DRC-2012-002442 - 0901a0688032bfd1

DRC-2012-00244 2
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www energyfuels com
November 29, 2012
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P O Box 144850
Salt Lake City, UT 84116-4850
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 3rd Quarter of 2012
Dear Mr. Lundberg.
Enclosed please find two copies of the DMT Performance Standards Monitonng Report and Cell 4A
BAT Performance Standards Monitoring Report for the 3rd Quarter of 2012, as required under Parts
LF2 and I.F3 of the White Mesa Mill's States of Utah Groundwater Discharge Permit No
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
Yours VI
ENfikGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Director, Compliance
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Kathy Weinel
November 29, 2012
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
. 303 974 2140
www .energyfuels.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 3rd Quarter of 2012
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell 4A
BAT Performance Standards Monitoring Report for the 3rd Quarter of 2012, as required under Parts
I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Kathy Weinel
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
3rd Quarter
July through September
2012
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
November 29, 2012
TABLE OF CONTENTS
1.0 INTRODUCTION ....••..••...................••....••••••...........•...•............••..•..................•......................•........•.....•...... 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE QUARTER .....••• 1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING ••••...............•.....••...•... 2
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING ..........................•..••.•..•..•............... 3
4.1 GENERAL ...................................................................................................................................................... 3
4.2 RESULTS FOR THE QUARTER ......................................................................................................................... 4
4.3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION ..................................................................... 5
4.4 GRAPHIC COMPARISON TO PREVIOUS YEAR ................................................................................................. 5
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ............................................ 5
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS OF
FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE AREA .•.••....•.•.•... 5
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ...............................................................• 6
8.0 DECONTAMINATION PADS ...............•..•............................•.........•........•............................•.................... 7
8.1 SUMMARYOFWEEKLYINSPECTIONS ........................................................................................................... ?
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ....................................................................... 8
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................................................. 8
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR THE QUARTER.9
9.1 LDS MONITORING ........................................................................................................................................ 9
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ........................................................... 9
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML ................................. 10
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS ............................................................... 10
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4B ................................................. 11
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .. ; ....................................................................................... 11
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING FOR THE QUARTER ......................................... 11
10.1 OPERATIONAL STATUS OFLDS PUMPING AND MONITORING EQUIPMENT ................................................. 11
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ....................................................... 12
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1, 2, AND 3 ................................................. 12
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... 12
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2012 •• 12
12.0 SIGNATURE AND CERTIFICATION ................................•••..............................••••••.•.•.......................•• 13
i
LIST OF TABLES
Table 1 -Summary of Waste Water Pool Elevations
Table 2-New Decontamination Pad Inspection Portal Level
ATTACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to Part I.G.3 of the GWDP
C Monthly Cel12 Slimes Drain Monitoring Data
D Graph of Cell 2 Slimes Drain Water Levels Over Time
E Cell Liner Repair Reports and Notices
F Cel14A and Cel14B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables lA and lB, Cell4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.l2)
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 3rd QUARTER OF 2012
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the third quarter of 2012 (the "Quarter") prepared by Energy Fuels
Resources (USA) Inc. ("EFRI"), as required under Part I.F.2 of the White Mesa Mill's (the
"Mill's") State of Utah Groundwater Discharge Permit No. UGW370004 (the "GWDP"), and the
Routine Cell 4A and Cell 4B Best Available Technology ("BAT") Performance Standards
Monitoring Reports for the Quarter, as required under Part I.F.3 of the GWDP.
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER
During the Quarter, the following DMT monitoring was performed or addressed, as required
under Part I.D .3, I.E. 7, and I.F .11 of the GWDP:
• W eeldy tailings wastewater pool elevations for tailings Cells 1 and 3 (Part
I.E.7(a));
• Quarterly slimes drain water levels in Cell2 (Part I.D.3(b)(l) and (2));
• Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.11);
• Weekly wastewater level measurements in Roberts Pond (Part I.D.3(e) and Part
I.E.7(c));
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part I.D.3(t) and Parts I.E.?( d); and
(e));
• Any tailings cell and pond liner system repairs (Part I.E.7 (t) and Part I.E.(8)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g)) and
• Annual Decontamination Pad Concrete Inspection (Part I.F.11) (not required this
reporting period)
Also during the Quarter, the following Cell4A and 4B BAT performance standards monitoring
was performed, or addressed, as applicable and as required by Parts I.E.8 and I.E.12 of the
GWDP:
• Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.8.(a)), and Cell
4B (Part I.E.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.8 (a))
and Cell4B (Part I.E.12 (a)).
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3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in the Mill's tailings
cells during the third quarter 2012, to ensure compliance with the maximum wastewater
elevation criteria mandated by Parts I.E.7(a), I.E.8(a) and I.E.l2(a) of the GWDP. The results of
such monitoring, reported as feet above mean sea level ("fmsl"), are included in Attachment A.
Part I.D.2 of the GWDP provides that under no circumstances shall the freeboard of any tailings
cell be less than three feet, as measured from the top of the flexible membrane liner ("FML").
The top of the FML in Cell 1 is at 5,618.5 fmsl, and the top of the FML in Cell 4B is 5600.4
fmsl. This means that the maximum wastewater pool elevations in Cells 1 and 4B permitted
under Part I.D.2 of the GWDP are 5,615.5, and 5597.4 fmsl, respectively.
The maximum wastewater pool elevations in Cells 1 and 4B, as measured during the Quarter, are
summarized in the following Table 1. The requirements to meet freeboard elevation limits in
Cell 3 and Cell4A were eliminated as documented on March 14 and 15, 2011 respectively. As
indicated in Table 1, the applicable freeboard limits were not exceeded during the Quarter for
any cell.
All cells also met the maximum wastewater criteria of the Mill's State of Utah Radioactive
Materials License No. UT 1900479 (the "License") throughout the period. However, the
requirements to maintain a minimum freeboard in Cell 3 and Cell 4A were removed by the
Director of the Utah Division of Radiation Control (the "Director") during the first quarter of
2011 as detailed below.
Condition 10.3 of the License provides that the freeboard limit for Cell 1 shall be set in
accordance with procedures that have been approved by the U.S. Nuclear Regulatory
Commission ("NRC"). Under those procedures the freeboard limit for Cell 1 is set as per the
January 10, 1990 Drainage Report for Celli at a liquid maximum elevation of 5,615.4 fmsl.
