. """""""""' 33
I. Aveu-enurY oFRrponrs... """"""""""' 33
J. PnopsRrvRlcurs """""""""' 33
K. SrvrnasLlrY.............. """""" 33
L. TnaNsnsRs """""" 33
M. Srerel-aws """""34
N. RropprmnPnov1s1oNs..........."... """""""34
List of Tables
Table 1. Ground Water Classification ...-..'..'..' """' I
rable 2. Groundwater compliance Limi;..:::.:::....:...:.:..::...'..... """""""" 3
Table 3. DMT Engineering Design and Specifications """""' 8
Table 4. Feedstock Storage Area Coordinates......... """""".' 11
Table 5. Groundwater Monitoring Reporting Schedule... """ 16
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Permi
2.
t No. UGW3700O4
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.
2) 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.
3) Gross Alpha Counting Variance - all gross alpha analysis reported shall have a
counting variance thui ir equal to or less than 20Vo of the reported activity
concentration.
Groundwater Head Monitoring - on a quarterly basis and at the same frequency as
groundwater monitoring r"quii.d by Part I.E.1, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers:
a) Pointof Compliancewells-identifiedinTable 2andPartI.E.l 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 contaminani investigation or groundwater corrective action, and
e) Any other wells or piezometers required by the Executive Secretary'
Groundwater Monitoring Well Design and Construction Criteria - all new groundwater
monitoring wells instattJO 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,
b) Screened and completed in the shallow aquifer'
c) Designed and constructed in compliance with UAC R317-6-6.3(IX6)' including the
EpA RCRA Ground Water Monitoring Technical Enforcement Guidance Document,
1986, OSWER-9950.1.
d) Aquifer tested to determine local hydraulic
hydraulic conductivitY.
properties, including but not limited to
J.
4. Monitoring Procedures for Wells - beginning with thedate 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
removalorpurgingofstandingwaterwithinthewellcasinghasbeenperformed.
b) sampling plan - all sampling shall be conducted to ensure collection of representative'
,un-lptrr, and reliability and validity of groundwater monitoring data' All
groundwater samplinjshall be conducted in accordance with the currently approved
Groundwater Monitoring Quality Assurance Plan'
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Permi
5.
6.
t No. UGw370004
c) Laboratory Approval - all analyses shall be performed by a laboratory certified by the
State of Utah to perform the tests required.
d) Damage to Monitoring Wells - if any monitor well is damaged or is otherwise
rendered inadequate for its intended purpose, the Permittee shall notify the Executive
Secretary in writing within five days of discovery.
e) 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.
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, the Permittee 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, including,
but not limited to the following activities:
a) Weekly Tailings Wastewater Pool Elevation Monitoring: Cells 1 and 3 - the
Permittee shall monitor and record weekly the elevation of wastewater in Tailings
Cells I 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.
b) Weekly Slimes Drain Water kvel 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.
c) Weekly Wastewater kvel 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.l3.
d) Weekly Feedstock Storage Area Inspection - the Permittee shall develop a Standard
Operating Procedure for the License and inspect the Feedstock Storage Areas to:
i. Confirm the bulk feedstock materials are maintained within the approved
Feedstock Storage Area defined by Table 4, and
ii. Verify that all alternate feedstock materials located outside the Feedstock Area
defined in Table 4, are maintained within water-tight containers.
r5
Q*,
Permi t No. UGW37O004
7. 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 kg/yr.
Said inventory shall be maintained on-site, and shall include, but is not limited to:
a) Identification of chemicals used in the milling process and the on-site laboratory,
b) Determination of volume and mass of each raw chemical currently held in storage at
the facility.
8. 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. RrpoRrnlc RseuREIlGx-rs - The following reporting procedures for routine and compliance
reports must be met.
l. 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.E.z,1.8.4, and I.E.6 of this Permit.
Reports shall be submitted according to the following schedule:
Table Schedule5. Groundwater Monitorin n
Ouarter Period Due Date
First Januarv - March June I
Second Aoril - June September I
Third July - September December I
Fourth October - December March 1
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 nzune, 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, analyical 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
t6
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Part I
Permit
2.
No. UGW370004
feet above mean sea level, and isocontour lines to delineate groundwater flow
directions observed during the quarterly sampling event'
d) euality Assurance Evaluation and Data Validation - including a written description' ura findings of all quality assurance and data validation efforts conducted by the
permittee in compliance with the Groundwater Monitoring Quality Assurance 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.
e) 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
,.ruit, for groundwater quality monitoring conducted. Said electronic files shall
consist of Comma Separated Values (CSV) format, or as otherwise approved by the
Executive Secretary.
Routine DMT performance Standard Monitoring Reports - the Permittee shall provide
quarterly monitoring reports of all DMT performance standard monitoring required by
iu.t f.f.O of this permii. Said monitoring shall be conducted in compliance with an
approved DMT Monitoring Plan, pursuant to Part I.H.l3 of this Permit. Said monitoring
,"po*r and results shall be submitted to the Executive Secretary on the schedule provided
in Table 5, above, and shall at a minimum include the following information:
a) Summary table of weekly wastewater pool elevation monitoring at Tailings Cells 1, 3,
and the Roberts Pond. Units of reporting shall be in feet above mean sea level.
b) Summary table of weekly slimes drain water level monitoring conducted at Tailings
Cells 2 and3. Said summary shall include, but is not limited to down-slope depth to
water level inside the slimes drain access pipe, as measured from one water level
measuring point at the centerline of the pipe'
DMT performance Upset Reports - the Permittee shall report any non-compliance with
the DMT performanci criteria of Part I.D in accordance with the requirements 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 br in uny i"port to the Executive Secretary, the Permittee shall submit such
facts or information within l0 days of discovery'
Groundwater Monitoring Well As-Built Reports - as-built reports for new groundwater
monitoring wells shall bi submitted for Executive Secretary approval, and at a minimum
will include the following information:
a) Geologic Logs - that detail all soil and rock lithologies and physical propenies 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:
t7
3.
4.
