DRC-2008-002501 - 0901a06880abe0a4

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Dave Rupp - RE: Revised 4A O & M Plan and DMT Plan
I
Cell
From:
To:
Date:
Subject:
CC:
Attachments:
Harold Roberts <HRoberts @ denisonmines.com>
Dave Rupp <[e-mail]>
911612008 12:25 PM
RE: Revised Cell4A O & M Plan and DMT Plan
Richard B artlett <RB artlett @ deni sonmines.com>, A- Ron Hochstein
<[e-mail]>, Steve Snyder <[e-mail]>,
DaneFinerfrock <DFINERFROCK @ utah. gov>
Cell 4A O & M Plan 09_16_08 Final.doc; Tailings Mgnt System and DMT MonPlan 3
14 07 (6) Proposed Revisions September 2008.doc; O & M 1.3 Redlined.pdf; O & M
1.3 Clean.pdf
Dave:
See the attached revised Cell 4A O&M Plan. I have attached a redlined PDF and clean PDF and clean Word
version. I am also attaching a Word version for the DMT Plan.
Harold Roberts
Executive Vice President, US Operations
t: [phone] | f: (303) 389-4t25
1050 17th Street, Suite 950, Denver, CO
80265
DENISON MINES (USA) CORP
www.denisonmines.com
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you
are not the intended recipient(s) please delete this message and notify the sender. You may not use,
distribute print or copy this message if you are not the intended recipient(s).
From: Dave Rupp [mailto:[e-mail]]
Sent: Tuesday, September 16, 2008 9:37 AM
To: Harold Roberts
Cc: Richard Baftlett; A- Ron Hochstein; Steve Snyder; Dane Finerfrock
Subject: RE: Revised Cell 44 O & M Plan and DMT Plan
Harold:
file://C:\Documents and Settings\Drupp\Local Settings\TempU(Pgrpwise\48CFA5ABEQD... 911612008
-r-Page 2 of 4
Yes. I believe word versions of the plans would be useful. Thanks. - -
David A. Rupp, P.E.
Utah Division of Radiation Control
P. O. Box 144850
Salt Lake City, UT 84114-4850
Ielephone [phone]
Fax (801) s33-4097
Email: [e-mail]
>>> Harold Robefts <[e-mail]> 9lL6l20OB 9:30 AM >>>
Dave:
I will forward the changes to you this morning. Do you also want Word versions of the documents as well as
PDF'S?
Harold Roberts
Executive Vice President, US Operations
t: [phone] | f: [phone]
1050 lTth Street, Suite 950, Denver, CO
80265
DENISON MINES (USA) CORP
www.denisonmines.corr
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you
are not the intended recipient(s) please delete this message and notify the sender. You may not use,
distribute print or copy this message if you are not the intended recipient(s).
From: Dave Rupp [mailto:[e-mail]]
Sent: Tuesday, September 16, 2008 9:28 AM
To: Harold Roberts
Cc: Richard BartletU A- Ron Hochstein; Steve Snyder; Dane Finerfrock
Subject: Re: Revised Cell 4A O & M Plan
Harold,
We have the following comment on the O&M plan submitted September t2,2O0B:
file://C:\Documents and Settings\Drupp\Local Settings\TempU(Pgrpwise\48CFA5ABEQD... 9l16/2008
Page 3 of 4
On page 8 of the O&M Plan, there is explicitly stated weekly LDS water level data collection and evaluation times. Parallel
verbiage needs to be added for collection and evaluation of the measured LDS flow rate. To do this, we suggest following
underlined wording be inserted into the paragraph on the Leak Detection System on page 8 as follows:
"Within 24 hours after collection of the weekly water level and pump flow data, the information will be evaluated to ensure
that: l) the water level in the leak detection sump did not exceed the allowable level (5556.14 feet amsl) and 2) the average
dailv fls at any time during the reporting
period."
I believe once this issue is resolved, we will be ready to approve the DMT and O&M Plans, as well as authorize operation
of Cell 4A.
We request the O&M Plan be revised and submitted with the above consideration. If you have any questions please contact
me. --
David A. Rupp, P.E.
Utah Division of Radiation Control
P. O. Box 144850
Salt Lake City, UT 84114-4850
Telephone [phone]
Fax [phone]
Email: [e-mail]
>>> Harold Roberts <[e-mail]> 9lLZ|200B 4:25 PM >>>
Loren and Dave:
See the attached documents. I believe this responds to all your comments in the September
lOth letter. I will call you Monday morning.
Harold Roberts
Executive Vice President, US Operations
t: [phone] | f: (303) 389-412s
1050 17th Street, Suite 950, Denver, CO DENISON MINES (USAI CORP
file://C:\Documents and Settings\Drupp\Local Settings\TempU(Pgrpwise\48CFA5ABEQD... 911612008
Page 4 of 4
80265 www.denisonmines.com
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you
are not the intended recipient(s) please delete this message and notify the sender. You may not use,
distribute print or copy this message if you are not the intended recipient(s).
a
file://C:\Documents and Settings\Drupp\Local Settings\TempU(Pgrpwise\48CFA5ABEQD... 91161200g
Orro, Revision Denison 1.3
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007. The construction
authorization provided that Cell4,A. shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370004 ("GWDP") and full fill the requirements of Parts
I.D.6, I.E.8, and I.F.S of the GWDP.
Cell Desisn
Tailings Cell4A consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
1V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from S9-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90o/o. Floor of
Cell 4A has an average slope of lo/o that grades from the northeast to the
southwest comers.
c) Tailings Capacity - the floor and inside slopes of Cell 4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed
Page I
below).
Cell4A BAT Monitorr.,*, Ou,rons and Maintenance Plan erm Revision Denison 1.3
2) Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 44, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an lS-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4,A. floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4,A., the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in tum overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In tum, the gravel is overlain
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Cell4,{ BAT Monitorirg,lru,lons and Maintenance Plan 09/08 Revision Denison 1.3
by a layer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cell4,A. where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4,A' at the southwest comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal 18-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this l8-inch pipe and used to
remove tailings wastewaters for purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) lO-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 4A,
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4,A..
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 4,A.. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and 3, will be managed and
contained in Cell 44, including the Probable Maximum Precipitation and
flood event.
Cell Operation
Solution Discharee
Cell 4,A. will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 44. through 6 inch or 8 inch diameter HDPE pipelines. The initial
solution discharge will be in the southwest corner of the Cell. The discharge pipe
will be routed down the Splash Pad provided in the comer of the Cell to protect
the pipeline running from the solution reclaim barge. The solution will be
discharged in the bottom of the Cell, away from any sand bags or other
installation on the top of the FML. Building the solution pool from the low end of
0
s)
Page 3
Cell4A BAT Monitorrnr, Ot,ons and Maintenance Plan /08 Revision Denison 1.3
the Cell will allow the solution pool to gradually rise around the slimes drarn
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution flowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 44, utilizing. the Splash Pads
described above. The subsequent discharge of process solutions will be near the
floor of the pond, through a discharge header designed to discharge through
multiple points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
feet of solution. As the cell begin to fill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharge
Once Cell 44. is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 44, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1. Figure 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Figure 2. Because of the depth of
Cell 44, each of the discharge points will be utilized for an extended period of
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved further to the interior of the cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporation rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to further protect the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
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Cell4A BAT Monito.ltgfrutions and Maintenance Plan Oonro, Revision Denison 1.3
Reclaim Water System
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3 illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharge
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4A. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and OA/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 44. Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailinss Cell4A.
DUSA will operate and maintain Tailings Cell4.A so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.19 of the GWDP. These performance
standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment - the
leak detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondary flexible
menbrane. A second leak detection pump with pressure transducer, flow
meter, and manufacturer recommended spare parts for the pump controller
and water level data collector is maintained in the Mill warehouse to
ensure that the pump and controller can be replaced and operational within
24 hours of detection of a failure of the pumping system. The root cause
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Cell4A BAT Monito.,.,r, fiurrons and Maintenance Plan /08 Revision Denison 1.3
of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occuffence.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3/07 Revision: Denison-3, or the currently
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in
the lower flexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table 1 to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
3-foot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4,A.. Said measurements shall be
made to the nearest 0.1 foot.
Slimes Drain Recovery Head Monitoring - immediately after the
Permiffee initiates pumping conditions in the Tailings Cell44. slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occuffences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
2)
3)
4)
s)
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Cell4A BAT Monito.irg,Q.utions and Maintenance Plan Orrffi Revision Denison 1.3
Measurements in Cell4,{ are to be taken by survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey
Instrument") accurate to 0.01 feet, such as a Sokkai No. 821, or
equivalent, together with a survey rod (the "Survey Rod") having a visible
scale in 0.01 foot increments1'
(iii)The reference Points (the "Reference Points") for Cells 4A are known
points established by Registered Land Surveyor. For Cell 44, the
Reference Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4,A'. The elevation at the top of this piece of rebar (the
Reference Point Elevation for Cell44. is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The Surveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell4,{,
this is typically on the road between Cell 3 and Cell4A, approximately 100
feet east of the Cell4,A. Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell 4,A.
Reference Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey lnstrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Reference Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell4,{.
The designated location for Cell 4A is in the northeast corner of the Cell
where the side slope allows for safe access to the solution surface.
The approximate coordinate locations for the measuring points for Cell 4,{
is 2,579,360 east, and320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant will hold the Survey Rod vertically with one end of the
Survey Rod just touching the pond surface. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will focus the cross hairs of the Survey lnstrument on the
scale on the Survey Rod, and record the number (the "Pond Surface
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Cell4,A BAT Monitorlng, t,ions and Maintenance Plan ero, Revision Denison 1.3
Reading"), which represents the number of feet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surface in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
Leak Detection Svstem
The Leak detection system is monitored on a continuous basis by use of a
pressure transducer that feeds water level information to an electronic data
collector. The water levels are measured every hour and the information
is stored for later retrieval. The water levels are measured to the nearest
0.10 inch. The data collector is currently programmed to store 7 days of
water level information. The number of days of stored data can be
increased beyond 7 days if needed. The water level data is downloaded to
a laptop computer on a weekly basis and incorporated into the Mill's
environmental monitoring data base, and into the files for weekly
inspection reports of the tailings cell leak detection systems. Within 24
hours after collection of the weekly water level data, the information will
be evaluated to ensure that: 1) the water level in the leak detection sump
did not exceed the allowable level (5556.14 feet amsl), and2) the average
daily flow rate from the LDS did not exceed the maximum daily allowable
flow rate at any time during the reporting period. For Cell 4A, under no
circumstance shall fluid head in the leak detection system sump exceed a
l-foot level above the lowest point in the lower flexible membrane liner.
To determine the Maximum Allowable Daily LDS Flow Rates in the Cell
4A leak detection system, the total volume of all fluids pumped from the
LDS on a weekly basis shall be recovered from the data collector, and that
information will be used to calculate an average volume pumped per day.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day. The maximum daily LDS flow volume will be compared
against the measured cell solution levels detailed on the attached Table 1,
to determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4,A.. Any abnormal or out of compliance water
levels must be immediately reported to Mill management. The data
collector is also equipped with an audible alarm that sounds if the water
level in the leak detection sump exceeds the allowable level (5556.14 feet
amsl). The current water level is displayed at all times on the data
collector and available for recording on the daily inspection form. The
leak detection system is also equipped with a leak detection pump, EPS
Model # 25505-3 stainless steel, or equal. The pump is capable of
pumping in excess of 25 gallons per minute at a total dynamic head of 50
Page 8
Cell 4A BAT Monitorit ge.ations and Maintenance Plan Crro, Revision Denison 1.3
feet. The pump has a 1.5 inch diameter discharge, and operates on 460
volt 3 phase power. The pump is equipped with a pressure sensing
transducer to start the pump once the level of solution in the leak detection
sump is approximately 2.25 feet (elevation 5555.89) above the lowest
level of the leak detection sump (9 inches above the lowest point on the
lower flexible membrane liner, to ensure the allowable 1.0 foot (5556.14
feet amsl) above the lowest point on the lower flexible membrane liner is
not exceeded). The attached Figure 6, Leak Detection Sump Operating
Elevations, illustrates the relationship between the sump elevation, the
lowest point on the lower flexible membrane liner and the pump-on
solution elevation for the leak detection pump. The pump also has manual
start and stop controls. The pump will operate until the solution is drawn
down to the lowest level possible, expected to be approximately 4 inches
above the lowest level of the sump (approximate elevation 5554.0). The
pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
is recorded by the lnspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
horizontal, perforated section of the PVC collection pipe. The distance
from the top flange face, at the collection pipe invert, to the centerline of
the 22.5 degree elbow is 133.4 feet, and the vertical height is
approximately 45 feet. The pump is installed at least 2 feet beyond the
centerline of the elbow. The bottom of the pump will be installed in the
leak detection sump at least 135.4 feet or more from the top of the flange
invert. A pressure transducer installed with the pump continuously
measures the solution head and is programmed to start and stop the pump
within the ranges specified above. The attached Figure 5 illustrates the
general configuration of the pump installation.
A second leak detection pump with pressure transducer, flow meter, and
manufacfurer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller can be replaced and operational within 24 hours
of detection of a failure of the pumping system. The root cause of the
equipment failure will be documented in a report to Mill management with
recommendations for prevention of a re-occuffence.
Slimes Drain System
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe and a near as possible to
the bottom of the slimes drain sump. The bottom of the slimes drain sump
is 38 feet below a water level measuring point at the centerline of the
Page 9
Cell4A BAT Monitori.,g, firions and Maintenance Plan ero, Revision Denison 1.3
slimes drain access pipe, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter,ElH Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The flow rate and total gallons will be recorded by
the Inspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 44. slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within 15 days;
(iv)Depth to wastewater in the Cell 4,A. slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. All head
measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional process solutions will be discharged to Cell4A, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
Page l0
Cell4A BAT Monito.ing,e.u,ions and Maintenance Plan Orro, Revision Denison 1.3
will notify Corporate Management. If dam failure occurs, notify yoirr supervisor and the
Mill Manager immediately. The Mill Manager will then notiff Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-I, Cell 2,Cell3 and Cell4A
are regulated by condition 10.3 of the White Mesa Mill 1le.(2) Materials License.
Condition 10.3 states that "Freeboard limits for Cells 1-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13,1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
CeIl3 shall be recalculated annually in accordance with the procedures set in the
October 13,1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Loc'al 6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
10 inches.
Based on the PMP storm event, the freeboard requirement for Cell I is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2,3 or 44.
Cell2 has no freeboard limit because the Cell is 99% tull of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume from the PMP event over the Cell2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing 24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 4,A. design includes a concrete spillway between Cell 3 and Cell 4,A' with the
invert elevation 4 feet below the top of the Cell 3 dike, at an elevation of 5604.5 feet
amsl. Once Cell 4A. is placed in operation, the cell would be available for emergency
overflows from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 4,A. would see any overflow water from Cell 3 unless the
full PMP event were to occur. Should Cell 3 receive the full PMP volume of 123.4 acre
feet of water, approximately 62 acre feet of that volume would flow through the spillway
into Cell4.A..
The flood volume from the PMP event over the Cell 4,A. area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). This
would result in a total flood volume of 98 acre-feet, including the 62 acre-feet of solution
from Cell 3. The freeboard depth required for Cell 44. from the PMP event would be
2.44 feet, plus a wave run-up depth of 0.77 feet (from the 1990 Drainage Report), for a
Page I I
Cell4A BAT Monitorirg, firions and Maintenance Plan ero, Revision Denison 1.3
total freeboard requirement of 3.2 feet. This calculation is illustrated on Attachment 4.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The freeboard for Cell 4,A. would therefore be 5595.3 amsl (top of
liner 5598.5 -3.2 feet). Figure 7, Hydraulic Profile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4A were required to store the entire PMP event for Cell 2, Cell3 and Cell 44, the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboardto 4.77 feet.
The required freeboard for Cell 4A. will be recalculated annually along with the re-
calculation of the Cell 3 freeboard requirement. A calculation of the current freeboard
calculation for both Cells is attached to this Plan.
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Cell4A BAT Monito.i.rgf.utions and Maintenance Plan 09/08 Revision Denison 1.3
Attachments
1) Figure 1, Initial Filling Plan, GeoSyntec Consultants
2) Figure 2, Initial Filling Plan, Details and Sections, GeoSyntec Consultants
3) Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
4) Figure 4, Interim Filling Plan, GeoSyntec Consultants
5) Figure 5, Leak Detection System Sump, GeoSyntec Consultants
6) Figure 6, Leak Detection Sump Operating Elevations
1) Figure 7, Hydraulic Profile Schematic
S) Cell 3 and Cell 4,A. Freeboard Calculation
9) Table 1, Calculated Action leakage Rates for Various Head Conditions,
Cell4A., White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
10) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan,3107 Revision: DUSA-2, 32 pages, or
currently approved version of the DMT
Page 13
erro, Revision Denison 1.2
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell4,{ was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007. The construction
authorization provided that Cell4,A. shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370004 ("GWDP") and full fill the requirements of Parts
I.D.6, LE.8, and LF.8 of the GWDP.
Cell Desien
Tailings Cell 4A consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
lV. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90o/o. Floor of
Cell 44 has an average slope of loh that grades from the northeast to the
southwest comers.
c) Tailings Capacity - the floor and inside slopes of Cell 4,A. encompass about 40
acres and have a maximum capacity of about 1.6 rnillion cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
1) Prirnary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
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Cell 4A BAT Monito.ing, Ourions and Maintenance Plan lrro, Revision Denison 1.2
2) Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4,{, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an l8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. ln tum, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeabilify bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 44, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
29,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in tum overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
1)
2)
Page 2
Cell4A BAT Monitorlrr, fu,rons and Maintenance Plan erro* Revision Denison 1.2
by a layer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cell 4A where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4,A' at the southwest comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal 18-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this l8-inch pipe and used to
remove tailings wastewaters for purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) lO-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 4A,
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed near the westem
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 4A. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and 3, will be managed and
contained in Cell 4A., including the Probable Maximum Precipitation and
flood event.
Cell Operation
Solution Discharee
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 4A through 6 inch or 8 inch diameter HDPE pipelines. The initial
solution discharge will be in the southwest corner of the Cell. The discharge pipe
will be routed down the Splash Pad provided in the corner of the Cell to protect
the pipeline running from the solution reclaim barge. The solution will be
discharged in the bottom of the Cell, away from any sand bags or other
installation on the top of the FML. Building the solution pool from the low end of
s)
Page 3
-r-
Cell4A BAT Monito.lrrg, |atlons and Maintenance Plan lrro, Revision Denison 1.2
the Cell will allow the solution pool to gradually rise around the slimes drain
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution flowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 44, utilizing the Splash Pads
described above. The subsequent discharge of process solutions will be near the
floor of the pond, through a discharge header designed to discharge through
multiple points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
feet of solution. As the cell begin to fill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharge
Once Cell 4,{ is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell4,{, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1. Figure 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Figure 2. Because of the depth of
Cell 4,{, each of the discharge points will be utilized for an extended period of
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved further to the interior of the cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporatiori rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to fuither protect the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
Page 4
Cell 44. BAT Monito.,ng, futions and Maintenance Plan erro, Revision Denison 1.2
Reclaim Water System
A purnp barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3 illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
lnterim Solids Discharge
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4,{. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and OA/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailinqs Cell4A
DUSA will operate and maintain Tailings Cell4,{ so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.19 of the GWDP. These performance
standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment - the
leak detection system pumping and monitoring equipment, includes a
subrnersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondary flexible
menbrane.lA second leak detection pump with pressure transducer, flow
meter, agilmanufacturer recommended spare parts for the pump controller
and vlter level data collector is maintained in the Mill warehouse to
9n{ure that the pump and controller can bg replaced and operational within
'24 hours of detection of a failure of thg__pumrogj5lem. The root cause
Page 5
Cell4A BAT Monitoring, Qtions and Maintenance Plan /08 Revision Denison 1.2
of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occulTence.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3/07 Revision: Denison-3, or the currently
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in
the lower flexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table 1 to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
3-foot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4A.. Said measurements shall be
made to the nearest 0.1 foot.
Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell4,{ slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitorins
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
2)
3)
4)
s)
Page 6
Cell4A BAT Monitorlng,futions and Maintenance Plan enro, Revision Denison 1.2
Measurements in Cell 4A are to be taken by survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey
lnstrument") accurate to 0.01 feet, such as a Sokkai No. 821, or
equivalent, together with a survey rod (the "Survey Rod") having a visible
scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 4,A. are known
points established by Registered Land Surveyor. For Cell 4A, the
Reference Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4,A.. The elevation at the top of this piece of rebar (the
Reference Point Elevation for Cell4A is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The Surveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 44,
this is typically on the road between Cell 3 and Cell4A, approximately 100
feet east of the Cell4A Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell4A
Reference Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Reference Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell4A-
The designated location for Cell4,A. is in the northeast corner of the Cell
where the side slope allows for safe access to the solution surface.
The approximate coordinate locations for the measuring points for Cell 4A
is 2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant will hold the Survey Rod vertically with one end of the
Survey Rod just touching the pond surface. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surface
Page 7
Cell4A BAT Monito.lrrg, Otions and Maintenance Plan /08 Revision Denison 1.2
Reading"), which represents the number of feet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surface in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
Leak Detection System
The Leak detection system is monitored on a continuous basis by use of a
pressure transducer that feeds water level information to an electronic data
collector. The water levels are measured every hour and the information
is stored for later retrieval. The water levels are measured to the nearest
thE leak detection svstem sumD exceed a 1-
point in the lower flexible memb@f. To determiuq lthg,Llaximum--
Allowable Daily LDS Flow Rates in the Cell 4
total volume of all fluids oumoed fro
data collector. and will be
used to an average volume pu dav. Under
crrcumstances the dar volume exceed 24-l60
ga ffilm daily L volume w
agamst solution leRels detailed on the ble 1,
ine the maximum daily alloy4blg volume for varyin
. -Eny abnormal or out of compliance water
levels must be immediately reported to Mill management. The data
collector is also equipped with an audible alarm that sounds if the water
level in the leak detection sump exceeds the allowable level (5556.14 feet
amsl). The current water level is displayed at all times on the data
collector and available for recording on the daily inspection form. The
leak detection system is also equipped with a leak detection pump, EPS
Model # 25305-3 stainless steel, or equal. The pump is capable of
pumping in excess of 25 gallons per minute at a total dynamic head of 50
feet. The pump has a 1.5 inch diameter discharge, and operates on 460
is stored for later retrieval. The water levels are measured to the nearest .(
0.10 inch. The data collector is currently programmed to store 7 days of | / uS
water level information. The number of days of stored data caq.b" f Uilf
increased beyond 7 days if needed. The water level data is doyrnlofil-ed to lfi lt
a laptop computer on a weekly basis and, incorOoray).6-the Milfs U,
,pfenvironmental monitoring data uur", lrl"i"io'"tffilrt for weekly -)l-'
inspection reports of the tailings cell leak detecld systems. Witbin "' '- ,r d,
hours after collection of the weeklv water leve/data- the infoffin-ruill . o . V- ^
^, ,b tJn-cl
be evaluated to ensure that the water t.""1 i, tne tea9af*tl lY: Jr/not eic J\ W*
Page 8
{
O}P. ; T
u'7{""
Cell 4,A BAT Monito.ing, fu,ions and Maintenance Plan erro, Revision Denison 1.2
volt 3 phase power. The pump is equipped with a pressure sensing
transducer to start the pump once the level of solution in the leak detection
sump is approximately 2.25 feet (elevation 5555.89) above the lowest
level of the leak detection sump (9 inches above the lowest point on the
lower flexible membrane liner, to ensure the allowable 1.0 foot (5556.14
feet amsl) above the lowest point on the lower flexible membrane liner is
not exceeded). The attached Figure 6, Leak Detection Sump Operating
Elevations, illustrates the relationship between the sump elevation, the
lowest point on the lower flexible membrane liner and the pump-on
solution elevation for the leak detection pump. The pump also has manual
start and stop controls. The pump will operate until the solution is drawn
down to the lowest level possible, expected to be approximately 4 inches
above the lowest level of the sump (approximate elevation 5554.0). The
pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
is recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
horizontal, perforated section of the PVC collection pipe. The distance
from the top flange face, at the collection pipe invert, to the centerline of
the 22.5 degree elbow is 133.4 feet, and the vertical height is
approximately 45 feet. The pump is installed at least 2 feet beyond the
centerline of the elbow. The bottom of the pump will be installed in the
leak detection sump at least 135.4 feet or more from the top of the flange
invert. A pressure transducer installed with the pump continuously
measures the solution head and is programmed to start and stop the pump
within the ranges specified above. The attached Figure 5 illustrates the
general configuration of the pump installation.
[-A second leak detection pump with pressure transducer, flow meter, and
lmanufacrurer recommended spare parts for the pump controller and water
I level data collector will be maintained in the Mill warehouse to ensure that
Ithe purnp and controller can be replaced and operational within 24 hours
lof detection of a failure of the pumping system. The root cause of the
f equipment failure will be documented in a report to Mill management with
| .e.oro-.rdations for prevention of a re-occuffence.t-
Slimes Drain SLstem
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe and a near as possible to
the bottom of the slimes drain sump. The bottom of the slimes drain sump
is 38 feet below a water level measuring point at the centerline of the
slimes drain access pipe, near the ground surface level. The pump
Page 9
Cell4A BAT Monito.irg,Q,ions and Maintenance Plan Oro, Revision Denison 1.2
discharge will be equipped with a 2 inch flow meter, EIH Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The flow rate and total gallons will be recorded by
the lnspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4,A. slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. All head
measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional process solutions will be discharged to Cell 4A, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Page 10
Cell4A BAT Monitorl.,g,Qutions and Maintenance Plan lrro, Revision Denison t.2
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-I, Cell 2,Cell3 and Cell4A
are regulated by condition 10.3 of the White Mesa Mill I le.(2) Materials License.
Condition 10.3 states that "Freeboard limits for Cells 1-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13,1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell3 shall be recalculated annually in accordance with the procedures set in the
October 13, 1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local 6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
10 inches.
Based on the PMP storm event, the freeboard requirement for Cell I is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3 or 4A.
CellZhas no freeboard limit because the Cell is 99% fullof tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume from the PMP event over the Cell2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing 24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 44 design includes a concrete spillway between Cell 3 and Cell 4,A. with the
invert elevation 4 feet below the top of the Cell 3 dike, at an elevation of 5604.5 feet
amsl. Once Cell 4A is placed in operation, the cell would be available for emergency
overflows from Cell 3, but as long as the freeboard limit in Cell3 is maintained at 5601.6
it is extremely unlikely that Cell 4A would see any overflow water from Cell 3 unless the
full PMP event were to occur. Should Cell 3 receive the full PMP volume of 123.4 acre
feet of water, approximately 62 acre feet of that volume would flow through the spillway
into Cell4A.
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage areaof 3.25 acres, times the PMP of 10 inches). This
would result in a total flood volume of 98 acre-feet, including the 62 acre-feet of solution
from Cell 3. The freeboard depth required for Cell 4,A. from the PMP event would be
2.44 feet, plus a wave run-up depth of 0.77 feet (from the 1990 Drainage Report), for a
total freeboard requirement of 3.2 feet. This calculation is illustrated on Attachment 4.
Page I I
Cell4A BAT Monitorlng, Ou,ions and Maintenance Plan ebro, Revision Denison 1.2
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The freeboard for Cell 4A would therefore be 5595.3 amsl (top of
liner 5598.5 -3.2 feet). Figure 7, Hydraulic Profile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4A were required to store the entire PMP event for Cell 2, Cell3 and Cell 44, the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboard to 4.77 feet.
The required freeboard for Cell 4,A' will be recalculated annually along with the re-
calculation of the Cell 3 freeboard requirement. A calculation of the current freeboard
calculation for both Cells is attached to this Plan.
Page 12
Cell4A BAT Monitoring,lutions and Maintenance Plan erro, Revision Denison 1.2
Attachments
1) Figure 1, Initial Filling Plan, GeoSyntec Consultants
2) Figure 2,Initial Filling Plan, Details and Sections, GeoSyntec Consultants
3) Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
4) Figure 4, Interim Filling Plan, GeoSyntec Consultants
5) Figure 5, Leak Detection System Sump, GeoSyntec Consultants
6) Figure 6, Leak Detection Sump Operating Elevations
7) Figure 7, Hydraulic Profile Schematic
8) Cell 3 and Cell4A. Freeboard Calculation
9) Table 1, Calculated Action leakage Rates for Various Head Conditions,
Cell4,{, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
10) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan,3107 Revision: DUSA-2, 32 pages, or
currently approved version of the DMT
Page 13
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Maximum Solution Elevation - 5556.14 feet amsl
Pump-on level
5555.89 feel amsl
Lowest Level on Sacondary Liner - 5555.14 feet amsl
Leak Detection Sump
Elevation - 5553.64 feet amsl
Denison Mines (USA) Corp.
Project white Mesa Mill
Figure 6
Leak Detection Sump
Operating Levels
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Table I
Calculated Action Leakage Rates
for Various Head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
GeoSyntec Consultants
Head Above Liner
Svstom (feetl
Calculated Action Leakage
Rate (oallons/acre/davl
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Page I of I
Dave Rupp - Re: Pump Specifications
From:
To:
Date:
Subject:
CC:
Attachments:
Harold Roberts <HRoberts @denisonmines.com>
Dave Rupp <[e-mail]>
81612008 4:31 PM
Re: Pump Specifications
D ane Finerfrock <dfinerfroc k @ utah. gov>, Ron Hochstein
<RHochstein @ deni sonmines.com>
20080806162803.pdf
See the attached pump specifications as per our conversation.The pump model is 25505-3.
Please give me your comments at your earliest opportunity.