Condition 10.3 of the License also provides that the freeboard limit for Cells 3, 4A and 4B shall
be recalculated annually in accordance with the procedures approved by the Director. A letter
from the Director dated January 27, 2011 which approved the use of Cell 4B and a subsequent
letter dated March 14, 2011, stated that authorization of the use of Cell 4B and approval of the
DMT and Cell 4A Operations and Maintenance ("O&M") Plans effectively eliminated the
former freeboard elevation requirements for tailings Cell 3. The approvals of the DMT and Cell
4A O&M Plans also resolved previous freeboard exceedance issues and further stated that
former issues regarding the freeboard exceedances for Cell 3 are closed-out. Pursuant to the
receipt of the March 14, 2011letter, freeboard elevation survey measurements in Cell 3 were no
longer required or conducted.
A letter from the Director dated January 27, 2011 which approved the use of Cell 4B and a
subsequent letter dated March 15, 2011, stated approval of the DMT and Cell 4A and Cell 4B
O&M Plans effective! y eliminated the former freeboard elevation requirements for tailings Cell
4A. The approvals of the DMT and Cell 4A and 4B O&M Plans also resolved previous
freeboard exceedance issues and further stated that former issues regarding the freeboard
2
exceedances for Cell 4A are closed out. Pursuant to the receipt of the March 15, 2011 letter,
freeboard limits in Cell 4A were no longer required. The solution elevation measurements in
Cell 4A are not required for compliance with freeboard limits but are required for the calculation
of the daily allowable volume of fluids pumped from the Cell 4A LDS and are collected for this
purpose.
Table 1 -Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measured During the Permitted Under Elevation Permitted
Quarter (fmsl) License Condition Under Part I.D.2 of
10.3 (fms1) the GWDP (fmsl)
Cell1 5610.76 5,615.40 5,615.50
Cell3 Not Measured -No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in Q 1 2011
Cell4A 5593.54 Freeboard limit No Limit No Limit
was removed in Q 1 (5,593.74**) (5,595.50**)
2011.
Cell4B 5579.65 5594.60 5597.40
*The Director approved the removal of the Cell 3 freeboard limit and authorized the use of Cell4B on January 27,
2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
**The Director granted a variance from the Cell4A freeboard limit on January 13, 2011, and approved the removal
of the Cell 4A limit and authorized the use of Cell 4B on January 27, 2011. The previous freeboard limit noted
above for Cell4A was not set out in the License. The freeboard limit of 5,593.74 for Cel14A was set out in a letter
from the Director dated November 20, 2008. The approved DMT Plan, Revision11.1 dated January 2011, included
the removal of the freeboard limit for Cell4A to be replaced by a freeboard limit for Cell4B that will accommodate
the freeboard requirements of Cells 1, 4A, and 4B.
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b)(1) of the GWDP provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the DMT Plan. Part I.D.3(b )(3) of the GWDP
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Part I.D.6(c) of the GWDP provides that, after the Permittee initiates pumping conditions in the
slimes drain layer in Cell 4A, the Permittee will provide: 1) continuous declining fluid heads in
the slimes drain layer, in a manner equivalent to the requirements found in Part I.D.3(b), and 2) a
maximum head of 1.0 feet in the tailings (as measured from the lowest point of the upper FML)
in 6.4 years or less. Similarly, Part I.D.13(c) of the GWDP provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4B, the Permittee will provide: 1)
continuous declining fluid heads in the slimes drain layer in a manner equivalent to the
requirements found in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as
measured from the lowest point of the upper FML) in 5.5 years or less.
3
The GWDP, dated July 14, 2011, Part I.D.3 (b)(2) states "effective July 11, 2011, the Permittee
shall conduct a quarterly slimes drain recovery test ... ". Monthly testing was conducted through
the second quarter of 2011. The frequency change dictated by the GWDP was implemented in
the third quarter 2011. The test ensures that each tailings cell meets the following minimum
requirements: 1) includes a duration of at least 90-hours, as measured from the time that
pumping ceases, and 2) achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements with no change in water level, as measured
to the nearest 0.01 foot.
At this time, dewatering operations have not commenced in Cell 3, Cell 4A, or Cell 4B. As a
result, the requirements in Part I.E.7(b) to monitor and record monthly the depth to wastewater in
the slimes drain access pipes as described in Part I.D.3 of the GWDP apply only to Cell 2 at this
time. Accordingly, this Report is limited to slimes drain recovery head information relating to
Cell2 only.
Pursuant to Parts I.E.7(b) and I.F.2 of the GWDP, Section 8.2 of the DMT Plan and
correspondence from DRC, dated February 7, 2008, the results of quarterly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Performance Standards Monitoring Report
and Cell 4A and Cell4B BAT Performance Standards Monitoring Reports (the "DMT Reports").
Further, beginning in 2008, quarterly DMT Reports must include both the current year values
and a graphic comparison to the previous year. The annual slimes drain recovery head report for
2012, which addresses the requirements of Part I.F.11 of the GWDP and Section 8.2 of the DMT
Plan, will be included in the 4th quarter 2012 DMT Report submitted to the Director on or before
March 1, 2013.
The requirement in Section 3.1(b)(v) of the DMT Plan to monitor the depth to wastewater in the
Cell 2 slimes drain access pipe weekly to determine maximum and minimum fluid head is a
requirement of the License, is not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP, and hence is not required to be included in the routine DMT
Performance Standards Monitoring Report under Part I.F.2 of the GWDP. EFRI has included, in
Attachment C, the information requested by DRC for completeness, as noted in the EFRI letter
dated November 14, 2011. However, EFRI revised the DMT Plan by preparing two separate
plans for the GWDP and the License requirements and submitted the revised plans on July 25,
2012. EFR received DRC approval of the plans on August 6, 2012. Since the approval of the
revised DMT plan was received mid-third quarter, the Cell 2 slimes drain data are included in
this third quarter report. EFRI will provide quarterly DMT reports addressing only the GWDP
DMT requirements beginning with the fourth quarter 2012 report.
4.2 Results for the Quarter
In accordance with these requirements, the quarterly slimes drain recovery head monitoring data
for the Quarter, which includes the date and time for the start and end of the recovery test, the
initial water level, and the final depth to stable water level, as well as a weekly summary data
4
table for the slimes drain head measurements for the Quarter required under the License, are
included as Attachment C to this Report.