5.
o
Part I
Permit No. UGW37OO04
l) 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,
Design, type, diameter, and construction of protective surface casing,
Survey coordinates prepared by a State of Utah licensed engineer or land
,o*ryor, 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 Part 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
..port shall provide all inventory information gathered pursuant to P.art 1.8.7 -
g. Tailings Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part I.E.S shall be reported to the Executive Secretary with the 3'd
euarter groundwater quality report due on December I of each calendar year. Said report
shall include all information required by Part I.F.l(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:
Local hydrogeologic conditions in the shallow aquifer, including, but not limited to:
local geologic conditions; time relationships and distribution of shallow aquifer head
*.uru."."nts from facility wells and piezometers; local groundwater flow directions;
and distribution of aquifer permeability and average linear groundwater velocity
across the site, and
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.
G. Our oFCoMPLIANCE STATUS
l. 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
18
4)
s)
a)
b)
oPart I
Permit No. UGW370004
shall
a) Notify the Executive Secretary in writing within 30 days of receipt of data; and
b) Immediately initiate accelerated sampling of the pollutant as follows:
1) euarterly Baseline Monitoring Wells - for wells defined by Part I.E.l(a) the
Permittee shall initiate monthly monitoring,
2) Semi-annual Baseline Monitoring Wells - for wells defined by Part I.E.l(b) the
Permittee sh all initi ate quarterly monitorin g.
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 Limits - out-of-compliance status exists when:
a) The concentration of a pollutant in two consecutive samples from a compliance
monitoring Point exceed:
l) A GWCL in Table 2 of this Permit, and;
2) Thereported 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
b) The concentration value of any pollutant in two or more consecutive samples is
sratistically 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 R3l7-6-6.16(CXl). Notification shall be given orally within 24
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(CX2), within five days of the Permittee's discovery of the failure
of best available technologY.
The Executive Secretary shall use the information provided under R3l7-6-6.16.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
a)
b)
c)
T9
Part I
Permit No. UGW370004
the following:
1) The Permittee submitted notification according to R317-6-6'13;
2) Thefailure 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 lg-s-to7 have not been violated.
4. Facility out of compliance Status - if the facility is out of compliance, the following is
required:
The Permittee shall notify the Executive Secretary of the out of compliance status
within 24 hours after detiction of that status, followed by a written notice within 5
days of the detection'
The Permittee shall continue accelerated sampling pursuant to Part I'G'1, 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 "o-friur"" monitoring point and that DMT will be reestablished'
b)
c)
a)
d) 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
reesiablish 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 appioval of the Background Groundwater Quality
Report required by Part I'H'4 of this Permit'
H. CorwmNCE sCmDrr._E REQUm.EMENTS. The permittee will compry with the schedules as
described and summarized below:
1. Installation of New Groundwater Monitoring wells - within 30 days of issuance of this
permit, the permittee shall submit a plan foithe installation of new monitoring wells for
Executive Secretary approval. Said plan shall include the following information:
a) Tailings Cell I DMT Wells -one (l) hydraulically upgradient well and two (2)
hydraulically downgradient wells that comply with the provisions of Part I.E.3 of this
20
2.
Part I
Permit No. UGW370004
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 Pan 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 Cell2 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 l, 2}Os,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.l, 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 IV.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:
2l
3.
o
Part I
Permit No. UGW370004
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 analyical 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-pafametric
statistical methods for each.
c) An examination and justification of any temporal and/or spatial groundwater quality
concentration phenomena, that shall include, but are not limited to:
l) Any long term or apparently increasing contaminant concentration trends found in
any existing monitoring wells,
2) Any long terrn 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 Compiiance 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
instaliation 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 sampiing shall comply with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part I'E'1'
b) well monitoring procedure requirements of Part I.E.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 reptrt shall be submitted for Executive Secretary approval no later than
June l, 2007. Aft", upp.oval of this report, the Executive Secretary will re-open this
22
1)
2)
3)
4)
s)
6)
7)
8)
o
Part I
Permi
5.
t No. UGW370004
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.1(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.S 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 repon 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, IvtW-I1, MW-18, 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:
l) 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.
6.
23
o
Part I
Permi
7.
t No. UGW370004
Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report - within 150
days of issiance 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
IVIW-3. The permittee shall provide at least 14 days notice and allow the Executive
Secretary to observe all fieldactivities 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 IVIW-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
aowngraaient or lateral gradient from the tailings cells on White Mesa. Said plan shall
include, but is not limited to:
Location of all seeps and springs to be sampled, including maps and surveyed
coordinates (physical location, and elevation),
Detailed description of sampling methods and equipment,
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.
Sampling and analysis of all ground water compliance parameters found on Table 2 of
ttris i'ermit, 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 finat report for Executive Secretary approval. Said report shall: l)
document the sampling project, 2) transmit copies of all field measurements and
laboratory results,i) piovide 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 notici to allow the Executive Secretary to collect split groundwater
quality samples of the seeps and springs.
g. 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
issuancl of this Permit. At the time of Permit renewal, the Permittee shall submit an
24
8.
a)
b)
c)
d)
e)
a
Part I
Permit No. UGW37OOO4
updated inventory report pursuant to Part I.F.7.
10. 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 LD.6 of this Permit. Within 180 days of Permit issuance, the
Permittee shall submit a work plan for Executive Secretary approval, that:
Identifies all applicable and pertinent historic studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance.
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 halfJife 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 for Executive Secretary approval.
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.
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.
a)
b)
c)
d)
25
oPart I
Permit No. UGW3700O4
I 1. Plan for Evaluation of Deep Supply Well WW-2 - within I 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 WW-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 PIan - 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 construction of 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 construction 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.
Design and construction of a water level gauge, or procedures and equipment needed
for completion of periodic elevation surveys at the Roberts Pond to measure
wastewater levels above the lowest point on the pond's FML.
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
26
e)
o
Part I
Permi t No. UGW370004
under Tailings Cell 4A, including periodic progress reports. The purpose of this work
shall be to recover, remove all contaminated materials and to dispose of these materials in
Tailings Cell 3. Within 60 days of completion of contaminant removal from Tailings
Cell 4A, the Permittee shall submit a report for Executive Secretary approval.
