DRC-2012-001963 - 0901a0688030adfc

RC-2012-001963
Operations and Maintenance Plan
Chloroform Pumping System
White Mesa Mill, Blanding, Utah
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INTRODUCTION
Beginning in Apnl of 2003 a long- term pumping test was started in the area of the
chloroform investigation with the pumping from wells MW-4 and TW4-19 Initially the
pump discharge was routed to temporary holding tanks located next to each well
Water pumped to the tanks was penodically removed and transported to Tailings Cell 1
for disposal Later, discharge lines were extended directly to Cell 1
On August 8, 2003, pumping was started from TW4-15 (renamed as MW-26) Water
from this well is also routed to Cell 1 through a discharge pipeline
In late November 2003, pumping from all of the wells was stopped suddenly due to the
freezing of the discharge pipelines The long term pumping test was essentially
complete when the system was shut down in November 2003 Pumping from all three
of the wells was restarted in August of 2004
After re-start of the pumping, preparations were made to wintenze the installations in
order to prevent a re-occurrence ofthe problems encountered dunng the winter of 2003
In August 2005, pumping of well TW4-20 was started with the water from this well also
being pumped to Cell 1
In January, 2010, pumping was started from TW4-4 Water from this well is also routed
to Cell 1 through a discharge pipeline
This operations and maintenance plan is required for all pumping wells approved by the
Executive Secretary associated with the chloroform pumping system
WINTERIZATION FOR LONG-TERM OPERATIONS
The following actions are implemented to provide continuous operations ofthe pumping
well system at the White Mesa Mill dunng cold weather conditions
1) Protective boxes are placed around the wellheads of the five (5) pumping
wells The protective boxes are lined with insulating foam and heat lamps
are installed to ensure that the intenor of the box is maintained at a
temperature above freezing dunng the winter months Winter months are
generally defined as the months of November through March, but
winterization of the pumping wells is maintained at any time the outside air
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temperature is forecast to fall below 20° F for a duration of one (1) day or
more
2) The pump discharge from each of the pumping wells is connected to a 2-
inch polypropylene dram line, which discharges to Cell 1 This line is
placed in an excavated trench and the lines are covered with a minimum
of 3 feet of soil to prevent freezing dunng the winter months
3) During winter weather with potentially freezing conditions (i e less than
20°F), the radiation safety department staff, observe the pumping daily to
ensure that the heat lamps remain functional The Mill maintenance
department is immediately notified if anything unusual is noted with the
system, or if a specific well has encountered a problem
4) The protective features, discharge line placement and winter inspections
descnbed in items 1), 2), or 3) above will apply to not only the (5) pumping
wells currently in operation, but will apply also to any future pumping wells
associated with the chloroform pumping system
OPERATIONS
Pumping wells MW4, MW-26, TW4-19 and TW4-20 were onginally operated dunng the
long term pumping test at a constant flow rate adjusted to allow for maximum drawdown
of the well This necessitated that each of the pumps be valved back to maintain the
drawdown at a pre-determined level This resulted in operating the pumps at a very low
flow rate, which subsequently caused each ofthe pumps to pre-maturely fail
When the pumps were re-started in August of 2004, each of the pumps was allowed to
operate at a higher flow rate, which allowed for full draw down, at which time the pump
was shut down by the internal safety features After the well had recharged the pump
automatically re-started The pump for TW4-4, installed and started up in January
2010, operates similarly
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MAINTANENCE
The operation of each of the pumping wells is monitored on a daily basis dunng the
winter under potentially freezing conditions by the Environmental Health and Safety
Department Any malfunction or abnormal operation of the pumping wells is
immediately reported to the Environmental Health and Safety Department
Environmental Health and Safety Department personnel will penodically inspect the
pumps, flow meters and operational controls and perform preventative maintenance to
reduce the frequency of unscheduled down time of the pumping system A spare pump
IS maintained in the Mill warehouse If a pump is replaced in any of the wells a new
spare is promptly ordered When a system failure occurs and is not repaired and fully
made operational within 24 hours of discovery, DUSA shall call the Executive Secretary
to verbally report the system failure and will report to the Executive secretary in a written
report within 5 days of the failure Each written submission shall contain the following
information
a) A descnption of the pumping system failure(s) and their root causes
b) The penod of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational,
d) Steps taken or that will be taken to repair and have the system fully
operational,
e) Steps taken or that will be taken to eliminate and prevent reoccurrence of
system failure (s)
f) Each system failure and corrective actions, listed above, will be summanzed
in the corresponding quarterly chloroform groundwater monitonng reports
In addition, all system failures will be reported in the following quarterly chloroform
groundwater momtonng report
Each pumping well shall be operating at a minimum of 330 days per calinder year
unless there is wntten approval from the Executive Secretary
MONITORING AND REPORTING
Monitonng of the system by the Mill's Environmental Health and Safety Department
occurs weekly and includes well depths, flow rates, pump operating times and gallons
pumped These items are recorded on a weekly basis on the Weekly Inspection
Report
On a quarterly basis, all chloroform investigation wells are sampled for chloroform,
nitrate+nitnte, dichloromethane, chloromethane, chloride and carbon tetrachloride This
data, including copies of chain of custody forms and laboratory analytical reports, is
reported to the DRC concurrent with the schedule for submission of Quarterly
Groundwater Monitonng Reports, and according to the following schedule
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First Quarter - June 1
Second Quarter - September 1
Third Quarter - December 1
Fourth Quarter - March 1
In addition to the quarterly sampling information, the following information regarding the
chlorofomi pumping system, is included in the quarterly reports
1) Descnption of the pumping operations including any operational problems
encountered dunng the quarter
2) Flow rates and total gallons pumped for the quarter
3) Histoncal gallons pumped to date
4) Updated water level contour map for the site indicating cones of depression
from the pumping and an evaluation of the potential of the pumping to
hydraulically capture the chloroform plume
5) Any additions, modifications or observations dunng the quarter
6) Suggestions for changes or modifications to the pumping system
7) Weekly Chloroform Inspection Form
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Date
Weekly Inspection Form - Chloroform Pumping Wells
Inspection By
MW-4
Time
Operating Condition
( ) System Operational
( ) System Not Operational
Operational problem
Fiow Totalizer reading (gal)
Flow Meter reading (gpm) _
Depth to water (to nearest 0 01 feet)
Corrective Action(s) Taken
MW-26
Time
Operating Condition
( ) System Operational
( ) System Not Operational
Operational problem
Flow Totalizer reading (gal)
Flow Meter reading (gpm) _
Depth to water (to nearest 0 01 feet)
Corrective Action(s) Taken
TW4-4
Time
Operating Condition
( ) System Operational
( ) System Not Operational
Operational problem
Flow Totalizer reading (gal)
Flow Meter reading (gpm) _
Depth to water (to nearest 0 01 feet)
Corrective Action(s) Taken
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TW4-19
Time
Operating Condition Flow Totalizer reading (gal)
( ) System Operational Flow Meter reading (gpm)
( ) System Not Operational Depth to water (to nearest 0 01 feet)
Operational problem
Corrective Action(s) Taken
TW4-20
Time
Operating Condition Flow Totalizer reading (gal)
( ) System Operational Flow Meter reading (gpm)
( ) System Not Operational Depth to water (to nearest 0 01 feet)
Operational problem
Corrective Action(s) Taken
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