4.3 Quality Assurance Evaluation and Data Validation
EFRI management has evaluated all slimes drain data collected, data collection methods, and all
related calculations required by the GWDP, and have verified the accuracy and reliability of both
the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, EFRI has concluded
that all of the 2009, and 2010 monthly slimes drain tailings fluid elevation measurements, and
the 2011 monthly (through June) and quarterly (July forward) slimes drain tailings fluid
elevation measurements to date meet the test performance standards found in Part I.D.3(b )(2) of
the GWDP and can be used for purposes of determining compliance with the requirements of
Part I.D.3(b)(2) of the GWDP.
4.4 Graphic Comparison to Previous Year
A graph showing the final depth to stable water level readings for each month in 2009 through
third quarter 2012 (quarterly beginning in July 2011), for which validated data is available (see
Section 4.3 above), is included as Attachment D, which shows a graphic comparison of this
Quarter's data to data for 2009, 2010, 2011 and 2012.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
During the Quarter, Mill personnel monitored and recorded weekly the wastewater levels at
Roberts Pond to determine compliance with the DMT operations standards in Part I.D.3(e) of the
GWDP. Part I.D.3(e) of the GWDP provides that the water level in Roberts Pond shall not
exceed an elevation of 5,624 fmsl.
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5,617.90
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The results of such
monitoring are included in Attachment A.
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the GWDP and that all alternate feedstock located outside the defined
feedstock area is maintained within containers that comply with the requirements of Part I.D.11
of the GWDP. The results of these inspections are recorded on the Weekly Mill Inspection
forms, which are available at the Mill for inspection. One item was noted during the third
quarter inspections. During the weekly inspections conducted on July 13, 2012, August 3, 2012,
August 24, 2012, September 9, 2012, and September 28, 2012 standing water was noted in the
5
feedstock storage areas. The water was the result of heavy precipitation. No corrective actions
were necessary as the areas where water was noted are sloped towards a drainage sump that
allows the water to drain to Cell 1. The remaining water noted during the weeki y inspections
listed above, was a small amount which remained after the majority of the rain water had
drained.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, 3, 4A, and 4B were inspected on a daily basis pursuant to the
requirements of Sections 2.1 and 2.2 of the Mill's DMT Plan. The results of those inspections
are recorded on the Mill's Daily Inspection Data sheets, which are available at the Mill for
review. A visual inspection of Roberts Pond was performed on a weekly basis. The results of
those inspections are recorded on the Weekly Mill Inspection forms, which are available at the
Mill for review.
In accordance with Part I.E.7(t) of the OWDP, in the event that any liner defect or damage is
identified during a liner system inspection, the Mill shall immediately implement the currently
approved Liner Maintenance Provisions. Further, Part I.F.2 of the OWDP provides that when a
liner repair is performed at any tailings cell or at Roberts Pond, a Repair Report shall be prepared
and included with the next quarterly DMT report.
The second quarter 2012 DMT report included the Cell1 FML repair activities report as required
by the September 22, 2010 Confirmatory Action Letter. DRC approved the EFRI Cell 1 FML
repair report by letter dated September 25, 2012. The September 25, 2012 DRC letter also noted
"The DRC will maintain an open file for the Cell 1 liner repair until the design maximum
operating fluid level is held for 30 days and monitoring of the leak detection system yields
results supporting a finding of successful repair. Routine leak detection system monitoring, as
presented in the quarterly DMT report will suffice as a reporting tool, along with noting the date
the fluid level reached design maximum." As noted in the September 22, 2010 Confirmatory
Action Letter, the fluid level design was lowered to 5613.1 fmsl to facilitate liner repair. The
design maximum operating fluid level is therefore above that level. Mill personnel monitored
and recorded weekly the elevation of wastewater in Cell 1 during the third quarter 2012, to
ensure compliance with the maximum wastewater elevation criteria mandated by Parts I.E.7(a),
I.E.8(a) and I.E.12(a) of the OWDP. The weekly measurements are included in Attachment A.
As noted in Attachment A, the fluid level in Cell 1 was at all times lower than 5613.1 fmsl
during the third quarter 2012. This open item will continue to be monitored and reported in
future DMT reports until the DRC conditions for closure of the Cell 1 FML repair report are met.
Mill operations notified EFRI Corporate environmental management on Tuesday, July 31, 2012,
of a tear in the FML of Roberts Pond. The notification of the tear in the FML was made during a
review of the readiness of environmental equipment for the upcoming Mill startup. EFRI
provided initial notification to the DRC by telephone at approximately 2:00pm on Tuesday, July
31, 2012 (within 24 hours of the readiness determination), as contemplated by Parts I.E.7 f) and
1.0.3 of the Permit. Additionally, EFRI provided 5-day written notification to DRC
contemplated by Parts I.E.7 f) and 1.0.3 of the Permit on August 6, 2012. The written
notification is included in Attachment B.
6
Roberts Pond was empty and taken out of service in June 2012 for routine maintenance and
preparation for Mill startup. Roberts Pond underwent cleanout of accumulated sediment during
the month of July 2012. The long-arm bucket excavator used for solids removal created a tear in
the FML of Roberts Pond at approximately 1:30pm on July 5, 2012. Roberts Pond was empty
of solutions or wastewaters at the time of the incident, and remained empty, due to the
maintenance outage until it was put back into service during the week of August 6, 2012.
Repairs to the liner were performed and completed during the week of July 12, 2012, in
accordance with the Mill's Liner Maintenance Provisions. Roberts Pond received process fluids,
as necessary, after the completion of repairs.
As noted in the EFRI notification letter dated August 6, 2012, repairs to the Roberts Pond FML
were performed and completed during the week of July 12, 2012. Consistent with Part I.F.2 of
the GWDP EFRI has included the required repair report as Tab E to this DMT report.
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Inspections
Part I.F.7 (g) of the GWDP and Section 3.1 of the DMT Plan require that a weekly inspection of
the New Decontamination Pad be performed, and that the vertical inspection portals on the New
Decontamination Pad which are located between the primary and secondary containments be
visually observed on a weekly basis as a means of detecting any leakage from the primary
containment into the void between the primary and secondary containments. The BAT
performance standards for the New Decontamination Pad are set out in Part I.D.14 of the
GWDP. The New Decontamination Pad was placed into service on March 22, 2010. Use of the
New Decontamination Pad was temporarily suspended during the second quarter 2010 as a result
of a cease and desist order from DRC dated May 18, 2010. Because the New Decontamination
Pad was not in use after the second quarter 2010, the weekly inspections of the containments
were stopped for the remainder of 2010. The Executive Secretary provided authorization for use
of the New Decontamination Pad in a letter dated February 1, 2011. Use of the New
Decontamination Pad resumed in February 2011 and the weekly inspections were resumed as
required.