Harold Roberts
Executive Vice President, US Operations
t: [phone] | f: [phone]
1050 17th Street, Suite 950, Denver, CO
80265
DENISON MINES (USA) CORP
ww-s/. deni senmi nes, q er_n
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you
are not the intended recipient(s) please delete this message and notify the sender. You may not use,
distribute print or copy this message if you are not the intended recipient(s).
file:l/C:\Documents and Settings\Drupp\Local Settings\TempU(Pgrpwise\4899DIF5EQDO... 81712008
Landnll bqulpment,
Operation
Service
Kemedlatlon bq ulpment
a
, Leachate Pumps and Sump Drar Landtrll Uontroller, ... Page I of'lners,
o
Com ma nder Pump Control Centers
o Custom built panels based on customer specification
c Stainless steel, fiberglass, and painted steel available in
many different sizes
o We stock both steel (stainless and painted) and
fiberglass panels for quick ship if needed
o Controls are built in both simplex and duplex models
o All panels include internal circuit breakers for pump and
motor protection, alleviating the need to stock
expensive fuses and safety concerns when personnel
have to pull and replace them
o Other options include:
-,ffi, r til:r i,::ii.,tt::riL:-:r::.i
'EiIi,, ,.,'.'. 't. ,..:,',:ii-
Intrinsically Safe Relays
Flow Meter Disolavs
Load Mo nitor/PhaseProtection
Alarm Beacons and Horns
Co m outer/Telemetrv
-
Auto Dialer w/ Cellular
Variable Speed Controllers
rrJ {"}]".*&A''{4r$
'r6n
3tn'
Please call us at 888-512-1110 for more information or
email
sales@environrnentalprr mpso!utions.cont
Home Page I Controls I Pumps I About Us
Copyright O 2006 ENVIRONMENTAL PUMP SOLUTIONS. All Rights Reserved.
http : //www. environmentalpumpsolutions. com/wstjage2.html 816t2008
LanOIlll rqulplnenl, t(emedratlon l,qulpmenl Leacnate rumps ano bump ural Landllll uontroller, ... rage I oI I
Encapsulator Submersible Pumps
Pump shroud is constructed of High-Density
Polyethylene for superior strength and durability
(lifetime warranty on shroud)
Teflon fitted stainless steel pump end and stainless
steel motor withstand the most extreme conditions and
chemicals
No splice, chemical, and wear resistant motor and
sensor cables
Designs availrhle fOr both horizantal and vertical
applications from 2 to 1200 GPM
Complete with stainless steel pull cable and stainless
steel quick connect fittings
Stainless steel hardware and fittings used for assembly
Internal stainless steel screen prevents large debris
from entering shroud and makes cleaning easy
HDPE shroud provides low-coefficient of friction when
installed in an HDPE sloperiser and machine rounded
caps allow the pump to slide easily over fusion beads
without a need for wheels
Please contact us for custom specification
Copyright O 2006 ENVIRONMENTAL PUMP SOLUTIONS. All Rights Reserved
ners,
o
http ://www. environmentalpumpsolutions. com/wstjage3.htm I 816/2008
Aug,0Q 0B{1:07p Environmenta, tO
MODEL 255
n*tzs p.3
25 GPM TECHN ICAL DATA
DI MENSIONS I\ND WEIGHTS
|.lODEL NO.FIG-HP
MOT(IB
srzE
DtSGH.
st2E
DIUENSIONSIN INCHES APPBOX,
SHIP TYT.A B c D E25S093A1121f2'NPi 18-1 9,5 8-6 3.8 3.9 26
25S07-s A 314 4'1,8'NFr 20.9 10.7 10.2 3.8 3.9 28
25S10-7 A 1 1,2^ NP 23:t 1'1.8 11.9 3.8 3.S 29zns15-9 A 1 1tZ 1/2" NP 27-1 13.5 13-5 3.8 3,S 34
25520-11 A 2 4'1,2'NP'30.3 15.1 t5.2 3.8 3.9 37
25530-1s A 3 4'I1E'NP 39-1 20.6 r8.s 3.8 3.9 5925S50-26 A 5 4'.1/2. NP.512 23.6 27.6 3.8 3,S 7625S7S39DSA7112o1I2'NP 66.8 ?{.2 42,6 5.rt 4.6 1685S100-s2DS'I 10 6'1i2'M?90.9 25.4 65-5 5.4 5.4 2?,6
NOTES: All models suitabls for use in f wellq unless othervrlse noied.Weighls include pump end with motor in lbs.' Built lnto sles\€ l trt' |vlPf discharge. 6" rrin. well dla.
MATEBIALS OF CONSTBUCTION
NOTES: Sp6cifications are subjed lo chanoe v/ithoul notioe.Valox@ is a rogisterect trademark of Gene6l Bectrlc Co.y.:trrg is a registered trademark of Hcechast Calanese GorporationByton@ is a rBgistor€d trademark ot phllllps 66.
'Slalnless Steel optrofl avaltable." lf using.4' non-stsodard motofs, rerer ro 32gl420t4g1stalnress sreer for coupring.A coupling key 16 not requlred.
FiS.B
Fig. A
COMPONENT SPLINED SHAFI {3-26 Stos-l CYLINDRICAL SHAFT (39 Stqs-)DEEP SET (52 StoslCheck Valve Housino 304 Slainless Sleel 304 Stainless Steel 304 Slainless SteelCheek Valve 304 Stainless Steel 304 Staintess Steet 304 Slainless SteelDiffuser Chamber SOrl Stainle*s Steel 304 $tainless Stee{304 Slainless Steellmpeller3O4 Stainless Sleel 3U4 Stainless Steel 304 Stainloss SteelSuciion I ntercon nector 304 Slainless Steet 304 Slainless Steel 3O4 Stainless Steelnlet Screen 304 Stainless Steel 304 Stainless Stenl 304 Stainless SteelPurno $hafl 304 Stainless Steel 431 Stainless Steel 431 Stainless SteelStraps304 Stainless Steel 304 Slainless Steet 304 Stainless Steellabls Guard 304 Stainless Steet 304 Stalnless Steel 304 Stainless Steelrnming lnducer 304 Stainless Steel 304 Stainless Steel 304 Slainless SteelCoupJing3181431 Stainless Steel 316143'l Stainless Steel 329141 6 Siainless Steel"Check Valve Seat NBF/304 Staintess Steel NBR/316 Stalnless Steet NBR/316 Stainless Sieelfop Bearing NBR NBR/3 16 Stainless Steel NBFU316 Stainless SteelImpeller Seal Rino NBR/PBT Malox@t NBR/PPS {Rvton@)NBR/PPS (Rvton@)lntemediate Bearinos NBR 304 Stainless Steet NBR/316 Stainless SleelShaftWasherNot Requlred LCP ruedra@)LCP (Vectra@l
Solit Cone Not Bequired 304 Stainless Steel 304 Stainless SteelSplit Gone Nut Not Required 316 Stainlnss Stcel 304 Staintass SleelSleeveNot Required Not Required 316 Stalnless SteelSleeve Flange Not Reouireo Not Reouired 304 Stainless Steel-oupung lley I Not Required Not Required 3OZ3A4 Stainless Sleel"
Aug 06 08 01:07p
PERFORMANCE CURVES 25 GPM
nlzzs p,2
MODEL 255
Environmenta, OO
FLOW HANGE: 1B -32 GPM
1600
1 500
1400
1 300
1200
1 100
1 000
s00
800
7AO
600
500
400
300
200
100
o
OUTLET SIZE: I1lz " NPT
15
CAPACIW (GPM)
NOMINAL DIA..4''
F
I.JJ
Ll"'
LL
o
ur
=
tl*ffi,
SP ECIFICANONS SUBJ ECT TO CHANG E WITHOUT NOTI CE.4,, MOTOR STANDAFID, .5.5 HPl3450 BP[T.6' MOTOR STANDAFID,T.S .1OHPl3i15O RPM.
2A
Performance conbrms to ISO 9906. 19Sg tE) Annex A
Mioimum submergance ls 2 fe€l.
09/08 Revisionfon,l.l
Cell4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007. The construction
authorization provided that Cell 4,A. shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370004 ("GWDP") and full fill the requirements of Parts
I.D.6,1.E.8, and I.F.S of the GWDP.
Cell Design
Tailings Cell 44. consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a l5-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H tolV. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 2l l-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90%. Floor of
Cell 4A has an average slope of l%o that grades from the northeast to the
southwest corners.
c) Tailings Capacity - the floor and inside slopes of Cell 4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
l) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
Page I
6fiut11 /r$' s,zoo&
vdl
I c"tt +e BAT Monitoring, op.rutioJ Maintenance Plan
2) Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an l8-inch inside diameter (lD) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of l0 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose ofboth the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top ofall four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 44, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2001
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
l) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 5O-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In tum, the gravel is overlain
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by a layer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cell 4.{ where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an l8-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal l8-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this lS-inch pipe and used to
remove tailings wastewaters for purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) l0-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 44,
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed near the western
comer of the north dike to allow emergency runoff fiom Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 4A. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and3, will be managed and
contained in Cell 4A, including the Probable Maximum Precipitation and
flood event.
Cell Operation
Solution Discharse
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 44 through 6 inch or 8 inch diameter HDPE pipelines. The initial
solution discharge will be in the southwest comer of the Cell. The discharge pipe
will be routed down the Splash Pad provided in the corner of the Cell to protect
the pipeline running from the solution reclaim barge. The solution will be
discharged in the bottom of the Cell, away from any sand bags or other
installation on the top of the FML. Building the solution pool from the low end of
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I cett +n BAT Monitorinc, on"rutiof Maintenance Plan ,09/08 Revisionfon l. t,i Deleted:
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the Cell will allow the solution pool to gradually rise around the slimes drain
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution flowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 4A, utilizing the Splash Pads
described above. The subsequent discharge ofprocess solutions will be near the
floor of the pond, through a discharge header designed to discharge through
multiple points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
feet of solution. As the cell begin to fil1 with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharee
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 44, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figtue 1. Figure 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Figure 2. Because of the depth of
Cell 4A, each of the discharge points will be utilized for an extended period of
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved ftrther to the interior of the cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporation rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to further protect the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned'on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
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Reclaim Water System
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figtue 3 illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharee
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4A. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and OA"/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailinqs Cell 4A
DUSA will operate and maintain Tailings Cell 4A so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.l9 of the GWDP. These performance
standards shall include:
l)Leak Detection System Pumping and Monitoring Equipment - the leak
detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondarv flexible
menbrane.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White Mesa Mill Tailings
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Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3107 Revision: Denison-3, or the currently
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in
the lower flexible membrane liner.
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallonsiday. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table I to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
4) 3-foot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell 4A.. Said measurements shall be
made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell 4A slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitorins
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements in Cell 4A are to be taken by survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey
Instrument") accurate to 0.01 feet, such as a Sokkai No. 821, or
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I c"tt ae BAT Monitoring, op.ru,iof Maintenance Plan .Oe,OS R.ririorfron :;
equivalent, together with a survey rod (the "Survey Rod") having a visible
scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 4,A. are known
points established by Registered Land Surveyor. For Cell 4,A', the
Reference Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4A. The elevation at the top of this piece of rebar (the
Reference Point Elevation for Cell 4A is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The Stuveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 4,A',
this is typically on the road between Cell 3 and Cell4A, approximately 100
feet east of the Cell 4,{ Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell 4.A
Reference Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Reference Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell 4,{.
The designated location for Cell 4,A, is in the northeast comer of the Cell
where the side slope allows for safe access to the solution surface.
The approximate coordinate locations for the measuring points for Cell 4A
is2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant will hold the Survey Rod vertically with one end of the
Survey Rod just touching the pond surface. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surface
Reading"), which represents the number of feet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surface in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
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Leak Detection System
i Deletedr !l
The Leak detection system is monitored on a continuous basis by use of a
pressure transducer that feeds water level information to an electronic data
collector. The water levels are measured every i_1o_Lu; and the information
is stored for later retrieval. The water levels are measured to the nearest
0.10 inch. The data collector is currently programmed to store 7 days of
water level information. The number of days of stored data can be
increased beyond 7 days if needed. The water level data is downloaded to
a laptop computer on a weekly basis and incorporated into the Mill's
environmental monitoring data base, and into the files for weekly
inspection reports of the tailings cell leak detection systems. _\11it,!:1u 21'l
htur"s iilipr _c{rl_lgtiiq!_9,[_!E_weeki-r'1v_;1_tg 1_e'!:sl_d_c{Q" ll]i: it "tqUiriitirru_rr:ill
not !_xgccd llrc allowa
r"e'nixilrr$ pcriod. Any abnorrnol or orit oi'conrpiiauce u,irter'
intrlr:r-liatcly lrportecl lo i\'iill nrauagenrent. lhc'--dl!!1 r:ollectol' is aiso
*qjriuCIlti \\,itl] erl at
iictci:tiot sutrp cxceecls the ailor.l,able ielel {555(r. l4 leet anrsl}. l.hc
cLn'rent r!'aicr level is tlispla-vticl "ri all tint*s otr the datii colleclol and
1$rl&ls-lL:l recoirlin,g on The leak detection
system is also equipped with a leak detection pump, EPS Model # 25S05-
3 stainless steel, or equal. The pump is capable of pumping in excess of
25 gallons per minute at a total dynamic head of 50 feet. The pump has a
1.5 inch diameter discharge, and operates on 460 volt 3 phase power. The
pump is equipped with a pressure sensing transducer to start the pump
once the level of solution in the leak detection sump is approximately 2.25
feet (elevation 5555.89) above the lowest level of the leak detection sump
(9 inches above the lowest point on the lower flexible membrane liner, to
ensure the allowable 1.0 foot (5556.14 feet amsl) above the lowest point
on the lower flexible membrane liner is not exceeded). The attached
Figure 6, Leak Detection Sump Operating Elevations, illustrates the
relationship between the sump elevation, the lowest point on the lower
flexible membrane liner and the pump-on solution elevation for the leak
detection pump. The pump also has manual start and stop controls. The
pump will operate until the solution is drawn down to the lowest level
possible, expected to be approximately 4 inches above the lowest level of
the sump (approximate elevation 5554.0). The pump discharge is
equipped with a 1.5 inch flow meter, EPS Paddle Wheel Flowsensor, or
equal, that reads the pump discharge in gallons per minute, and records
total gailons pumped. The flow rate and total gallons is recorded by the
Inspector on the weekly inspection form. The leak detection pump is
installed in the horizontal section of the l8 inch, horizontal, perforated
section of the PVC collection pipe. The distance from the top flange face,
Page 8
1
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Cell 44. BAT Monitorins, on.rrti$ Maintenance Plan ,09/08 Revisiolison !, !i Deleted:
i Deleted: ot
at the collection pipe invert, to the centerline of the 22.5 degree elbow is
133.4 feet, and the vertical height is approximately 45 feet. The pump is
installed at least 2 feet beyond the centerline ofthe elbow
llrc pr.rrrif u'il1-b" lii1.r]lg.!-tr,,i,lre' leli' dr:tcutiol sut11pl4__LqA$_1-::lliSl-rl
lrorc iioll thc top ot_tlre ll.,Ugl_!_Ug11-A pressure transducer installed
with the pump continuor-rsly measures the solution head and is
programmed to start and stop the pump within the ranges specified above.
The attached Figure 5 illustrates the general configuration of the pump
installation.
A second leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller can be replaced and operational within 24 hours
of detection of a failure of the pumping system. The root cause of the
equipment failure will be documented in a report to Mill management with
recommendations for prevention of a re-occurrence.
Slimes Drain Slzstem
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside ofthe slimes drain access riser pipe and a near as possible to
the bottom of the slimes drain sump. The bottom of the slimes drain sump
is 38 feet below a water level measuring point at the centerline of the
slimes drain access pipe, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter, EiH Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The flow rate and total gallons will be recorded by
the Inspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4,A' slimes drain pump wrll be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within l5 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. Al1 head
measuements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
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I c"tt +n BAT Monitoring, operatiofMaintenance Plan ,t)9/08 RevrsionOr*: Deleted:
i Deleted: 0l i
in water level for three (3) successive readings taken no less than one (l)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional process solutions will be discharged to Cell 4A, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
Tailinss Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notifo Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells l-I, Cell2, Cell 3 and Cell 4.{
are regulated by condition 10.3 of the White Mesa Mill l1e.(2) Materials License.
Condition 10.3 states that "Freeboard limits for Cells l-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13,1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell 3 shall be recalculated annually in accordance with the procedures set in the
October 13,1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local 6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
l0 inches.
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Based on the PMP storm event, the freeboard requirement for Cell I is a maxtmum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell I freeboard
limit is not affected by operations or conditions in Cells 2,3 or 4A.
Cell 2 has no freeboard limit because the Cell is99% full of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing24-aue
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 4,A. design includes a concrete spillway between Cell 3 and Cell 4A, with the
invert elevation 4 feet below the top ofthe Cell 3 dike, at an elevation of5604.5 feet
amsl. Once Cell 4A is placed in operation, the cell would be available for emergency
overflows from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 4A would see any overflow water from Cell 3 unless the
full PMP event were to occlrr. Should Cell 3 receive the full PMP volume of 123.4 acle
feet of water, approximately 62 acre feet of that volume would flow through the spillway
into Cell4A.
The flood volume from the PMP event over the Cell 4A are4 is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of l0 inches). This
would result in a total flood volume of 98 acre-feet, including the 62 acre-feet of solution
from Cell 3. The freeboard depth required for Cell 4.A, from the PMP event would be
2.44 feet, plus a wave run-up depth of 0.77 feet (from the 1990 Drainage Report), for a
total freeboard requirement of 3.2 feet. This calculation is illustrated on Attachment 4.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The freeboard for Cell 4A would therefore be 5595.3 amsl (top of
liner 5598.5 - 3.2 feet). Figure 7, Hydraulic Profile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4A were required to store the entire PMP event for Cell 2, Cell 3 and Cell 4,A., the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboard to 4.ll feet.
The required freeboard for Cell 4A will be recalculated annually along with the re-
calculation ofthe Cell 3 freeboard requirement. A calculation ofthe current freeboard
calculation for both Cells is attached to this Plan.
Attachments
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I cett ae BAT Monitorins, on.rutiofMaintenance Plan ,09/08 RevisionO.r*
I ) Figure l, Initial Filling Plan, GeoSyntec Consultants
2) Figure 2, Initial Filling Plan, Details and Sections, GeoSyntec Consultants
3) Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
4) Figure 4, Interim Filling Plan, GeoSyntec Consultants
5) Figure 5, Leak Detection System Sump, GeoSyntec Consultants
6) Figtue 6,LeakDetection Sump Operating Elevations
7) Figure 7, Hydraulic Profile Schematic
8) Cell 3 and Cell 4A Freeboard Calculation
9) Table 1, Calculated Action leakage Rates for Various Head Conditions,
Cell 4A, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
10) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan,3107 Revision: DUSA-2, 32 pages, or
currently approved version of the DMT
Page 12
Cell4A BAT Monitoring, Operations and Maintenance PIan.
Introduction
Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007 . The construction
authorization provided that Cell 4,A, shall not be in operation until atter a BAT
Monitoring, Operations and Maintenance Plan is submitted fbr Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370004 ("GWDP") and full till the requirements of Parts
I.D.6, I.E.8, and I.F.S of the GWDP.
Cell Desien
Tailings Cell 4,{ consists oi the following major elements:
Dikes - consisting ol earthen embankments of compacted soil, constructed
between 1989-1990, and composed of tbur dikes, each including a l5-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
t V. Width of these dikes varies; each has a minimum crest width of at least
15 lbet to support an access road. Base width also varies t'rom 89-t'eet on the
east dike (with no exterior embankment), to 2l l-feet at the west dike.
Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90o/o. Floor of
Cell 44. has an average slope of lo/o that grades fiom the northeast to the
southwest corners.
Tailings Capacity - the tloor and inside slopes of Cell 4A encompass about 40
acrcs and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measurcd below the required 3-foot freeboard).
Liner and Leak Detection Systems - including the tbllowing layers, in
descending order:
I ) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extencls across both
the entire cell t'loor and the inside side-slopes, and is anchored in a trench
at thc top of the dikes on all fbur sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4,A, floor
arca. In other locations, the primary FML will be in contact with the
slirnes drain collection system (discussed below).
Page I
a)
b)
c)
d)
Cell 44 BAT MonitorinS, Onc.atlof Maintenance PIan n.,f .o
2) Leak Detection System - includes a permeable HDPE geonet tabric that
extends across ihe entire area under the primary FML in Cell 4A., and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an l8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be sunounded with a gravel filter set in
the leak detection sump, having dimensions of l0 t'eet by 10 t'eet by 2 t'eet
deep. In turn, the gravel filter layer will be enclosed in an envelope ol'
geotextile tabric. The purpose ol both the gravcl and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
tbund immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A tloor, up the inside side-slopes and is
also anchored in a trcnch at the top of all four dikes.
4) Geosynthetic Clay Liner - consisting ol a manut'actured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4,{, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 507o by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and pcrfbrated collection pipes both installed immediately above the primary
FML, as follows:
l) Horizontal Strip Drain System - is installed in a herringbone pattem
across the lloor of Cell 4,A. that drain to a "backbone" ol perfbrated
collcction pipes. These strip drains are made ol a pretabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-tbot centers,
where they conduct. tluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the pertbrated slimes drain collection
pipe. A series of continuous sand bags, I'illcd with lilter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
l'illed with well graded l'ilter sand to protcct the ch'ainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drairr
collection (SDC) pipe lbund at the downgradicnt end ol. the strip drain
lines. This pipe is in turn overlain by a berm of gravcl that runs the entire
diagonal length of the cell, surrounded by a geotextile labric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
Page 2
Cell 4A BAT MonitorinS, Oneratiof Maintenance Plan
0
by a layer of non-woven geotextile to serve as an additional filter matel'ial.
This pertbrated collection pipe serves as the "backbone" to the slimes
drain system and runs tiorn the tar northeast corner downhill to the far
southwest cornel' of Celi 4A where it.ioins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an l8-inch ID Schedule 40 PVC
pipe placed down the insicle slope of Cell 4A at the southwest corner,
above the primary FML. Saicl pipe then merges with another horizontal
pipe o1 equivalent diametel and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal l8-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this 18-inch pipe and used to
remove tailings wastewaters fbr purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) 1O-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 4A,
from the top ol the dike and down the inside slope. The pads on the north side
oi the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications'
Emergency Spillway - a concrete lined spillway constructed near the westem
corner of the north dike to allow emergency runotf fiom Cell 3 into Cell 4A.
This'spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overt'low structure will be constructed at Cell 4A. All stotmwater runotf
and tailings wastewaters not retained in Cells 2 attd 3, will be managed and
contained in Cell 4A, including the Probable Maximum Precipitation and
flood event.
Cell Operation
Solution Discharge
Cell 4A will initially be used tbr storage and evaporation ol pfocess solutions
fiom the Mill operations. These process solutions will be lrom the
uranium/vanadium solvent exlraction cilcuit, or transferred from Cell I
evaporation pond or the free water surtace from Cell 3. The solution will be
pumped to Cell 4,A. through 6 inch or 8 inch dian-reter HDPE pipelines. The initial
solution discharge will be in the southwest corner of the Cell. The discharge pipe
will be routed down the Sptash Pad provided in the corner ol the Cell to protect
the pipeline running tiom the solution r-eclaim barge. The solution will be
discharged in the bottom of the Cell, away kom any sand bags or other
installation on the top of the FML. Building the solution pool from the low end o['
the Cell will allow the solution pool to gradually rise around the slimes drain
Page 3
nevi!.0
s)
Cell 4A BAT Monitorins, oneratior! Maintenance Plan nevif o
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution t'lowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 4A, utilizing the Splash Pads
described above. The subscquent discharge of process solutions will be near the
tloor of the pond, through a discharge header designed to discharge throLrgh
multiplc points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
t'eet of solution. As the cell begin to lill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharge
Once Cell 4,A is needed fbr storage for tailings solids the sluny discharge ttom
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 4A, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all ol the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fmction settling out closer to the
discharge point. The initial discharge locations are shown on Figure l. Figule 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at ol near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Ftgure 2. Because ol the depth of
Cell 4A, each of the discharge points will bc utilized fbr an extended period of
time betbre the cone of material is above the maximum level ol the solution. The
discharge location will then moved further to the interior of thc cell allowing fbr
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal cvaporation rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to turther protect the FML. The tailings
slurry will discharge directly in to the solul"ion contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equirrment Access
Access will be restricted to the interior portion of the cell due to thc potential to
damage the flexible membtane liner. Only rubber tired all terrain vehicles or tbot
trafl'ic will be allowed on the flexible membrane liner. Personnel ale also
cautioncd on the potential damage to the tlexible membrane liner through the use
and handling of hand tools and maintenance rnaterials.
Reclairn Water Systcm
Page 4
, Cell 4A BAT Monitorins, Oneratiof Maintenance Plan nevi!.0
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell tbr water balance purposes or for
re-use in the Mill process. Figure 3 illustrates the routing of the solution retum
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial tilling oi the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharge
Figure 4 illustrates the progression of the sluny discharge points around the east
side of Cell 4A,. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will elirninate any potential fbr damage to the liner systen.
Liner Maintenance and OfuOC
Any construction defects or operational damage discovered during observation of
the f'lexible membrane liner will be repaired, tested and documented accotding to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 44 Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailines Cell4A
DUSA will operate and maintain Tailings Cell 44, so as to prevent release of wastewater
[o groundwater and the environment in accordancc with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H. l9 of the GWDP. These perlormance
standards shall include:
I ) Leak Detection System Pumping and Monitoring Equipmcnt - the leak
detection system pumping and monitoring equipment, includes a
submersible pump, pump contloller, water level indicator (head
monitoring), and f'low meter with volume totalizer. The pump controller
is set to maintain the maximum lcvel in the leak detection system at no
more than I tbot above the lowest level of the secondary llexible
menbrane.
(DJIT) monitoring Plan. 3/07 Revision: Denison-3, or tht: currentlv
Page 5
2)
/
Maximum Allowable Head - the Pemrittee shall measure the lluid head
Cell 44, BAT MonitorinS, Oneratlo! Maintenance Plan ne'f 'o
approved DMT Plan. Under no circumstance shall fluid head in the leaka-ffin ffiffirp exceed a l-foot level above the lowest. point in
the lower tlexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of alt tluids pumped lrom the LDS on a weekly
basis, and use that intbrmation to calculate ;in average volume pumped
per day. Under no circumstances shall the daily LDS llow volume
exceed 24,160 gallons/day. The maximum daily LDS tlow volume will
be compared against the measured cell solution levels detailed on the
attached Table I to determine the maximum daily allowable LDS flow
volume tbr varying head conditions in the cell. .
3-fbot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-tbot Minimum ol
vertical fieeboard in Tailings Cell 4,{. Said measurements shall be
made to the nearest 0. I tbot.
Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell 4A slimes
drain system, monthly recovery head tests and f'luid level measulements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine IVlaintenance and Monitorins
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrcnces or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings matelial as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports arc
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements in Cell 4A are to be taken by survey on a wcekly basis as tbllows:
(i) The survey will be pertbrmed by the Mill's Radiation Sat'ety Otficer or
clesignee (the "Surveyor") with the assistance ol another Mill worker (the
"Assistant");
(ii) The survey will be pertbrmed using a sulvey itrstrument (the "Survey
Instrument") accurate to 0.01 leet, such as a Sokkai No. 82l, or
equivalent, together with a survey rod (the "Survey Rod") having a visible
scalc in 0.0 I tbot increments;
Page 6
?\
4)
s)
. Cell 4A BAT Monitolins, oneratiof Maintenance Plan nwrl.o
(iii)Thc ret-erence Points (the "Ret'crence Points") fbr Cells 4A are known
points established by Registered Land Surveyor. For Cell 4A, the
Rel'erence Point is a piece of metal rebar located on the dike betwecn Cell
3 and Cell 4A. The elevation at the top of this piece of rebar (the
Ret'er-ence Point Elevation for Cell 44' is at 5,607.83 tbet above mean sea
level ("amsl");
(iv) The Surveyor will set up the Survey Instrurnent in a location where both
the appticable Ret'elence Point and pond surlace are visible. For Cell 44,
this is typically on the road between Cell 3 and Cell4A, approximately 100
f,eet east ol the Cell 44 Retbrence Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrurnent is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell 4,A.
Ref'erence Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will tbcus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Ret'erence Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Ref-erence Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell 4A.
The designated location lor Cell 4A is in the northeast corler of the Ccll
where the side slope allows for saf'e access to the solution surface.
The approximate coordinate locations for the measuring points tbr Cell 4A
is2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solt-ttion elevations in the Cell.
The Assistant will hold the Survey Rod vertically with one end o[ the
Survey Rod iust touching the pond surtace. The Assisrant will ensure that
the Survey Rod is vertical by gently rocking the rod back and tbrth until
the Surveyor has established a level reading;
(viii) The Surveyor will tbcus the cross hairs olthe Survcy Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surtace
Reading"), which represents the number of f'eet the Survey Instrument is
rcading above the pond surtace level.
The Surveyor will calculate the elevation of the pond surface in I'eet amsl
by adding the Ref'erence Point Reading for the Cell and subtracting the
Pond Surfhce Reading lor the Ccll, and will record the number accuratc to
0.01 tcet.
Leak Detection Svstem
Page 7
Ccll44 BAT MonitorinS, Oneratio! Maintenance PIan n."f.o
/tuffi:ir"*
'\"hu t*4k-{p11:s-uaLfyt!prul$".ugn-!pLq-i!_"q.1_+ cpn-ttttr.*tts-]-rtrir--h::urtt-d-l-
pt-qgiUr-r lrqn;_rluqp1 1fut_I9c-d,s_j{Atg_lUyt:j"1rt-i1g"[dtigf*to*iyl glffUqglg r"lara --->
r.rrllc\:tor. - 'l'hr;
--wrttcr lcvcls arc rne usur,-tl cvcrl lrLtrtUle u,rr.t
-riri /
irrlirg1;;tit1t i* U,ftg!Lti,. l,,t"f-.i] i;,
thC_1U_AlrSt 0,1-0*irc[*.Jbri:!rtta colloctor is cqrg:;{ly*g111g1g1q3rr.i]-ltr",:CIrS
Liayr_ol*rv.Ugil93gl inlbrLlation. TlU t_Uuftsl-q].d{y$-si_s1s$ddagl -qat
-l1qllgrcirscd-_"tSlitnd_7_d.ry-U it, tr_c"qdS1t'j'hg*UatS1lcvcl tiata is downleadcd
lo a ltltop co!:nputcl ol gL wccku basis-ilnd" inc.orporatcd inro lhg_Ltlli
e n v*i r o r_Uren ta I nttxr i tori n E d ata . b$g. *Utt_tl- -tl tq-, lh-a__ [_lS.L&[* _W_aQU ]
lppqqli-on rc.pqrtt-gLjhcl.i!.iljtl$ts ccll lcak dctcclion s-ysrcms. The leak
detection system is aiso equipped with a leak detection pump, EPS Model
# 25505-3 stainless steel, or equal. The pump is capable of puntping in
cxcess of 25 gallons per minute at a total dynamic head of 50 t'eet. The
pump has a L5 inch diameter discharge, ancl operates on 460 volt 3 phase
power. The pump is equipped with a pressure sensing transducer to stall
the pump once the lcvel of solution in the leak detection sump is
approximately 2.25 feet (elevation 5555.89) above the lowcst level ol'rhe
leak detection sump (9 inches above the lowest point on the lower tlexible
membrane liner, to ensure the allowable 1.0 tbot (5556,I-4 feet anrsl)
above the lowest point on the lower flexible membrane liner is not
exceeded). Tbo attacbgd FiguiB 6. L*ak Detection Sump Opelating
Hgvatiolll-illtr$lri[p$-lhs rclationship bc trnr, -cIcva1igrr,j1q
l-Awgg1*na!-0t (m lhe_,ttwg1_-Uexlb]q__ngg1b.1utC--.ljngl-"_11n.l- tlp__il-r_l4t12:.!)[
s_rllution_clcvatlgrllbillrc_lg4k_d9-t9t"U!n I2U!1;1O-.fhe pump also has manual
start and stop controls. The pump will operate until ti€ solution is drawn
down to the lowest level possible, cxpected tt> be q{pr<>ximately 4 inches
above the lowest level ol the sump (approxinpty'elevation 5554.0). The
pump discharge is equipped with a 1.5 incffllow merer, EPS Paddle
Wheel Flowsensor, or rgqual, that rcads the pump discharge in gallons per
minute, and records total gallons pumped. Thc tlow rate and total qallons
is reconled by the lnspector on the wcckly insrrcction flrrrnr. Thc lcak-dffiii.6-n-F'r'mp is installed in tht: horizontal scction ol the l8 inch,
horizontal, perforated section of the PVC collection pipe. The distance
frorn the top flange face.g!-iLq*gllggli-q11{l0g-i&y,!ltt. tr> rhe cenrerlinc of
the 22.5 degree elbow is 133.4 feet, and rhe verrical height is
approximately 41, feet.
centerline of the elbow. A prcssure transducer installcd with the pump
---
ctmtin-fil@fiffitr-res the solution head ancl is pro_erammecl to start and
stop thc pump within the ranges specified above. The attached Figure 5
illustrates the general configuration ol the pump installation.