14. Tailings Cell44 Redesign and Reconstruction - after contaminant removal pursuant to
Part I.H.14, and prior to any new construction including, but not limited to: foundations,
sub-base materials, liners, or leak detection systems at existing Tailings Cell4A, the
Permittee shall:
Submit engineering design plans and specifications that demonstrate how the new
construction will comply with the requirements of the Utah Water Quality Act, all
rules and regulations promulgated thereunder, and the Best Available Technology
requirements 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 and
construction specifications, and any related operations, monitoring, or reporting
requirements necessary.
15. Contingency Plan - within 180 days of issuance of this Permit, the Permittee shall submit
a Contingency Plan for Executive Secretary approval that provides a detailed list of
actions the Permittee will take to regain compliance with Permit limits and DMT
requirements defined in Parts I.C and I.D of this Permit. At a minimum, the Contingency
Plan will include, but is not limited to measures to resolve the following general
categories of non-compli ance :
Groundwater Contamination - as shown by any contaminant concentrations in
compliance monitoring wells that exceed their respective groundwater compliance
limit found in Part I.C.l and Table 2 of this Permit.
Mill Discharge Violations - including unauthorized discharge or release of prohibited
contaminants to the tailings cells, pursuant to PartI.C.2 and I.C.3; and
c) DMT Violations - which include several types of non-compliance, including but not
limited to:
l) 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 modify
this Permit to include any new requirements therefrom.
16. Stormwater Best Management Practices Plan - within 180 days of Permit issuance the
Permittee shall submit a final Stormwater Best Management Practices Plan for Executive
Secretary approval. Said plan shall comply with the requirements of Part I.D.8 of this
permit. Upon Executive Secretary approval, the Permittee shall immediately implement
a)
b)
a)
b)
27
o
Part I
Permit No. UGW370004
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 oider 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: IvfW-l, N[W-
2, MW:3, MW-5, ind 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
TTIF 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 TFIF 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'
28
Permit No. UGW37000,4
STATE OF UTAH
DTVISION OF WATER QUALITY
DEPARTMENT OF ENTVIRONMENTAL QUALITY
I.l"rAH WATER QUALITY BOARD
SALT LAKE CITY, UTAH 84114-4870
, GROI.JND WATER DISCHARGE PERMIT
In compliance with the provisions of the Utah Water Quality Act, Title 19, Chsp'"er 5, 'Jtah Codc
Annotated 1953, as amended, the Act,
International Uranium (USA) 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
diJposal faciiity located approximately 6 miles south of Blanding, Utah. The facility is located
o, u tru"t of land in Sections 28,29,32, and 33, 'Iownship 37 South, Range 22Bast, Salt Lake
Base and Meridian, San Juan County, Utah'
The permit is based on representations made by the Permittee and other information contained in
the aiministrative record. It is the responsibility of the Permittee to read and understand all
provis;ons 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.
This permit shall become "ff"a*, l,n'l /9?AL
This permit shall expire-March-E -2010'
Utah Water QualitY Board
PART
A.
B.
C.
l.)
aJ.
D.
I.
2.
aJ.
4.
5.
6.
7.
8.
E.
1.
2.
4.
5.
6.
7.
8.
F.
1.
2.
aJ.
4.
5.
6.
7.
8.
9.
G.
1.
2.
aJ.
4.
5.
H.
l.
2.
J.
4.
5.
6.
7.
Table of Contents
I. SPECIFIC PERMIT CONDITIONS ............ ........... 1
GRouwo Weren CressnrcerloN.......... ....................... I
BecrcRouNoWarsRQuer-rrv... ............... 1
PeRrrtrr Lnars .........2
Ground Water Compliance Limits.... ......2
Tailings Cell Operations......... ................2
Prohibited Discharges ...........2
DrscuRRcBMnrmuzaroNTBcuNorocy SrANDARD........... .......... 8
DMT Design Standards for Existing Tailings Cells 2, and 3......... ............... 8
Existing Tailings Cell Construction Authorized ..... 10
Existing Facility DMT Performance Standards............... ......... 10
Best Available Technology Requirements for New Construction................................ 11
Definition of I le.(2) Waste .................. 12
Closed Cell Performance Requirements .................12
Facility Reclamation Requirements........... ............. 12
Stormwater Management and Spill Control Requirements .......... ..............12
GRouNo Weren ColprnNCE AND Trcrniolocy PERFoRMANCE MoNrroRnqc............. l3
Routine Groundwater Compliance Monitoring.......... .............. 13
Groundwater Head Monitoring .............14
Groundwater Monitoring Well Design and Construction Criteria..... .........14
Monitoring Procedures for Wells... ....... 14
White Mesa Seep and Spring Monitoring ............... 15
DMT Performance Standard Monitoring ................ 15
On-site Chemicals Inventory.. ............... 16
Tailings Cell Wastewater Quality Monitoring ........ 16
RBpoRrrNcRreunrmNTS........... ............ 16
Routine Groundwater Monitoring Reports ............. 16
Routine DMT Performance Standard Monitoring Reports..... .................... 17
DMT Performance Upset Reports..... ....17
Other Information ............... ..................I7
Groundwater Monitoring Well As-Built Reports ..................... 17
White Mesa Seep and Spring Monitoring Reports ................... l8
Chemicals Inventory Report ................. 18
Tailings Cell Wastewater Quality Reports..... ......... l8
Revised Hydrogeologic Report ............. 18
OuropCowr-reNcESrATUS .................... 18
Accelerated Monitoring Status........ ...... l8
Violation of Permit Limits .................... 19
Failure to Maintain DMT Required by Permit.. ...... 19
Facility Out of Compliance Status ........20
Accelerated Monitoring Status for New Wells .......20
Cortplra,NcE ScIIEDULE Rnerrm.rl,mNTs. .......... .........20
Installation of New GroundwaterMonitoringWells ................20
Revised Hydrogeologic Report .............21