Table 2 below indicates the water level measurements in each portal measured during the
quarter.
7
Table 2 -New Decontamination Pad Inspection Portal Level for the Third Quarter 2012
Portal1 Portal2 Portal3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
7/6/2012 0.00 0.00 0.00
7/12/2012 0.00 0.00 0.00
7/20/2012 0.00 0.00 0.00
7/27/2012 0.00 0.00 0.00
8/3/2012 0.00 0.00 0.00
8/10/2012 0.00 0.00 0.00
8/17/2012 0.00 0.00 0.00
8/24/2012 0.00 0.00 0.00
8/30/2012 0.00 0.00 0.00
9/7/2012 0.00 0.00 0.00
9/14/2012 0.00 0.00 0.00
9/20/2012 0.00 0.00 0.00
9/28/2012 0.00 0.00 0.00
As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the quarter.
Any soil and debris identified during the weekly inspections was removed from the wash pad of
the New Decontamination Pad, in accordance with part I.D.14 (a) of the GWDP and Section 3.1
(e)(i)(F) of the DMT Plan. No cracks greater than 1/8" were observed during any weekly
inspections.
8.2 Annual Inspection of Existing Decontamination Pad
As required by Part I.F.12 of the Permit, annual inspections of the existing decontamination pad
must be conducted during the second quarter of each year. The documentation for the 2012
annual inspections was reported in the Second Quarter DMT report submitted August 23, 2012.
The 2013 annual inspection will be conducted during the second quarter of 2013.
8.3 Annual Inspection of New Decontamination Pad
As previously stated, the New Decontamination Pad was placed into service on March 22, 2010.
Use of the New Decontamination Pad was temporarily suspended as a result of a cease and desist
order from DRC dated May 18, 2010. DRC's approval for use of the New Decontamination Pad
was granted on February 1, 2011, following submittal of revisions to the DMT Plan and DRC
observation of hydrostatic testing of the in-ground water holding tanks. Revisions to the DMT
Plan were submitted by Denison on November 12, 2010 and reviewed by DRC. Hydrostatic
testing was re-performed from November 24 to 26, 2010 following a 10-day advanced notice to
DRC on November 12, 2010. The Executive Secretary provided an authorization for use of the
8
New Decontamination Pad in a letter dated February 1, 2011. Use of the New Decontamination
Pad resumed in February 2011.
Annual inspections of the new decontamination pad are conducted during the second quarter of
each year. The documentation for the annual inspections was reported in the Second Quarter
DMT report submitted August 23, 2012. The 2013 annual inspection will be conducted during
the second quarter of 2013.
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR
THE QUARTER
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report for the Quarter, as required under Part I.F.3 of the GWDP.
9.1 LDS Monitoring
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 4A and Cell 4B, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment,
operated continuously during the Quarter.
Cell4A
During the Quarter, there were no failures of any pumping or monitoring equipment not repaired
and made fully operational within 24-hours of discovery, as contemplated by Part I.E.8(a)(1) for
Cell4A.
During the Quarter there was one failure of the Cell 4A monitoring equipment which was made
operational within 24-hours of discovery, as required by Part I.E.8(a)(1) for Cell 4A. On July
23, 2012, Mill Personnel noted that the Cell4A LDS monitoring equipment was malfunctioning
and the computer feeds were not recording properly. The daily readings required by the
approved DMT Plan in effect at that time, Section 2.l.q), Revision 11.5, dated 2/12 were
measured and recorded on the Daily Inspection form and no compliance data were lost. Mill
personnel reset the electronic components and all functionality was restored. EFRI notified DRC
by telephone on July 23, 2012. DRC personnel concurred that no additional notifications were
necessary since full function was restored within 24-hours of discovery.
Cell4B
During the Quarter, there were no failures of any pumping or monitoring equipment not repaired
and made fully operational within 24-hours of discovery, as contemplated by Part I.E.12(a)(1)
for Cell4B.
9
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML
The readings pertaining to the fluid head above the lowest point in the secondary FML for Cells
4A and 4B are provided in Attachment F.
As can be seen from a review of Attachment F, at no point in the Quarter did the fluid head in the
Cell 4A LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring this 1-foot distance equates to 2.28 feet
[27.36 inches] above the LDS system transducer), as stipulated by Part I.E.8(a)(2) of the GWDP.
During the Quarter, the fluid head in the Cell 4A LDS sump did not exceed 12.1 inches above
the LDS transducer.
As can be seen from a review of Attachment F, at no point in the Quarter did the fluid head in the
Cell 4 B LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor, as stipulated by Part I.E.12(a)(2) of the GWDP. For the purposes of compliance
monitoring this 1-foot distance equates to 2.25 feet (27 inches) above the LDS system. During
the quarter the fluid head in Cell4B sump did not exceed 2.41 inches above the LDS transducer.
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment F.
Cell4A
As can be seen from a review of Attachment F, 2,689 gallons of fluid were pumped from the Cell
4A LDS for the third quarter of 2012. Based on this, the average daily LDS flow volume in Cell
4A did not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the GWDP.
Daily allowable volume of fluids pumped from the Cell 4A LDS have also been calculated based
on weekly tailings cell fluid measurements using the calculations provided in the Cell 4A BAT
Operations and Maintenance Plan. A letter from the Director dated January 27, 2011 which
approved the use of Cell4B, and a subsequent letter dated March 15, 2011, stated approval of the
DMT and Cell 4A Operations and Maintenance ("O&M") Plans and effectively eliminated the
former freeboard elevation requirements for tailings Cell 4A. Pursuant to the receipt of the
March 15, 2011 letter, freeboard limits in Cell 4A were no longer required. However, the
weekly wastewater elevations were completed in order to calculate the maximum daily allowable
flow volume, based on in the Cell 4A BAT Operations and Maintenance Plan. Based on the
wastewater pool elevation surveys conducted during the quarter, and the maximum head
recorded on the FML during the Quarter of approximately 38 feet, the allowable flow rate would
be approximately 604.0 gallons/acre/day, as determined under the Mill's Cell 4B BAT
Operations and Maintenance Plan, Table 1A (also included in Attachment F of this report), and
assuming a liner elevation of 5555.55 feet and approximately 40 acres of liquid area. The
average daily flow volume in Cell 4A did not exceed the calculated flow volume of 24,160
gallons/day. As mentioned above, during third quarter of 2012, 2,689 gallons of fluid were
pumped from Cell 4A LDS during the period and did not exceed the calculated flow volume.