A seconcl leak detectittn pump._yy!-Lh*pgilgylc_tfApgdlqc!'" flow meter. and
Page 8
oelJed: :l'hc I xnk dcrccrion sysrcm
rvill be nxrnitored on a wcekly basis for
the presence of tailings solution lrtween
(he HDPf, liners. 'l'he presence of
solution will be delernrincd by use of I
"blow pipe" to delect the prc$ence of
solution in the bo[onr of the leak
dclcction sump. The blow pipe is
constructed of 7, inch diarneter schedule
-10 PVC pi1*. 'l'he bortorn of rhe blow
pipc cxlends to the lowest lcvel of tlre
lcak detection sunlp (elevarion 5553.6).
ilnd the top of the blow pipc extends
rpproxinutely I foot out 0f the top of the
lcak dctcction access riscr pipe (clcvrtion
5599..16). 1'he top several tber of rhe
blow pipe is marked in 1.0 inch
increments tbr measurenrent ot' the
solurion level. On a weekly basis. the
water level will br checked by the
Inspector. '[he inspector lvill starr with
lhe blow pipe exlended to rhe lowest level
of lhe leak detcction sunrp and begin
tJlowing into lhe pipe. while slorvly
pulling the pipe up the leak derection
access riser. As soon as the Inslxctor
slops hearing bubbles front the access
riser, the bottom of rhe blow pipe is ar or
near the level of (he solution in the letk
detection sump. The Inspector rvill nrove
the blorv pilr slowly up and dom the
access riser, while blorving in the pipe, to
cnsure lhat the lcvcl of the solution is
accurately rneasured. Once the solution
level is accurately deterrnined, the
lnsp€ctor will record thc water level
rca<ling on the rveckly inspection tbrnr.
Formatted: Space Before: 0 pi-l
Deleted: -l hc prcssure transducer Iprovidcs water lcvel data to the purnlt I
control system which records the da{a on
an hourly basis. 'Ihis inlbrnHtion is
tlownloadetl frorn lhe pun)p control
systern and is nraintained rvirh thc weekly
inspcction rcporls.
Deleted: 2
Deletedi rnd
Ccll 44 BAT Monitorin8, Oneratif Maintcnance Plan te'fr.o
IUISJ*djUA-Udltr;qgr- will be rnaintained in the Mill warehouse to ensure that
the pump itful uo$11gllct ,can be replacecl and operational within 24 hours
ol'detcction of a lttilur:e ol' thc pumping system. The root cause ol' the
equipmeut tailure will be clocurnented in a rep<;rt to Mill nranagcrnent with
recommenclations fbr prevention of a re-occurrence.
Slimos Drairr System
(i) A pump, Tsururni Moclcl # KTZ23.7-62 stainless steel, or equal, will be
placcd inside clf thc slimes drain access riser pipe and a near as possible to
the bottom of the slimes drain sump. The bottom of the slirnes clrain sump
is 38 fbet below a water level measuring point at the centcrline ol the
slimes clrain access pipe, near thc ground surtace lcvel. The pump
discharge will be equipped with a 2 inch tlow meter, E/H Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons purnpecl. The flow rate and total gallons will be recorded by
the Inspector on the weekly inspection fbrm.
(ii) The slimes drain pump will be on ad.justable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A slimes drain pump will be checked weekly to observe that it
is operating and that the level probcs al'e sst prc4terly, which is noted on
the Weekly Tailings [nspection Fonl. [f at any timc the pump is observecl
to be not working properly, it will bc repaired or replaced within l -5 days;
(iv)Dcpth to wastewatcr in the Ccll 4A slimes drain access riser pipe shall be
monitorecl and recorcled weekly to determine maximum ancl minimum
fluid hcad befbrc ancl al'tcr a punrping cycle, respectively. All head
measurements must bc made tionr thc samc measuring point, to the
nearest 0.01 fbot. The results wilt be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimcs drain pump will be turnecl otT and the
wastewatcr in thc slimes drain access pipe will be allowed to stabilize tbr
at least 90 hours. Oncc thc wator lcvel has stabilized (basecl on no change
in water level firr three (3) successive readings takcn no less than one (l)
hour apart) thc water lcvel ol- the wastewater will be measured and
recordecl as a depth-in-pipe rncasurement on the Monthly Inspection Data
tbrm, by measuring the depth to water below the water level measuring
point on the slimes drain acccss pipc;
The slimes drain purrrp will not be opcratcd until IVIill nranagement has
determined that no additional proccss solutions will be clischargcd to Ccll 4A, and
the Cell has bcen partially covercd with the first phase of the reclanration cap.
Thc long term effbctiveness and perlbrmance oi thc slimcs drain dewatcring will
be cvaluated on the same basis as the currently operating slimes drain system for
Cell2.
Page 9
Cell 4A BAT Monitorins, Oneratio! Maintenance Plan ne'f 'o
Tailinss Emergencies
Inspectors will notify the Radiation Safety Otficer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources duling tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Sat'ety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA QA3-231-5465), and the State of Utah, Division of Dam Sat'ety (801-538-1200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells l-I, Cell2, Cell 3 and Cell 4A
are regulated by condition I0.3 of the White Mesa Mill 11e.(2) Materials License.
Condition 10.3 states that "Freeboard limits for Cells 1-1, and 3, shall tre set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13,1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell 3 shall be recalculated annually in accordance with the procedures set in the
October 13, 1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local 6-hour Probable Maximum Precipitation (PMP) event fbr calculating the
freeboard requirements tbr each of the tailings cells. The PMP lor the White Mesa site is
l0 inches.
Based on the PMP stom event, the lteeboard requirement tbr Cell I is a maximum
operating water level o1'5615.4 feet above mean sea level (amsl). The Cell I f'reeboard
limit is not af'fbcted by operations or conditions in Cells 2,3 or 4A.
Cell 2 has no freeboard limit because the Cell is 99Vo full of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume lrom the PMP event ovcr thc Cell 2 and Cell 3 pond areas, plus the
ad.iacent drainage arrcas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existin gZ4-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601 .6
lect amsl.
Page l0
Cell44 BAT Monitorins, Oneratio! Maintenance Plan n.,fr.o
The Cell 44 design includes a concrete spillway between Cell 3 and Cell 4A with the
invert elevation 4 t-eet below the top of the Cell 3 dike, at an elevation of 5604.5 t'eet
amsl. Once Cell 4A is placed in operation, the cell would be available lor emergency
overf'lows from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 44, would see any overtlow water tiom Cell 3 unless the
tull PMP event were to occur. Should Cell 3 receive the tull PMP volurne of 123.4 acre
f'eet ol'water, apploximately 62 acre feet of that volume would flow throLrgh the spillway
into Cell4A.
The tlood volume from the PMP event over the Cell 4A area is 36 acre-f'eet of water (40
acres, plus the adjacent drainage area ol 3.25 acres, timcs the PMP of l0 inches). This
would result in a total flood volume ol98 acre-teet, including the 62 acre-feet ol'solution
liom Cell 3. The freeboard depth required fbr Cell 4A iiom the PMP event would be
2.44 feet, plus a wave run-up depth oi 0.77 feet (tiom the 1990 Drainage Report), for a
total t'r'eeboard r-equirement of 3.2 teet. This calculation is illustrated on Attachment 4.
The Gloundwater Quality Discharge Permit, No. UGW370004, tbr the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The lreeboard for Cell 44 would therefore be 5595.3 amsl (top of
I tlner 5598.5 - 3.2 t-eet). Figure l, Hyclraulic Prolile Schematic, shows the relationship
between the Cells, and the lelative elevations oI the solution pools and the spillway
elevations.
If Cell 4A were required to store the entire PMP event for Cell 2, Cell3 and Cell 4A, the
required storage volume would be approximately 160 acre-t'eet ol solution. This would
increase the necessary fieeboard to 4.77 feet.
The required iieeboard tbr Cell 4A will be recalculated annually along with the re-
calculation ol the Cell 3 li'eeboard requircment. A calculation ol'the current freeboard
calculation fbr both Cells is attached to this Plan.
Attachments
r)
2)
3)
4)
5\
Figure 1, Initial Filling Plan, GeoSyntec Consultants
Figure 2, Initial Filling Plan, Details and Sections, GeoSyntec Consultants
Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
Figure 4, Interim Filling Plan, GeoSyntec Consultants
Figure 5, Leak Detection System Sump, GeoSyntec Consultants
Page I I
Cell 4A BAT MonitorinS, Oneratio! Maintenance Plan ne,!.0
6) Figure 6. Leak Detcction Sump Operating Elevations
7) Figure l, Hydraulic Profile Schematic
9) . Table l, Calculated Action leakage Rates tbr Various Head Conditions, t
Cell 4A,, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
l0) White Mesa Mill Tailings Management System and Discharge Minimization.
Technology (DMT) Monitoring Plan, 3/07 Revision: DUSA-2, 32 pages, or
currently approved version of the DMT
Page 12
Formatted3 Bullets and Numbering
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Maximum Solution Elevation - 5556.14 feet amsl
Pump-on level
5555.89 feet amsl
Lowest Level on Secondary Liner - 5555.1 4 feet amsl
Leak Detection Sump
Elevation - 5553.64 feet amsl
Denison Mines (USA) Corp.
Figure 6
Leak Detection Sump
Operating Levels
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calculated Action Leakage Rates
for Various Head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
GeoSyntec Consultants
1of 1
Head Above Liner
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Calculated Action Leakage
Rate (qallons/acre/dav)
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 6U4.U1
leak detection system geonet062006.xls 812312006
Page I of I
Dave Rupp - Re: Revised Plan Cell4A
o
o&M
From:
To:
Date:
Subject:
CC:
Attachments:
Harold Roberts <HRoberts @ denisonmines.com>
Dave Rupp <DRUPP@ utah. gov>
81712008 2:23PNI
Re: Revised O&M Plan Cell44.
Ron Hochstein <RHoc hstein @ deni sonmines.com>, Dane Finerfrock
<dfinerfrock @ utah. gov>
20080807134849.pdf
Dave:
Attached is a revision, in red line, to the Cell 4A O&M plan addressing the issues detailed in your August 1 e-mail.
I have added specific language on the operating ranges (water levels) of the pump, and additional information on
the water level measurement and recording, and a drawing ol the pump installation.
I look forward to your comments.
Harold Roberts
Executive Vice President, US Operations
t: [phone] | f: [phone]
1050 lTth Street, Suite 950, Denver, CO
80265
DENISON MINES (USA) CORP
www.denisonmines.com
This e-mail is intended for exclusive use the person(s) mentioned as'the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information. If you
are not the intended recipient(s) please delete this message and notify the sender. You may not use,
distribute print or copy this message if you are not the intended recipient(s).
file://C:\Documents and Settings\Drupp\Local Settings\Temp\XPgrpwise\489B054FEQD... 8/l 1/2008
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4A was authorized by the Utah Depanment of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007. The construction
authorization provided that Cell 4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UCW370004 ("GWDP") and full fill the requirements of Parts
I.D.6, I.8.8, and I.F.8 of the GWDP.
Cell Desisn
Tailings Cell 4A consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a lS-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
lV. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies liom 89-feet on the
east dike (with no exterior embankment), to 2l I -feet at the west dike,
b) Foundation - including subgradc soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imponed soils to a maximum dry density of 9OVo. Floor of
Cell 4A, has an average slope of l7o that grades from the northeast to the
southwest corners.
c) Tailings Capacity - the floor and inside slopes of Cell 44 encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
. tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and lrak Detection Systems - including the following layers, in
descending order:
l) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
Page I
Cell 4A BAT Monitoring, Operations and Maintenance Plan Rcvision l.O
2) Leak Detection System - includes a permeable HDPE geonet iabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest comer. Access to the leak
detection sump is via an lS-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be sunounded with a gravel filter set in
the leak detection sump, having dimensions of l0 feet by l0 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose ofboth the gravel and geotextile labric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Celt 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic CIay Liner - consisting of a manulactured geosynthetic clay
liner (GCL) composed of 0.2-inch o[ low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4,A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 504/c by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,200'7
e) Slimes Drain Collection System - including a two-pan system of sirip drains
and pertbrated collection pipes both installed immediately above the primary
FML, as follows:
l) Horizontal Strip Drain System - is installed in a herringbone pattern
across the tloor of Cell 4A that drain to a "backbone" of perlbrated
collection pipes. These strip drains are made of a prefabricared two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-rvoven geotextile filter fabric. The strip
drains are placed immediately over the primary FIvIL on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, fllled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester tabric
filled with well graded filter sand to protect the drainage system i'rom
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimcs drain
collection (SDC) pipe found at the downgradient end of thc strip drain
lines. This pipe is in tum overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In Lurn, the gravel is overlain
Page 2
Cell 4,A BAT Monitoring, Opcrations and Maintenance Plan Revision 1.0
by a layer of non-woven geotexlile to serve as an additional tllter material.
This perforated collection pipe serves as the "backbonc" to thc slimes
drain system and runs tiom the far northeast corncr downhill to the far
southwest comer of Cell 4A whcrc it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an I 8-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serues as a cushion to protect the primary FML.
A reducer connccts the horizontal l8-inch pipe with the 4-inch SDC pipc.
At some future time, a pump will be set in this l8-inch pipe and used to
remove tailings wastewaters for purposes of de-watering thc taitings ccll.
Dike Splash Pads - A minimum of cight (8) l0-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML liom abrasion
and scouring by tailings slurry. These pads will consist ofan extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell .4A,
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point S-feet beyond the toe of the slope to prorect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailcd on the As-Built Plans and Specifications.
Emergency Spilhvay - a concrete lined spillway constructed near the westem
corner of the north dike to allow emergency runotT from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reintbrccd concrete slab sct dircctly
over the primary FML in a 4-foot dcep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 4A. All stormwater runotf
and tailings wastcwaters not retained in Cells 2 and 3, will be managed and
contained in Cell 4A, including the Probable Maximum Precipitation and
tlood event.
Cell Operation
Solution Discharge
Cell 4A will initially be used tirr storage and evaporation of process solutions
t'rom the Mill operations. These process solutions will be l'rom the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
cvaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 4A through 6 inch or 8 inch diameter HDPE pipelines. The initial
solution discharge will be in the southwest comer of rhe Cell. The discharge pipc
will bc routed down the Splash Pad provided in rhe comer of the Cell to protect
the pipeline running from the solution reclaim barge. Thc solution will be
discharged in rhe bottom of the Cell, away from any sand bags or other
installation on thc top of rhe FML. Building the solution pool lrom the low cnd of
the Cell will allow rhe solution pool ro gradually rise around the slimcs drain
c)
Page 3
Cell 4,A BAT Monitoring, Operations and Maintenance Plan Revision 1.0
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution flowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 4A, utilizing the Splash Pads
described above. The subsequent discharge of process solutions wi'll be near the
floor of the pond, through a discharge header designed to discharge through
multiple points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
feet of solution. As the cell begin to fill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharge
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell thmugh 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 4A, with discharge valves and drop pipes extending down thc Splash Pads to
the solution level- C)ne or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
undcr the solution level, with the courser fraction scttling out closer to the
discharge point. The initial discharge locations are shown on Figure l. Figure 2
illustrates the gcneral location of the solution and slurry discharge pipelines and
control valvc locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, cagli4g1qg to discharge at or near the water
surface. This is illustrated in'Sc-Ci[i?A, each of the rJischarge points will be utilized tbr an extended period ot
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved turther to the interior of &e cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the ce'll will vary depcnding on the operating schedule of the Mill and the
seasonal evaporation rates. The teilings slurly will not bc allow"l !^ rlisch"'ge
@ order to flrther protect thc FMI . fneiail:lg!-
slurry will discharge directly inETE@iotrffii6i6Ei-in the Cell onto an
additional protecaive sheet, or on to previously dePosited tailings sand.
Eouioment Access
Access will be restricted to the interior portion of the cell due to ihe potential to
damage the flexible membrane liner. Only rubber tircd all terrain vehicles or t'oot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
Reclaim Water System
Page 4
Cell 4,q BAT Moniloring, Operations md Maintenance Platr Revision 1.0
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or lbr
re-use in the Mitl process. Figure 3 illustrates the routing of the solution retum
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
Interim Solids Discharge
Figure 4 illustrates the progression of the slurry discharge points around the east
side ofCell 4A. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and OA./OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2W7, by GeoSyntec Consultants.
BAT Performance Standards for Tailines Cell4A
DUSA will operate and maintain Tailings Cell 4A so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.l9 of the GWDP. These perlbrmance
standards shall include:
I ) Leak Detection System Pumping and Monitoring Equipment - the leak
detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water Ievel indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the
menbrane-
2) Maximqpfifowable Head - the Permittee shall measure the fluid head
a\x6 the lowest point on the secondary flexible membrane by the use of
rocedures and equipment specified in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3y'0? Revision: Denimn-3, or the currentl
Cell 4A BAT MonitoriBg, Op€rations and MainEnance PIan Revision 1.0
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in
the lower flexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all tluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS t'low volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table I to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
3-fmt Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freebozrd in Tailings Cell 4A. Said measurements shall be
made to the nearest 0. I foot.
5) Slimes Drain Recovery Head Monitoring - immediately after the
Permiuee initiates pumping conditions in the Tailings Cell 4A slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system urillpumping and monitoring
equipment, includes a submersible ffi, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system m a ooce per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements in Cell 4A are to be taken by survey on a weekly basis as tbllows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"AssistanC');
(ii) The survey will be performed using a survey instrument (the "Survey
Instrument") accurate to 0.01 feet, such as a Sokkai No. 82l, or
equivalent, together with a survey rod (the "Survey Rod") having a visible
scale in 0.01 foot increments;
3)
4)
Page 6
Cell 4A BAT Monitoring, Operations and Maintenancc Plan Revision 1.0
(iii)The reference Points (the "Ret'erence Points") for Cells 4A are known
points established by Rcgistered Land Surveyor. For Cell 4.4, the
Ret'erence Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4A. The elevation at the top of this piece of rebar (the
Rei'erence Point Elevation for Cell 4A is at 5,607.83 feet above mean sea
leve[ ("amsl");
(iv) The Surveyor will set up the Survey Instrument in a |ocation where both
the applicable Reference Point and pond surface are visible. For Cell 4A,
this is typically on thc road between Cell 3 and Cell4A, approximately 100
feet east of the Cell 4,A Rcf'erence Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will placc the Survey Rod vertically on the Cell 4A
Refercnce Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and tbrth until the Surveyor has established
a level reading;
(vii) The Surveyor will lbcus thc cross hairs of the Survey Instrument on the
scale on the Survey Rod. and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Rel'erence Point;
The Assistant will then move to a designated location whcre the Survey
Rod can be placed on the surtace of the main solution pond in Cell 4A.
The designated location for Cell 4.4 is in the no(heast comer of the Cell
where the side slope allows for saf'e access to the solution surface.
The approximate coordinate locations tbr the measuring points for Cell 4A
is 2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistanr will hold the Survcy Rod vertically with one end of the
Survey Rodjust touching the pond surtace. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will locus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surf'ace
Reading"), which represents the number of f'eet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surl'ace in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
Leak Detection System
Page 7
The Leak dctection system will he monitored on a
presence of tailings solution between the HDPE li
solution will use of a "blow pipe'' to
bbw pipe is
blow pipe extends to the\lowest level of the leak vatlon
5553.Q. and the top of t\e blow pipe cxtends
the top of the leak derccd\ access riser pipe {
several leet of the blow jripe is
mcasurcmcnt of thc solution levei.
I start with the
eitended to the lowest level of $re leak
into the pipe. while slowly pulling rhc
riser. As soon as the Inspector ftops he,
p the leak detecdon access
bubbles t'rom the access riser,
the bottom of the blow pipe is Bt or near Ievel of the solution in the
leak detection sump. The InspeCtor wil the blow pipe slowly up
and down the access riser, while b
level of the solution is accurately
in the pipe, to ensure that the
red. Once the solution level is
accurately deteflnined, the Inspeclor
the weekly inspection form.
record the water level reading on
Cell 4A BAT Moniloring. Operations and Maintenance Plan Revision I O
The leak detection system is equipped with a leak detection pump, EPS
Model # 25505-3 stainless steel, or equal. The pump is capable of
pumping in excess ol'2t gallons per minute at a total dynamic head of 50
t'eet. The pump has a 1.5, inch diameter discharge, and operates on 460
volt 3 phase power. The punrp is equipped with a orcssurc sensing
transduce( to start the pump once the level of solution in the leak detection
sump is approximatcly 2.25- ilut (clcvation 5555.89) above the lowesr
level of the leak detection sumo (9 inches above the lowest point on the
lower flexible membrane liner. to cnsure thc allowable 1.0 ibot above the
lowest ppint on the lower tlexible membrane liner is not exceeded)- The
oressurc transducer provides watcr level daa to the pump control s],stem
which records the data on an hourly basis. This intbmration is
downloaded from the pumo control system and is maintained with the
weeklv insoection reports. The pump also has manual start and srop
controls. The pump will operate until the solurion is drawn down to the
lowest level possible. expected to be appruxi
lowest level of the sumo (aooroxirnate elevation 555"1,0)- The pump
discharge is cquipped with a 1.5. inch llow meter, Egs*PadrUs_l{hge!
Flowsensor, slsgggL that reads the pump discharge in gallons per minute,
and records total gallons pumped. The tlow rate and rotal gallons is
recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in rhe horizontal section of the 18 inch.
horizontal. perforated section of the PVC collection oipe. The distance
/r"n. q-L'oi
E!"*"a-]
G#'.,-llri--:--.._-*r
aF#-frl"3r,1iffi-l
DeHed: 2
i9:gl:r1e.5-)
Deleted: moe thm I fux liDve rhe
k)wesl Ievel ofrb ldakddredion
i Del€ted:
i Dcletedr 2
: DeletEd: /H Molel fll i
Page 8
Cetl 4A BAT Monitoring, Operations md MainEnance Plan Revision 1.0
from the too flange face to the centerline of thc 22.5 degree elbow is 133.4
feet. and the vertical heisht is aporoximatelv 42 feet. lllF $tmp is
instelkd at lea$ 2 foe bepod the centcrfine uf dte elbow. A pressure
transducer installed with the pump continuouslv measures the solution
head and is proqrammed to start and ston the pump within the ranses
specified above. The attached Fiqur€ 5 illustmtes the qeneral
configuration of the pump installation"
A second leak detection pump and flow meter will be maintained in the
Mill warehouse to ensure that the pump can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.
Slimes Drain Svstem
(i) A pumn, Tsunrmi Mo<Jel # KT723.742 stainless steel, orequal, will be
-
placed inside of the slimes drain access riscr pipe and a near as possible to
the bottom oi the slimr:.s drain sump. The bottom of the slimes drain sump
is 38 fcet below a water level measuring point at the centerline of the
slimes drain acccss pipc, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter, E/H Model #33, or
equal, that reads the pump discharge in gallons per minute, and reconils
total gallons pumped. The flow rate and total gallons will be recorded by
the Inspector on the weekly inspection tbrm.
(ii) The slimes drain pump will be on adjustable probes &at allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4.{ slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
lo be not working properly, it will he repaired or replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
t'luid head before and after a pumping cycle, respectively. All head
measurements must be made t'rom the same measuring point, to the
nearest 0.01 foot. The results will be rocorded as deprh-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successiye readings taken no less than one (l)
hour apart) lhe water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
Page 9
Cell 4A BAT Monitoring, Operations md Maintenmce Plan Revisioo l -0
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill inanagement has
determined that no additional process solutions will be discharged to Cell 4A, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currendy operating slimes drain system tbr
Cell 2.
Tailinss Emereercies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
it', during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resourccs during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notity Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
CelI 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells l-I, Cell 2, Cell 3 and Cell 4A
are regulated by condition 10.3 of the White Mesa Mill I le.(2) Materials License.
Condition l0-3 states that "Freeboard limits for Cells 1-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October l3rl999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell 3 shall be recalculated annually in accordance with the procedures sel in the
October 13,1999 revision to the Drainage ReporL" The 1990 Drainage Repon uses
the Local 6-hour Probable Maximum Precipitation (PMP) event for calculating the
lreeboard requirements for each of the tailings cells. The PMP for the White Mesa sitc is
l0 inches.
Based on the PMP storm event, the freeboard requirement for Cell I is a maximum
operating water level of 561 5.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3 or 4A..
Page l0
Cell 4A BAT Monitoring. Operations aod Maintenaoce Plan Revision 1.0
Cell 2 has no t'rceboard limit because the Cell is 997o full of tailings solids and all
precipitation tilling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume lrom the PMP event over the Cell 2 and Cell 3 pond areas, plus the
adjacent drainage areas, is I 23.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be conrained in the existing 24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
t'eet amsl.
The Cell 4A desi_m includes a concrete spillway between Cell 3 and Cell 4A with the
invert elevation 4 l'eet below the top of the Cell 3 dike, at an elevation of 5604.5 feet
amsl. Once Cell 4A is placed in operation, the cell would be available tbr emergency
overtlows t'rom Cell 3, but as long as the freeboard Iimit in Cell 3 is rnaintained at 5601 .6
it is cxtremely unlikely that Cell 4A would see any overtlow water l'rom Cell 3 unless the
tull PMP event were to occur. Should Cell 3 receive the tull PMP volume of l?J.4 acrc
feet of water, approximately 62 acre feet of that volume rvould llow through the spillway
into Cell 4.A.
The flood volume tiom the PMP event over the Cell 4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). This
would result in a total l'lood volume of 98 acre-feet, including the 62 acre-fect of solution
lrom Cell 3. The freeboard dcpth required for Cell 4A from the PMP event would be
2.44 f'eet, plus a wave run-up depth o10.77 feet (from the 1990 Drainage Relnrt), tbr a
total freeboardrequirementof3.2feet. ThiscalculationisillustratedonAtlrchment4.
Thc Groundwater Quality Discharge Permit, No. UGW3700O4, tbr the White Mesa Mill
requires that the minimurn lteeboand be no less than 3.0 t'ect tbr any of the existing Cell
construction, bur based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The ireehoard for Cell 4A would therefore be 5595.3 amsl (top oi
liner 5598.5 - 3.2 fee0. Figure (, Hydraulic !,pofile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4A were required to store the entire PMP event for Cell 2, Cell 3 and Cell 4A, the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboard to 4.'17 feet.
The required tircboard tbr Cell 4.4, will be recalculated annually along with rhe re-
calculation of the Cell 3 freeboard requirement. A calculation of rhe cuEIEtE4lgld
calcuiation for both Cells is attrehed to this.Plan.
Attachments
l) Figure l, Initial Filling Plan, GeoSyntec Consultants
,;* f -"]
! Deleted:
Page I I
Cell 4..\ BAT Monitoring, Operations and Maintenarce Plan Revision 1.0
2) Figure 2, Initial Filling Plan, Details and Sections, GeoSyntec Consultants
3) Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
4) Figure 4, Interim Filling Plan, GeoSyntec Consulunts
5) Figure 5. kak Detection System Sump. Geosvntec Consultanls
6) Figure (, Hydr4qtig Pro-file lclemaric
7) Cell 3 and Cetl 4A Freeboard Calculation
8) Table l, Calculated Action leakage Rates for Various Head Conditions
Cell 4A, White Mesa Mill, Blanding, Utah, GeoSynlec Consultants
9) White Mesa Mill Tailings Management System and Discharge Minimization'
Technolory (DMT) Monitoring Plan, 3/07 Revision: DUSA-2, 32 pages, or
currently approved versir:n of the DMT
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Calculated Action Leakage Rates
for Various Head Conditions
Gell 4A White Mesa Mill
Blanding, Utah
GeoSyntec Consultants
1of 1
Head Above Liner
Svstom lfoetl
Calculated Action Leakage
Rate Ioallonq/ecraldawl
5 222.rJ4
10 314.01
15 384.58
20 t44.Ud
25 496.50
30 543.88
35 587.46
37 604.01
leak detection system geonet062006-xls 8t23t2006
Telephone Conversation *lO, with Harold Roberts, DUSA
Items:
l.
Date: August 6, 2008, 3:00 p.m. and 4:20 p.m.
With: David Rupp, DRC
References:
Email dated August 6, 2008 from DUSA with 2 photos of spillway HDPE rub sheet.
Email dated August 5, 2008 from DUSA with internet catalog excerpts for EPG Companies
Liquid Level Monitoring Stand Alone System (LMSA) and a Horizontal Wheeled Sump
Drainer pump.
DRC letter dated July 29,2008, subject: White Mesa Uranium Mill Operation
August I , 2008, received overnight delivery of compact disk containi ng 252 photos of DUSA
efforts on involving sandbags.
Spillway. I conveyed two main concerns:
a). That the spillway if in use, would not form a "pocket inlet" with respect to the streamline path.
I mentioned that the photos, as shown in reference a. above, do not show the top ofthe rub sheet
clearly, as to what it would be welded or attached to, and preclude "pocketing." Harold thought a
bolted batten strip to the concrete spillway with a separate piece of FML thence extrusion welded
to the rub sheet would preclude pocket formation. I agreed, and stated I was more comfortable
with that provision in the design.
b). The lateral width of the rub sheet is not wide enough for the PMF flow. Harold said they
would include additional width for the PMF.
I mentioned per reference c. above, that spillway slope protection changes discussed above would
need to be P.E. certified as completed on a revised drawing.
LDS Sump Monitoring and Pumping. Harold supplied the items in reference b. above,
photocopies attached.
a). I mentioned the requirement for equipment to have continuous sump water level monitoring,
pump volume totalizing and recording. It is not clear if LMSA has such. He mentioned there was
about a 3 week delivery delay for this equipment.
b). Horizontal Wheeled Sump Drainer (HWSD) pump has a l0-week delivery delay. Harold said
the LMSA would be the level sensor for the HWSD as shown as the sensor at the tip of the pump.
The pump would wheel into the sump and lay flat in the bottom.
Due to the equipment delivery delays mentioned, Harold proposed temporarily doing hourly
reading and recording of the sump elevation level and switching the pump on if needed, by using
manual techniques. I felt if these were hourly, it would be OK. The blow tube and dipstick
method are being contemplated for this.
3. Sandbag Issues. Per Harold, before and after pictures were submitted by reference d.
I had felt that DUSA would submit representative photos from each slimes drain line, as they were
corrected. However, DUSA submitted representative photos from representative slimes drain
lines according to Harold. He stated they could submit more photos to document the other slimes
drain lines. He felt I should remember that the slimes drains could have l07o of their area exposed
to slimes, and still drain the cell relatively rapidly. I mentioned that I understood the calculation
performed by GeoSyntec, which showed a 6.5-year drain down time vs. the original 5.5-year time
if the sides of the slimes drains did not allow entry of liquids for drainage, but the top of the drains
still allowed 1007o liquid conveyed through the top of the slimes drains. DRC needs to comment
in writing on the sandbag efforts. I mentioned per reference c. above, that sandbag efforts would
need to be P.E. certified as completed in support of the photographic evidence.
However, I did not mention in this particular conversation, that plugging of the slimes drains
themselves, i.e. the piping plugging within the slimes drains, as opposed to only l07o of the
geotextile entry path being plugged was my concern. Plugging of the piping within the slimes
drains, unprotected by sandbags, could completely void the value of entire slimes drain lines.
Attachment: Photocopies item b.
F:\Cell 44\Completion Report\Telephore Conversation 8-06-08
2.
Llqulo Level Monttonng 5 Sulrmersrble Sensors, Level Meter, Prcssure Transducer... Page I of 2
Service School 800-443-7426
ystern,
o
124-25t:3
Liquid Level Monitoring System -
LMSA
purnps control panels disconnects nrisc. comp. telcmetry level flow junction boxes
E.
EHfiffi
Effiryffi]
ffi#$ry,. l
tffiffi:r
Inquire About This Product
(See also: LMSA 500Portable Liquid Level
Mollitcrling Systun)
f'hc LevelMasterm Stand Alone (LMSA)
Liquid Level Monitoring System monitors and
displays liquid levels in sideslope risers, wells,
tanks, sumps, rcservoirs, and scttling ponds
including corrosive, viscous, hot, explosive,
and slurry-type liquids. The Level Monitoring
System includes the lollowing timc-tested,
fi eld-proven components:
s Available seperately or as part of a complcte
system.