Background Ground Water Quality Report: Existing WeIIs........ ..............21
Background Groundwater Quality Report: New Monitoring Wells ..........22
Tailings Cells Wastewater Quality Sampling Plan.......... .........23
Monitoring Well Remedial Construction and Repair Work Plan and Report ..............23
Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report...................24
8. White Mesa s"O*O Springs Sampling Work etan urdiport............. ...................249. On-site Chemicals Inventory Report....... ................2410. Infiltration and Contaminant Transport Modeling Work Plan and Report...............2511. Plan for Evaluation of Deep Supply Well WW-2............... ....................2612. DMT Monitoring P1an.......... ............2613. Tailings Cell4,A' Contaminant Removal Schedule and Report ..............2614. Tailings Cell 4,A' Redesign and Reconstruction ....................2715. Contingency Plan ............2716. Stormwater Best Management Practices Plan ......... .............2717. Roberts Pond As-Built Report ..........2818. Tetrahydrofuran Demonstration Study Work Plan and Report....... ........28
PART tr. REPORTTNG REQUIREMENTS.... ....29A. RrpnpsrNrATrvE SaleuNc. .....................29B. ANeryucer- Pnoc8ounss............... .........29C. PsNerrrEs FoR TAMpERrNG............... ........29D. RBpoRrnrc oF MoNTToRTNG R8SULTS.............. ...........29E. ColrpuaNcE ScrrEDUL8s............... ...........29F. AooIrroNar-MoluroRnrcBy rr{E Pgnvtrree ............29G. Rsconos CovreNrs. ...............29H. RsrENTroN orRecoRns................ ............29I. NorrcsoFNoNCoMpLrANCEREpoRTrNG.......... .......... 30J. OrrenNoNcoleuANcERspox.rnrc ........30K. INsprcnoN AND ENrRy ........... 30
PART M. COMPLIANCE RESPONSIBILTTIES ................. 3IA. DuryrocoMply ....................31B. PsNar-rms FoR VToLATToNS oF PERn[rr ColorrroNs ............... ..... 3lC. Nnno ro HALT oR Rsoucs Acrrvrry Nor A Drn'eNsB .................. 3lD. Dury ro M1ncRTE.............. ...................... 3lE. PnopBn OpnReuoN exo ManrrENANCE....... .............. 31
PART rV. GENERAL REQUrREMENTS............... .............32A. PlaxxeoCnRNcrs .................32B. ANrrcparep NoNcolpuANCE........ .........32C. PenvrrAcnoNs... ...................32D. DuryroRrappry............... ....32E. Dury ro Pnovpe Ii.rroRuerroN ......... .....32F. Orrmn IxroRuenoN............. ....................32G. SrcNeroRy RreunsvmNTs........... ...........32H. PeNarurs roR FarsnrcATroN or RnpoRrs ............... ................... 33I. Avau-arurry opRBpoRTS......... ............... 33J. PnopnRry Rrcrns ................... 33K. SsvBResLrry............ ..............33L. TRRNsrsRs ............33M. Srarslaws ..........34N. RroprunR PRovrsroNs................ ..............34
List of Tables
Table l. Ground Water Classification ............. ....... I
Table 2. Groundwater Complianc" Lil;;........................:.........:.................................................. 3
Table 3. DMT Engineering Design and Specifications ........... 8
Table 4. Feedstock Storage Area Coordinates ..... 1l
Table 5. Groundwater Monitoring Reporting Schedule... ...... 16
Part I
Permit No. UGW310004
PART I. SPECIFIC PERMIT CONDITIONS
A. GnouNo WersR Cr-essmcerroN - 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 1,
below:
Footnotes:
1) Based on historic total dissolved solids (TDS) data provided by IUC for period between October, 1979 and May, 1999. Average
concentrations calculated by Utah Division of Radiation Control (DRC) staff in a November 29,1999 memorandum.
2) Based on average of DRC split samples collected from the ruC facility between May, 1999 and September, 2002.
3) Number of IUC or DRC samples used in the evaluation of average TDS concentrations.
4) Classification of IUC well MW-19 based on the conservatively lower IUC data.
5) Wells MW-20 and MW-22 are not point of compliance monitoring wells, but instead are groundwater head monitoring wells as per Pafil.E.z.
6) Well MW-26 was originally named TW4-15 and was installed 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 tailings cells (see Part I.E.l) .
7) Welt TW4-16 was installed as a part of a recent chloroform investigation at the facility, and has been included in the Permit as groundwater
head monitoring well (Part I.E.2). Groundwater classification provided here based on average of both the tUC and DRC data (2 samples).
8) Well MW-32 was originally named TW4-17 and was installed as a part of a recent chloroform contaminant investigation at the facility. Under
this Permit it is included as a POC well for the tailings cells in Part I.E.l .
B. BecrcnouND Warrn Quar-rrv - background groundwater quality will be determined on a
well-by-well basis, as defined by the mean plus second standard deviation concentration.
After Executive 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.
Table l. Ground Water Classification
CIass II Groundwater Class III Groundwater
Well ID Average T'DS (me/l
Well ID
Average TDS (me/l)
IUC Data DRC Data IUC Data DRC Data ("
Avg.
Conc.(l)
No. of
Data(3)
Avg.
Conc.(2)
No. of
Data(3)
Avg.
Conc.(l)
No. of
Data(3)
Avg.
Conc.(2)
No. of
Data(3)
Historic IL C Monitorinp Wells
MW-1 t.276 68 r,268 4 MW-2 3,031 67 3,1 03 4
MW-5 2,081 69 2,068 4 MW-3 5,200 67 5,289 4
MW-l1 1,834 50 2,039 4 MW-2 3.939 50 3,756 4
MW-l8 2.545 9 2,611 4 IvIW-4 3.582 30 3,589 4
MW-1g'"',2,697 9 3,r20 4 MW-5 3,855 30 3,847 4
MW-20,"2,977 I nla 0 MTW-7 4,538 ll 4,542 4
NNV.22'''5,105 I nla 0
Recent IUC Monitorinp Wells
MW-26'"',3,120 I 3,206 1
TW4-16,"2,930 I 3,430 1
MW-32,"'3,190 I 3,650 I
Part I
Permit No. UGW370004
C. PBnrrnr Lnzurs - the Permittee shall comply with the following permit limits:
l. Ground Water Compliance Limits - contaminant concentrations measured in each
monitoring well shall not exceed the Ground Water Compliance Limits (GWCL) defined
in 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 I l.e.(2) by-product material authorized by Utah
Radioactive Materials License No. UT-2300478 (hereafter License) shall be discharged to
or disposed of in the tailings ponds.