The third quarter allowable flow rate calculation for Cell 4A is included in Attachment F of this
report.
10
Cell4B
As can be seen from a review of Attachment F, 25 gallons of fluids were pumped from the Cell
4B LDS for the third quarter of 2012 and the flowrate is therefore below the 26,145 gallons/day
limit, as stipulated by Part I.E.12(a)(3) of the GWDP.
Based on the wastewater pool elevation surveys conducted during the quarter, the maximum
head recorded on the FML during the Quarter was approximately 22 feet. The allowable flow
rate would therefore be approximately 475.6 gallons/acre/day, as determined under the Mill's
Cell 4B BAT Operations and Maintenance Plan, Table 1B (also included in Attachment F of this
report), and assuming' a liner elevation of 5557.5 feet and approximately 36.17 acres of liquid
area. The average daily flow volume in Cell 4B did not exceed the calculated flow volume of
17,202 gallons/day. During third quarter 2012, 25 gallons of fluids were pumped from Cell 4B
LDS and therefore did not exceed the calculated flow volume. The third quarter allowable flow
rate calculation for Cell 4 B is included in Attachment F of this report.
9.2 Measurement of Weekly Wastewater Fluids in Cells 4A and 4B
Weeldy fluid elevations for Cells 4A and 4B for the quarter are provided in Attachment A along
with elevations for Cell 1 and Roberts Pond.
9.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Cell4A or Cell4B slimes drain system at
this time, monthly recovery head tests and fluid level measurements are not required to be made
at this time pursuant to Part I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING FOR THE QUARTER
The requirement in Section 3.1(a) of the DMT Plan to monitor the LDS for Cells 1 and 3 is a
requirement of the License, is not a· DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP, and hence is not required to be included in the routine DMT
Performance Standards Monitoring Report under Part I.F.2 of the GWDP. EFRI has included, in
Attachment F, the information requested by DRC for completeness, as noted in the EFRI letter
dated November 14, 2011. However, EFRI revised the DMT Plan by preparing two separate
plans for the GWDP and the License requirements and submitted the revised plans on July 25,
2012. EFR received DRC approval of the plans on August 6, 2012. Since the approval of the
revised DMT plan was received mid-third quarter, the Cell1, Cell2, and Cell3 data are included
in this third quarter report. EFRI will provide quarterly DMT reports addressing only the GWDP
DMT requirements beginning with the fourth quarter 2012 report.
10.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 1, Cell 2, and Cell 3, including,
but not limited to, the submersible pump, pump controller, head monitoring, and flow meter
equipment, operated continuously during the Quarter.
11
For Cell 1, during the Quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
For Cell 2, during the Quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
Cell3
For Cell 3, during the Quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
10.2 Measurement of the Volume of Fluids Pumped from the LDS
No fluids were pumped from the Cells 1, 2 or 3 LDSs during the quarter because no fluids were
detected in the Cells 1, 2 or Cell3 LDSs.
10.3 Measurement of Weekly Wastewater Fluids in Cells 1, 2, and 3
A summary of the fluid elevations for the Cells 1, 2 and 3 LDSs for the quarter are provided in
Attachment F. The LDS for Cells 1, 2, and 3 were dry during the quarter.
10.4 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Cells 1 or Cell 3 slimes drain system at
this time, monthly recovery head tests and fluid level measurements are not required at this time.
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2012
The annual slimes drain recovery head report for Cell 2 for calendar year 2012 (the "Period"), as
required under Parts I.D.3 (b) and I.F.11 of the GWDP and Section 8.2 of the DMT Plan will be
included with the 4th quarter DMT report which will be submitted on or before March 1, 2013.
12
12.0 SIGNATURE AND CERTIFICATION
This document was prepared by Energy Fuels Resources (USA) Inc. on November 29, 2012.
By:
David . ryde lund
Senior Vice President, Regulatory Affairs and General Counsel
13
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and co plet I am aware that there are significant penalties for submitting false information,
includ· g th possibility of fine and imprisonment for knowing violations.
Da
Senior Vice President, Regulatory Affairs and General Counsel
Energy Fuels Resources (USA) Inc.
14
Attachment A
Date Celll Cell3 2 Cell 4A 3 Cell 4B 4 Roberts Pond
Free Board
Limit under the
License 1 5615.40 5602.50 5593.74 5594.60 5624.00
7/6/2012 5610.76 No Longer Required 5592.22 5579.65 DRY
7/12/2012 5610.46 No Longer Required 5592.27 5579.47 DRY
7/20/2012 5610.41 No Longer Required 5592.22 5579.28 DRY
7/27/2012 5610.51 No Longer Required 5592.16 5579.20 DRY
8/3/2012 5610.38 No Longer Required 5592.18 5579.15 DRY
8110/2012 5610.30 No Longer Required 5592.12 5579.13 DRY
8117/2012 5610.30 No Longer Required 5592.07 5579.12 DRY
8/24/2012 5610.42 No Longer Required 5592.79 5578.73 5617.10
8/30/2012 5610.46 No Longer Required 5592.97 5578.91 5617.04
9/7/2012 5610.39 No Longer Required 5593.51 5578.94 5617.52
9/14/2012 5610.42 No Longer Required 5593.54 5578.73 5617.68
9/20/2012 5610.39 No Longer Required 5593.42 5578.88 5617.74
9/28/2012 5610.64 No Longer Required 5593.43 5578.99 5617.90
1 The freeboard limit as permitted under License condition 10.3 is no longer applicable to Cell3 or Cell4A.
2Cell 3 is nearly full of solids, and is undergoing pre-closure steps. The freeboard limit specified here is no longer
required and the weekly measurements are no longer required per the January 27 and March 14, 2011letters from
DRC.
3 The freeboard limit for Cell4A is not set out in the License. The freeboard limit of 5,593.74 for Cell4A is set out
in a letter from the Director dated November 20, 2008. Denison proposed in the DMT Plan revision dated
November 12, 2010 the removal of the freeboard limit for Cell4A to be replaced by a freeboard limit for new Cell
4B that will accommodate the freeboard requirements of Cells 2, 3, 4A, and 4B. The Director granted a variance
from the Cell4A freeboard limit on January 13, 2011 and approved the removal of the Cell4A limit and the use of
Cell 4 B on January 27, 2011. The weekly measurements are no longer required for compliance with freeboard
limts, but are required to calculate the daily permissable leakage rate for Cell 4A.