*LevelMasterrm CHl(m0 Levd Meter:
An easy-to-program meter used to monitor
liquid levels. Includes level mctcr memory,
digital display, can be configured in any
mcasurement increnrent and optional output
rclays can be used as a level controller.
*LevelMasterrrrr Level Sensor:
A fully subrnersible and extremely accurate
liquid level sensor with oustanding noise
immunity, SS housing, built-in temperature
compensation and precise calibration.
EPG Panel Heater:
'I'he bui lt-in thermostaticall y controllecl panel
heater maintains minimum temperature and
climinates condensation, optimizing meter
accuracy and extending the lifb of the systcm.
l'used Power Supply/Surge
Supressor/NEMA4X Enclosure* :*Option: intrinsically safe barricr
Available C)ptions:
r Level sensols with additional surge
suprcssion
o Tefzel sensor cable. Intrinsically salt circuitry. Control with other cquipment. I".MSA 500 - Portable Liquicl Level
Monitoring l2 Volt Systern
For more liquid level and flow measuring and
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Srr"rorpHorizontal & Venical Sump Drainers
Hofizontal \Theeled Sump Drainer
More details at www.epgco.com
\With no-splice, chemical and abrasion resistant motor and sensor leads,
the SurePump is easy to install and assures greater system integriry in
aggressive environments.
The multistage centrifugal pump design enables smaller diameter
pumps to be used in high discharge head applications. SurePump
models are available for flow rates fro.m 2 to 1,200 gpm.
All stainless steel construction for maximum
performance in aggressive envi ronmen rs.
Equipped with EPG's E-Glide'' bearings, the
SurePump lasts longer and performs better.
Unique design places at least
four wheels in contact with
riser pipe surface at all times
assuring easy installation
and retrieval of the pump.
i::;,1
Patented vent valve
system purges air
from the sump drainer
preventing pump air lock.
SurePump motors are designed for
use in aggressive environments and
are available in a variery of voltages
and in single or three phase models.
SurePump runs cooler than other pumps
because the intake screen is located below the
motor. The sealed top assures that the liquid is
only drawn from the bottom, over the motor.
SurePump sump drainer as a sealed unit with bottom
intake provides maximum pump down levels in
horizontal, vertical or inclined applications.
The patented submersible level sensor is mounted along the central axis of the sump
drainer, is removable from the bottom and assures accurate, repeatable level control.
O 2001 tlPG (iompanies lnc.
Sure I)ump & E-Glide are Reg. TM of [iPG (lompanies Inc.
Bullerin 0400b-03
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From:
To:
Date:
Sublect:
Attachmentr:
Dave:
'Harold R. Rob€rts' <[e-mail]>
"Dave Rupp'' <drupp@ utah.prr>
7/ld20OB 4:00 PM
Re: Cell 4A
20080716154428.pd1; 200807161 54&11.pdf
Attached are revisions to the lO€ll 4A BAT Monitoring, OFerations ard
Maintenance Plan' per our conversation ol earlier this week. The changss
are in red.
I will call you in the moming to follow up on my voftr mail ol earlier
today.
Harold R. Roberts
Executive Vice President - US Operations
Denison Minm (USA) Corp.
(303) 38S4160
t
I
II
:
It
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
//0!, Revision: Denisond
Page I of 33
WHITB MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
I. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring PIan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures lor monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures thatare adequate todemonstrate DMTcompliance underState
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "CWDP').
This PIan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, Iiner integrity, and transporr
systems, as well as monitoring of water levels in Roberts Pond and l'eedstock storage areas at. the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DATLY TAILINGS INSPECTIONS
The fbllowing daily tailings inspections shall be pertbrmed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the curent condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for perfbrming the daily tailings
inspections, except on weekends when the Shift Foreman will pertbrm the weekend tailings
inspections. The Radiation Sat'ety OtTicer may designate other individuals with training, as
described in Section 2.4below, to perfbrm the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy ol
which is attached in Appendix A). The Daily Inspection Data forun contains an inspection checklist,
Df (
f'l
b'0'l' I
F;i;J;--*- -l
White Mesa {Vlill - Standald Operating Proccclurcs
Book I l: Environmental Protection lvlanual. Section 3. I
1/0!, Revisiorr : Deniso n,.{.
Pa.qc 2 of 33
I oetetear 2 Ii-. --,iDeleted:l j-
I ry1et9a:7 )
i Deletedr t iwhich incluclcs a tailings cells map, and spaces to record observations, cspccially those of irnmediate
concern and those rcquiring oorrcctive action. The inspector will placc a chcck by all inspection
items that appear to be operating properly. 'lhose iterns where conditions of potential concern are
observccl should be rnarked with an "X". A note should accompany the "X" specilyin-e what the
concern is and,uvhat corrective measurss will resolve the problcnr. This obsclvation of concern
should be noted on the fbrm until the problem has becn rcmcdierl. 'l'ho clate that corrective action
was taken should be noted as well.
Areas to be inspected include the tbllowing: Cell 1,2,3, ancl 4A, Dikes 1,2, 3,4A-S, ancl 4A-W,
wind movement of tailings, efl'ectiveness of dust minimization methods, spray evaporation. Cell 2
spillway, Cell 3 spillway, Cell 3 and 4A liquicl pools and associated liquid return equipment, cell
leak detection systems, and the wildlil'e ponds.
Operational f'eatures of the tailings area are checked for c<xditions of potential concern. Thc
foliowing items require visual inspection during the daily tailings inspection;
r)
Tailings slurry and SX rallinate trausport systems ti'om the Nlill to the active
disposal ccll(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be peribrmed when the Mill
is operating. The lines to be inspected include the: tailings sluny lines I'rorn CCD
totheactivctailingscell;SXraffinatelinesthatcanclischargeintoCell l,Cell)
or Cell 4& tne poncl rcturn line fiom the tailings area ro thc Mill; and, lines
transporting poncl solutions fronr one cell [o another.
Cell L
Cell2.
Cell3.
Cell44.
Dike structures including dikes l, 2, 3, 4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 suilli,vay. Ccll 3 anrl Cell 44, liquid pools ancl
associatcd l iquid rcturn equipment.
Presence oi wildlif'e ancl/or clomcsticatcd animals in the tailings area. including
waterlbwl and burrowing animal habitations.
Spray evaporation pumps and lines.
a)
I Deletedr .r
F"l.t"d.i --t
b)
c)
d)
e)
c)
h)
White lvlesr Mill - Standard Opcrating Procedules
Book I t: Environmental Protection Manual. Section 3. I
J/0$ Revision: Denison-g
Page 3 of 33
fDeht"d;,
j)Wind movement of tailings and dust minimization.
Wind movement of tailings rvill be evaluated for conclitions which may require
initiation of preventative dust minimization measures tbr colls oontaining tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the tbllowing: I ) areas of tailings subject to blowing and/or wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage ol'the total cell area. The evaluations will be reviewed
on a weckly basis, or more irequently if warranted, and will be used to direct dust
minimization activi ties.
Obscrvat ion of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells I , 3,
and 4A.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Dail| Inspection Data form.
An estimate o[ l]ow hrr active tailings slurry and SX line(s).
An estimate of tlow in the solution return line(s).
Daily measurements in the leak detection system (LDS) sumps o1'the tailings
cells will be made when wananted by changes in the solution level of the
respective leak detection system.
The for further action when evaluat in anv ol the
ons If this
ion is made, the Mill Manager should be immediately and the
leak detection system pump started.
Whenever the leak detection system pump is operating ancl the Uow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data fbrm. This data will be used in accordance with License
Condition Il.3.Bthrough ll.3.E of theMill'sRadioactiveMaterialsLicense,to
determine whether or not the llow rate into thc leak detection system is in excess
o[ the License Conditions.
k)
r)
m)
n)
o)
p)
Deleted:3
Deleted3 7
Deletedi 2
Deleted! 3
Whitc Mesa lvtill - Standard Operating Procetluros
I-look I I: Envil'onlnental Plotccti<>n IVlanual. Section 3.1
j//0$ Rcvision: [)enison;f
Page 4 of 33
i Deleted: .r
I Deleted: -l
I o.tetedr z
i oeleted::q) An estirnate of the percentage of thc taitings beach suriacc area and solution pool
area is made, including estimates of solutions, cove[ aleas, and tailings sands fbr
Cells 3 and 4A.
ltcrns (a), (rn), (n), and (o) are to be done only when the Mill is operating. When the Mitl is down,
these items cannot be pertbrmed.
2.2. DaillOperations Inspelllot]
Dr.rring Mill operation, the Shifl Foreman, or otherpcrson with the training specilied in Section 2.4
below, designated by the Radiation Saf'ety Olficer, will pcrlbrm an inspection oithc tailings line and
tailings area at least once per shift, paying close attention lor potential leaks and to the discharges
tiom the pipelines. Observations by the Inspcctor will be recordecl on the appropriate line on thc
Opercrtirtg Foreman's DaiLy Inspection tbrm.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2. I ancl 2.2 irbovc, a Mitl ernployee will patrol
the tailings area at least twice per shift during Mill opcrations to cnsure that there are no obvious
safety or'operational issues, such as leaking pipes or unusual wildlit'e activity or incidences.
No rccord of thcse patrols need be madc, but the inspectors will notily the Radiation Sal'cty OlTicer
andlor Mill management in the event that cluring their inspection they discover that an abnorrnal
condition clr tailings emergency has occurretl.
2.4. Training
All individuals pertbrming inspections described in Sections 2. I and 2.2 above must havc Tailings
Management System training as set out in the'lailings lnspection Training procedure, which is
attachcd as Appendix B. This trzrining will include a training pack cxplaining the procedure l'or
perforrning the inspection and addressing inspection items to be observed. ln addition, each
individual, afterreviewing the training pack, will sign acertification fbrm, indicating that trainin-e
has been received relative to his/her duties as an inspector.
2.5. Tailin-esEmcrgencics
Inspcctors will notity the Radiation Satbty Olficcr and/or Mill management irnmediately ii during
thcir inspectittn, they discover that an abnormal conclition exists or an event has occurred that could
cause a tailings emel'gency. Until relieved by the Environmental or Radiation Technician or
Radiation Sat'ety Otficer, inspectors will have the authority to clirect resources cluring ttrilings
emergencies.
I oeteted: r
White ivlcsa lvlill - Standard Operating Procedurcs
Book t 1 : Envilonnrental Pt otection Manual, Section 3. 1
//0$ ll.cvision : Dcnison-;t
Page 5 of 33
Any major catastrophic eveuts ol'conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Saf'ety Officer, one of whom wilt notify Corporate
Management. If dam t'ailure occurs, notity your supervisor and the Mill Manager immediately. The
Mill Manager willthen notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division o['Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.r Weekly Tai I ings Inspections
Weekly tailings inspections are to be conducted by the Radiation Sat'ety Department and include the
tbllowing:
Leak Det ectio n Sys t ems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leakdetection system is rneasured by use of a
pipe that is removed f}om the system which will indicate the presence of
solutions in the LDS system. Cell 4A has a blow tube, which has been measured
and marked. Once solutions have been identifled by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the markcd tubing.
If suflicicnt tluid is present in the leak detection system of any cel[, the fluid shall
be pumped tiom the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped fiorn an LDA shall be returned to a
disposal cell.
If fluid is pumped liorn an LDS, thc llow rate shall be calculated by dividing the
recorded volume of tluid recovercd by the elapsed time since tluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
morc feccnt. This calculation shall be docuffrented as part of the weekly
inspection.
Upon the initial pumpin-e of fluid fi'om an LDS, a I'luid sample shall be collectcd
and analyzed in accordance with paragraph I 1.3 C. of the Radioactivc Materials
License.
lqlCell 4A. under no circumstance shall fluid head in the leak detection
slystem sump exceed a 1-lbot level above the lowest point in the lower l'lexible
a)
Formatted: Indent: Left: 1.25",
First line: 0", Tabs: 1.25', Left +
Not at 1.13"
White Mesa Miil - Standard Operating Proccdurcs
IJook I l: Envirorurcntal Protection lVlanual. Scction J.l
//0$ Itevision: l)en i son-1,
l'age 6 ol 33
$cll1bmCIs [i qqt*Tajlclsr]uCIej]sM!&rJlu!]_&]lgua-t LBatb. I..DS Flow
Sgtqs in the cell 4A leak deteciion systent, the volume ol'all fluids purtipcd
{iorl thll I-DS on a weekly basis shall be measured, and that in{'ormation will
be used to-calgulatefln av-.erqe yeluntc p-umnccl per da]t. Under no
circurnstances shall the tiaily LDS tlow volurne exceed 24, 160 gallons/da_y.
The nraximum daily LDS flow volume will be comErred against the rneas-urcd
qell solulion levcls detailcd on Table 1 in Appendix A, to tlctcrmine the:
nraxinrunr rlaily allowable LDS llow volurne tbr var-ying hcad conditions in
Cell4A-
b) Slimes Drain lYater Level fulonitoring
(i) Cell 3 is an aclive tailings cell while Cell 2 is partially reclaimed with approximately
L)07o of the surface covered by platlbrm iill. Each cell has a slitncs clrain systcm
which aids in dewatering the slimes and sancls placed in the cell;
(ii) Celt 2 has a pump placed inside ol the slimes drain acoess pipe at the bottom ol the
slimes clrain. As taken ltom actual measurernents, the bottorn of the slimes drain is
38 t'eet below a water lsvcl measuring point at the centerline oi the slirncs dr:ain
access pipe, at the ground surt'ace level. This means that the bottorn ol the slimes
clrain pool and the location ol the pump are onc lbot above the lowcst point oi the
FML in Cell 2, which, basecl on construction reports, is at a depth of 39 t'eet below
the water level measuring point on l.he slimes drain access pipe tor Cell2;
(iii)The slimcs drain pump in Ccll 2 is on a timed system, under which it pumps for 1.5
minutes each hour, thereby allowing the slimcrs wastewater to recharge tbr 45
minutes bctbre being pumped again. Bused on measuremonts taken in August 2006,
thc water leve I in the Cell 2 slimes drain rccharges to a depth of about 28.-50 t'eet
betbrc each pumping ancl is pumped to a depth o1'38 t'eet alter each purnpin-e, in each
case measured below the water level rneasuring point on lhe slimes dlain access pipc.
'Ihe avcragc wastgwatcr head in the Cell 2 slimes drain is theretbre about 5 t'eet. The
clepLh to water of about 28.-50 t'eet after recharge is below the phreatic surthce ol
tailings Cell 2, which is at a depth ol about 20 fbct below thc water levcl mcasuring
point on the slirnes drain access pipe. As a lesult, there is a continuous flow ol'
wastcwater iiom Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater hoacl in the Cell 2 slimes drain
rcsulting t)rlm pumping at these intervals is satistactory ancl is as low as reasonably
achievable. Based on past experience,,cyclin,g the pump more thzrn l5 minutes e very
hour can result in more replacernent costs tbr purrrps ancl more resulting systoll'r
dorvntime;
(iv)The Cell 2 slimes drain pump is checked weckly to observe that it is operating ancl
that the timer is set propelly, which is notecl on the Weekly Tailings Inspcction Form.
lf at any time the pump is observed to be not working properly, it will be lixed or
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Whitc Mcsa ivlill - Standald Operating Prt:cedures
Book I l: Environmental Protection Manutl. Section -l.l
,1J0& Itevision : Dcnison -,{
Page 7 of .13
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rcplaccd r.vithin l5 days;
(v) Depth to wastewater in thc Cctl 2 slimos drain access pipe shall be monitorecl and
recordcd wcekly to determinc maximum and minirnum fluid head befix'e and al'ter a
pumping cycle, respccrively. AU_hgXUt-&earurSugu$-m$$l lt*:nadS-"kggf&S_railrg
nrea"sqring poilrt (tl&', irotqL{-tlU,-nqlh-fllg-qllhq_juggtutpg), anri marle to ths
ncarc$t 0.01 f'ool, "The rcsults will be rccorded as depth-in-pipe measurements on the
Weckly Tailings lnspection Form;
(vi)On a monthly basis, thc slimos drain pump will be turned ollancl the wastewater in
the slirnes clrain access pipe will be allorved to stabilize.l.ql it lg$!-$L bggg. Once
the watcr levcl has stabilized (based on no chan-9e in water level for three (3)
successive readings taken no less than one (l) hour apart) the water level ol the
wastewater will be measurcd and recordcd as a depth-in-pipe measurcment on the
Monthly lnspection I)ata lorm, by measuring the depth to watcr bclow the water level
measuring point on the slimes drain access pipe;
0/ii) - . Ns*raepsi]tcutlt{t tt,bc-aU.trgsdto be dischargqd into Cell 2;
{viii) .***.lt'alelyj]glqjllq_ltt}sl_lgtent average annual heacl in theCell2 slirnes drain ii
i'ound to hav"q incrcased.ahey*-.grE*a.verags hgad f'or the p
U9g1ff9*Wjj-9pgtpk.$rr1h_ 1j1S Lo:qq_irqmql!:l r,rf Part I.G.3 olthc CWDP. including the
requiremenfio prrlt{S-(pli[i-q1yiqU_to tlte Executive Se*etary orally within 24 hours
fo.tlq!&d-by-ui ttsr -n e"li fi -q-rllr eit i
{ix)Because Cell 3 and Cell 4AAltj,curently activc, no purnping liom the Cell 3 or Ccll
4A slirnes drain is authorized. Prior to initiation oltailingsdewatcringoperations f,or
Cell 3 or Cell 4A, a similar proceclure will be developed fbr ensuring that average
head elevations in the Cell 3 qrtd Ce ll 4A slimes clraing are kept as low as rcasonably
achievable, and that the Cell 3 and Cell 4A slimes draing arq.inspectcd trnd thc rcsults
reported in accordance with the recluirements of the permit."
c) Witrd ldovement of Ttrilittgs
An evaluatiorr of wind moverncut of tailings or dusting and control measures
shall be taken if neecled.
d) Tailitrgs Wqstewater Pool Elevation Monitoring
Solution elcvation lne.lsuremcnts in Cells l-3 ancl 4:tand Roberts Pond ae to be taken by
survey on a weekly basis trs lbllows:
(i) The survey will be perlbrmecl by the Mill's Radiation Sat'ety Olficer or designec
(the "survcyor") with the assistancc of anothcl Mill workcr (the "Assistant");
(ii) The survey will be perlbrmed using a survey instruurent (the "Survey Instrunrent")
accurate to 0.01 l'ect, such as a Sokkai No. 82l, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 toot incrernents;
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White N4esa Vlill - StandaLcl Operating Procedurcs
llook I l: Environmcntal Protcction Manual, Scction i.l l0SRevision: Denisonlzt
P.rgo 8 of 33
(iii)'I'he refbrence Points (the "Rel'erence Points") lbrCells 1,3 ancl 4A, and Iloberts
Pond are known points establishcd by prolessional survcy. lior Cell I and Roberts
Pond, the Rct'erence Point is a wooden stake with il mctal clisk on it located on the
southeast corner ot'Cell L The clevation ot'thc metal clisk (the "Relbrence Point
Elevation") ibr Celt I and Roberts Pond is at 5,623.14 t'cct abovc moan sea level
("FMSL"). For Cell 3 and cell 4A,. the Rct-erence Point is a picce ol rnetal rebar
located on the south dike of Ccll 3. The elevation at the top of this piece t:l{'rcbar
(the Ref'erence Point Elevation fbr Cell 3 and cdl 4,4.) is at 5,607.83 FMSL;
(iv) 'fhe Surveyor will set up thc Survey Instrument in a location where both the
applicable Rel'ercnce Point ancl poncl surlaco are visible. For Cell I and Roberts
Pond, this is typically on thc roacl on thc Cell I south dike between Cell I and
Roberts Pond, approxinrately t00 lbct cast ol'the Cell l/Roberts Pond Ret'erence
Point. For Cell 3 and Cell 4,4,, this is typically on the roa(l on the Cell 3 dike
approximately 100 fbct cast ol the Cell 3 Reltrence Point;
(v) Once in location, thc Surveyor will ensure that the Survey Instrument is level by
centering thc bubblc in the level gauge on the Sr.rrvey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal clisk on thc Ccll llRoberts Pond Rei'erencc Point and on the top o['the rebar
on the Ccll 3 and cell 4A Retbrcncc Point. The Assistant will ensure that thc
Survey Rod is vertical by gently rocking the rod back and lbrth until the Surveyor
has establishcd a level rcading;
(vii) The Surveyor will locus the oross hairs of the Survey Instrument on the scale on
the Survey Rod, and recorcl the number (the "Ret'erence Point Retrding"), which
represents the number of t'eet the Survey Instrument is reading abovc thc
Rcl'crence Point;
(viii) The Assistant will then movc to a designated location where the Survey llod can
be placed on the surfhce of thc main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to bc used by the
Assistant to consistently use the same locations are as lbllows:
A. Cell3
A stake has been place in the central area of the south <Iike of Cell 3. The
Assistant will walk perpendicular to the ciike lbm the stake to the nearest point
on the liquid surlacc olCell 3 ancl placc thc Survey Rod at that location:
H. " --C"il-L4A
llg,Assistanr will walk down thc sloos in thc northeaSt op"11tgt-Ul$gl|-{Ajld
,
$-Cell I
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White Mesa Vlill - Standard Opcrating Procedures
Book I l: Environmcntal Protectiou iVlauual, Section J.l
J/0$, lic vision : Deni son-;f
Pagc 9 of 33
A mark has been painted on the north side ol the rarrrp -going to the pump
plattorrn in Cell l. The Assistant will{2!-aEg the Survcy Rocl against that ntark
mdllqld_tjre-$L{tsr"llsilIJ-rrrth rxts elt Lj$r,t t0ur.bi-tS_th!-li_t}u,irl.surtace; and
D Robcrts Pond
A rnark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will-place the Survey Rod against that rnark agl-hullUlhgrgll
v e rti c a I I y. Uii t h o qg e n d jus!,1su0!"in&Jjrcliquld-$ur-[ars,
Based on the folegoing methods, the approxitnate coordinate locations fbr the
measuring points for Roberts Poncl and the Cells are:
Northins Eastins
Roberts Pond 323,041 2,579,697
Cell I 322.196 2,519.211
Cell3 320,508 2,577,160
Cell4A 1?_0 300 2,579.360
Thcse coordinate locatit'rns may vary somewhat depending on solution elevations
in the Pond and Cells;
(ix)The Assistant will holcl the Survey Rocl vertically rvith one end olthe Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and lbrth until the Surveyor has establishod
a level reading;
(x) The Surveyor will lbcus the cross hairs o[ the Survey Instrument on the scale on
the Survey Rod, and record the number (thc "Pond Surlhce Reading"), which
represents the number of leet thc Survey InStnrment is rcacling above the pond
surlacc lcvcl.
The Surveyor will oalculatc the elcvadon ol the pond surtirce as FSML by adding the
Rel'erence Point Reacling for the Cell or RoberLs Pond, as the case may be, to the Refbre nce
Point Elevation fbr thc Ccll or Roberts Pond and subtractin-9 the Pond Surface Reading tilr
the Cell or Roberts Pond, and will rocord tho number accurate to 0.01 tbct.
e) Sumrnary
In addition, the wcekly inspection should sumrnarize all activitics concerning the
tailings area fbr that particular week.
i Formattedr Indent; Left: 1.15"
I Formatted: Bullets and Numbering I
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I Wfrite iV{esa ivlill - Standard Operating Procedules
Book I l: Environnrental Protection iVIanurl. Section 3.1
,710& Itr:vision : [)cni son
"4,Pa.sg l0 of 3.1
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Results of the ,,veckly tailings inspcction arc recordcd on rbc Weeklv'failings untl. DM7' Inspection
tbrm. An cxarnple of thc Weekly TaiLittgs cuttl DMT lrtsltection lonn is provided in Appendix A.
3.2.Weekly Inspcction ol Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond. in accordance rvith the procedures
set orrt in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recordcd on the
Weekly'ktilings and DMT Irtspection form. Based on historical observations, the FML at the Pond
Surface Reading area ti)r Roberts Pond, isppproximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surtace Reading area is at or below the FML
f'or that area, the pond lvill be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly f'eedstock storage area inspections will be perlbrmed by the Radiation Satbty Department, t<r
confirrr that:
a) the bulk fbedstock rnaterials are stored and maintained within the defined area clescribcd in
the GWDP, as indicated on the map attached hereto as Appendix D; and
b) all alternate t'eedstock located outside the deiincd Feedstock Area are maintained within
watcr tight containels.
The results of this inspection will be recorclcd on thc Orz Stora.ge/Sample Plant Weekly Inspection
Report, a copy ol which is contained in Appendix A. Any variance in storcd matcrials from this
requilement or observed leaking alternate feedstock clrums or other containers will be brought to the
attention oi Mill Management and rectif.ied within l5 clays.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Racliation Safbty Of licer or his clcsignee tiorn
tlre Radiation Sal'ety Department ond recorcled on thc Montlily Inspectiott Datn f<>rm, an example ol
which is oontained in Appendix A. Monthly inspections are to bc pertbrmcd no sooner than l4 days
since the last monthly tailings inspection ancl can be conducted concurrently with the quarterly
tailings inspection when applicable. The tbllowing items are to be inspected:
a) Taithtgs Slurry Pipeline
When thc Mill is oporatin-e, the slurry pipeline will bc inspected at key locations to
deterrnine pipe wear. Pipe thickness will be rneasured using an ultrasonic device by
either the racliation sat'ety staff or other trained clesignees. The critical points ol the
pipe include bends, slope changes, valves, andjunctions, which are critical to dike
I Deleted:
White lvlesa NIill - Standartl Operating Procedures
Uook I t: Environmcntal Plotection lvlanual. Section 3.1
//0& ttcvision : Dcni son-$
Page I I of33
stability. These locations to bc monitored lvill be determinecl by the Radiation Sat'ety
Ol'l'iccr or his designce llorn l-hc Radiation Saf'ety Department duting the Mill run.
Diversiott Ditches
Diversion ditshes 1,2 and 3 shall be rnonitored monthly tbr sloughing, erosion,
undcsirable vegetation, and obstruction of flow. Diversion berm 2 shoulcl be checked
for stability and signs ol distress.
Sedimentation Poncl
Activities around the Mill and thcilities area sedimentation pond shall be summarized
for the month.
Oversprcty D ust Minimizctt ion
The inspection shall include an evaluation of overspray minimization, i[applicable.
This entails ensuring that thc ovcrspray systom is lunctioning propcrly. In the event
that overspray is carried more thar -50 teet tiorn the cell, the overspray systcm should
be imrnediately shut-off.
Renrurks
A section is inclucled on the Mon.tltly Inspectiott Data torn tbr remarks in which
rccommendations can be made or obscrvations of concern can bc clocumcnted.
Sunmran, of Daily, Weekly and QtrurterLl, Inspectiorts
The rnonthly inspection will also summarize the daily, weekly and, il'applicable,
quarterly tailings inspections tur thc spccil'ic month.
In addition, settlement monitors are typically surveyed nronthly and the results reported on the
M ottt h Ly I ns pect iott D ata torm.
5. QUARTERLY TATLINGS INSPBCTION
Thc quarterly tailings inspection is perlorrned by the Radiation Safbty Ollicer or his designee ti'om
the Radiation Salbty Department, having the training specil'iccl in Section 2.4 above, once per
calcnclar qual'tcr. A quarterly inspection should be perfbrmecl no sooner than 45 days since thc
prcvious quarterly inspection was pcrlorrncd.
Each quarterly irrspection shall includc an Embankment [nspection, an Operations/Maintenance
1 Deleted::
D)
c)
d)
e)
f)
Wlrite lvlcsa lv{ill -.Standard Operating Procedures
l}rok I l: Environrnenlal Plotection Manual, Scction 3.1
Review, a Construction Ilevicw and a Summary, as fbllows:
/J0$ Ile vision: Deni son-;!
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Entbar t kme ti I n.s pe ct i o n
The E,mbankrnent inspection involves a visual inspection of thc crcst, slope ancl toe
of each dike lor movcmcnt, seepage, severe erosit-rn, subsidencc, shrinkage cracks,
ancl exposed liner.
O p e rat io n s/M ainte trunce Rev iew
"lhe Operations/Maintenance Review
Maintenance activities pertaining to the
Constructiort Review
consists of reviewing Operations and
tailings area on a quarterly basis.
c)
The Construction Review consists ol revicwing any construction changes
moclifications made to the tailings area on a cluaterly basis.
d) Sumnttry,
The summary will inclutlc all major activities or observations noted around the
tailings area on a quarterly basis.
Il any of these conditions are noted, the conditions and con'ective rneasures taken should bs
documented in the Quarterly hxpectiort Data form. An example of the Quartcrly Inspectiott Datcr
fbrnr is provided in Appendix A.
6. ANNUALEVALUATIONS
The lollowing annual evaluations shall be perfbrmeci:
6.1. Annual Tcchnical Evaluarion
An annual techniczrl evaluation of the tailings'mana-qement systcm is perlbrrned by a registered
professional cngincer (PE), who has cxpericnce and training in the area ol'geotcchnical aspects ol
rctcntion structurcs. 'l'he technical evaluation includes an on-site inspection ol the tailings
rnanagementsystemandathoroughrevicwofall tailin-esrccoKlslbrthopastycar. The'fechnical
Evaluation also includcs a teview and summary of the annual rnovemcnt monitor survcy (scc Scction
-5.2 below).
All tailings cells and corresponding dikes will bc inspectccl fbr signs of orosi<:n, suhsidence,
a)
b)
White lvlcsa Vlill - Standard Operating Proccdurcs
Book I l: Errvirernmental Protcctiou Vlanual, Section ,l.l
//0& Ruvision: Dcnisond
Page l3 ol 33
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'"-lshrinkagc, and seepage. 'fhe drainage ditches will be inspectecl to evaluatc sudhce watcr control
stl uctures.
In the event tailings capacity evaluations (as per SOP PBL-3) lvere performed ftrr the receipt o['
alternate t'eed material during the year, the capacity cvaluation ti>rms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amounI o[ tailings aclded to the systern since tlre last evaluation rvill also be calculated to cletermine
the estimated capacity at the time ol thc evaluation.
Tailings inspcction records will consist o['daily, weekly, rnonthly, and quarterly tailings inspections.
These inspection records will be evaluated to deterrnine il any tieeboard limits are being
approached. Recorcls will also be reviewed to summarize observations of potential concern. The
evalutrtion also involves discussion with the Environmental and/or Radiation Tcchnician and thc
RadiationSat'etyOtTicerregardingactivitiesiiroundthctailingsarcaforthepastyear. Dudngthc
annual inspection, photographs ol the tailin-es area will be taken. The training of individuals will be
rgviewcd as a part of the Annual Technical Evaluation.
The registered enginecr will obtain copios of selectecl tailings inspections, along with the monthly
and quartcrly sutnmaries of observations ol conccrn and the con'ective actions taken. Thesc copies
will then be includecl in the Annual Technical Evaluation Report.
Thc Annual Technical Evaluation Report must be submittecl by Septembcr l't of every yoar to:
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6.2.
Directing Dam Sal'cty Enginecr
State of Utah, Natural Rcsources
1636 West North Temple, Suite 220
Salt Lake City, Utah 841 i6-3156
Movement Monitors
A movement monitor survey is to be c<lnducted by a licensed surveyor annually during the second
quarter olcach year. Thc movcmcnt monitor survey consists of surveying monitom along dikes 3-S,
4A-W, and 4A-S to dotect any possible settlemcnt or rnovement oi the dikes. The data generated
tiom this survey is rcviewed and incorporated into lhe Annual Technical Evaluatiort Report of the
tailings managemcnt system.