3. Prohibited Discharges - discharge of other compounds such as paints, used oil,
antifreeze, pesticides, or any other contaminant not defined as l1e.(2) material is
prohibited.
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iNOr+n\Or @or\
Q*,
Permit No. UGW370004
D. DrscHance MnutvtzATIoNTscnNoI-ocv SreNoeno - the tailings disposal facility must be
built and operated according to the following Discharge Minimization Technology (DMT)
standards:
1. DMT Design Standards for Existing Tailings Cells l, 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:
Table 3. DMT En Desi and ifications
l) D'Appolonia Consulting Engineers, Inc., June, 1979, "Engineers Report Tailings Management System White Mesa Uranium Project
Blanding, Utah Energy Fuels Nuclear, lnc. Denver, Colorado', unpublished consultants report, approximately 50 pp., 2 figures, l6 sheea, 2
appendices.
2) D'Appolonia Consulting Engineers, hc., 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.
D'Appolonia Consulting Engineers, Inc., May, 1981, "Engineer's Report Second Phase Design - Cell 3 Tailings Management System White
Mesa Uranium Project Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado", unpublished consultants report, approximately 20 pp., I
figure, 5 sheets, 3 appendices.
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.
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:l 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 are cut-slopes at 3:1
grade.
Liner System - including a single 30 mil PVC flexible membrane liner (FML)
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 l8-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
3)
4)
1)
2)
3)
Ilcelr
Tailings
Cell
Report
Tvoe Ensineering Report Desisn Fisures
Construction
Soecifications
Cell I Design June, 1979 D'Appolonia
Consultine Engineers. Inc (r)
Appendix A, Sheets 2,4,8,
9. t2-t5
Appendix B
Cell2 Design June, 1979 D'Appolonia
Consulting Engineers, Inc (r)
Appendix A, Sheets 2,4,7-
10,12-15
Appendix B
As-Built February, 1982 D'Appolonia
Consultins Enqineers, Inc (2)
Figures 1,2, and Il N/A
Cell3 Design May, 1981D'Appolonia
Consulting Enqineers, Inc (3)
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear, Inc. (a)
Figures 1-4 N/A
Footnotes:
b)
Part I
Permit No. UGW370004
to gather fluids at the upstream toe of the cross-valley dike.
Tailings Cell2 - which consists of the following major design elements:
1) Cross-valley Dike - constructed at the south margin of Cell 2 of native granular
materials with a 3:l slope, a 2O-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: I
grade. The Cell 1 south dike forms the north margin of Cell 2, with a crest
elevation of 5,620 ft amsl.
2) Liner System - includes a single 30 mil PVC FML liner 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 Cell2 is 5,615.0 ft and 5,613.5 ft amsl
on the north and south dikes, respectively. Said Cell2 FML liner is independent
of all other disposal cell FML liners. Immediately above the FML, a nominal 12-
inch (cell floor) to 18-inch (inside sideslope) soil protective blanket was
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 pipe laterals gravity
drain to a 3-inch diameter perforated PVC collector pipe which also drains toward
the south dike and is accessed from the ground surface via aZ4-inch diameter,
vertical non-perforated HDPE access pipe. Each run of lateral drainpipe and
collector piping was covered with a 12 to lS-inch thick berm of native granular
filter material. At cell closure, leachate head inside the pipe network will be
removed via a submersible pump installed inside the24-inch diameter HDPE
access pipe.
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, a20-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) Liner System - includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML 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
c)
2.
Part I
Permit No. UGW37OOO4
thick layer of crushed sandstone was prepared and rolled smooth as a FML sub-
base layer. Beneath this underla/, 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 Layer and System - immediately above the FML, a
nominal 12-inch (cell floor) to 1S-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 12-inch diameter, inclined HDPE access
pipe. Each run of the 3-inch lateral drainpipe and collector pipe was covered with
a 12 to lS-inch thick berm of native granular filter media. At cell closure,
leachate head inside the pipe network will be removed via a submersible pump
installed inside the 12-inch diameter inclined access pipe.
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 1 -at all times the Permittee shall operate and
maintain Tailings Cell 1 to prevent groundwater quality conditions in any nearby
monitoring well from exceeding any Ground Water Compliance Limit established in
Table 2 of this Permit.
b) Tailings Cells 2 and 3 - including the following performance criteria:
1) 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.l3 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.
-J.
l0
Part I
Permit No. UGW370004
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.
c) 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 elevation of 5,624 feet amsl. In the event that the wastewater
elevation exceeds this maximum level, the Permittee shall remove the excess
wastewater and place it into containment in Tailings Cell I within 72 hours of
discovery. At the 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).
d) Feedstock Storage Area -open-air or bulk storage of all feedstock materials at the
facility awaiting mill processing shall be limited to the eastern portion 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 Permittee shall reclaim and decommission the
Feedstock Storage Area in compliance with an approved Reclamation Plan.
Table 4. Feedstock Storage Area Coordrna
Corner Northins (ft)Eastins (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,t20 2,580,085
West 4 323,3t5 2,580,285
West 5 323,415 2,579,990
Northwest 323,600 2,579,990
Footnote: I ) Approximate State Plane Coordinates beginning from the extreme northeast comer and progressing
flSffiT.H:rr;[}re
feedstock area (from6t22t0l IUC Response, Attachment K, Site Topographic Map,
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 reagent(s) that might be
released at any individual storage area. Response to spills, cleanup thereof, and
required reporting shall comply with the provisions of 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
tes (l)
ll
5.
O punl
Permit No. UGW370004
submitted shall demonstrate compliance with all Best Available Technology requirements
stipulated by the 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.(Z) 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 11e.(2)
of the U.S. Atomic Energy Act of 1954, 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 requirements of an approved
Reclamation Plan, and will for a period of not less than 200 years meet the following
minimum performance requirements :
a) Minimize infiltration of precipitation or other surface water into the tailings,
including, but not limited to the radon barrier, and
b) 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.
c) 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 LC.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
reserves 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, pursuant to
Part I.H.17 of the Permit. Said plan shall include provisions to adequately:
a) Protect groundwater quality or other waters of the state by design, construction,
and/or active operational measures that meet the requirements of the Ground Water
Quality Protection Regulations found in UAC R317-6-6.3(G) and R317-6-6.4(C),
b) Prevent, control and contain spills of stored reagents or other chemicals at the mill
site,
c) Cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery,
t2
6.