4 The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A pool
surface area of 40 acres is used because there are no beaches present in Cell 4 B at this time.
Attachment B
)
August6,2012
VIA PDF AND EXPRESS DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Dear Mr. Lundberg:
Re: Utah Ground Water Discharge Permit No. UGW3700004
White Mesa Uranium Mill-Notice Pursuant to Parts I.E.7 f) and I.G.3 of the Permit
Please take notice pursuant to Parts I.E.? f) and I.G.3 of the White Mesa Mill's (the "Mill's") State of Utah
Groundwater Discharge Permit No. UGW370004 (the "Permit"), that Energy Fuels Resources (USA) Inc.
("EFR"), (formerly named Deniso_n Mines (USA) Corp.), as operator of the Mill and holder of the Permit,
identified and repaired damage to the Roberts Pond Liner System as described in more detail below.
Roberts Pond has been empty and out of service since June 2012 for routine maintenance and
preparation for Mill startup. Roberts Pond underwent cleanout of accumulated sediment during the month
of July 2012. The long-arm bucket excavator used for solids removal created a tear in the flexible
membrane liner ("FML") of Roberts Pond at approximately 1 :30 pm on July 5, 2012. Roberts Pond was
empty of solutions or wastewaters at the time of the incident, and remains empty, due to the maintenance
outage.
Repairs to the liner were performed and completed during the weeks of July 5 and July 12, 2012, in
accordance with the Mill's Liner Maintenance Provisions. The Mill will return Roberts Pond to service
during the week of August 6, 2012, and it may receive process fluids, as necessary, at any time
afterwards.
Mill operations notified EFR Corporate environmental management on Tuesday, July 31, 2012, during a
review of the readiness of environmental equipment for the upcoming Mill startup. EFR provided initial
notification to the Division of Radiation Control ("DRC") by telephone at approximately 2:00 pm on
Tuesday, July 31 , 2012 (within 24 hours of the readiness determination), as contemplated by Parts I.E.?
f) and I.G.3 of the Permit.
1. Facts and Background Information
a) Part I.E.? f) of the Permit requires that the licensee conduct daily inspections for each of the
tailings cells and weekly inspections of Roberts Pond. According to Part I.E.? f):
"In the event that any liner defect or damage is identified during a liner system
inspection, the Permittee shall: 1) report and repair said defect or damage pursuant
to Part I.G.3 by implementation of the currently approved Liner Maintenance
Provisions, and 2) report all repairs made pursuant to Part I.F.2."
Energy Fuels Resources (USA) Inc.
Lakewood, CO 80228
225 Union Boulevard, Suite 600
Phone: [phone]
Notice to Director
8/6/2012
Page 2
b) Although Part 1.G.3 of the Permit is stated to apply to circumstances where the Permittee fails
to maintain Discharge Minimization Technology ("DMT") or Best Available Technology ("BAT")
standards, Part I.E.? f) requires that the notification provisions of Part I.G.3 also apply to liner
defects or damage, regardless of whether or not the liner defect or damage constitutes a failure
of DMT or BAT. Under Part I.G.3, the Permittee is required to submit to the Executive
Secretary1 a notification and description of the defect or damage orally within 24-hours of the
Permittee's discovery, followed by written notification within five calendar days.
c) The liner damage occurred, and was immediately identified, at 1 :30 pm on July 5, 2012, apart
from a liner maintenance inspection. The damage incident occurred as a result of
maintenance activities, when Roberts Pond was in empty condition during a planned
maintenance outage. The liner was repaired during the weeks of July 5 and July 12, 2012, in
accordance with the Mill's Liner Maintenance Provisions, which describe the types of repairs
that will be implemented, as well as requirements for a repair report describing the nature of
the damage and the repairs.
d) As contemplated by Parts I.E.? f) and I.G.3 of the Permit, EFR provided notification to Mr. Phil
Goble of DRC at 2:00 pm on July 31, 2012, within 24 hours of corporate environmental staff
receiving information from Mill personnel regarding the incident, as part of a readiness
determination prior to Mill start up and use of the pond.
e) This Notice constitutes the 5-day written notice contemplated by Parts I.E.? f) and I.G.3 of the
Permit.
2. Actions Taken
Upon receipt of the initial identification, the Mill's Environmental Coordinator notified the Mill Manager by
2:00 pm that day. The following plan of action was immediately put into place in accordance with the
Liner Maintenance Provisions and Section 3.1 of the Mill's Environmental Protection Manual:
a) The Roberts Pond liner was repaired during the weeks of July 5 and July 12, 2012.
b) Mill personnel prepared daily liner maintenance reports and collected data required for
submittal consistent with the Liner Maintenance Provisions and Part I.F.2 of the Permit.
c) Corporate Environmental Staff received notification that the Liner Maintenance Provisions had
been implemented.
3. Actions That Will be Taken to Prevent a Reoccurrence of this Incident
The following actions will be taken to prevent a reoccurrence of this incident:
a) The Mill will perform cleanouts of Roberts Pond on a more frequent basis, to minimize the
volume of solids accumulated, and reduce the size of equipment needed for solids removal.
b) If heavy equipment is required for solids removal from Roberts Pond, the Mill will use
equipment smaller than the long-arm bucket excavator used in July 2012, where possible.
1 The Executive Secretary is currently referred to as the Director as a result of revisions to R317 passed
during the Utah 2012 legislative session.
Notice to Director
8/6/2012
Page 3
c) A repair report containing a root cause analysis and further documentation of the repairs will be
submitted to the Director with the quarterly DMT Report following the incident, as discussed in
Section 4, below.
4. Required Reporting
As required by Part I.F.2 of the permit and by the Mill's Liner Maintenance Provisions, a repair report will
be submitted to the Director with the next quarterly DMT Report following completion of the repairs.
Repairs were completed during the third quarter of 2012. The repair report will be submitted with the third
quarter 2012 DMT Report on or before December 1, 2012. The repair report will contain, in addition to a
root cause analysis, the following elements:
• Repair narrative describing the nature of the damage and the repair work completed to repair the
damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
5. Affirmative Defense
EFR does not believe that identification of a defect or damage to the Roberts Pond liner caused by
maintenance activities and repair of such defect or damage in accordance with the Mill's Liner
Maintenance Provisions constitutes a failure of DMT under the Permit. Further, at the time of the incident,
Roberts Pond was not in use and was empty. As a result, EFR is not making a claim for an affirmative
defense under Part I.G.3 of the Permit.