6.3.Frecboard Limits
a) T'aiLings CeLls I antl 4A
The tieeboarcl limits arc ars pcr .lntructrv 10, 1990 Drainctge Reportfor Cells I
curd ,lA ancl are stated below:
Whirc Mtlsa Mill Standard Operating Ploccdures
Book I l: Environmental Plotection Manual, Section 3.1
,1J0$ tievi sion : Deni sonll
Page l4 of33
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(i) A liquid maxinlumelevation o15,615.4 teetnrean sea level inCell l.
(ii) A liquid maximum cle vation oi 5,596.4 teet mean sea lcvcl in Ccll 4A.
b) Tailings Celt 3
Thc ll'ceboard limit tbr Cell 3 is determined annually using thc tollowing
procedure:
(i) From a survey ol Cell 3, the pool surtirce will be dctcrmined.
(ii) An estimate of the rnaximum tons o{'clry tailings to be gencrated during
the next l2 months will be made. This estimate is multiplied by 1.5, a
tactor of saf'ety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is dividcd by the number of trxrs required
to reduce the pool size by ene acrc and then subtracted tiorn the pool
surtace (determined in Step i), yielding thc Roduced Pool Arca.
The PMP Flood Volume Rcquirement, as per the Jarutary 10, 1990
Drailtctge Report, is 123.4 acre feet. The PMP Flood Volurne
I{equirement is divided by the Reduced Pool Area to cletermine the PMP
Freeboard Level.
The Wave Run Up of 0.78 t'eet (as spccil'ied in the Jcmuat'y 10, 1990
Drainage Report) is added to the PMP Fleeboard Level to deterrrrine the
Total Required Freeboard.
The calculation of the Total Required Frceboard fbr Cell 3 will be calculated
annually and thc calculation sheet filecl in the Mill Central File.
c) Tctilitrst Cetl 1A
Thc frccboard-ljmit lor Cell 44 is dsllermined annuaiiy using the following
Droccdusj:
"lhe Cell 4.A, design includes a concrete_ Cpifl]r"qy betlysqn Ccll 3 an ,
with thc invqt clevation 4 f'cet bel-owjlre "tgp at tlrc Cqll 3 dik
ol'-5604.5 i'eet amsl-,SlgulSle-Eli 3 ro{qive the fu
lect ol water. apprr:ximately {r2
thg_spilhv,iy into Qgll 4&.
(iv)
(v)
Wlrite Mesa Mill - Stanclard Operating Procodurcs
Book I l: Envilonrnental Protection Mlanual. Scction 3.1
fi)[l{cvisiorr: l)errisond r Deleted: ]
Pagc15ol 33 i -' - -- """""'""*''"""'1llgr:1"9, r =.'_ :==:l{-qsse,.:-
)
i:eir:Esrjg,st,sgrcq,q l
i Dglgted: 2
fle-.flood volurne tioln the PMP event over the Ccll 4A area is 36 acre-ltct of I oeteted' r
waler (40 aqres. pltrs the a<liacent clrainaqe are a of'3.?5 acr*s, times the PMP of
l0 inches). This would result in a total l'lood volumc of 98 acrc.fect. including
the 62 acre-f'eet of solution frorn Cell 3. The tieekrard depth reguired lbr Cell
4A fiorn the PMP event"ryq}ld be 2.44 feet, plus a wave nrn-urr depth ol'0.77 tcet
Lfrom the 1990 Drainagc Rcport). for a total liecboard requircment ol 3.2 fcct.
This cnlculation is illustrated on Attachment 4. Thc Groundwatcr Quality
Ifischarye Permit. No. UCW370004. lor the White Mcsa Mill rqqqircs that_thg
trrhimum freeboard be no lcss than 3.0 feet fur any 01' the gxisting Coll
construction, but based on the above calculation the freeboard wuuld be set 3.2
feet below the top of liner. 'I'he tieeboard lbr Cell 4A would theretbre be 5595.3
amsl (top of lincr 5598.5 - 3.2 fsct).
The calculation of thc'Iotal Required lrreeboffd for Cell 4A will bg calculatad
annually and the calculation sheet filecl in tbr: Mill :ecnfal liilc.
d) Roberts Porul
The lieeboarcl limit tbr Roberts Pond is a liquid maximuur elevation of 5,624.0
fbet above mean sea levcl, as specified in the GWDP.
6.4. Annual [-eak Dctcction Fluid Samples
In the evenl solution has bcen dctected in a leak detection system, a sarnple will be collected on an
annual basis. This sample will be analyzed according to the conditions set fbrtlr in l.icense
Conclition tl.3.C. Thc results ol th<: analysis will be reviewed to detcrrnine the origin of the
solutkrn.
7. OTHER INSPECTIONS
All daily, weekly. monthly, quarterly and annual inspections and evaluations shoulcl be perlbrmed as
specified in Sections 2,3,4,5 and 6 above. However, aclditional inspections shoukl be conducted
after any significant storm or significant natural or man-made cvent occurs.
It. REPORTING REQUIREMENTS
In addition to the Daily Inspecti.on Data, Weekly ToiLings Inspectiott, lulontlt.ty Inspectiott Dcua and
QueuterLy lrtspectiott Datatorms includecl as Appenclix r\ and clcscribcd in Sections 2,3,4 and 5
rcspcctively, and the Operating Foremut's Dailv ltt.spectiotr itncl WeekLy Mill ln.spection lbrms
described in Sections 2 ancl3, rcspectivcly, thc tollowing adclitional rcports shall also be prepared:
White Mcsa Vlill - Stanclard Operating Proccdures
Book I l: Envir'onmental Protcction Manual. Section .l.l
J/0$ Revision: Denison;!
Page 16 of 33
i
I
. .....=--'-*.)
8.l.Monthl v'lai lings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around thc tailin,gs area. Il' not prepared by the Radiation Sat'cty Officer, thc report shall be
submitted to the Radiation Sat'ety OtTicer ftrr review. The Mill Manager will revicw the report as
wcll bclbre the report is tiled in the Mill Ccntral File. Thc report will contain a summary of
obscrvations o[ concern noted on the daily and weekly tailings inspections. Correct.ive measures
taken during the nronth will be documented along with the observations wherc appropriate. Allclaily
and weckly tailings inspection forms will be attached to the report. A monthly inspection iorm will
also be attached. Quarterly inspection tbrms will accornpany the report when applicable. The report
will be signed and dated by the preparer in acldition to the Radiation Sat'ety Ofiicer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required intbrmation recluired by Part LF.2 of
the GWDP relating to the inspections dcscribed in Section 3.1(b) (Slimcs Drain Water Levcl
Monitoring), 3.1(d) (Tailin-qs Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspcction of
Solution Levels in Roberts Pond) ancl 3.3 (Weekly Feedstock Stora-9e Area Inspections) rvill be
provided to the Executive Secretary on the schedulc provicled in Table 5 of the CWDP. An annual
Slll&malf 4nd graph for each calcndar Year oJthc dcpth tq"-gj,Ilelil-alsx in lhe Ccll zJlirncs drain mu$t
belnqludedirthefburthauarlerreport. Alierthelirs]! ear-atdheginninginZQ{}li.qugtedyrgp$rts
rball_lilcludq"!:0th.th* currcnt ycar rncnthly values and a graphLq conrgarison tt"r the previous yca{.
I Wtrite Mesa Mill - Standard Operating Procedures
Book l[: Environmental Protection Manual, Section 3.1
//0!, Revision: Denison;f
Page l7 of33
APPENDIX A
FORMS
Whire llesa Mill - Standard Opcrating l)rocedulcs
Book I 1: Environmcntal Protection VIanual, Section -1. I
APPENDIX A (CONT.)
DAII,Y INSPBCTION DATA
lnspector:
Date:
Accompanied by
Time:
Any ltern not "OK" must be documented. A check mark = OK, X = Action llequired
/0& l{cvision: Dcnrson;f
Paue l8 of 33
I. TAILINGS SLURRY TRANSPORT SYSTEM
Lcaks. Damasc. Blockacc, Sharp tscnds
Leaks. l.oose Connections
Lcaks. Blocked. Closcd
Location or Orientation
II. OPERATIONAI, SYS:TEMS
Greater Than Operating Level, Large Change
Since Previous Inspection
Cracks, Severe Erosiorr, Subsidencc
Elosion ol cover. Exoosurc of LineLLiner and Cover
III. DIKES AND ENIBANKMENTS
Sloughs or Slicling Cracks, Bul-ecs, Subsidcnce.
Severe Erosion, Nloist Areas, Areas oi Seepage
Outbreak
Cracks, S ubsidence. Severe Elosion
White Mesa Vlill - Standard Opelating Procedulcs
Book I I: Environmental Protcction Manual. Section 3.1
//0$ Revision: Dcnisond
Page t9 oi33
IV. FLOW RATES )eleted3 2
Slrrrrv Line(s)Pond Return S-X Tails )eleted:5
CPM
V. PHYSICAL INSPECTION OF SLURRY
LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VIII OBSERVATIONS OF POTENTIAL CONCERN I Action Required
Yes
--No
Yes _No
VI, DUST CONTROL
Cell 2 Cell 3
Dustins
Wind Movement of Tailinss
Precinitation: inches liouid
Ceneral Meteorological conditions:
VII. DAILY LEi\K DETECTION CHECK
Leak Detection System
Checked Wet--Dry
Initial level
Final level
-Wet--Dry
_Wet_Dry
lnitial level_
Final level
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section f.l JlO$ Ilevision: Deni son-jl
Page 20 of 33
White Mesa Mill * Standard Operating Procedures
Book I l: Environmental Protection lvlanual, Section 3.1
[MAPOFTAILINGS AREAI
//0$ Revision: Denison;l
Page 2l of33
White Mesa lvlill - Standard Operating Procedules
Book I l: Environmental Protection Manual. Section 3.1
APPENDIX A (CONT)
DENISON MINES (USil) CORP.
WEEKLY TAII,INGS INSPECTION
Date:_Inspectors:
l. Pond elevations (msl,li) Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above PML ((a)-(b))
Cetl 3: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
Cell 4A: (a'lPond Sohrtion Elevation
J/0_$ Revi sion : Den i son ;!
Pagc 22 of 33
_5597
5-570
6)FML Bouqm Elevation _- , , 5564
(c)Denth of Water above FML ((a)-6))
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML (a)-(b)
56 I 2.34_
2. Slimes Drain Liquid Levcls Cell 2 Pump functioning properly
Pump Timer set at l5min on AS *in ott
Depth to Liquid pre-purnp
Depth to Liquid Post-pump
(all measurements are depth-in-pipc)
Pre-purnp head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
oumD =
White Mesa lvlil[ - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section -j.l
3. Leak Dctcction Systems
4. Tailings Area Inspection (Note dispersal ol'blowing tailings):
J/0$ Revision: Denisonlf
Page 23 ol'33
Observation;
Cell I Cell 2 Cell 3 Cell 4A
Is LDS wet or dry'/wet dry wet-dry wet drv wet dry
If wet, Record
liouid level:
_Ft to
Liquid
_Ft to
I-iouid
Ft to
Liquid
--Ft
to
Li<ruid e
If sult'icient t'luid is
present. record
volumc of tluid
pumped and flow
ratei
Volume
Flow Rate
Volume
Flow Rate
Volume
-
Flow Rate
Volume
Flow Rate_
Was fluid sample
collccted ?
_yes_no _yes_no _yes_no yes_no
5. Control Methods Implemented:
6.
7.Contaminated Waste Dump:
x Docs lxvcl exceed l2 inches? *-*-* no '.-.---._ ycs
If cell 4A leak detection systr:m le vcl excccds I I inchcs. n$tily $upervisilr or Mill manager immediately.
White Mesa Mill - Standard Operating Procedures
Book I l: Environrnental Protectiorr Manual. Section 3.1
{/0$ l{evision : Denison-S,
Page 2.1 of 33
i oeletedr l
I o"t"t"ar J i_.1
I oeteted: z l.-_*=:J
fgg:!9qi.*- -- j
i Deleted: I I...)
APPENDIX A (CONT.)
NIONTHLY INSPECTION DATA
Inspector:
Date:
l. Slurry Pipeliue:
Pipe Thick
2. Diversion Ditches and Diversion Berm:
To be measured only during periods when the Mill is operating)
C)bservation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
C)bstruction of Flow
Diversion IJerm:
Stability Issues
Signs of Distress
Diversion Ditch I
_yes_noyes_no
_yes-_no
-yes-no
Diversion Ditch 2
_yes_noves no
_yes_no
--yes_no
Diversion Ditch 3 Diversion Berm 2
_yes_noves no
ves no
ves no
ves no
ves no
Commen
3. Summary of Activities Around Sedirnentation Pond:
White iVlesa iVIill - Standard Opcrating Procedures
Book I l: Environrnental Protection Manual, Section 3.1
4. Overspray Dust Nlinimization:
Overspray sysrem tirnctioning properly:
-yes-no
Overspray carried luore than 50 t'eet from the cell:
-yes_no
Il "yes". was system immediately shut ofP
-yes-no
J-IOI ltevision: Denisonl]
Page 25 of 33
5. Remarks:
6. SettJementilIonitors
Cell 2 Wl:
Cell 2 W2:
Cell 2 W3:
Cell 2 W4:
Cell2WT-C:
(lcU ? !vj-N"*--
Clell 2 W{iC:
Cell 2W5-N:{le[J_}"v7_$-_ _rsjllWfN
Ccll I W6S:(bil I w"lN.
Cell2W3-S:
Cell 2El-N:
Cell 2El-lS:
Cell2El-2S:
Cell 2 East:
Cell 3-lN:
Cell -l-lC:
Cell3-lS:
Cell 3-2N:
Cell4A-Toe:(1.:ll ? W4S:Ccll ? W5C:
Cell i-2S:
7. Summary of Daily, Weekly and Quarterly lnspections:
8. M<lntlrly Slimes Drain Static H€ad Nlensurement for Cell 2 (Depth-in-Pipe lYater Level
Reading):
White lvlesa Mill - StandaLd Operating Procedurcs
Book I l: Environmental Protection Marrual. Scction 3.1
l,/01! Re vi sion : Denison -9,
Page 26 of 33
APPENDIX A (CONT,)
WHITB MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY TNSPECTION DATA
Deleted: l
Inspector:
Date:
I l. f*bunkment Inspection:t*@l
| 2. OperationslMaintenanceReview:Li,@
| 1.. Construction Activites:Formatted! Bullets and
| 4. summary,tE;ffi,ffiffiffib.;il
I Wf,it" Mesa lvlilt - Stanclarcl Operating Procedures
Book ll: Environmental Protection Manual, Seotion .l.l "l/0$ Ite vision : Dcn isr.ln;f
Page 27 of 33
APPENDTX A (CONT.)
ORE STORAGE/SAMPI,E PI,ANT WEEKLY INSPECTION REPORT
Week of
-
through Date ol Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken tbr the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
ves: no:
comments:
Are all alternate feedstock materials located
within water-tight containers:
vcs: no:
outside the area indicated on the attached diagram maintained
comments (c.g., conditions of containers):
Conditions of storage areas tbr materials:
Othel comments:
White lvlesa iVlill - Standirrtl Opcrating Prtrcedules
Book I I: Environnrental Protection lvlanual, Section 3. I
J/0$Revision: Denisorrif
Prge 28 ol'.13 t.
I
APPENDIX B
IAILINGS INSPECTOR TRAINING
This document providos tlrc training necessary lbr qualifying management-designatcd individuals tbr
conducting daily tailings inspections. Training inlormation is presented by the Radiation Salety
Oflicer cir designee liom the Envitonmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Managemcnt System and Discharge Minimization
Teohnology (DMT) Monitoring Plan. The Radiation Sat'ety OtTicer or designee tiom the Radiation
Sat'ety Department is responsible tor pedbrming rnonthly ancl quarterly tailings inspections. Tailings
inspection forms will be included in the rnonthly tailings inspection reports, which summarizc the
conditions, activities, and areas ofconcern regarding the tailings areas.
Notifications:
The inspector is requilecl to record whether all inspection items are norrnal (satistactory, requiring no
acticln)orthatconditionsolpotentialconcernexist(requiringaction). A"check"markindicatesno
action required. lf conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specity tl-re corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is rcmediecl. The dates ol all corrective actions shoulcl be notcd on the rcports
as well.
Any major catastrophic cvcnts or conditions pcrtaining to the tailin-ss area sht'rul<l be rcportcd
immediatety to the Mill Manager or the Radiation Sat'ety Of t'icer. one of whom will notity Corporate
Management. Ilclam thilure occurs, notity your sLrpervisor ancl the Mitt Mana-9er immecliately. The
Mill Managcr rvill then notify Corporatc Mana-qement, MSHA (303-23 l-546-5), and thc State ol
Utah, Division oF Danr Sal'cty (801 -538-7200).
Inspections:
All areas ol'the tailings clisposal system arc routinely patrolled and visible obscrvations are to be
noted on a daily tailings inspection lorm. Reler to Appendix A lbr an examplc of thc claily tailin-us
inspection tilrnr. The inspcction lorm consists of three pagcs and is summarized as iirllclws:
l. Tailings Slurry 'fransport System:
Theslulrypipelineistobeinspectedforleaks,darrrage,andsharpbends. Thepipelinejoints
arc to be monitored tbr leaks, and loose connections. The pipeline supports are to be
Formatted: Font: (Defaul0 Times
New Roman, Not ltalic
White Mesa Mill - Standald Opcrating Procedures
Book I l: Envilonmental Protection Manual, Section 3.1
J/0S llevision: [)enisonll
Pagc 29 of 33
inspected lbr damage and loss of support. Valves are also to be inspected particularty tor
leaks, blocked valves, ancl closed valves. Points of discharge need to be inspected tbr
improper location and orientation.
Operational Systems:
Opcrating systcms including watcr lcvels, beach lincrs, and covcrcd areas arc itcms to bc
inspected and noted on the daily inspection fbrrns. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are obsel'ved as having cracks, severe
erosion or cavities are also items that requil'e investigation and notation on daily forms.
Exposed liner or absence ol cover tiom erosion are potential iterns of conccrn tbr ponds and
covered areas. These should also be noted on the daily inspection fbrm.
Cells l, 3 and 4A solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documentccl. In Cells I and 3, the
PVC liner needs to be monitored closely tbr exposed liner, especially al'ter storm events. [t is
irnportant to cover exposed liner immediately as exposure to sunlight will cause degradation
ol'the PVC liner. Small areas of exposed lincr should be covered by hand. Large sections of
exposcd liner will recluire the use of heavy equipment
These conditions are considered serious ancl require immediate action. At'ter these conditions
have been notcd to the Radiation Sat'ety Officer, a work orcler will be written by the
Radiation Salbty Ofl'icer and turned into the Maintenance Department. AlI such repairs
should be noted in the report and should contain the start and finish date olthe repairs.
Dikes and Embankments:
lnspection iterns include the slopes and the crests ofeach dike. For slopes, areas ol'concern
ar-o sloughs or sliding clacks, bulges, subsidcnce, sevcre erosion, rnoist areas, and arcas ol'
seepage outbreak. For crests, areas of conoern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3,4A-S and 4A-W, should be inspected closely tbr
micc holes and more importantly lor prairie do-u holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. Ii any ol these cclnditions exist, the inspection report
should be marked accordin-ely.
Florv Rates:
I oeleted: u
White Mosa Mlitl - Stanrtard Ope rating, Procedurcs
llook I l: Environnrental Protection lvlanual. Scction 3. I
,l/0$ Revision : Deni son-;f
Page 110 of -13
Presence of all tlows in ancl out o['thc cclls shoLrld be noted. Florv rates arc to bc estinlritc(l
in gallons per minute (GPM). Rates nced to he cletclmined l'ur slurry linos, pond return, SX-
tails, and thc spray systeln. During non-operational modes, thc t'low ratc colunrn should be
nrarked irs "0". Thc salnc holds truc when the splay systcm is not utilizetl.
Physical Inspection of Slurry Line(s):
A physical inspection ofall slurry lines has to be madeevery4 hoursduringoperation ofthe
mill. Il possiblc, the inspoction should inclucle obsel'vation ol'the cntire dischargo line. and
clischargc spill point into the ccll. If "fill to elevation" flags are in place, the tailings and
builcl-up is to be monitored and controlled so iis to not cover the t'lags.
Drrst Control:
Dusting and wincl movement of tailings should be noted fbr Cclls 2, 3, ancl 4A.. Other
observations to bc noted incluclc a briel description of present weather conditions, ancl a
record of any precipitation received. Any dusting or wind movement ol tailings should be
documcntecl. In addition, an estimirte should be made tbr wind speecl at the time ol the
observecl clusting or wind nlovement of tailings.
The Radiation Sat'ety l)epartment measures precipitation on a daily basis. Daily
measurements should be rnade as near to 8:00 a.m. as possible every day. Weekend
meilsurcmcnts will be taken by thc Shifter as close to 8:00 a.rn. .ls possible. All snow or ice
shoulcl be rnelted belbre a reading is taken.
Otrservations of Potential Concern:
All <lbservations of concern during the inspection should be noted in this section. Corrective
action should tbllow each alca of concorn notccl. All work ordcrs issucd, contacts, rx'
notilications made should be noted in this section as wcll. It is important to documcnt all
these iterns in orcler to assurc that thc tirilings managcment system rccords are complete and
accurate.
Map of Tailings Cells:
The last section ol the inspcction involves clrawing, as accurately as possiblc, thc tollorving
items where applicabtc.
i.
2.
3.
4
Cover arcit
Bcach/tailing sands area
Solution as it cxists
Pump lines
1 oeleted: z I
loeteted:: J.
I o.l.t"o, u I
j Deletedr r ;
IJ"rJt".*i.*- *----^ -l
(r.
7.
8.
White Mesa lviill - Standard Operating Proccdurcs
Book I l: Environrncntal Protection Manual. Section 3. I
//0_$ Re vision: Denisonl{.
Page3l oi33
9.
5. Activities around tailings cell (i.e. hauling trash to the dump, lincr repairs, etc.)
6. Slurry discharge when operating'7. Over spray system when operating
Safety l{ules:
AII sat'ety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations lor the tailings area. Please pay particular noticc to the
lbllowing rules:
l. Thepostedspeedlimitfolthetailingsareaisl5mphandshouldnotbeexceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a lour-wheel drive vehicle is required in the
alea.
7. Any work pertbrmed in which therc is a danger ol talling or slipping in ttre cell will
require the use o[ a sal'ety bclt or harness with attended lile line ancl an approved life
iacket. A portable eyewash must be present on site as wcll.
8. Anytime the boat is used to perfbrm any work; an approvpd lit'e jacket and goggles must
be worn at all times. There must also be an approved salety watch with a two-way hand-
held ladio on shore. A portable eycwash must be present on site as well.
Preservation of Wildlife:
Every et'fort should be made to pr€vent wildlitc and domesticated animals tiom entering the
tailings area. All wildlit'e observed should be reported on the Wildlife Report Worksheet
during each shifi. Waterfowl seen near the tailings cells should be discouraged li'om landing
by the use of noisemakers.
Certification:
Following the review ol this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to pertbrm daily tailings
inspections. Thc Radiation Sat'ety Of licer authorizes certil'ication. Ret'er to the Certil'ication
Form, Appe ndix C. This lbrm should be signed and dated only at'tor a thorough review of the
tailings infbrmation previously presented. The tbrm will then be signed by the Radiation
Sat'ety Ofticer and filed.
10.
11.
I oetetea: :
White Mesa Mill - Standarcl Operating Procedures
Book I l: Envilonmental Protection Manual, Section 3. I
l/0$ Revision: t)eni son-;l
Page 32 of 33
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Taiiings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation ol'daily tailings inspections, analysis of potential problems (dike
tailures, unusual t'lows), notitlcation procedures and sat-ety.
Signature
I certify that the above-named person is qualified to pertbrm the daily inspection of the tailings
system at the White Mesa Milt.
Radiation Safety Peruonnel/ Tailings Systcm
Supervisor
White Mlesa Mill - Standard Operating Procedures
Book I l: Environnrental Protcstion Manual, Section 3.1
//0$Revision: Denisonl{,
Page 33 of 33
APPENDIX D
FEEDSTOCK STORACE AREA Deleted: l
Cell4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division ol Radiation Control ("DRC) on June 25, 200'1 . The construction
authorization provided that Cell 44 shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370004 ("GWDP") and full fill the requirements of Parts
I.D.6, I.E.8, and I.F.8 of the GWDP.
Cell Desien
Tailings Cell 44. consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of tbur dikes, each including a lS-tbot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
I V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 2l 1-[eet at t]re west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 907o. Floor of
Cell 4A has an average slope of l%o that grades from the northeast to the
southwest corners.
c) Tailings Capacity - the f'loor and inside slopes of Cell 4.{ encompass about 40
acrcs and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot treeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high dcnsity polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchorcd in a ilench
at the top ol the dikcs on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
Page I
rlr'f ogw
Ya{,
Cell 4,A BAT Monitoring, Op.ro,inf Maintenance Plan
2) Leak Detection System - includes a permeable HDPE geonet labric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest cornei. Access to the leak
detection sump is via an l8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of l0 feet by 10 feet by 2 feet
deep. In turn, the gravel tilter layer will be enclosed in an envelope of
geotextile fhbric. The purpose of both the gravel and geotextile tabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top ofall fourdikes.
4) Geosynthetic CIay Liner - consisting of a manutacturcd geosynthetic clay
liner (GCL) composed of O.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 507o by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and perfbrated collection pipes both installed immediately above the primary
FML, as follows:
l) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the prirnary FML on 5O-t'oot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, tilled with filter sand covel the
strip drains. The sand bags are composed of a woven polyester fabric
lilled with well graded fllter sand to protect. the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perfbrated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
Page2
O"r,QO
cctt 4A BAT Monitorins, orr.l^tl.f iVlaintcnancr: Plan n.uf.o
by a layer o['non-wovon gcotextile to serve as an adclitional I'iltcr matcrial.
This perf'orated collcction pipe scrves as thc "backborle" to the slirncs
drain systcrn and runs ticlrn the far northeast corner downhill to the lar
southwcst corner ol' Coll 4A where it joins the slimes clrain access pipc.
3) Slirnes Drain Access Pipe - consisting oI an l8-inch ID Schedulc 40 PVC
pipe placecl clown the insiclc slope of Cell 44 at the southwest col'ner,
above the primary FML. Said pipe then mcrgcs with anot.her horizontal
pipe of equivalent diametcr and material, where it is cnveloped by gravel
and woven geotextile that serves as a clrshion to protect the primary FML.
A reducer connects the horizontal l8-inch pipe rvith the 4-inch SDC pipc.
At some future time, a pump will be set in this l8-inch pipe and used to
remove tailings wastewaters tbr purposes ol de-watering the tailings cell.
Dike Sptash Pads - A rninirnum ol' eight (8) lO-fbot widc splash pads are
installed on the interior dikc slopcs to protect the primary FML fiom abrasion
and scouring by tailings slurry. These pads will consist of an extra layer ol60
rrril HDPE membrane that will be placed down the inside slope ol Cell 4A,
t-rom the top of the dike and clown the insidc slope. Thc pads on the north side
o[ the Cell will extend to a point S-feet beyond the toe of the slope to protect
the liner bottom during initial startup of thc Cell. The exact location of the
splash pads is detailcd on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed ncar thc wcstcnl
corner of the north dike to allow emergency runolf tiom Cell 3 into Cell 4A'.
This spillway will be limited to a 6-inch reintbrced concrete slab set directly
over the primary FML in a 4-fbot cleep trapezoidal channel. No other spillway
or overf-low structure will be constructed at Cell 4A. All storrnwater runofl'
and tailings wastewaters not rctained in Cclls 2 and 3, will be managed and
contained in Cell 4.{, including the Probable Maximum Precipitation and
t'loocl event.
Cell Operation
Solution Discharge
Cell 4A will initially be used tbl storage and evaporation of proccss solutions
Irom the Mill operations. These process solutions will be fiom the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
evaporation poncl or the free watcr surlace f'rom Cell 3. The solution will be
punrpecl to Cei[ 4A through 6 inch or 8 inch diameter HDPE pipelines. The inititl
Xbt":L,n tt;scharrre w l_h"wcct_sgmqr_al-ills_(]qIlJf,&;|isgluggJ-ige
:vilf hc routed dt l'rxl*u*dg{l_rsru_sr.rnar,-efullr_]U(ll3a*p&ttst
the piplinc runring=kUt1fue* solgtlon rcclaim barge" lhU"t$jUlton*lydl*ile
tlnrbarsrd-ig-lhs-hattom s-l:hs-egll-lrwgy*-lpu-i$il*-til)d -h"ass*gl"*irhsr
instizlla.tieq *:n-lhe.trlp ql'the lr:h{I,. l}uildinsr tlrc solution orxrl frtlrn thajory cg{J ar!
{iaCell will allow_r}q $uluriltn p-t:l]I, djhajjsjsill$h
Page 3
c)
Ccll 4A flz\T Monitoling. op.:ru,iof Nlaintcnancc Plan rt."if.ri
,t-tgfi._g')*!1;;jgjltu&*e*y. *rftaim_ cr the _s;;d trag cilt{t*du{-1rl
so.l$!Llln_!10wing past lh* drain*ge stri$s.* . Thc solution will evsntuall), be
discharged along thc clike between Cell 3 and Cell 4A, utilizin-e the Splash Pads
dcscribed above. Therq$h eqQc-xrt dischargc of process solutions will bepear thc
tloor ol' the poncl, through a discharge header designed to discharge through
multiple points, thereby rcclucing the potential to damagc the Splash Pads or the
Sli mes Drain system. AU:g tiulq-xdilhu_$ltutll;l:_I,t dischrrgEd intCI le
I_tg!"glfglglg&*As the cell begin to fill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharge
Once Cell 4A is needed for storage tbr tailings solids the slurry discharge tiom
No. 8 CCD thickener will bc pumpcd to thc ccll through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cetl 44, with discharge valves and drop pipes extending down the Splash Pacls to
the solution level. One or all ol'the discharye points can be used depcnding on
operational sonsiderations. Solids will scttle into a cone, or mound, o[ matcrial
under the solution level, with the courser lraction settling out closer to the
discharge point. The initial discharge locations are shown on Figurc L Figure 2
illustrates the general location o[ the solution and slurry discharge pipclines and
control valve locations. The valves are 6" or 8" stainless steel knitb-gate valves.
The initial discharge of slurry will be at or near the toe ol the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Figure 2. Because ol the depth of
Cell 4A, cach of the discharge points will be utilized fur an cxtended period of
time befbre the cone of material is above the maximurn leveI oI the solution. The
clischarge location will then moved turther to the interior of the cell allowing lor
additional volume ot'solids to be placed under the solution levcl. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporation rates. The tailings slurry will not be allowed to discharye
directly on to the Splash Pads, in order to lurther protcct the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equ.ipment Access
Access will be restricted to the interior portion of thc ccll due to the potential to
clamagc the t'lexihle membrane liner. Only rubber tired all terrain vehicles or tbot
tra{fic will bc allowed on the f]cxiblc membrane liner. Personnel are also
cautioned on the potential darnage to the flcxible membrane liner through the use
and handling ol hand (ools and maintenance materials.
Reclaim Water S
Page 4
i Deleted: inirirt
1 Deleted: at or
Cell 4,A BAT Monitoring, op..o,lfir Maintenancc Plan o."Jo
A pump barge and solution recovery system will be installed in the southwest
corner ol the cell to pump solution lrom the cell tbr water balance purposes or tbr
re-use in the Mill process. Figure 3 illustrates thc routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the tlexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activitics.
The condition o[ the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharge
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4A'. C)nce the tailings solids have been deposited along the north and
east sides of'the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential tbr damage to the liner system.