7.
8.
Part I
Permit No. UGW370004
d) Report reagent spills or other releases at the mill site to the Executive Secretary in
accordance with UAC I9-5-I14.
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 IV.N.3
of this Permit.
E. Gnouwo Warrn ColrplraNcE AND TncnNor-ocy PERFoRMANCE MomroRnvc - 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 and keep records of the
operation of the facility, as follows:
l. Routine Groundwater Compliance 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 10 feet/year.
For purposes of this Permit, quarterly monitoring is required at the following wells:
1) Upgradient Wells: none
2) Lateral or Downgradient Wells: MW-l1, MW-14, MW-26 (formerly TW4-15),
and MW-32 (formerly TW4-17).
b) Semi-annual Monitoring - the Permittee shall monitor 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 be less than l0 feetlyear.
For purposes of this Permit, semi-annual monitoring is required at the following
wells:
1) Upgradient Wells: MW-1, MW-18, and MW-19,
2) Lateral or 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
analyzed for the following parameters:
1) Field Parameters -depth to groundwater, pH, temperature, and specific
conductance.
2) LaboratoryParameters
i. GWCL Parameters - all contaminants specified in Table 2.
ii. General Inorganics -chloride, sulfate, carbonate, bicarbonate, sodium,
potassium, magnesium, calcium, and total anions and cations.
d) Special Provisions for Groundwater Monitoring - the Permittee shall ensure that all
t3
O pur, r
Permit No. UGW370004
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.
2) 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.
3) Gross Alpha Counting Variance - all gross alpha analysis reported shall have a
counting variance that is equal to or less than20Vo 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) Point of Compliance Wells - identified in Table 2 and Part I.E.l of this Permit,
b) Piezometers - P-1, P-2,P-3,P-4,P-5.
c) Existing Monitoring Wells - IvIW-20 and MW-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(IX6), 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
Groundw ater Moni torin g Qual i ty Assurance Pl an.
b)
c)
t4
5.
6.
Part I
Permit No. UGW370004
c) Laboratory Approval - all analyses shall be performed by a laboratory certified by the
State of Utah to perform the tests required.
d) Damage to Monitoring Wells - if any monitor well is damaged or is otherwise
rendered inadequate for its intended purpose, the Permittee shall notify the Executive
Secretary in writing within five days of discovery.
e) 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.
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.l3, the Permittee 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, including,
but not limited to the following activities:
a) Weekly Tailings Wastewater Pool Elevation Monitoring: Cells I and 3 - the
Permittee shall monitor and record weekly the elevation of wastewater in Tailings
Cells I 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.
b) 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.
c) Weekly Wastewater Level 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.
d) Weekly Feedstock Storage Area Inspection - the Permittee shall develop a Standard
Operating Procedure for the License and inspect the Feedstock Storage Areas to:
i. Confirm the bulk feedstock materials are maintained within the approved
Feedstock Storage Area defined by Table 4, and
ii. 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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Permit No. UGW370004
7. 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 kglyr.
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.
8. 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. RsponuNc Rnqum.rwNrs - 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 tield and laboratory analyses of all well
monitoring and samples described in Parts LE.l, 1.8.2,1.8.4, and I.E.6 of this Permit.
Reports shall be submitted according to the following schedule:
Table 5. Gro Schedule5. Groundwater Monitorin I
Ouarter Period Due Date
First January - March June I
Second April - June September 1
Third July - September December I
Fourth 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 name, date and
time of well purging, date and time of well sampling, type and condition of well
pump, depth to groundwater before purging and sampling, calculated well casing
volume, volume of water purged before sampling, volume of water collected for
analysis, types of sample containers and preservatives.
b) Laboratory Results - or copies thereof that provide the following: date and time
sampled, date received by laboratory, and for each parameter analyzed, the following
information: laboratory result or concentration, units of measurement, minimum
detection limit or reporting limit, analyical 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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Part I
Permit No. UGW3700O4
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 Quality Assurance 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, analyical methods used, etc.
Electronic Data Files and Format - in addition to written results required for every
sampling repoft, 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 the
Executive Secretary.
2. Routine DMT Performance Standard Monitoring Reports - the Permittee shall provide
quarterly monitoring reports of all DMT performance standard monitoring required by
Part I.E.6 of this Permit. Said monitoring shall be conducted in compliance with an
approved DMT Monitoring Plan, pursuant to Part I.H.13 of this Permit. Said monitoring
reports and results shall be submitted to the Executive Secretary on the schedule provided
in Table 5, above, and shall at a minimum include the following information:
a) Summary table of weekly wastewater pool elevation monitoring at Tailings Cells l, 3,
and the Roberts Pond. Units of reporting shall be in 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 to
water level inside the slimes drain access pipe, as measured from one water level
measuring point at the centerline of the pipe.
3. DMT Performance Upset Reports - the Permittee shall report any non-compliance with
the DMT performance criteria of Part I.D in accordance with the requirements of Part
I.G.3 of this Permit.
4. 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.
5. Groundwater Monitoring Well As-Built Reports - as-built reports for new groundwater
monitoring wells shall be submitted for Executive Secretary approval, and at a minimum
will 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:
d)
e)
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Part I
Permit No. UGW370004
l) 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.
White Mesa Seep and Spring Monitoring Reports - after approval of the work plan and
report required by Part I.H.9, this Permit may be modified to require annual monitoring
and reporting of selected seeps or springs on White Mesa.
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.
Tailings Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part I.E.S 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.l(a), (b), (d), and (e) of this Permit.
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.
G. Our oF CoMPLTANCE Srarus
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
18
6.
7.
8.