Please contact me if you have any additional questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Katherine A. Weinel
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 9/27/2012
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer
9/21/12 9/22/12 9/23/12 9/24/12 9/25/12 9/26/12
700 23.82 22~97 22.43
800 23.78 22.95 22.41
900 35.56 23.74 22.92 22.39
1000 34.10 23.70 22.90 22.36
1100 33.45 23.67 22.85 22.32
1200 32.80 23.61 22.80 22.27
1300 32.26 23.55 22.76 22.22
1400 31.82 23.50 22.73 22.15
1500 31.40 23.44 22.69 22.09
1600 26.26 24.40
Comments:
We started the quarterly slimes recovery on 9/21/2012 at 0900 which was a Friday.
The single readings were taken on a Saturday and a Sunday when the environmental staff was
out of the office.
9/27/12
21.84
21.84
21.84
' , . . ' ··•· .. ..,, ·,,, I .•. • . ·.>1··•· ·.· ~-' 'i~' .. •\',f>i.ii\:111
Date .·. [).epthto<Uquid pr¢-pepthto .Hquid • Pr~~Pur11~ Ro~tj .. 2.> ; ·. Fygf,ti?rJl~~;:
I. pump (ft.) ·•· post-pum,p (ft.) · . Head (ft.) .···· .. ··I fiee~~lfi· 1 • ••..••.. ............ :eroperly ··
..• .·· .... ... •• ·..•. .• .•. .··. ..·•.·· ··.·• • •...•... .•. ······•·····.···· > ·.· ··. • .•.... · '· ; .. (yes/nq)
7/6/2012 35.43 36.49 2.54 1.48 Yes
7/12/2012 35.51 36.48 2.46
7/20/2012 35.67 36.74 2.30
7/27/2012 35.51 36.48 2.46
8/3/2012 35.51 36.59 2.46
8/10/2012 35.41 36.62 2.56
8/17/2012 35.61 36.64 2.36
8/24/2012 35.59 36.65 2.38
8/30/2012 35.60 36.61 2.37
9/7/2012 35.60 36.71 2.37
9/14/2012 35.53 36.67 2.44
9/20/2012 35.63 36.47 2.34
9/28/2012 35.67 36.76 2.30
The pre and post-pump head level calculations are done as follows :
Pre-pump head= (37 .97(ft)-depth to liquid pre-pump)
Post-pump head= (37.97 (ft)-depth to liquid post-pump)
1.49 Yes
1.23 Yes
1.49 Yes
1.38 Yes
1.35 Yes
1.33 Yes
1.32 Yes
1.36 Yes
1.26 Yes
1.30 Yes
1.50 Yes
1.21 Yes
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/12 Revision: Denison11.5
Page 33 of 55
Date: 1/Lf'lDYJ..
1. Pond and Beach
elevations (n1sl, ft) ·
• A \
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Ce111: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) -~1~...,.~7--''----
Ce114A: (a)Pond Solution Elevation SStt~AA
(b )FML Bottom Elevation __ 5555 .14_
( c )Depth of Water above FML ( ( a)-(b)) 37. 08
Cell4B: (a)Pond Solution Elevation S571.b5
Roberts
(b)~ML Bqttom Elevation 5S57:SO
.· ( c.)Q.epth of W at~r above FML ( ( £J}(b)). gg.).S , ·
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation ==-r65. _
(b )FML Bottom Elevation -U v
(c)Depth of Water above FML ((a)-(b)) ----~-
" ,. ""' ...
···"' ..
•• J
2. Slimes Drain Liquid Levels Cell2 Pump functioning properly '-/t!~
< ••
_-:)=-S.--S...'i~~~-__;_.-Depth to Liquid pre-pump
-~~~'-'<..'i_._..<f ___ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37 .97' -Depth to Liquid Pre-
pump= 25!f
Post-pump head is 37.97' -Depth to Liquid Post-
putnp = J ."{t
C:\Documents and Settin~s\dturk.DMOl.ocal Settimrs\Temporary Internet Files\Content.Outlook\Vl\!I3Y6SH\DMT Plan February 2012 Rev 11 5
clean.docN:\DMT P~ Plan 00.19.12 R&1 ll.S\DMT Plan Feb11:1ary 2012 Re>l 11.5 ele~l\'IT Plan\DMT Plaa-92.29.12 R,et,.
11.5\D±v!T Plan ~--2(}.f..2-.P&Y 11.5 redline.doe
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3J
3. Leak Detection Systems
2/12 Revision: Denison11.5
Page 34 of 55
(Same data as Daily Inspection Fmn1. Record data on daily form).
-Observation: 1!1,
New Decon Pad2 New Decon Pad2 New Decon Pad
Portall Portal2 Portal3
,.
Is LDS (Portal) __ wet_£_dry __ wet~dry __ wet~dry
wet or dry?
If wet, RecGrd -. ... ... Ftto -Ftto r Ft to
liquid level: Liquid Liquid Liquid
'-. -,, ....
If wet, Repmt to
RSO
5. Control Methods Implemented: ______________________ _
~ .
6. Remarks:~~~~~~~~~~~~~~~~~~~~~~~~~~~A~~~~-----~ n ~ • t 00 k..s ,Esooc.t.
7. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
L •• ~,.. CroJ
* Does Level exceed 12 inches above the lowest point on the bottom flexible 1nembrane liner (solution
elevation of 5556.14 an1sl for Cell-~A and 5558.50 for Ce114B)? _$_no __ yes
If Cell4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill1nanager immediately.
C:\Documents and Settings\dturk.DMOLocal Settings\Tempora.J.y Intemet Files\Content.Outlook\VM3Y6S1I\DMT Plan Februarv 2012 Rev 11 5
dean.docN:\DMT PlaffiDMT Plan 02.29.12 Rm.z....f..l...:§.DMT Plan Febrnarv 2012 R:e·.: 11.5 deaa:fl
~cbnmry 2012 Re>: 11.5 redline.des
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/12 Revision: Denison11.5
Page 33 of 55
Date: 7/12. /2-0l'J...