Liner Maintenance and OA/OC
Any construction defbcts or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the apprioved Revised construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailinss Cell4A
DUSA will operate and maintain Tailings Cell 4A so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H. l9 of the GWDP. These performance
standards shall include:
Leak Detection System Pumping and Monitoring Equipment - the leak
detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and tlow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondary llexible
menbrane.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary f lexible membrane by the use of
procedures and equipment specitied in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3107 Revision: Denison-3, or the currently
Page 5
r)
2)
Ccll4A BAT Monitoring, op.r.,i,Q Maintenanco Plnn n.,,if.o
approved DMT Plan. Under no circumstance shall fluid head in the lcak
detection system sump exceed a 1-fbot level abovc the lowest point in
the lower Uexible membrane liner.
3) Maximum Allowable Daily LDS Flow Rates - the Permittec shall
measure the volume of all tluids pumped from the LDS on a weekly
basis, and use that inlormation to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS tlow volume will
bc compared against the measured cell solution levels detailed on the
attached Table I to determine the maximum daily allowable LDS ilow
volume tbr varying head conditions in the cell. .
4) 3-fbot Minimum Vertical Freeboard Criteria - the Pemittee shall
operate and maintain wastewater levels to provide a 3-fbot Minimum ol'
vertical fr-eeboard in Tailings Cell 4A.. Said measurements shall be
made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring - immediately afier the
Permittee initiates pumping conditions in the Tailings Cell 4A slimes
drain system, monthly l'ecovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain systern will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occuffences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look fbr events
involving the routine placement of tailings material as well as events that could al'fect the
integrity of the tailings cell dikes or lining sysiems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements in Cell 4A are to be taken by survey on a weekly basis as tbllows:
(i) The survey will be perfbrmed by the Mill's RaOiation Sat'ety Oificer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant");
(ii) The survey will be perfbrmed using a survey instrument (the "Survey
Instrument") accurate to 0.01 t'eet, such as a Sokkai No. 82l , or
cquivalent, togcthcr with a survey rod (the "Survey Rod") having a visible
scale in 0.0 I fbot increments;
Page 6
Cell 44 BAT Monito.ing, on"rn,ifl Matntenancc Plan ,r.fro
(iii)The rel'erence Points (the "Rcl'crence Points") tbr Cells 44. are known
points cstablishcd by Rcgistercd Land Sulveyot'. For Ccll 44, thc
Retbrence Point is a piece ol metal rebar located on the dike between Cell
3 and Cell 4A.. The elevation at the top ol'this piece of rebar (the
Relerence Point Elevation for Cell 4A is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The Surveyor will set up the Survey Instrument in a location where both
the applicable Ret'erence Point and pond surface are visible. For Celt 4A,
this is typically on the road between Cell 3 and Cell4A, approxirlatcly 100
feet east ol the Cell 44. Ret'erence Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
lcvel by centering thc bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell44.
Reference Point. The Assistant will ensure thar the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of f'eet the Sur-vey Instrument is
reading above the Ret'erence Point:
The Assistant will then move to a designated location where the Survey
Rod can be placed on the sur[ace of the main solution pond in Cell 4A.
The designated location tbr Cell 44, is in the northeast coffrer of the Cell
where the side slope allows for safe access to the solution surtace.
The approximate coordinate locations tbr the measuring points lor Cell 44
is 2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant wilt hotcl the Survey Rod vertically with one end ol the
Survey Rod just touching the pond surlace. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and tbrth until
the Surveyor has established a level readingl
(viii) The Surveyor will tbcus the cross hairs of the Survey Instrument on the
scale on the Sulvey Rod, and record the number (the "Pond Surface
Reading"), which represents the number ol't'eet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surthce in tber amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surtace Reading tbr the Cell, and wilI record the number accurate to
0.01 lbet.
Leak Detection Svstem
Page 7
Cell4,A BAT Vlonitoring, op"rn,,oQ Maintenancc Plan R.,rf.o
The Leak detection system will be monitored on a weekly basis tbr the
presence ol tailings solution between the HDPE liners. The presence of
solution will be determined by use of a "blow pipe" to detect the presence
of solution in the bottom ol thc leak detection sump. The blow pipe is
constructed ol % inch diameter schedule 40 PVC pipe. The bottom of the
blow pipe extends to the lowest level of the leak detection sump (elevation
5562._), and the top of the blow pipe extends approximately I fbot out of
the top of the leak detection access riser pipe (elevation 5603._). The top
several f'eet of the blow pipc is marked in 1.0 inch increments tbr
measurement of the solution level. On a weekly basis, the water level will
be checked by the Inspector. The inspector will start with the blow pipe
extended to the lowest level ol the leak detection sump and begin blowing
into the pipe, while slowly pulling rhe pipe up the leak detection access' riser'. As soon as the Inspector stops hearing bubbles t-rom the access riser,
the bottom of the blow pipe is at or near the level of the solution in the
leak dctection sulnp. The Inspector will nrove the blow pipe slowly up
and down the access riser, while blowing in the pipe, to ensure that the
level of the solution is accurately measured. Once the solution level is
accurately determined, the Inspector will record the water level reading on
the weekly inspection tbrm.
The leak detection systom is equipped with a leak detection pump,
Tsurumi Model # KTZ23.1-62 stainless steel, or equal. The pump is
capable of pumping in excess ol 20 gallons per minute at a total dynamic
head of 50 feet. The pump has a 2 inch diameter discharge, and operates
on 460 volt 3 phase power. The pump is equipped with level probes to
start the pump once the level ol'solution in the leak de[ection sump is
more than I fbot above the lowest level of the leak detection sump. The
purnp will operate until the solution is drawn down to the lowest level
possible. The pump discharge is equipped with a 2 inch tlow meter, E/H
Model #33, that reads the pump discharge in gallons per minute, and
records total gallons pumped. Thc flow ratc and total gallons is recorded
by the Inspector on the weekly inspection tbrm.
A second leak detection pump and tlow meter will be maintained in the
Mill warehouse [o ensure that the pump can be replaced and opelational
within 24 hours of detection ol'a lailure o['thc pumping system. The loot
cause of the equipment failurc will be documcnted in a report to Mill
management with recommendations lor prevention ol a re-occurrence.
Slimes Drain System
Pase 8
celt 4A Br\T &tonitoring, op...o,ifo Maintcnitnce Plan o",f.o
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or cqual, will be
placecl inside of the slimes drain access riser pipc and a near as possible to
the bottom of the slimes drain sump. The bottom ol the slimes drain sump
is 38 f'eet below a water level measuring point at the centerline o[ the
slimes drain access pipe, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter, E/H Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The t'low rate and total gallons will be recorded by
the Inspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4.A slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set prtperly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within l5 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. All head
measurements must be made tiom the same measuring point, to the
nearest 0.01 tbot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize tbr
. at least 90 hours. Once the water level has stabilized (based on no change
in water level fbr three (3) successive readings taken no less than one (l)
hour apart) the water level of the wastewater will be measurcd and
reconded as a depth-in-pipe measurement on the Monthly Inspection Data
fbrm, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional proce- 'olutions will be discharged to Cell 4A,, and
the Cell has been partially covered with the tirst phase ol the reclamation cap.
The long term eflbctiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operatinp slimes drain system for
Cell2.
Tailings Emersencies
Inspectors will notify the Radiation Saf'ety OtTicer and/or Mill management immediately
it', during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Sat'ety Officer, inspectors will have the authority to
d i rect resources du ri ng tai I i n gs emergencies.
Page 9
Cell44. BAT MonitoLins. Op.ruti,,Q Maintenance Plan rr.uif.o
Any major catastrophic events or conditions pertaining to the tailings ar.ea should be
reported immediately to the Mill Manager or the Radiation Satbty Otficer, one o[ whom
will notify Corporate Management. Ildarn tailurc occurs, notity your supervisor and the
Mill Manager immediately. The Mill Manager will then notity Corpomte Management,
MSHA {303-231-5465), and the State of Utah, Division of Dam Sat'ety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells l-1, Cell 2, Cell 3 and Cell 44
are regulated by condition 10,3 of the White Mesa Mill I I e.(2) Materials License.
Condition 10.3 states that "Freeboard limits for Cells 1-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13,1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell 3 shall be recalculated annually in accordance with the procedures set in the
October 13, 1999 revision to the Drainage Report." The 1990 Drainage Repoft uses
the Local 6-hour Probable Maximum Precipitation (PMP) event fbr calculating the
f'reeboard requirements fbr each of the tailings cells. The PMP for the White Mesa site is
l0 inches.
Based on the PMP storm event, the freeboard requirement fbr Cell I is a maximum
operating water level of 5615.4 f'eet above mean sea level (amsl). The Cell I freeboard
limit is not at-tected by operations or conditions in Cells 2,3 or 4A.
Cell 2 has no treeboard limit because the Cell is 99?o full of tailings solids and all
precipitation talling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The tlood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet o[ water. According to the frceboard
calculation procedures, this volume currently r:rust be contained in the existin g24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 44 design includes a concrete spillway between Cell 3 and Cell 4A with rhe
invert elevation 4 feet below the top ol the Cell 3 dike, at an elevarion of 5604.5 feet
amsl. Once Cell 44 is placed in operation, the cell would be available tbr emergcncy
overl'lows from Cell 3, but as long as the fieeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 4,{ would see any overtlow water tiom Cel[ 3 unless the
tull PMP event were to occur. Should Cell 3 receive the full PMP volume of 123.4 acre
t'eet ol'water, approximately 62 acre f'cet of that volume would tlow through the spillway
into Cell4A..
The flood volume iiom the PMP event over the Cell 44. area is 36 acre-t'eet ol water (40
acres, plus the adjacent drainage arca of 3.25 acres, times the PMP of' l0 inches). This
Page l0
Cell 4.A, BAT Monitorins, OueraLifl Maintenrncc Plan n""fr o
would result in a total ilood volume o['98 acre-f'eet, including the 62 acre-ttet ol solution
lrom Cell 3. The lrccboarcl depth required tbr Cell 4A l'rom the PMP cvcnt would be
2.44 teet, plus a wave run-up depth of 0.11 leet (from the 1990 Drainage Report), tbr a
total tieeboard requirement o[ 3.2 t'eet. This calculation i.s illustrated on Attachment 4.
The Groundwater Quality Discharge Permit, No. UGW370004, lor the White Mesa Mill
requires thar the rninirrurn freeboard be no less than 3.0 f'eet tbrany olthe existingCell
construction, but based on the above calculation the t'reeboard would be set 3.2 t'eet
below the top oI liner. The fleeboard tbr Cell 4A. would theretbre be 5595.3 amsl (top of
liner 5598.5 - 3.2 {eet). Figure 5, Hydraulic profile Schematic, shows the rclationship
between the Cells, and the relative elevations o[ the solution pools and the spillway
elevations.
If Cell 4A were requircd to store the entire PMP event for Cell 2, Cell3 and Cell 4A, the
required stomge volume would be approximately 160 acre-f'eet o[ solution. This would
increase the necessary freeboard to 4.17 feet.
The required t'reeboard fbr Cell 4A. will be recalculated annually along with the re-
calculation of the Cell 3 freeboard requircment. A calculation of the current fieeboard
calculationforbothCellsisattachedtothisPlan
Attachments
1) Figure Filling Plan, GeoSyntec Consultants
4)
s)
6)
7)
2)
3)
Figure 2, tnitial Filling Plan, Details and Sections, GeoSyntec Consultants
Figure 3, Initial
Consultants
Solution and Slurry Pipeline lloutes, Geosyntec
Figure 4, [nterim Filling Plan, GeoSyntec Consultants
Figure 5, Hydraulic Profile Schematic
Cell 3 and Cell 4A Freeboard Calculation
Table l, Calculated Action leakage Rates lbr Various Head Conditions,
Cell 4.A., White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
White Mesa Mill Tailings Management System and Dischargc Minimization
Technology (DMT) Monitoring Plan, 3/07 Revision: DUSA-2, 32 pages. or
Cg11qntlv approvcd vcrs
Page I I
I,
-'la
Dave Rupp - Re: Cell4A BAT Monitoring, Operations and Maintenance Plan
Page I of I
From: "Harold R. Roberts" <[e-mail]>
To: "'Dave Rupp"' <[e-mail]>Date: WZnoogs:oz Ptr,t
Subject: Re: Cell4A BAT Monitoring, Operations and Maintenance Plan
CC: <[e-mail]>, "'Rich Bartlett"' <[e-mail]>,
"'Loren Morton"' <lmorton @ utah. gov>, "'Dane Finerfrock"' <dfinerfrock @ utah. gov>
Attachments: 200807 02170205.pdf
Dave:
Attached is the revised copy of the Cell 4A BAT Monitoring, Operations and Maintenance Plan. I believe this
addresses all of the changes and comments in your June 6th letter to Steve Landau. The proposed modifications
to the DMT plan will be forwarded to you tomorrow or Monday. I willcall you nelt week to discuss the revised
plan and hopefully address any additional comments or questions.
Regards,
iia.c-.1C P.. Rober:s
i..l.rO('.r'..:'.,r, .,'i,-.c >rr-iSi<.j,,':L LIS L)p{]rat:iOn:,;
lJ+i:l:l rion i:.i.:res (risA) L-o::p.
Itt)]) 3119 I:(,tj
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file://C:\Documents and Settings\Drupp\Local Settings\Temp\XPgrpwise\4868B5E9EQD... 7ll0l2008
o
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Construction of Cell 44. was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007, The construction
authorization provided that Cell 4,A' shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW37O0O4 ("GWDP") and full fill the requirements of Parts
I.D.6, LE.8, and I.F.8 of the GWDP.
Cell Desien
Tailings Cell 4A consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
lV. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 907o. Floor of
Cell 4A has an average slope of l%a that grades from the northeast to the
southwest corners.
c) Tailings Capacity - the floor and inside slopes of Cell 44 encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 44, floor
area. In other locations, the primary FML will be in contact with theslimes drain collection system (discussed below).
Page I
Cell4A BAT Monito.ing,Q.utions and Maintenance Plan Revision 1.0
2) Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 44, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an l8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A' floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 44, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least SOVo by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
l) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
sumounded by an envelope of non-woven geotextile filter fabric. The su'ip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
Page 2
Cell 4A BAT Monitorlng, lurions and Maintenance Plan Revision 1.0
by a Iayer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cetl 44, where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 44, at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal 1S-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this l8-inch pipe and used to
remove tailings wastewaters for purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) l0-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 4A,,
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure wiil be constructed at Cell 4,\. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and 3, will be managed and
contained in Cell 4A., including the Probable Maximum Precipitation and
flood event.
Cell Operation
Solution Discharge
Cell 44. will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 44. through 6 inch or 8 inch diameter HDPE pipelines. The
solution will be discharged along the dike between Cell 3 and Cell 4A, utilizing
the Splash Pads described above. The initial discharge of process solutions will
be at or near the floor of the pond, through a discharge header designed to
discharge through multiple points, thereby reducing the potential to damage the
Splash Pads or the Slimes Drain system. As the cell begin to fill with solution the
discharge point will be pull back up the Splash Pad and allowed to continue
s)
Page 3
Cell4,A. BAT Monitoring, |ations and Maintenance Plan Revision 1.0
discharging at or near the solution level.
Initial Solids Discharge
Once Cell 4,A is needed for storage fol tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell4A, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1. Figure 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Figure 2. Because of the depth of
Cell 44, each of the discharge points will be utilized for an extended period of
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved further to the interior of the cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporation rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to further protect the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
Reclaim Water System
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3 illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Page 4
Cell 4A BAT Monitor,n*, Oo,ions and Maintenance Plan Revision 1.0
Interim Solids Discharge
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4,{. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and OA/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailines Cell4A
DUSA will operate and maintain Tailings Cell 4.A' so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.19 of the GWDP. These performance
standards shall include:
Leak Detection System Pumping and Monitoring Equipment - the leak
detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondary flexible
menbrane.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3/07 Revision: Denison-3, or the currently
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a l-foot level above the lowest point in
the lower flexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis., and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will
1)
2)
3)
Page 5
Cell 4A BAT Monitoring, futlons and Maintenance plan Revision I.0
be compared against the measured cell solution levels detailed on the
attached Table 1 to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
3-foot Minimum Vertical Frceboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4A.. Said measurements shall be
made to the nearest 0.1 foot.
Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell 4,{ slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors ale trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection rcports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements in Cell4,{ are to be taken by survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation safery officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant");
(ii) The survey will be performed using a survey instrument (the "survey
Instrument") accurate to 0.01 feet, such as a Sokkai No. 82l, or
equivalent, together with a survey rod (the "survey Rod") having a visible
scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 4A are known
points established by Registered Land Surveyor. For Cell 4A,, the
Reference Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4,A. The elevation at the top of this piece of rebar (the
Reference Point Elevation for cell4A is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The surveyor will set up the survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 44,
4)
s)
Page 6
Cell4A BAT Monitoring, fu,lons and Maintenance Plan Revision 1.0
this is typically on the road between Cell 3 and Cell4A, approximately 100
feet east of the Cell 4A Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell4A
Reference Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Reference Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell 44.
The designated location for Cell 4A is in the northeast corner of the Cell
where the side slope allows for safe access to the solution surface.
The approximate coordinate locations for the measuring points for Cell 44
is2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant will hold the Survey Rod vertically with one end of the
Survey Rod just touching the pond surface. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surface
Reading"), which represents the number of feet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surface in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
Leak Detection Svstem
The Leak detection system will be monitored on a weekly basis for the
presence of tailings solution between the HDPE liners. The presence of
solution will be determined by use of a "blow pipe" to detect the presence
of solution in the bottom of the leak detection sump. The blow pipe is
constructed of Yz inch diameter schedule 40 PVC pipe. The bottom of the
blow pipe extends to the lowest level of the leak detection sump (elevation
PageT
Cell4A BAT Monitoring, fi,ions and Maintenance Plan Revision 1.0
5562.-), and the top of the blow pipe extends approximately I foot out of
the top of the leak detection access riser pipe (elevation 5603.--). The rop
several feet of the blow pipe is marked in 1.0 inch increments for
measurement of the solution level. On a weekly basis, the water level will
be checked by the Inspector. The inspector will start with the blow pipe
extended to the lowest level of the leak detection sump and begin blowing
into the pipe, while slowly pulling the pipe up the leak detection access
riser. As soon as the Inspector stops hearing bubbles from the access riser,
the bottom of the blow pipe is at or near the level of the solution in the
leak detection sump. The Inspector will move the blow pipe slowly up
and down the access riser, while blowing in the pipe, to ensure that the
level of the solution is accurately measured. Once the solution level is
accurately determined, the Inspector will record the water level reading on
the weekly inspection form.
The leak detection system is equipped with a leak detection pump,
Tsurumi Model # KTZ23.7-62 stainless steel, or equal. The pump is
capable of pumping in excess of 20 gallons per minute at a total dynamic
head of 50 feet. The pump has a 2 inch diameter discharge, and operates
on 460 volt 3 phase power. The pump is equipped with level probes to
start the pump once the level of solution in the leak detection sump is
more than I foot above the lowest level of the leak detection sump. The
pump will operate until the solution is drawn down to the lowest level
possible. The pump discharge is equipped with a 2 inch flow meter, E/FI
Model #33, that reads the pump discharge in gallons per minute, and
records total gallons pumped. The flow rate and total gallons is recorded
by the Inspector on the weekly inspection form.
A second leak detection pump and flow meter will be maintained in the
Mill warehouse to ensure that the pump can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.
Slimes Drain System
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe and a near as possible to
the bottom of the slimes drain sump. The bottom of the slimes drain sump
is 38 feet below a water level measuring point at the centerline of the
slimes drain access pipe, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter, E/H Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
Page B
Cell4,A BAT Monitorirg, ;r,ions and Maintenance Plan Revision 1.0
total gailons pumped. The flow rate and total gallons will be recorded by
the lnspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within t5 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. All head
measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (l)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional process solutions will be discharged to Cell4A, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Page 9
Cell 4A BAT Monitoring, Oorions and Mainrenance Plan Revision 1.0
Cell 4,4. Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-I, Cell 2, Cell 3 and Cell 4A
are regulated by condition 10.3 of the White Mesa Mill I 1e.(2) Materials License.
condition 10.3 states that "Freeboard limits for Cells 1-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13, L999
revisions made to the January 10, 1990 Drainage Report. The freetroard limit for
Cell 3 shall be recalculated annually in accordance with the procedures set in the
October l3r1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local 6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
10 inches.
Based on the PMP storm event, the freeboard requirement for Cell I is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell I freeboard
limit is not affected by operations or conditions in Cells 2, 3 or 4A.
Cell2 has no freeboard limit because the Cell is 99Vo full of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing 24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 4,{ design includes a concrete spillway between Cell 3 and Cell 4.A. with the
invert elevation 4 feet below the top of the Cell 3 dike, at an elevation of 5604.5 feet
amsl. Once Cell 44 is placed in operation, the cell would be available for emergency
overflows from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 4A would see any overflow water from Cell 3 unless the
full PMP event were to occur. Should Cell 3 receive the full PMP volume of 123.4 acre
feet of water, approximately 62 acre feet of that volume would flow through the spillway
into Cell4,A'.
The flood volume from the PMP event over the Cell 44. area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). This
would result in a total flood volume of 98 acre-feet, including the 62 acre-feet of solution
from Cell 3. The freeboard depth required for Cell 4,A from the PMP event would be
2.44 feet, plus a wave run-up depth of 0.77 feet (from the 1990 Drainage Report), for a
total fieeboard requirement of 3.2 feet. This calculation is illustrated on Attachment 4.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum fieeboard be no less than 3.0 feet for any of the existing Cell
Page 10
Cell44. BAT Monitoring,Oo,ions and Maintenance Plan Revision 1.0
constrlrction, but based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The freeboard for Cell 44' would therefore be 5595.3 amsl (top of
liner 5598.5 -3.2feet). Figure 5, Hydraulic profile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4,A were required to store the entire PMP event for Cell 2, Cell3 and Cell 4A., the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboardto 4.71 feet.
The required freeboard for Cell4A will be recalculated annually along with the re-
calculation of the Cell 3 freeboard requirement. A calculation of the cument freeboard
calculation for both Cells is attached to this Plan.
Attachments
Figure l, Initial Filling Plan, GeoSyntec Consultants
Figure 2,Initial Filling Plan, Details and Sections, GeoSyntec Consultants
Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
Figure 4,Interim Filling Plan, GeoSyntec Consultants
Figure 5, Hydraulic Profile Schematic
Cell3 and Cell44. Freeboard Calculation
7) Table 1, Calculated Action leakage Rates for Various Head Conditions,
Cell4A,, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
8) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan,3lA7 Revision: DUSA-2, 32pages
1)
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Table L
Calculated Action Leakage Rates
for Various Head Conditions
Gell 44 White Mesa Mill
Blanding, Utah
GeoSyntec Consultanls
Head Above Liner
Svstem lfaatl
calculated Action Leakage
Rate (oallons/acre/davl
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
leak detection system geonet062006.xls 1of1 8123t2006
Action Leakage Rate
Calculations
Geosyntec Consultants
700
.E H 600
€issoo-ctro*E-gaoo
E 8,! .oo*>tu- E-9200ohtrE 100
0
1zls1 o'
ALR/FS vs Varying Head Conditions
10 20 30
head above primary geomembrane (fl)
7.00
6.00
5.oo F(E4.00 u,
o3,00 5
2.oo f
1.00
0.00
(s
Leachate Flow Through GConremErane DetrA
vatue Unils variable Deflnition
60 mil d
defect diameter (EPA HELP
Model assumes equal to
lhickness of oeomembrane)
60 60 60 60 60 60 60
1.524 mm d Cefect diam€ter 't.524 1.524 1.524 1.524 1.524 1.524 1.5240.0015 m d Jefect diameter 0.0015 0.0015 0.0015 0.0015 0.0015 0.0015 0.00159.8067 m/s2 q acceleration due to oravifu 9.8067 9.8067 9.8067 9.8067 9.8067 9.8067 9.8067
37 ft hrin
read of leachate on top of
:he primary liner (max height
rf 40' - freeboard of 3')
5 10 15 20 25 30 35
't1.2776 m hpm h€ad of lsachate on top of
lhe orimarv liner 1.524 3.048 4.572 6.096 7.62 9.144 10.668
1.638-O5 n3/sec 5.99E-06 8.47E-06 .05 r.zoE-o5 1-34 1.47E-05 1.58E.
leak detection system geonet0620o6.xls 8123t2006
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DEN,soJr/l,ltNEs
klk.,.
Steven D. Landau
Manager, Environmental Affairs
Cc. Ron Hochstein
Harold Roberts
David C. Frydenlund
David Turk
Donbon tlml (USA) Corp.
f 050 lnh Stn t,Sui!.950
Drnvrr, CO EOru
USA
Trl:30lt62t779t
Fu : 303 38$4125
wuw.de nLonmlncc.com
March 28,2008
Sent Via Federal Express
Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
salt Lake city, uT 84114-4810
Dear Mr. Finerfrock:
Re: White Mesa Uranium Mill-Tailings Cell 4A BAT Operations and Maintenance Plan
Please find enclosed the Best Available Technology (BAT) Operations and Maintenance Plan for Cell
4A at the White Mesa Uranium Mill. The submission of this Plan fulfills the requirement of Part
I.H.lg of Groundwater Discharge Permit UGW370004 pertaining to the facility.
If you should have any questions regarding this Plan please contact me.
Yours very truly,
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of cell 4,\ was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2006. The construction
authorization provided that Cell 44. shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370004 ("GWDP") and full fill the requirements of Parts
I.D.6, I.8.8, and I.F.8 of the GWDP.
Cell Desien
Tailings Cell 4,A. consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a l5-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
1V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to Zll-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 9OVo. Floor of
Cell 44 has an average slope of l%o thaL grades from the northeast to the
southwest corners.
c) Tailings Capacity - the floor and inside slopes of Cell 44, encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection
Page I
system (discussed below).
Cell 4A BAT Monitoring, fiurions and Maintenance Plan Revision 1.0
2) Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 44, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an l8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4.A. floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4.A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 5OVo by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 44, that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on SO-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
Page2
Cell4A BAT Monitorlng, fu,ions and Maintenance Plan Revision 1.0
by a layer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cell 4A where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an l8-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal 18-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this l8-inch pipe and used to
remove tailings wastewaters for purposes of de-watering the tailings cell.
North Dike Splash Pads - three 20-foot wide splash pads constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings
slury. These pads will consist of an extra layer of 60 mil HDPE membrane
that will be installed in the anchor trench and placed down the inside slope of
Cell 4A, from the top of the dike, under the inlet pipe, and down the inside
slope to a point S-feet beyond the toe of the slope.
Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4,A'.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 4A,. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and 3, will be managed and
contained in Cell 4A,, including the Probable Maximum Precipitation and
flood event.
CellOperation
Solution Discharge
Cell 44 will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 4A through 6 inch or 8 inch diameter HDPE pipelines. The
solution will be discharged along the dike between Cell 3 and Cell 44, utilizing
the Splash Pads described above. The initial discharge of process solutions will
be at or near the floor of the pond, through a discharge header designed to
discharge through multiple points, thereby reducing the potential to damage the
Splash Pads or the Slimes Drain system. As the cell begin to fill with solution the
discharge point will be pull back up the Splash Pad and allowed to continue
discharging at or near the solution level.
s)
Page 3
Cell4A BAT Monito.ing, turions and Maintenance Plan Revision 1.0
Solids Discharge
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 44, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge location are shown on Figure 1. Because of
the depth of Cell 4,{ each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then moved further to the interior of the cell
allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
Reclaim Water System
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. The pump will be constructed and maintained to
ensure that the flexible membrane liner is not damaged during the initial filling of
the cell or subsequent maintenance activities. The condition of the pump barge
and access walkway will be noted during the regular scheduled cell inspection.
Liner Maintenance and OA/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the cell 4A Lining System, Nday 2007,
by GeoSyntec Consultants.
Page 4
t I cell4A BAT Monitoring, turions and Maintenance Plan Revision 1.0
BAT Performance Standards for Tailines Cell4A
DUSA will operate and maintain Tailings Cell 4A so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.19 of the GWDP. These performance
standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment - the leak
detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and flow meter. The pump controller is set to maintain the
maximum level in the leak detection system at no more than 1 foot
above the lowest level of the secondary flexible menbrane.
2) Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,2/07 Revision: DUSA-2. Under no
circumstance shall fluid head in the leak detection system sump exceed a
1-foot level above the lowest point in the lower flexible membrane liner.
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,L6O gallons/day. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table 1 to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
4) 3-foot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4,A,. Said measurements shall be
made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell4,A. slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary.
Page 5
I (
cell4,A. BAT Monito.ing, il",ions and Maintenance Plan Revision 1.0
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed by the Mill Manager.
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-I, Cell 2,Cell3 and Cell4,{
are regulated by condition 10.3 of the White Mesa Mill 1 le.(Z) Materials License.
Condition 10.3 states that "Freeboard limits for Cells l-1r3, and 4A, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13,1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell3 shall be recalculated annually in accordance with the procedures set in the
October l3r1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
10 inches.
Based on the PMP storm event, the freeboard requirement for Cell I is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell I freeboard
limit is not affected by operations or conditions in Cells 2, 3 or 4,\.
Cell2 has no freeboard limit because the Cell is 99Vo fuJl of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume from the PMP event over the Cell2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing Z4-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
Page 6
Cell4A BAT Monitoring, fi,ions and Maintenance Plan Revision 1.0
The Cell 4A design includes a concrete spillway between Cell 3 and Cell 44' with the
invert elevation 4 feet below the top of the Cell 3 dike, at an elevation of 5606 feet amsl.
Once Cell4,{ is placed in operation, the cell would be available for emergency overflows
from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6 it is
extremely unlikely that Cell4,{ would see any overflow water from Cell 3. Should Cell
3 receive the full PMP volume of 123.4 acre feet of water, approximately 44 acre feet of
that volume would flow through the spillway into Cell4,A'.
The flood volume from the PMP event over the Cell 4,A, area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). This
would result in a total volume of 80 acre-feet including the 44 acre-feet of solution from
Cell 3. The freeboard depth required for Cell4,A. from the PMP event would be 2.0 feet,
plus a wave run-up depth of 0.77 feet (from the 1990 Drainage Report), for a total
freeboard requirement of 2.77 feet. However, the Groundwater Quality Discharge
Permit, No. UGW3700O4, for the White Mesa Mill requires that the minimum freeboard
be no less than 3.0 feet for any of the existing Cell construction. The freeboard for Cell
4,{ would therefore be 5595.0 amsl (top of liner 5598.0 - 3.0 feet). This freeboard
elevation would provide a factor of safety of 1.1 for storm events above the PMP, and
therefore there are no anticipated conditions that could result in overtopping of the cell.
If Cell 4,\ were required to store the entire PMP event for Cell 2, Cell3 and Cell 44, the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboardto 4.'77 feet.
In the unlikely event the PMP storm event is exceeded, Cell 44 could handle an
additional 13.5 acre-feet of water before overtopping would occur.
The required freeboard for Cell4,A. will be recalculated annually along with the re-
calculation of the cell 3 freeboard requirement, but the current freeboard requirement is
3.0 feet according to the GWDQ requirement.