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Part I
Permit No. UGW37OOO4
shall then:
a) Notify the Executive Secretary in writing within 30 days of receipt of data; and
b) Immediately initiate accelerated sampling of the pollutant as follows:
1) Quarterly Baseline Monitoring Wells - for wells defined by Part I.E.l(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 initiate 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 Limits - out-of-compliance status exists when:
a) 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
b) 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
a) 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(CX1). 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 R3l7-6-6.16(CX2), within five days of the Permittee's discovery of the failure
of best available technology
The Executive Secretary shall use the information provided under R3l7-6-6.16.C(l)
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
b)
c)
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Part I
Permit No. UGW3700O4
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 l9-5-107 have not been violated.
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.
c) 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.
d) The Executive Secretary may require immediate implementation of the contingency
plan to be submitted pursuant to Part I.H.l6, 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.
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 LG of this Permit, after
submittal and Executive Secretary approval of the Background Groundwater Quality
Report required by Part LH.4 of this Permit.
H. ColpltANCE Scmoure Rnqum.rwNTs. The Permittee will comply with the schedules as
described and summarized below:
1. 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 (l) hydraulically upgradient well and two (2)
hydraulically downgradient wells that comply with the provisions of Part I.E.3 of this
4.
5.
20
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Part I
Permit No. UGW370OO4
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 Cell2 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.l, 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 IV.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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Part I
Permit No. UGW370004
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 phenomena, that shall include, but are not limited to:
l) 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.1,
b) Well monitoring procedure requirements of Part I.E.4, and
c) Quarterly reporting requirements of Part I.F.l.
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 LH.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
22
3)
l)
2)
4)
s)
6)
7)
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Part I
Permit No. UGW370004
Permit and establish Groundwater Compliance Limits in Table 2for the new monitoring
wells.
5. 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 characteize 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.S 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.
6. 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:
Well Development - the Permittee shall develop existing wells at the facility so that
they produce clear groundwater, including wells: MW-5, MW-l1, MW-18, 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.
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:
l) 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.
a)
b)
23
7.
Part I
Permit No. UGW370004
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,
d) Description of sample preservation methods,
e) Determination of the laboratory analytical 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.
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 reporl 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
8.
9.
24
Part I
Permit No. UGW3100O4
updated inventory report pursuant to Part I.F.7.
10. 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 (Ifu) 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 for Executive 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.
25
Part I
Permit No. UGW310O04
I l. Plan for Evaluation of Deep Supply Well WW-2 - within I 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 WW-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.1 and I.D.3; adequate DMT monitoring
procedures in compliance with Parts LE.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:
Design and construction of a wastewater pool elevation gauge to be installed at each
tailings cell, or procedures and equipment needed for completion of periodic
wastewater elevation surveys.
Designation of a water level measuring point on the slimes drain access pipe at both
Tailings Cells 2 and 3.
Based on historical construction 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.
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.
Design and construction of a water level gauge, or procedures and equipment needed
for completion of periodic elevation surveys at the Roberts Pond to measure
wastewater levels above the lowest point on the pond's FML.
Procedures for monitoring the Feedstock Storage Area to determine appropriate
location of feedstock storage, and water-tight condition of containerized feedstocks.
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
26
a)
b)
c)
d)
e)
0
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Part I
Permit No. UGW370004
under Tailings Cell 4,{, including periodic progress reports. The purpose of this work
shall be to recover, remove all contaminated materials and to dispose of these materials in
Tailings Cell 3. Within 60 days of completion of contaminant removal from Tailings
Cell 4A, the Permittee shall submit a report for Executive Secretary approval.
14. Tailings Cell 44 Redesign and Reconstruction - after contaminant removal pursuant to
Part I.H.14, and prior to any new construction including, but not limited to: foundations,
sub-base materials, liners, or leak detection systems at existing Tailings Cell 4,{, the
Permittee shall:
a) Submit engineering design plans and specifications that demonstrate how the new
construction will comply with the requirements of the Utah Water Quality Act, all
rules and regulations promulgated thereunder, and the Best Available Technology
requirements mandated by Part I.D.4 of this Permit.
b) 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 and
construction specifications, and any related operations, monitoring, or reporting
requirements necessary.
15. Contingency Plan - within 180 days of issuance of this Permit, the Permittee shall submit
a Contingency Plan for Executive Secretary approval that provides a detailed list of
actions the Permittee will take to regain compliance with Permit limits and DMT
requirements defined in Parts I.C and I.D of this Permit. At a minimum, the Contingency
Plan 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 in
compliance monitoring wells that exceed their respective groundwater compliance
limit found in Part I.C.1 and Table 2 of this Permit.
Mill Discharge Violations - including unauthorized discharge or release of prohibited
contaminants to the tailings cells, pursuant to PartI.C.2 and I.C.3; and
c) DMT Violations - which include several types of non-compliance, including but not
limited to:
l) Excess tailings cell wastewater pool elevation above the maximum elevations
mandated by Part I.D.3;
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 LH.l3; and
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 modify
this Permit to include any new requirements therefrom.
16. Stormwater Best Management Practices Plan - within 180 days of Permit issuance the
Permittee shall submit a final Stormwater Best Management Practices Plan for Executive
Secretary approval. Said plan shall comply with the requirements of Part I.D.8 of this
permit. Upon Executive Secretary approval, the Permittee shall immediately implement
a)
b)
2)
3)
27
Part I
Permit No. UGW370004
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 (TIf) contamination identified in several
existing monitoring wells at the facility, including but not limited to wells: MW-1, MW-
2, MW-3, MW-5, and MW-12. Said plan shall be submitted for Executive Secretary
approval, and shall include collection ofdirect evidence to verify the source and extent of
TI{F contamination in the aquifer. Such work shall include field and laboratory studies to
determine if the TF{F 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 TFIF 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 THF as a GWCL parameter.
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B.
C.
D.
E.
F.
i punu
Permit No. UGW370OO4
PART tr. REPORTING REQUIREMENTS
A. RBpnTSENTATTE Satwutvc. Samples taken in compliance with the monitoring requirements
established under Part I shall be representative of the monitored activity.
ANllvucer PnoceouRgs. Water sample analysis must be conducted according to test
procedures specified under UAC R3 I 7 -6-6.3 .12 unless other test procedures have been specified
in this permit.
PnNaI-rres FoR TAMpEnnic. 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 permit 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.