Attachments
1)
2)
Figure 1, Initial Filling Plan, GeoSyntec Consultants
Table l, Calculated Action leakage Rates for Various Head Conditions, cell
4A, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan,2107 Revision: DUSA-2,25 pages
3)
PageT
Table L
Calculated Action Leakage Rates
for Various Head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
GeoSyntec Consultants
Head Above Liner
Svsfam lfaetl
Calculated Action Leakage
Rate (oallons/acre/dav)
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 ou4.u1
leak detection system geonet062006.xls 1of 1 8t23t2006
Geosyntec ConsultantsAction Leakage Rate
Calculations
7.00
6.00
5oo E(lt4.00 u,
o3.00 5
2.oo $
1.00
0.00
700
.t 600'-oI E; soo-ctr(uaflg+oo
i' B, E .oo
= >.!3!9200OEtr'E 100
0
ALR/FS vs Varying Head Conditions
10
head above primary geomembrane (ft)
3020
Q = (2/3) d2 (s
Leachate rlow Throuqh Geomembrane Defect
Value Units Variable Definition Additional values
60 mil d
lefect diameter (EPA HELP
Vlodel assumes equal to
,hickness of qeomembrane)
60 60 60 60 60 60 60
1.524 mm d iefect diameter 1.524 1.524 1.524 1.524 1.524 1.524 1.524
0.0015 m d lefect diameter 0.0015 0.0015 0.0015 0.0015 0.0015 0.0015 0.0015
9.8067 mls2 q rcceleration due to qravity 9.8067 9.8067 9.8067 9.8067 9.8067 9.8067 9.8067
37 ft hprim
read of leachate on top of
:he primary liner (max height
:f 40' - freeboard of 3')
5 10 15 20 25 30 35
11.2776 m hp,i,lead of leachate on top of
.he primary liner 1.524 3.048 4.572 6.096 7.62 9.144 10.668
Q:1.63E-05 m3/sec 1 -05 1.47E-{t5 1.58E-0s
hpri.A (gad)Qfull FS
31 604.01 0.0489f t84.18 I.30
222.Ot 0.01 526 1282.42 5.78
1(314.0'l 0.02053 I 131 .68 3.60
1 384.5t o.02579 1027.73 2.67
2(444.Ot 0.03105 )50.24 2.14
2l 496.5(0.03632 189 47 179
3(543.8[0 04158 840.08 t.54
,E 587.4e 0.04684 798.86 136
y = -0.1652* + 18.601x + 138.54
Rz = 0.999
leak detection system geonet062006.xls 8t23t2006
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page I of25
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of utah Ground water Discharge Permit No. 370004 for the Mill (the "GwDp").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at theMill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings lnspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Dataform (a copy of
which is attached in Appendix A). The Daily Inspection Dataform contains an inspection checklist,
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 3 of25
j)Wind movement of tailings and dust minimization.
wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement,z)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust control/spray evaporation
system(s).
observations of any abnormal variations in tailings pond elevations in cells 1, 3,
and 4A.
Locations of slurry and sX discharge within the active cells. Slurry and sX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
n) An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in any of the
leak detection systems is a gain of more than 12 inches in 24 hours. If this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
condition I 1.3.8 through 1 1.3.E of the Mill's Radioactive Materials License, ro
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
k)
m)
o)
p)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page5 of25
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
Leak Detection Systems
Each tailings cell's Ieak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. h Cell I and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. Cell44. has a blow tube, which has been measured
and marked. Once solutions have been identified byblowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the marked tubing.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be retumed to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph 11.3 C. of the Radioactive Materials
License.
Slimes Drain Water l,evel Monitoing
(i) Cell 3 is an active tailings cell while Cell2 is partially reclaimed with approximately
a)
b)
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
(vii)
2/07 Revision: DUSA-2
PageT of25
No process liquids shall be allowed to be discharged into Cell2:(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar ye:[, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 is currently active, no pumping from the Cell 3 slimes drain is
authorized. Prior to initiation of tailings dewatering operations for Cell 3, a similar
procedure will be developed for ensuring that average head elevations in the Cell 3
slimes drain are kept as low as reasonably achievable, and that the Cell 3 slimes drain
is inspected and the results reported in accordance with the requirements of the
permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells I and 3 and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be perfonned using a survey instrument (the "survey lnstrument")
accurate to 0.01 feet, such as a Sokkai No. B2l, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 1 and 3 and Roberts Pond
are known points established by professional survey. For Cell 1 and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell 1. The elevation of the metal disk (the "Reference Point
Elevation") for Cell I and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3, the Reference Point is a piece of metal rebar located on the
south dike of Cell 3. The elevation at the top of this piece of rebar (the Reference
Point Elevation for Cell 3) is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey lnstrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell I and Roberts
Pond, this is typically on the road on the Cell I south dike between Cell 1 and
Roberts Pond, approximately 100 feet east of the Cell l/Roberts Pond Reference
Point. For Cell 3, this is typically on the road on the Cell 3 dike approximately
100 feet east of the Cell 3 Reference Point;
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.I
2/07 Revision: DUSA-2
Page 9 of 25
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Summary
In addition, the weekly inspection should summarize all activities conceming the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of theWeekly Tailings and DMT Inspection form is provided in Appendix A.
3.?.. Weekl), lnspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at orbelow the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storase Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page I I of25
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
ln addition, settlement monitors are typically surveyed monthly and the results reported on the
M onthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/lVlaintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/MaintenanceReview
The OperationsAvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 13 of 25
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September lst of every year to:
6.2.
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake City, Utah 84116-3156
Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January .i0, 1gg0 Drainage Reportfor Cetts l
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell 1.
(ii) A liquid maximum elevation of 5,596.4 feet mean sea level in Cell 4,{.
b) Tailings Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, a
factor of safety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is divided by the number of tons required
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 15 of25
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
8.2. DMT Reports
Quarterly repoffi of DMT monitoring activities of all required information required by Part I .F.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring),3.2 (Weekly lnspection of
Solution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
sunrmary and graph for each calendar year of the depth to wastewater in the Cell? slimes drain must
be included in the fourth quarter report. After the first year, and beginning in 2008, quarterly reports
shall include both the current year monthly values and a graphic comparison to the previous year.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
PagelT of25
APPENDTX A (CONT.)
DAILY INSPECTION DATA
Date;_
Accompanied by:_
Time:
Any Item not "oK" must be documented. A check mark = oK, x = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM
Inspection Items Conditions of Potential Concern Cell I Cell2 Cell3 Cell
4A
Slurry Pipeline Leaks, Damage, Blockaee. Sham Bends
Pioeline Joints Leaks, Loose Connections
Pioeline Suooorts Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharse Improper Location or Orientation
II. OPERATIONAL SYSTEMS
Inspection Items Conditions of Potential Concern Cell I Cell2 Cell3 Cell
4A
Water Level Greater Than Operating Level, Large Change
Since Previous Inspection
Beach Cracks, Severe Erosion. Subsidence
Liner and Cover Erosion of cover. ExDosure of Liner
III. DIKES AND EMBANKMENTS
Inspection Items Conditions of Potential Concem Dike
l-I
Dike l-
IA
Dike 2 Dike 3 Dike 4A-
S
Dike
4A,-W
Slopes Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosion, Moist
Areas, Areas of SeeDase Outbreak
_- 94tlt ,rsptCrr0tt REp0RrrAruil{Gs sLuRRy DrscH.dRcE' iiiiarroH
OATE:
IITSPECTOR:
III LL
AREACELL I. II
N
I
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
2/07 Revision: DUSA-2
Page2l of25
Observation:
Cell I Cell2 Cell3 Cell4,A
Is LDS wet or drv?wet drv wet drv wet drv wet dry
If wet, Record
liquid level:
Ft to
Liouid
Ft to
Liquid
Ft to
Liquid
_Ft to
Liouid
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate_Volume
Flow Rate
Volume
FIow Rate_Volume
Flow Rate_
Was fluid sample
collected?
ves no _yes_no ves no ves no
5. Control Methods Implemented:
6. Remarks:
7. Contaminated Waste Dump:
, ., a
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: yes_no
Overspray carried more than 50 feet from the cell: yes_no
If "yes", was system immediately shut off? yes_no
2/07 Revision: DUSA-2
Page23 of 25
Comments:
5. Remarks:
6. Settlement Monitors
Cell2Wl:
Cell2W2
Cell 2 W3:
Cell 2 W4:
Cell2WT-C:
Cell4A-Toe:
Cell2W3-S:
Cell2El-N:
Cell2El-lS:
Cell2El-2S:
Cell2 East:
Cell3-lN:
Cell3-lC:
Cell3-lS:
Cell3-2N:
Cell2W5-N:
7. Summary of Daily, Weekly and Quarterly Inspections:
8. Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading):
I,.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 25 of 25
APPENDIX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of _ through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
Are all altemate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
YCS: NO:
comments (e.g., conditions of containers):
Conditions of storage areas for materials:
Other comments:
State of Utah
JON M. HUNTSMAN, JR
Govemor
GARY HERBERT
Lieutenant Governor
ITepartment of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
September 17,20OB
Mr. Ron Hochstein, President
Denison Mines (USA) Corp. (DUSA)
1050 17th Street, Ste. 950
Denver, CO 80225
Dear Mr. Hochstein:
SIIBJECT: September 16, 2008 DUSA Email Conveying Proposed Revisions tothe Cell4A BAT
Monitoring, Operations and Maintenance Plan (O&M Plan); September 16, 2008 DRC
Email with Comments on the O&M Plan; September 12,2008 DUSA Email conveying
Proposed Revisions to the Wite Mesa Mill Tailings Management System; and Discharge
MinimizationTechnology @Mf) Monitoring Plan(DMT Plan) and the O&M Plan;
O&M and DMT Plan Approval, and Authorization to Operate Tailings CelI4A
We have received and reviewed the subject submittals. The September 16, 2008 DUSA submittal
conveyed the "09/08 Revision Denison 1.3" of the O&M Plan for Cell4,{ without figure attachments. The
September 12,2008 DUSA submittal conveyed "09/08 Revision: Denison-6" of the DMT Plan and an
earlier "09/08 Revision Denison 1.2" version of the O&M Plan with all attachments. We have compared
these submittals to our comment email dated September 16, 2008, and to our previous comment letter
dated September 10,2008. Therefore, we hereby approve these versions of the Cell4,A' O&M Plan and
the DMT Plan with the September 12,2008 attachments, copies of these documents are attached herewith.
The items in our letter of July 29,2OO8 regarding major items needing resolution prior to beginning the
operation of the cell now appear to be completed, therefore we hereby authorize DUSA to operate
reconstructed Cell4A.
UTAH RADIATION CONTROL BOARD
DLF:LBM:DAR:dT
Attachments
cc: Mr. Harold Roberts, Executive V.P., DUSA
F:\DUSA\Cell 4A\Op Approval\Monitoring, O&M Planvlan Approvals & Auth to Opemle 09-08
168 North I950 West . Salt lake City, UT
Mailing Address: P.O. Box I44850 . Salt Lake City, UT 841 l4-4850
Telephone [phone]. Fax [phone] . T.D.D. (801) 5364414
wu'w.deq.utah.got'
Prinied on I00% recycled paper
Dane L. Finerfroc
Executive Secretary
OosloS Revision Denison 1.3
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4A, was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007. The construction
authorization provided that Cell 44. shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW3700O4 ("GWDP") and full fill the requirements of Parts
I.D.6, I.E.8, and I.F.8 of the GWDP.
Cell Desien
Tailings Cell 4A' consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a l5-foot
wide road at the top (minirnum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H tolV. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 271-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 907o. Floor of
Cell 4,A. has an average slope of l%o that grades from the northeast to the
southwest corners.
c) Tailings Capacity - the floor and inside slopes of Cell 4.{ encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
1) Primary Flexible Membrane T.iner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
Page I
Cell 4A BAT Monitoring, futions and Maintenance Plan erro, Revision Denison 1.3
2) Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an lS-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet' deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50Vo by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2001
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 44. that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in tum overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
PageZ
Cell 44 BAT Monito.irg,?"ru,ions and Maintenance Plan Oorro, Revision Denison 1.3
by a layer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cell 4A where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal l8-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this 18-inch pipe and used to
remov€ tailings wastewaters for purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) l0-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 4A',
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A..
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 44. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and 3, will be managed and
contained in Cell 4A, including the Probable Maximum Precipitation and
flood event.
Cell Operation
Solution Discharse
Cell 44. will initially be used for storage and evaporation of process solutions
from the Mill operations. These process iolutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell I
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 4A through 6 inch or 8 inch diameter IIDPE pipelines. The initial
solution discharge will be in the southwest corner of the Cell. The discharge pipe
will be routed down the Splash Pad provided in the corner of the Cell to protect
the pipeline running from the solution reclaim barge. The solution will be
discharged in the bottom of the Cell, away from any sand bags or other
installation on the top of the FML. Building the solution pool from the low end of
0
g)
Page 3
Cell 4,A, BAT Monitoring, Qutlons and Maintenance Plan ,9/08 Revision Denison 1.3
the Cell will allow the solution pool to gradually rise around the slimes drarn
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution flowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 4,A', utilizing the Splash Pads
described above. The subsequent discharge of process solutions will be near the
floor of the pond, through a discharge header designed to discharge through
multiple points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
feet of solution. As the cell begin to fill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solution level.
Initial Solids Discharee
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell4A, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will setfle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1. Figure 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves are 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Figure 2. Because of the depth of
Cell 4A, each of the discharge points will be utilized for an extended period of
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved further to the interior of the cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporation rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to further protect the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
traffic will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
Page 4
Cell44. BAT Monito.ing,Qrurions and Maintenance Plan Oorro, Revision Denison 1.3
Reclaim Water System
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3 illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharee
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4A.. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and OA/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailinss Cell4A
DUSA will operate and maintain Tailings Cell 44. so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part I.H.19 of the GWDP. These performance
standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment - the
leak detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondary flexible
menbrane. A second leak detection pump with pressure transducer, flow
meter, and manufacturer recommended spare parts for the pump controller
and water level data collector is maintained in the Mill warehouse to
ensure that the pump and controller can be replaced and operational within
24 hours of detection of a failure of the pumping system. The root cause
Page 5
Cell 4A BAT Monitorlng, fiutions and Maintenance Plan erro, Revision Denison 1.3
of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3/07 Revision: Denison-3, or the currently
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a l-foot level above the lowest point in
the lower flexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table I to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
3-foot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4A. Said measurements shall be
made to the nearest 0.1 foot.
Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell4A slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occuffences or changes in. the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
2)
3)
4)
s)
Page 6
Cell44 BAT Monitorirg,Q".urlons and Maintenance Plan OOrrO, Revision Denison 1.3
Measurements in Cell 4A are to be taken by survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey
Instrument") accurate to 0.01 feet, such as a Sokkai No. 821, or
equivalent, together with a survey rod (the "Survey Rod") having a visible
scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 4A are known
points established by Registered Land Surveyor. For Cell 4A, the
Reference Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4A. The elevation at the top of this piece of rebar (the
Reference Point Elevation for Cell 4,A. is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The Surveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 4A.,
this is typically on the road between Cell 3 and Cell4A, approximately 100
feet east of the Cell 4A Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble'in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell 4A
Reference Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Reference Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell 4A.
The designated location for Cell 4A is in the northeast corner of the Cell
where the side slope allows for safe access to the solution surface.
The approximate coordinate locations for the measuring points for Cell 4A
is 2$79,360 east, and320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant will hold th.e Survey Rod vertically with one end of the
Survey Rod just touching the pond surface. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surface
PageT
Cell44 BAT Monitorlng, {}u,tons and Maintenance Plan 9/08 Revision Denison 1.3
Reading"), which represents the number of feet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surface in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
Leak Detection System
The Leak detection system is monitored on a continuous basis by use of a
pressure transducer that feeds water level information to an electronic data
collector. The water levels are measured every hour and the information
is stored for later retrieval. The water levels are measured to the nearest
0.10 inch. The data collector is currently prografilmed to store 7 days of
water level information. The number of days of stored data can be
increased beyond 7 days if needed. The water level data is downloaded to
a laptop computer on a weekly basis and incorporated into the Mill's
environmental monitoring data base, and into the files for weekly
inspection reports of the tailings cell leak detection systems. Within 24
hours after collection of the weekly water level data, the information will
be evaluated to ensure that: 1) the water level in the leak detection sump
did not exceed the allowable level (5556.14 feet amsl), and 2) the average
daily flow rate from the LDS did not exceed the maximum daily allowable
flow rate at any time during the reporting period. For Cell 4A, under no
circumstance shall fluid head in the leak detection system sump exceed a
l-foot level above the lowest point in the lower flexible membrane liner.
To determine the Maximum Allowable Daily LDS Flow Rates in the Cell
44. leak detection system, the total volume of all fluids pumped from the
LDS on a weekly basis shall be recovered from the data collector, and that
information will be used to calculate an average volume pumped per day.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day. The maximum daily LDS flow volume will be compared
against the measured cell solution levels detailed on the attached Table 1,
to determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4A.. Any abnormal or out of compliance water
levels must be immediately reported to Mill management. The data
collector is also equipped with an audible alarm that sounds if the water
level in the leak detection sump exceeds the allowable level (5556.14 feet
amsl). The current water level is displayed at all times on the data
collector and available for recording on the daily inspection form. The
leak detection system is also equipped with a leak detection pump, EPS
Model # 25505-3 stainless steel, or equal. The pump is capable of
pumping in excess of 25 gallons per minute at a total dynamic head of 50
Page 8
Cell4,+ BAT Monitoring,{p..utions and Maintenance Plan lorro, Revision Denison 1.3
feet. The pump has a 1.5 inch diameter discharge, and operates on 460
volt 3 phase power. The pump is equipped with a pressure sensing
transducer to start the pump once the level of solution in the leak detection
sump is approximately 2.25 feet (elevation 5555.89) above the lowest
level of the leak detection sump (9 inches above the lowest point on the
lower flexible membrane liner, to ensure the allowable 1.0 foot (5556.14
feet amsl) above the lowest point on the lower flexible membrane liner is
not exceeded). The attached Figure 6, I-eak Detection Sump Operating
Elevations, illustrates the relationship between the sump elevation, the
Iowest point on the lower flexible membrane liner and the pump-on
solution elevation for the leak detection pump. The pump also has manual
start and stop controls. The pump will operate until the solution is drawn
dow{r to the lowest level possible, expected to be approximately 4 inches
above the lowest level of the sump (approximate elevation 5554.0). The
pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
is recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
horizontal, perforated section of the PVC collection pipe. The distance
from the top flange face, at the collection pipe invert, to the centerline of
the 225 degree elbow is 133.4 feet, and the vertical height is
approximately 45 feet. The pump is installed at least 2 feet beyond the
centerline of the elbow. The bottom of the pump will be installed in the
leak detection surnp at least 135.4 feet or more from the top of the flange
invert. A pressure transducer installed with the pump continuously
measures the solution head and is programmed to start and stop the pump
within the ranges specified above. The attached Figure 5 illustrates the
general configuration of the pump installation.
A second leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller can be replaced and operational within 24 hours
of detection of a failure of the pumping system. The root cause of the
equipment failure will be documented in a report to Mill management with
recommendations for prevention of a re-occulTence.
Slimes Drain Svstem
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe and a near as possible to
the bottom of the slimes drain sump. The bottom of the slimes drain sump
is 38 feet below a water level measuring point at the centerline of the
Page 9
Cell4A BAT Monito.ing, frutions and Maintenance Plan 9/08 Revision Denison 1.3
slimes drain access pipe, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter, E/H Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The flow rate and total gallons will be recorded by
the Inspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. All head
measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional procsss solutions will be discharged to Cell 4,{, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
Page l0
Cell 4A BAT Monito.ing,?ru,ions and Maintenance Plan Oorro, Revision Denison 1.3
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-I, Cell 2, Cell3 and Cell 4.A
are regulated by condition 10.3 of the White Mesa Mill 1 le.(z) Materials License.
Condition 10.3 states that "Freeboard limits for CeIIs L-L, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13, 1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell3 shall be recalculated annually in accordance with the procedures set in the
October 13r 1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local 6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
10 inches.
Based on the PMP storm event, the freeboard requirement for Cell 1 is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3 or 4,A..
Cell2 has no freeboard limit because the Cell is 997o full of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3:
The flood volume from the PMP event over the Cell2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing 24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 4A design includes a concrete spillway between Cell 3 and Cell 4A with the
invert elevation 4 feet below the top of the Cell 3 dike, at an elevation of 5604.5 feet
amsl. Once Cell 4,{ is placed in operation, the cell would be available for emergency
overflows from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 4A would see any overflow water from Cell 3 unless the
full PMP event were to occur. Should Cell 3 receive the full PMP volume of 123.4 acre
feet of water, approximately 62 acre feet of that volume would flow through the spillway
into Cell4A..
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). This
would result in a total flood volume of 98 acre-feet, including the 62 acre-feet of solution
from Cell 3. The freeboard depth required for Cell 44. from the PMP event would be
2.M feet, plus a wave run-up depth of 0.77 feet (from the 1990 Drainage Report), for a
Page I I
Cell4,A BAT Monitorrn*, Ou,rons and Maintenance Plan 9/08 Revision Denison 1.3
total freeboard requirement of 3.2feet. This calculation is illustrated on Attachment 4.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2 feet
below the top of liner. The freeboard for Cell 4A would therefore be 5595.3 amsl (top of
liner 5598.5 -3.2 feet). FigureT,Hydraulic Profile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4A were required to store the entire PMP event for Cell 2, Cell3 and Cell 4A, the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboard to 4.77 feet.
The required freeboard for Cell44, will be recalculated annually along with the re-
calculation of the Cell 3 freeboard requirement. A calculation of the current freeboard
calculation for both Cells is attached to this Plan.
Page 12
Cell4A BAT Monitoring,?".u,ions and Maintenance Plan Oorro, Revision Denison 1.3
Attachments
4)
s)
6)
7)
8)
e)
l0)
1)
2)
3)
Figure l,Initial Filling Plan, GeoSyntec Consultants
Figure 2,Initial Filling Plan, Details and Sections, GeoSyntec Consultants
Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
Figure 4,Interim Filling Plan, GeoSyntec Consultants
Figure 5,I-eak Detection System Sump, GeoSyntec Consultants
Figure 6,Irak Detection Sump Operating Elevations
Figure 7, Hydraulic Profile Schematic
Cell 3 and Cell 44. Freeboard Calculation
Table 1, Calculated Action leakage Rates for Various Head Conditions,
Cell4A, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
White Mesa Mill Tailings Management System and Discharge Minimization
Technology (Dlvfl) Monitoring Plan,3107 Revision: DUSA-2, 32 pages, or
currently approved version of the DMT
Page 13
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Maximum Solution Elevation - 5556.14 feet amsl
Pump-on level
5555.89 feet amsl
Lowest Level on Secondary Liner - 5555.1 4 feet amsl
Leak Detection Sump
Elevation - 5553.64 feet amsl
Denison Mines (USA) Corp.
Figure 6
Leak Detection Sump
Operating Levels
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Table L
Calculated Action Leakage Rates
for Various Head Gonditions
Gell 4A White Mesa Mill
Blanding, Utah
GeoSyntec Consultants
Head Above Liner
Svstem (feetl
Galculated Action Leakage
Rate (oallons/acre/davl
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 1 of36
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive MaterialsLicense"), as well as procedures foroperating andmaintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form(a copy of
which is attached in Appendix A). The Daily Inspection Dataformcontains an inspection checklist,
White Mesa Mill - Standard Operating Procedures
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which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those requiring colrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 4.A', Dikes 1,2,3,4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation, Cell 2
spillway, Cell 3 spillway, Cell 3 and 4,A. liquid pools and associated liquid return equipment, cell
leak detection systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell 3
or Cell 4A; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
Cell 1.
Cell2.
Cell 3.
Cell4A.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
g) The Cell 2 spillway, Cell 3 spillway, Cell 3 and Cell 4,A. liquid pools and
associated liquid return equipment.
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
a)
b)
c)
d)
e)
f)
h)
i)
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j)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures forcells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
and 4A.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
D aily Inspection D ata form.
An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
p) Daily measurements in the leak detection system (LDS) sumps of the
cells will be made when warranted by changes in the solution level
respective leak detection system.
The trigger for further action when evaluating the measurements in the Cell I and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell 4A leak detection is not allowed to be more than 1.0 foot
above the lowest point on the bottom flexible membrane liner (elevation 5556.14
feet amsl). If any of these observation are made, the Mill Manager should be
notified immediately and the leak detection system pump started.
k)
l)
m)
n)
o)
tailings
of the
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Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Dataform. This data will be usi:d in accordance with License
Condition l1.3.Bthrough 11.3.E of theMill'sRadioactiveMaterialsLicense,to
determine whether ornot the flow rate into the leak detection system is in excess
of the License Conditions.
q) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4,A..
lrems (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings areaat least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.I and2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
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2.5. TailingsEmergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.I. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the,
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. The Cell 4,A, leak detection system is monitored on
a continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The pressure transducer is calibrated
for fluid with a specific gravity of 1.0. The water levels are measured every hour
and the information is stored for later retrieval. The water levels are measured to
the nearest 0.10 inch. The data collector is currently programmed to store 7 days
of water level information. The number of days of stored data can be increased
beyond 7 days if needed. The water level data is downloaded to a laptop
computer on a weekly basis and incorporated into the Mill's environmental
monitoring data base, and into the files for weekly inspection reports of the
tailings cell leak detection systems
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b)
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be returned to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph I 1.3 C. of the Radioactive Materials
License.
For Cell 44, under no circumstance shall fluid head in the leak detection
system sump exceed a l-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow
Rates in the Cell 4A leak detection system, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,L60 gallons/day. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table 1 in
Appendix E, to determine the maximum daily allowable LDS flow volume for
varying head conditions in Cell 4A.
Slimes Drain Water Level Monitoring
Cell 3 is an active tailings cell while Cell2 is partiaily reclaimed with approximately
907o of the surface covered by platform fill. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
Cell2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell2, which, based on construction reports, is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(i)
(ii)
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Book I l: Environmental Protection Manual, Section 3.1
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(viii)
9/08 Revision: Denison-6' PageT of36
(iii)The slimes drain pump in Cell 2 is on a timed system, under which it pumps for 15
minutes each hour, thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 feet
before each pumping and is pumped to a depth of 38 feet after each pumping, in each
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewater head in the Cell? slimes drain is therefore about 5 feet. The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell2, which is at a depth of about 20 feet below the water level measuring
point on the slimes drain access pipe. As a result, there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience, cycling the pump more than 15 minutes every
hour can result in more replacement costs for pumps and more resulting system
downtime;
(iv)The Cell2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly, which is noted on the WeeklyTailings Inspection Form.
If at any time the pump is observed to be not working properly, it will be fixed or
replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. All head measuremsnts must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
No process liquids shall be allowed to be discharged into Cell 2;
If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Cell 4Aare currently active, no pumping from the Cell 3 or Cell
4A. slimes drain is authorized. Prior to initiation of tailings dewatering operations for
Cell 3 or Cell 4A, a similar procedure will be developed for ensuring that average
White Mesa Mill - Standard Operating Procedures
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Page 8 of 36
head elevations in the Cell 3 and Cell 4A slimes drains are kept as low as reasonably
achievable, and that the Cell 3 and Cell 4A slimes drains are inspected and the results
reported in accordance with the requirements of the permit."
Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
T ailin g s W as t ew at e r P o ol El ev at i on M onit o rin g
Solution elevation measurements in Cells 1, 3 and 44. and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. 821, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 1, 3 and 4,A., and Roberts
Pond are known points established by professional survey. For Cell 1 and Roberts
. Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell 1. The elevation of the metal disk (the "Reference Point
Elevation") for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3 and cell 4A, the Reference Point is a piece of metal rebar
located on the south dike of Cell 3. The elevation at the top of this piece of rebar
(the Reference Point Elevation for Cell 3 and cell 4A.) is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell I and Roberts
Pond, this is typically on the road on the Cell 1 south dike between Cell I and
Roberts Pond, approximately 100 feet east of the Cell l/Roberts Pond Reference
Point. For Cell 3 and Cell4A., this is typically on the road on the Cell 3 dike
approximately 100 feet east of the Cell 3 Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference Point (on the
'metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 3 and cell 4A Reference Point. The Assistant will ensure that the
Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor
has established a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
d)
White Mesa Mill - Standard Operating Procedures
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Page 9 of 36
represents the number of feet the Survey Instrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
A. Cell 3
A stake has been place in the central area of the south dike of Cell 3. The
Assistant will walk perpendicular to the dike from the stake to the nearest point
on the liquid surface of Cell 3 and place the Survey Rod at that location;
B. Cell44.
The Assistant will walk down the slope in the northeast corner of Cell 44. and
place the Survey Rod at the liquid level.
C. Cell I
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
D Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid su'rface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Northins Eastins
Roberts Pond 323,041 2,579,697
Cell I 322,196 2,579,277
Cell 3 320,508 2.577.160
Cell4,A.320,300 2,579,360
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Page 10 of36
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weeklv Insoection of Solution Irvels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly.solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
b) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
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Page ll of36
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Dataform, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
Diversion Ditches
Diversion ditches l, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm? should be checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
Ov e rspray D ust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
b)
c)
d)
White Mesa Mill - Standard Operating Procedures
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Page 12 of 36
e) Remarlcs
' A ssction is included on the Monthly Inspection Data form for remarks in which
recofirmendations can be made or observations of concern can be documented.
fl Summary of Daily, WeeHy and Quarterly Inspections
The monthly inspection will also summaize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Insp e ction Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
Emb anlcrne nt Ins p e cti on
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
Op er ations/ M aint e nanc e Rev iew
The OperationsAvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
a)
b)
c)
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d) Summary
The summary will include all major activities or observations noted around the
rr any ,r ,h"rJ'::::i,fr:3'J""#,il:1il"oil,lo,,ions and corrective measures taken shourd be
documented in the Quarterly Inspection Dataform. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be insp'ected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
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The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the colrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by Septernber I't of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
salt Lake city, utah 84116-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January 10, 1990 Drainage Report for Cells I
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell
(ii) A liquid maximum elevation of 5,596.4 feet mean sea level in Cell
b) Tailings Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, a
factor of safety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is divided by the number of tons required
1.
4A.
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
(iv)
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced Pool Area.
The PMP Flood Volume Requirement, as per the January 10, 1990
Drainage Report, is 123.4 acre feet. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to determine the PMP
Freeboard Level.
9/08 Revision: Denison-6
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(v) The Wave Run Up of 0.78 feet (as specified in the January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill Central File.
c) Tailings Cell4A
The freeboard limit for Cell 44, is determined annually using the following
procedure:
The Cell4A design includes a concrete spillway between Cell 3 and Cell4A,
with the invert elevation 4 feet below the top of the Cell 3 dike, at an elevation
of 5604.5 feet amsl. Should Cell 3 receive the full PMP volume of 123.4 acre
feet of water, approximately 62 acre feet of that volume would flow through
the spillway into Cell 4A.'
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of
water (40 acres, plus the adjacent drainage area of 3.25 acres, times the PMP of
10 inches). This would result in a total flood volume of 98 acre-feet, including
the 62 acre-feet of solution from Cell 3. The freeboard depth required for Cell
4,A, from the PMP event would be2.44 feet, plus a wave run-up depth of 0.77 feet
(from the 1990 Drainage Report), for a total freeboard requirement of 3.2 feet.
This calculation is illustrated on Attachment 4. The Groundwater Quality
Discharge Permit, No. UGW370004, for the White Mesa Mill requires that the
minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2
feet below the top of liner. The freeboard for Cell 4A would therefore be 5595.3
amsl (top of liner 5598.5 - 3.2 feet)-
The calculation of the Total Required Freeboard for Cell 4,A. will be calculated
annually and the calculation sheet filed in the Mill Central File.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 16 of 36
d) Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
6.4. Annual Irak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storrn or significant natural or man-made event occurs.
8. REPORTING RE,QT.IIRE,MENTS
In addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection andWeekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailinss RePortS
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 17 of36
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part 1.F.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspection of
Solution Irvels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
summary and graph for each calendar year of the depth to wastewater in the Cell2 slimes drain must
be included in the fourth quarter report. After the first year, and beginning in 2008, quarterly reports
shall include both the current year monthly values and a graphic comparison to the previous year.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 18 of36
APPE}[DIX A
FORMS
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White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 23 of36
Date:
1. Pond elevations (msl,ft)
2. Slimes Drain Liquid Levels Cell2
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors:
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
Cell 3: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of,Water above FML ((a)-(b))
Cell 4A.: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above EML ((a)-(b))
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
5597
_5570
5564
_5612.34-
Pump functioning properly
Pump Timer set at l5min on 45 min off_
Deoth to Liouid Dre-DumD
Deoth to Liouid Post-oumo
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
PumP =
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
9/08 Revision: Denison-6
Page24 of36
Observation:
Cell 1 Cell2 Cell3 Cell4,A.
Is LDS wet or drv?wet-dry wet dry wet_dry
-wet-dryIf wet, Record
liquid level:
Ft to
Liquid
Ft to
Liquid
Ft to
Liquid
Ft to
Liouid *
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate-
Volume
Flow Rate_
Volume
Flow Rate-
Volume
Flow Rate_
Was fluid sample
collected?
ves no ves no ves no ves no
5. Control Methods Implemented:
6. Remarks:
7. Contaminated Waste Dump:
& Does Level exceed l2 inches aborre the lowest point on the bclttom flexible membrane liner (elevation
5556.14 amsl)?no _ yes
If Cell 4A leak detection system level exceeds l2 inches above the lowest point on the bottorn flexible
lrembrane liner (elevation 5556.14 amsl), notify supervisor or Mill tnanager immediately'.
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page25 of36
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
l. Slurry Pipeline:
PipeThickness:-(TobemeasuredonlyduringperiodswhentheMillisoperating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch I Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing
-yes-no -yes
no
-yes_no
Erosion _yes_no _yes no _yes_noUndesirable _yes_no _yes__no _yes_no
Vegetation
Obstruction of Flow ves .no ves no ves no
Diversion Berm:
Stability Issues _yes_no
Signs of Distress ves no
Comments:
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly:
-yes
no
Overspray carried more than 50 feet from the cell: yes-no
If "yes", was system immediately shut off? yes no
9/08 Revision: Denison-6
Page26 of36
Comments:
5. Remarks:
Cell2 Wl:
Cell2W2:
Cell2 W3:
Cell2W4:
Cell2WT-C:
Cell2 W7N:
Cell2 W6C:
Cell4A-Toe:
6. Settlement Monitors
Cell2W3-S:
Cell2El-N:
Cell2El-1S:
Cell2El-2S:
Cell2 East:
Cell2 W7S:
Cell2 W6S:
Cell2 W4S:
Cell3-2C:Cell3-2S:
7. Summary of Daily, Weekly and Quarterly Inspections:
Cell3-1N:
Cell3-1C:
Cell3-1S:
Cell3-2N:
Cell2W5-N:
Cell2 W6N:
Cell2 W4N:
Cell2 W5C:
8. Monthly Slimes Drain Static Head Measurement for Cell2 (Depth-in-Pipe Water Level
Reading):
White Mesa Mill - Standard Operating Procedures
Book ll: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page27 of36
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
lnspector:
Date:
1. Embankment Inspection:
2. Operations/lVlaintenance Reyiew:
3. Construction Activites:
4. Summary:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
Week of
-
through Date of Inspection:
Inspector:-
Weather conditions for the week:
9/08 Revision: Denison-6
Page 28 of 36
APPENDIX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes:_ no:_
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water+ight containers:
yes:_ no:_
comments (e.g., conditions of containers):
Conditions of storage areas for materials:
Other comments:
White Mesa Mill - Standard Operating Procedures
Book 1 l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page29 of36
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (Dlvff) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas ofconcern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection fonn. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
inspected for damage and loss of support.
leaks, blocked valves, and closed valves.
improper location and orientation.
2. Operational Systems:
9/08 Revision: Denison-6
Page 30 of 36
Valves are also to be inspected particularly for
Points of discharge need to be inspected for
3.
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern forponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4A solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:4.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 3l of36
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
Cover area
Beach/tailing sands area
Solution as it exists
Pump lines
5.
6.
7.
8.
1.
2.
J.
4.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page32 of 36
to the dump, liner repairs, etc.)5.
6.
7.
Activities around tailings cell (i.e. hauling trash
Slurry discharge when operating
Over spray system when operating
Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
9.
10.
11.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 33 of 36
APPENDIX C
CERTIFICATION FORM
' Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 34 of 36
APPENDD( D
FEEDSTOCK STORAGE AREA
White Mesa Mill- Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 35 of36
APPENDX E
TABLES
a
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3' I
9/08 Revision: Denison-6
Page 36 of 36
' Table I
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( eallons I acre / dav )
5 222.04
10 3t4.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587 _46
37 604.01
-. glrLr ,{sPtcrr0il REPORTrAr u n{Gs sLuRRy Drscnane-e r.iiiertox
OATI:
IIISPECTOR:
HI LL
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Denieon Mines ( USF,) Corp.
Feedslock Storage Area Map
[p*,1P,ur)
State of Utah
JON M, HUNTSMAN, JR. Govemor
GARY HERBERT
Lieutenant Govemor
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
September 10,2008
Mr. Harold R. Roberts
Executive Vice President - US Operations
Denison Mines (USA) Corp. (DUSA)
1050 17d'Street, Ste. 950
Denver, CO 80225
Dear Mr. Roberts:
SLIBJECT: September 5, 2008 DUSA Email conveying the Proposed Revisions to the White Mesa
Mill Tailings Management System and Discharge MinimizationTechnolog @MT)
Monitoring Plan (DMl Plan) and the Cell4A BAT Monitoring, Operations and
Maintenance Plan (O&M Plan),' September 4,2008 DRC Letter, subject as above;
Comments and Request for Information
We received and reviewed the subject submittal. The submittal conveyed two documents, i.e. "09/08
Revision: Denison-5" of the DMT Plan and the "09/08 Revision Denison 1.1" of the O&M Plan. We
compared this submittal to our letter dated September 4,2008, and have the following cornrnents:
Regardine the Subject O&M Plan:
a) The attachments in the September 2,2008 version were omitted from the September 5, 2008
submittal. Please submit a complete and current version that includes the attachments.
b) On the last page of the O&M Plan, the table of "Calculated Action Leakage Rates [ALR] for
Various Head Conditions Cell 4A White Mesa Mill," needs to be labeled as Table I in order to
complete references made in the body of the plan (per page 6, paragraph 3).
c) A provision requiring any leak detection system (LDS) pumping or monitoring equipment
discovered not to be operational, to be repaired or made fully operational within 24-hours of
discovery, needs to be added to the section on page 5 titled "BAT Performance Standards for
Tailings Cell 4A" (Permit Part I.E.8(a)(1)). This issue was brought to your attention in two
previous DRC letters dated August 26, and September 4,2008 (comments numbered 9).
d) On page 8 of the O&M Plan, please add verbiage for a compliance evaluation that is:
1) Based on both a maximum LDS fluid level and a maximum daily average LDS flow limit, and
2) Completed within 24-hours of weekly data collection.' This issue was brought to your attention previously in the DRC letter dated September 4,2008
(comment no. 9).
168 Norrh 1950 West. Salt l,ake City, UT
Mailing Address: P.O. Box 144850. Salt L-ake City, UT 84114-4850
Telephohe [phone]. Fax [phone] . T.D.D. [phone]
www.deq.utah.gov
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State of Utah
JON M. HUNTSMAN, JR
Governor
GARY HERBERT
Lieutenant Governor
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
September 4,2009
Mr. Harold R. Roberts
Executive Vice President - US Operations
Denison Mines (USA) Corp. (DUSA)
1050 17"'Street, Ste. 950
Denver, CO 80225
Dear Mr. Robets:
SUBJECT: September 3,2008 DUSA Email conveying Proposed Revisions to the DMT Plan;
September 2,2008 DUSA Email conveying Revised Cell4A BAT Monitoing, Operations
and Maintenance Plan (O&M Plan); August 11, 2008 DUSA letter conveying information
on the Cell4A Construction Quality Assurance (Q,\) Report; Comments and Request
for Additional Information
We received and reviewed the subject submittals above. Also on September 4,2008, we had a telephone
discussion on the subject. The above DUSA submittals were compared to our previous letter on the O&M
Plan dated August 26,2008. The following comments are given with respect to the comment number from
that letter:
Comment 1:
a) In the DUSA proposed revisions to the DMT Monitoring Plan, several tables in the Appendix A
appear incomplete with respect to Cell 4,A.. The appropriate tables need to be completed to include
the daily Cell4A inspection information items.
b) In the DMT Plan the weekJy leak detection system (LDS) inspection table, on the top of page 23
for Cell44, should include the maximum liquid level for compliance on the form.
c) The paragraph in the DMT Plan on page 3 beginning with, "The trigger for further action when
evaluating the measurements in any of the leak detection systems is a gain of more than 12 inches
in 24 hours," needs to be removed or amended. Instead of basing compliance determination on a
rate of head increase (12 inches in 24 hours) they need to be based on an excess of a maximum
allowed head (feet) in the leak detection system.
d) Will the transducer for fluid level or pressure indication be calibrated for a specific gravity of 1.0
or some other value? If not to be calibrated for a specific gravity of 1.0 please justify.
Comment 3: On page 8, 133.4 feetis given as the distance from the top of the flange face invert of the
sloped l8-inch LDS pipe, to the centerline of the 22.5 degree elbow. The plan requires
the LDS sump pump to be installed "at least 2 feet beyond the centerline of the elbow."
168 North 1950 West . Salt Lake Ciry. UT
Mailing Address: P.O. Box 144850 . Salt hke City, UT 84114-4850
Telephone [phone]. Fax [phone] . T.D.D. [phone]
www.deq.utah.gov
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From: Dave RuppTo: Harold R. RobertsCC: Dane Finerfrock; [e-mail]; Loren Morton; rhochstein@de...Date: S|U2OOB 1:31 PMSubject O&M Plan Discussion on the LDS Secondary Liner at Cell 4A
Harold,
We reviewed the reference Greg C. supplied, i.e. 40CFR264.251 (c)(4), as stated below:
" (c)(4) The owner or operator shall collect and remove pumpable liquids in the leak detection system sumps to minimize the head on
the bottom liner."
Therefore, we request DUSA provide an adequately detailed demonstration with appropriate design of how DUSA will achieve the
above in the O&M plan. This should highlight the proposed point of compliance for pressure head on the secondary liner. Please
include the necessary descriptive text with calculations, drawings, graphics, and procedures, as necessary, to demonstmte meeting all
the O&M requirements previously communicated.
ln the design, please include the proper equipment with controls and thejustification of such, to perform, monitor and record the all
necessary functions. E.g. part of the justification of a pump would include the specific pump curve which demonstrates the pump will
perform to maintain compliance with the head limitation, and still pump appropriately above the allowable leakage rate at the various
corresponding head depths.
Hopefully, this is helpful. Please contact me if you have questions. I will be back in the office Monday. - -
David A. Rupp, P.E.
[Jtah Division of Radiation Control
P. O. Box 144850
Salt take city, uT 84114-4850
Telephone [phone]
Fax [phone]
Email: [e-mail]
TITLE 4O--PROTECTION OF ENVIRONMENT
CHAPTER ]-_ENVIRONMENTAL PROTECTION AGENCY (CONTINUED)
PART 264--STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE
TREATMENT,
STORAGE, AND DISPOSAL FACfLITIES--Table of Contents
Subpart L--Waste Piles
Sec. 264.251, Design and operating requirements.
(c) (2) 'The leachate collection and removal system immediately above the
top liner must be designed, constructed, operated, and maintained tocollect and remove feachate from the waste pile during the active life
and post-closure care period. The Regional Administrator will specify
design and operating conditions in the permit to ensure that the
leachate depth over the finer does not exceed 30 cm (one foot). The
leachate collection and removal system must comply with paragraphs
(c) (3) (iii) and (iv) of this section.
(c) (3) (v) Constructed with sumps and liquid removal methods (e.9.,
pumps) of sufficient size to collect and remove liquids from the sump
and prevent liquids from backing up into the drainage layer. Each unit
must have its own sump(s). The design of each sump and removal system
must provide a method for measuring and recording the volume of liquidspresent in the sump and of liquids removed.
(c) (4) The owner or operator shaLl collect and remove pumpable
liquids in the leak detection system sumps to minimize the head on the
bottom liner.
Q> urre E'-ee)
State of Utah
JON M. HUNTSMAN, JR
Goventor
GARY HERBERT
Lieutenant Govemor
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Dit'ector
August 26,2008
Mr. Harold R. Roberts
Executive Vice President - US Operations
Denison Mines (USA) Corp. (DUSA)
1050 17th SreeL Ste. 950
Denver, CO 80225
Dear Mr. Roberts:
SIIBJECT: August 7,2008 DUSA Email conveying Revised Cell4A BAT Monitoring, Operations and
Maintenance Plan (O&M Plan); Comments and Request for Additional Information
We received and reviewed your submittal on the subject above. In addition, we have considered several
other DUSA submittals including:
. Emails dated August 5,6, and 7, 2008 regarding the Leak Detection System (LDS), the LDS
pump and control center, a proposed LDS Liquid Level Monitoring System and Horizontal Sump
Pump systems respectively;
. Email dated July 16, 2008 DUSA conveying a Revised O&M Plan and proposed 7/08 DMT
Monitoring Plan (DMT Plan).
DRC emails of August 1 and 7, 2008 were given in response to the other submittals. In accordance with
our letter of July 29,2CfJ,8, we had several major comments on the subject O&M Plan that needed to be
resolved prior to commencing operation. This letter pursues those major cornments. Our minor cornments
will be pursued later, under separate cover. The minor items are deemed to not be critical for DUSA to
resolve before initial operation of Cell 4A.
We have comments and requests for information regarding the August 7 , 2008 subject submittal. Listed
below are headings in bold, taken from our July 29,2008 DRC letter, and other introductory remarks
regarding the O&M Plan. Our comments are enumerated thereafter:
a. Detail drawings and procedures for the monitoring, operations and maintenance of the leak
detection system (LDS) are needed. Similar details are also needed for the slimes drain
system.
On page 5, of the DUSA August 7 ,2008 O&M Plan submittal, the last paragraph states, ". . . the
fluid head above the lowest point on the secondary flexible membrane by use of procedures and
equipment specified in the . . . DMT monitoring Plan."
Comment 1: It appears that paragraph 3.1.a of the DMT plan gives the maximum head and
leakage limits, but the bulk of the drawings and procedures requested for the LDS
168 North 1950 West . Salt lake City, UT
Mailing Address: P.O. Box 144850 . Salt L:ke City, UT 84114-4850
Telephone (801 ) 536-4250 . Fax [phone] . T.D.D. (80 I ) 536-44 14
wwl.deq.utah.gov
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Mr. Harold Roberts
August 26,2008
Page 3
please include a diagram showing additional control head depths with respect to
the LDS sump bottom, with the corresponding amsl elevations. At a minimum,
this diagram will include the following: the bottom of the LDS sump, the
representative lowest level on the secondary liner, the pump-on level, and the
maximum level of compliance (i.e. the corresponding head distance and elevation
at 1.00 foot above the lowest point on the secondary liner).
b3. The Ground Water Discharge Permit [Parts I.E.8(a Xl) and I.F.3] requires that continuous
monitoring of the sump water elevation is provided, and certain other measurements be
recorded. Drawings and adjustments to the plan text need to be made to incorporate these
requirements.
Comment 9:An apparent conflict exists in the latest O&M Plan submittal, which needs to be
resolved. The August 7 ,2008 version of the O&M Plan on page 8, first
paragraph, states that the LDS fluid levels will be measured on a weekly basis. As
you are aware, these fluid levels determine compliance with BAT performance
standards for Cell4A, found at Part I.E.8 of the permit. In Part I.E.S(aX1), the
Permit requires continuous operation of the LDS pumping and monitoring
equipment. As a result, a potential conflict is apparent, where the LDS pumping
equipment could fail shortly after a manual weekly fluid level measurement that
could go undetected for as long as 6 days before the next weekly manual fluid
level measurement is made.
Such a period of non-operation of the LDS pumping equipment would fail the
"continuous operation" performance standard set in Part I.E.8(aX1) of the Permit.
Please revise the O&M Plan to resolve and prevent this possible performance
standard failure, by showing how equipment and procedures will be provided to
minimize the interval of undetected non-operation of the Cell 4A LDS pump
sYStem.
Comment 10: Since the LDS fluid levels are proposed to be measured and recorded both
manually and by automated means (pressure transducer), it is possible that
discrepancies in reported fluid levels could exist (O&M Plan of August 7 ,2008,
page 8). Please explain how these discrepancies will be reconciled, and which
source of data will be used to determine compliance with the BAT performance
standard for the LDS fluid levels.
Comment I 1: Provisions for rapid replacement of LDS monitoring equipment (as well as the
pump) needs to be provided in the O&M Plan. This includes the pump controller
head monitoring, and flow meter equipment, per.part I.E.8(aX1) of the permit.
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State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
.,o^ r.OrrMAN.rR
Govemor
CARY HERBERT
Lieulenanl Govenutr
June 6, 2008
Mr. Steven D. Landau
Manager of Environmental Affairs
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
Dear Mr. Landau:
Denison Mines (USA) Corp. (DUSA)
White Mesa Uranium Mill - Tailings Cell4A
Cell4A BAT Monitoring, Operations and Maintenance Plan
Request for Additional Information
We received your letter conveying the subject plan dated March 28,2008. As you are aware, the DRC
design approval letter of Jun e 25, 2007 and the Ground Water Discharge Permit list requirements for the
subject plan. The permit discusses the plan with respect to required performance standards (I.D.6),
monitoring (I.E.8), repofts (I.F.3-4), plan submission (I.H.19), proper operation and maintenance (III.E)
and other items. As part of the plan submitted by DUSA, the 2107 revision of the White Mesa Uranium
Mill Tailings Management System and Discharge Minimization Technology Monitoring Plan (the DMT
Plan) was referenced and included.
One of the purposes of the DMT Plan is for existing tailings cell operations, not for new cells such as Cell
4A. Cell 4A is to be operated under the numerous Best Available Technology (BAT) provisions of the
permit. The subject BAT plan will need to stand alone and be separated from the DMT Plan, if the
commingling of these plans creates any negative effects.
We have reviewed the subject plan and have the following comments that must be resolved before the plan
can be approved:
DRC Design Approval Letter of .lune 25. 2007:
1. Per the above letter, the manual for Cell44' must include "Actions for successful prevention of
pond overflow. Planned efforl must be made to properly manage and apply volume inventory
controls to prevent overflow events from occurring. These efforts must be described in the
operations and maintenance manual." A description of the specific efforts needed to prevent pond
overflow by properly managing and applying volume inventory controls needs to be in the subject
plan. This description should include not only the current need. but the level of effort that will be
l68Northt950West.POBoxl4.ltt50.SaltLnkeCity.UT84ll4-4850'phone[phone]'fax[phone]
T.l).1). (801 ) 536-4414. wn'v'.deq.utaLgot
Mr. Steven D. Landau
June 6, 2008
Page 2
needed for overflow prevention as the levels oftailings inventory changes and progressive cell
reclamation occurs.
Performance Standard Monitorins (I.8.8):
2. Per the permit section referenced directly above, "At a minimum, said BAT montoring shall
include: Weekly Leak Detection System (LDS) Monitoring - including: Leak Detection System .
Pumping and Monitoring Equipment - the Permittee shall provide continuous operation of the leak
detection system pumping and monitoring equipment, including, but not Iimited to, the
submersible pump, pump controller, head monitoring, and flow meter equipment approved by the
Executive Secretary. Failure of any pumping or monitoring equipment not repaired and made fully
operational within 24-hours of discovery shall constitute failure of BAT and a violation of this
Permit. . . the Permittee shall measure the fluid head above the lowest point on the secondary
flexible membrane by the use of procedures and equipment approved by the Executive Secretary."
a). We do not detect from the current plan the detail level required by the above, i.e. the
equipment items listed above, and the procedures to use that equipment for the required
measurements. The design configuration, equipment specifications and salient elevations
for the equipment and pertinent facilities needs to be submitted as well.
The operation of all LDS equipment must be described in detail with their location
specified. The head sensors for measurement must be at attached at fixed locations and
elevations with certified surveyed bottom liner elevations shown on the as-built drawings.
Exclusive location dedicated flow meters with volume totalizers are required. Equipment
maintenance frequencies must be at least as often as the manufacturer recommendations,
and maintenance must be recorded and submitted in accordance with the permit reporting
requirements.
b). Please include in the subject plan the requirements to record and report to management on
the above. There does not seem to be conveyed in the plan a sense ofthe urgency for any
needed repairs as described above. Please include these items, and provide deadlines for
corrective actions, and a description of how maintenance and repairs will be documented.
Monitorins Reports (I.F.3-4):
3.Per the permit section I.F.3 referenced directly above, "the Permittee shall provide quarterly
monitoringreports...requiredbyPartl.E.8ofthisPermit....Ataminimum,reportingofBAT
monitoring for Cell 44, will include: a) Leak detection system (LDS) Monitoring - including:
l) Report on the operational status of the LDS pumping and monitoring equipment during the
quarter, including identification of any intervals of non-operational status and repairs. 2)
Measurement of the weekly fluid head at the lowest point of the secondary membrane . . . b)
Measurement of the weekly wastewater fluids elevation in the Cell 44, to determine freeboard."
These report items need to be appropriately included in the verbiage of the methods and the forms
for the subject plan (I.H.19). Please provide detailed descriptions of all equipment, forms, and
procedures that will be used in this reporting.
Per the permit section I.F.4 referenced above, "DMT and BAT Performance Upset Reports - the
Permittee (DUSA) shall report any non-compliance with the DMT or BAT performance criteria of
Part LD in accordance with the requirements of Part I.G.3 of this Permit." This verbiage with
direct reference to the actual performance criteria needs to be included in the subject plan.
4.
Mr. Steven D. Landau
June 6,2008
Page 3
Plan Submission (I.H.l9):
5. Per the permit section I.H.l9, "Said Plan shall include [the reporting] requirements in Part [L]F.3
of the Permit and include . . . the following: a) Operation and Maintenance Procedures - including
operational sequences, transporting methods, equipment operation / maintenance, safety and
emergency procedures, b) Operation, Maintenance, Monitoring, and Recordkeeping - for
evaluation of the following: i) Leak detection system - including operational status of equipment,
daily wastewater head, daily flow rates, etc., ii) Slimes drainage system - including operational
status of equipment, daily flow rates, monthly wastewater recovery head monitoring, etc, c)
Freeboard limits on dikes - including monitoring and proper management and volume inventory
controls to prevent release of wastewater to the environment'"
The permit (LH.19) requires the subject plan to specifically capture the concepts expressed the
items in the paragraphs above. Please demonstrate that these specific concepts are addressed in the
submitted plan, or capture in writing this information in a revised plan including these items.
As mentioned earlier, the operation of all LDS equipment must be described in detail with their
location specified. The head sensors for measurement must be at attached at fixed locations and
elevations with certified surveyed bottom liner elevations shown on the as-built drawings. Flow
meters with sole location dedicated volume totalizers for the LDS are required. Equipment
maintenance frequencies must be specified to be at least as often as the manufacturers recommend.
This must be verifiable by the subject plan specifying the frequencies and giving reference to on-
site retrievable manufacturer manuals or manufacturer maintenance manual inserts in the subject
plan. Maintenance of equipment must be recorded and submitted in accordance with the permit
reporting requirements.
Proper operation and maintenance (III.E):
6. Per the permit section III.E, "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."
The subject plan must specifically capture the concepts expressed the items in the paragraph above
both in terms of equipment and procedures. Please demonstrate that these specific concepts are
addressed in the submitted plan, or capture in writing this information in a revised plan including
these items.
Other Comments:
1. The as-built plans and specifications must be referenced and included as part of the subject plan.
Approval of the subject plan will need to be contingent upon submission and approval of these
items.
8. In the subject plan on page l, the last number of first sentence should be 2007 .
Mr. Steven D. Landau
June 6,2008
Page 4
10.
9. Page 3, item f) discusses splash pads. Additional splash pads are needed per plan Figure l, than
are currently required by the approved plans. Please provide the timeline for the installation of the
additional pads with respect to the timeline for facility construction completion and the
comnencement tailings deposition.
On page 4:
a. With respect to the first paragraph, please indicate by drawings or otherwise, where the
operational valves for tailings conveyance will be placed with respect to the new lining
system. Also, specify the types of valves that will be used.to minimize potential damage
to the lining system.
b. The third paragraph pertains to the reclaimed water system. The second sentence should
begin with, "The pump barge . . .", and the last phrase of that sentence end with ". . . or
subsequent operation and maintenance activities."
c. The last sentence of the third paragraph should end with the word "inspections." The
frequency and description of the pump barge inspections needs to be included in the text
and the corresponding forms prepafed accurately to receive all necessary data described.
On page 5 of the subject plan:
a. The paragraph numbered 1) needs to state that the flow meter includes a volume totalizer.
A separate totalizing meter also needs to be stated as required for the slimes drain system.
b. The paragraph numbered 2) states that "the Permittee shall measure the fluid head above
the lowest point on the secondary flexible membrane by the use of procedures and
equipment specified in the Wite Mesa Uranium Mill Tailings Management System and
Discharge Minimization Technology Monitoring Plan [the DMT Planl2107 Revision:
DUSA-2." There are some issues regarding this statement that need to be resolved, as
follows:
( l). By making the DMT Plan'part of the subject plan, additional changes to the
currently approved DMT Plan will be necessary.
(2) The DRC currently approved DMT Plan is the 3/07 Revision: DUSA-3, not the
one stated in the plan.(3). A copy of the2l07 DMT Plan was provided as an attachment to subject plan. The
subject plan needs to state the currently approved DMT Plan is part of and
attached to the subject plan. (The currently approved DMT Plan must also be kept
with and attached to the subject plan).
(4). How is the head measured in the Cell 44' LDS per the DMT plan? In addition to
the actual measurement methods, please include as a side note in the plan verbiage
that BAT requirements apply for Cell4A..(5). Other comments, specific to using the DMT Plan as part of the subject Cell 4A
BAT Monitoring, Operations and Maintenance Plan, are noted below in this letter.
On page 6 of the subject plan:
a. Part of last sentence ofthe first paragraph needs to be changed to " . . . on a monthly basis,
reviewed and signed by the Mill Manager."
b. A section on this page discusses the freeboard calculation for Cell 4A. Comment number
one above. refers to this as well. In the plan, the relationship of the current freeboard
calculation methods, as-built conditions, and the new spillway(s) elevations is unclear.
11.
t2.
Mr. Steven D. Landau
June 6, 2008
Page 5
Freeboard management in the subject plan needs to be demonstrated clearly. Please revise
and clarify.
An annually updated hydraulic profile drawing needs to be used as one of the dynamic
tools used to clarify and visually verify the calculation (with the impacted elevations) for
the required freeboard in Cell 4A. This profile must include the upstream tailings cells.
As you are aware, the freeboard of the last tailings cell (one without a spillway) must be
considered with respect to the calculated required freeboard and the necessary PMF
required storage.
The use of as-built elevations in the hydraulic profile schematic drawing which includes
the impact of projected iriventories, PMF water levels, runoff volumes, freeboards and the
spillway elevations is needed to help demonstrate their relationship. Please provide the
drawing and verbiage in the subject plan to explain the relationship of the required
calculated freeboard, spillway elevations, and the necessary set aside PMF storage volume.
c. The second and third paragraphs of the page need to be revised to remove the references to
Cell 4,{ in License Condition 10.3. There is no reference to Cell4A in this license
condition.
13. On pageT of the subject plan:
a. The first sentence of this page states the spillway elevation between Cells 3 and 4A is 5606
amsl. However, that elevation conflicts with the dike crest (DC) elevation stated in the
2007 Annual Technical Evaluation Report (ATER) for the Cell 3 freeboard calculate,
which shows the DC as 5608 amsl. The approved plans show the spillway flow level
elevation to be 4-feet below the top of the dike, or about 5604 amsl. These elevations in
the subject plan and the ATER need to be corrected in accordance with as-built conditions.
b. Correct the elevations in the second paragraph correspondingly.
c. The last word in the fifth paragraph of this page should be changed to the acronym for
Ground Water Discharge Permit.
14. On page 8 of the subject plan, Figure I should appeff in order before Figure 2.
15. Regarding the DMT Plan submitted as part of the subject plan:
a. On page 3 of the DMT Plan, the last paragraph needs to add verbiage of how to evaluate
the LDS for Cell44' to determine compliance with the BAT performance standards in Part
I.D.6 of the Ground Water Discharge Permit. As you are aware, the volume of any
leakage pumped from the LDS is an important parameter. Verbiage addressing and
clarifying volumetric leakage limits for at the various liquid depths of Cell 4,{ must be
added as well.
b. On page 5 of the DMT Plan under 3.1.a, the first paragraph regarding the blow tube for
Cell 4A needs to be updated. Also the last sentence of second paragraph of 3.1.a needs to
use the term "LDS."
c. On page 7 of the DMT Plan in paragraph 3.1.b.vii needs to be updated per Part I.D.3 of the
Ground Water Discharge Permit dated March 17, 2008.
d. On page 8 of the DMT Plan, assure that the items required by the DUSA letter of March
14.2007 are added to 3.l.d.viii.A & B.
e. On page 13 of the DMT Plan, the second paragraph should also list tlie Director of the
DRC as a recipient of the ATER. Also, the discussion of the freeboard limits in Section
6.3.a. needs to be updated per the previous discussions in this letter.
Mr. Steven D. Landau
June 6,2008
Page 6
f. On page 2L of the DMT Plan, the table for the LDS needs to be updated with room to
record and calculate all the specific data required for cell 4,A' including the total date, time,
volume pumped, hours since last pumping, calculated leakage rate in gallons/hour and
leakage rate in gallons/day.
g. DUSA's copies of the DMT Plan at all locations must be updated with the above changes
and those required by the DRC approval letter of May 9,2007 .
Please resolve the above comments, and revise the subject Cell4A BAT Monitoring, Operations and
Maintenance Plan, and resubmit such for DRC approval. If you have questions on the above, feel free to
contact me.
sin/"ty,
fi-x
David A. Rupp, P.E.
Geotechnical Section
Cc: Harold R. Roberts, DUSA
DAR:dr
F:\DUSA\Cell 4AtMonitoring and O&M Plans\Plan Comnrnts Jure 6, 2008
(c)
liquids
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7
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TITLE 4O-_PROTECT]ON OF ENVIRONMENT
CHAPTER I_-ENVIRONMENTAL PROTECTION AGENCY (CONTINUED)
PART 264--STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE
TREATMENT,
STORAGE, AND DISPOSAL FACILITIES--Tab1e of Contents
Subpart L--Waste Piles
Sec. 264.251 Design and operating requirements.
(c) (2) The leachate collection and removal system immediately above t.hetop liner must be designed, constructed, operated, and maintained tocollect and remove leachate from the wast.e pile durinq the active lifeand post-cl-osure care period. the Regional Administrator will speci-fydesign and operating conditions in the permit to ensure that theleachate depth over the liner does not exceed 30 cm (one foot). .The
leachate collection and removal system must comply with paragraphs
(c) (3) (iii) and (iv) of this section.
(c) (3) (v) Construct,ed with sumps and liquid removal methods (e.9.,
pumps) of sufficient size to collect and remove liquids from the sump
and prevent liquids from backing up into the drainage layer- Each unit
must have its own sump(s). The design of each sump and removal system
musL provide a meLhod for measuring and recording the volume of liquidspresent in the sump and of liquids removed.
(4) The owner or operator shall colLect and remove pumpable
in the leak detection system sumps to minimize the head on the1iner.
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