RrpoRrnqc oF MoNTToRING RESULTS. Monitoring results obtained during reporting periods
specified in the permit, shall be submitted to the Executive Secretary, Utah Division of Water
Quality at the following address no later than the date specified following the completed
reporting 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 1, September 1, December 1, and March l.
CotwlIeNCE ScIIEDuLES. 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.
AoornoNet MoNrronwc By rlIE PeRIrnrrsB. If the permittee monitors any pollutant more
frequently than required by this permit, using approved test procedures as specified in this
permit, the results of this monitoring shall be included in the calculation and reporting of the data
submitted. Such increased frequency shall also be indicated.
G. Rrconps CoN-rEr.[s.
l. 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 analytical techniques or methods used; and,
The results of such analyses.
H. RsrrNnoN oF RecoRos. The permittee shall retain records of all monitoring information,
a)
b)
c)
d)
e)
0
29
Part II
Permit No. UGW370004
including all calibration and maintenance records and copies of all reports required by this
permit, and records of all data used to complete the application for this permit, for a period of at
least 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.
I. Nortcs oF NoNCoMpLIANCE Reponrnlc.
l.The permittee shall verbally report any noncompliance which may endanger public health or
the environment as soon as possible, but no later than 24 hours from the time the permittee
first became aware of the circumstances. The report shall be made to the Utah Department of
Environmental Quality Z4hour number, [phone], or to the Division of Water Quality,
Ground Water Protection Section at [phone], during normal business hours (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) A description of the noncompliance and its cause;
b) The period of noncompliance, including exact dates and times;
c) The estimated time noncompliance is expected to continue if it has not been corrected;
and,
d) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
3. Reports shall be submitted to the addresses in Part II.D, Reporting of Monitoring Results.
Orrmn NoNcorwuANCE RrpoRrntc. Instances of noncompliance not required to be reported
within 5 days, shall be reported at the time that monitoring reports for Part tr.D are submitted.
INspgcrroN AND ENTRv. The permittee shall allow the Executive Secretary, or an authorized
representative, upon the presentation of credentials and other documents as may be required by
law, to:
1. Enter upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of the permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit;
3. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and,
4. Sample or monitor at reasonable times, for the purpose of assuring permit compliance or as
otherwise authorized by the Act, any substances or parameters at any location.
2.
J.
K.
30
B.
Part Itr
Permit No. UGW370004
PART M. COMPLIANCE RESPONSIBILITIES
A. 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.
PgNarrms FoR VToLATToNS oF PERIflt CoxorrroNs. 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.
NrBp ro HALT oR Rrpuce Acuvrry 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.
D. Dury To MrrrcAre. The permittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
E. Pnoprn OppRanoN AND MAINTENANCE. The permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the permittee to achieve compliance with the conditions of this permit.
Proper operation and maintenance also includes adequate laboratory controls and quality
assurance procedures. This provision requires the operation of back-up or auxiliary facilities or
similar systems which are installed by a permittee only when the operation is necessary to
achieve compliance with the conditions of the permit.
C.
31
A.
O pu,t rv
Permit No. UGW370004
PART IV. GENERAL REQUIREMENTS
Pt-aulwp CnaNogs. The permittee shall give notice to the Executive Secretary as soon as
possible of any planned physical alterations or additions to the permitted facility. Notice is
required when the alteration or addition could significantly change the nature of the facility or
increase the quantity of pollutants discharged.
ANucparpo NoNcolelIANCE. The permittee shall give advance notice of any planned changes
in the permitted facility or activity which may result in noncompliance with permit requirements.
Pentwr AcrtoNs. This permit may be modified, revoked and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation and re-issuance, or
termination, or a notification of planned changes or anticipated noncompliance, does not stay any
permit condition.
Durv ro RBlppt-v. If the permittee wishes to continue an activity regulated by this permit after
the expiration date of this permit, the permittee must apply for and obtain a new permit. The
application should be submitted at least 180 days before the expiration date of this permit.
Durv ro Pnovpe IuroRMATIoN. 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 compliance with this permit. The permittee shall also furnish to the Executive
Secretary, upon request, copies of records required to be kept by this permit.
Orrmn IwronuenoN. When the permittee becomes aware that it failed to submit any relevant
facts in a permit application, or submitted incorrect information in a permit application or any
report to the Executive Secretary, it shall promptly submit such facts or information.
StcNaronvRnqunrlcexrs. All applications, reports orinformation submittedtotheExecutive
Secretary shall be signed and certified.
l. All permit applications shall be signed as follows:
a) For a corporation: by a responsible corporate officer;
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. AII 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. A person is a duly authorized representative only if:
a) The authorization is made in writing by a person described above and submitted to the
Executive Secretary, and,
b) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
B.
C.
D.
E.
F.
G.
32
H.
Part IV
Permit No. UGW37OOO4
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 company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.)
3. Changes to Authorization. If an authorization 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 IV.G.2 must be submitted to
the Executive Secretary prior to or together with any reports, information, or applications 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. "
PrNarrres ron FersnrcATIoN 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
$10,000 per violation, or by imprisonment for not more than six months per violation, or by both.
Avau-asLITY oFRrponrs. 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.
PRopBRrv Rtcnrs. 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 propefty or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations.
SpvpResLITY. 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. TRaNsrsns. 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
-aJJ
J.
K.
M.
N.
Part IV
Permit No. UGW370004
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 agreement mentioned in
paragraph 2 above.
Srerr Lews. Nothing in this permit shall be construed to preclude the institution of any legal
action or relieve the permittee from any responsibilities, liabilities, penalties established pursuant
to any applicable state law or regulation under authority preserved by Section 19-5-ll5 ofthe
Act.
RnoprueR PnovtsroNs. This permit may be reopened and modified (following proper
administrative procedures) to include the appropriate limitations and compliance schedule, if
necessary, if one or more of the following events occurs:
1. If new ground water standards are adopted by the.Board, the permit may be reopened and
modified to extend the terms of the permit or to include pollutants covered by new standards.
The permittee may apply for a variance under the conditions outlined in R3l7-6-6.4(D).
2. Changes have been determined in background ground water quality.
3. The Executive Secretary determines permit modification is necessaryto protect human health
or the environment.
LBM:lm
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