1. Pond and Beach
elevations (n1sl, ft)
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Botton1 Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) -~' !..=--...~'iL.::::';..__ __
Cell4A: (a)Pond Solution Elevation S.SCJ"-.. 27
(b)FMLBottomElevation __ 5555.14_
(c)Depth of Water above FML ((a)-(b)) S7.1S
Cell4B: (a)Pond Solution Elevation S571.1.f7
Roberts
(b )FiyiL Bottpl?J;-~l~vation~ 5557.50
(c) Depth o_f Water ~l:>ove FML { ( a);(b)) ~1. q7
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Pong: ( a)Pond,Bolutio11 E.~eyation
· -(b .. ) .. FML Botto11-i Elev .. a.tion <• •,' r 'A < •,
(c)Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly 'l~'5i
_3.....;;~'"""".,5_1-'--------:Depth to Liquidpre-pump
.....;3::;.:4oo:..;;.__,'i..,.._I ____ .Depth to Liquid Post-pump
(all1neasurements are depth-in-pipe)
Pre-pump head is 37 .97' -Depth to Liquid Pre-
pump = ;1. ."''
Post-pump head is 37 .97' -Depth to Liquid Post-
pump= f .. '-fdl
C:\Documents and Setting:s\dturk.DMC\Local Setti11g:s\Temporary InternetFiles\Content.Outlook\VM3Y6Sll\D1v1T P1anFebruacy 2012 Rev 115
clean.clocN:\D'fl.'IT P~~.~~~~2 Rev11.5 dean.docN:\I1i\IT Pftt~'1\DilriTP1aa-~
~, 2012 Rev 11.5 Fcalil~e.dee
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/12 Revision: Denisonll.5
Page 34 of 55
3. Leak Detection Systen1s
(San1e data as Daily Inspection Fonn. Record data on daily fonn).
Observation: '· '
New Decon Pad2 New Decon Pad~
Portall Portal2
'
Is LDS (Portal) __ wet ./dry __ wet~dry
wet or dry?
If wet, Record Ftto Ftto
liquid level: Liquid Liquid
'···
If wet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
t $one. L..\a lva.\Jc. &oo.cls o. J:+Hc """"~.
New Decon Pad
Portal3
/.
__ wet -'dry
Ftto
Liquid
I
5. Control Methods Implemented: f'\e.tt\.J.cnotl£< , M 011 cell 'if\-fbon.j p~1"1f .ror
-p~ tcl.At'f\ LiA€. ·"'""'~ (.:rew ou:\ \,t.J:~ f{oo.4.
7. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
loolls. 6-.a.l. !
* Does Level exceed 12 inches above the lqvv-~st point on the bottmn flexible meybrane liner (solution
elevation of 5556.14 ruusl for Cell4A-.and 5558.50 for Cell4B)? __ no __ yes
If Cel14A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 a1nsl), notify supervisor or Mill n1anager in1n1ediately.
C:\Documents and SettiMs\dturk.DMC\Local Settings\Temporru.:y IntemetFiles\Content.Outlook\VM3Y6Sli\DMT Plan February 2012 Rev 11 5
clean.docN:\D:tlT Platr\DMT Plaa 02.29.12 Re'>~.t>MT-Plaa Pcbruan ~011 R:::.: l1.5 deaa:flooN:WMf Pla."'l\DMT Plaa 92.29.1~
-1~\Qi>r!T Plaa Februm~w; 11.5 redliae.doo
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonll.5
Page 33 of 55
Date: i / ')...0 / ~a\l..
1. Pond and Beach
elevations (msl, ft)
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation .SblO .. 'i J
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) ----=-·-=~:£....'"f-+-'-l __
Cell4A: (a)Pond Solution Elevation S5<f~ .A2.
(b)FML Botton1 Elevation __ 5555.14
(c)Depth of Water above FML ((a)-(b)) 37.0g-
Ce114B: (a)Pond Solution Elevation sS7f.2.t
(b )FML Bottom Elevation 5557 ;so
(c)Depth of Water above FML ((a)-(b)) lJ .. 78
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Roberts ]
Pond: (~)Pond Solution Elev~tion ~ L
(b)FML.B,ottom Elevation • · ·. ·. ,.) . 6f?.3~ '
(c)Depth ofWaier aboveFML ((a)-(b)) ·. ' ~·
~ ' ~ I 'I
2. Slimes Drain Liquid Levels Cell2 Pump functioning properly '{<..~
_'!>_!>_ .. _,~,=------_Depth to Liquid pre-pump
-~---=-·1_,_j....._ ___ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37.97' -Depth to Liquid Pre-
pump = .2 .~(.)
Post-pump head is 37.97' -Depth to Liquid Post-
pump= 1.~3
C:\Documents and Settimrs\dlurk.DMO.Local Settings\ Temporary Internet Files\Content.Outlook\VM3Y6Sll\DMT Plan February 2012 Rev 11 5
clean.doc:N:\DMT Plaa\DMT Plan 02.29.12 Re:v 11.5\DMT Plan Peeraary 2012 Rev 11.5 elean.docN:\DiVIT Plan\DMT Plan{}2.29.l2 Rev
-11.5\DMT Plan Peemmy 2012 Rev 11.5 realffie.dec
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
2/12 Revision: Denison11.5
Page 34 of 55
(Same data as Daily Inspection Form. Record data on daily form).
Observation:, •'
New Decon Pad, New Decon Pad,
Pmtal1 Porta12
Is LDS (Portal) __ wet_$_dry __ wet__:i_dry
wet or dry?
If wet, Record. -Ftto ' Ft to
liquid level: Liquid Liquid
; t
If wet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
~~ q.~ bib~ §!to~ o\JtrA.\1 .
New Decon Pad
Portal3
__ wet~ dry
" Ft to
Liquid
6. Remarks:~t!.!!.!4~~~-tAI~~~___J~~':l-.3!~~·~\A,;~~~"~'~·'~~~~o:!:.I'~<~d~1 __!/~. ----~----,_.1\J;~tl \TO~i ~ [).MUle t.\cr t, ln. S•'h .S..It•of:"r Mo~"'~rrt~~onifors., Se+tk""f"t ,_.A:.l.'tf, 11F-.:l. "''Aifa
7. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
LGO~ &tel
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell4A .. and 5558.50 for Cel14B)? _:i__ no __ yes
If Cell4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
me1nbrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Settings\dturk.DMC\Local Settings\Temporruy Intemet Files\Content.Outlook\VM3Y6Sll\DMT Plru1 Februruy 2012 Rev 11 5
clean.docN:\DMTP-lan\DMT Plafl 02.29.12 Rev 11.5\DMT Plan-Pebmarv 2012 Re-v 11.5 eleruLtloeN:\DMT Plan\DMT Plan 02.29.12 Rev
11.5\DMT PlaH Pebmary 2012 Rev 11.5 redl:ine.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denisonl2.1
Page 18 of26
l ' Date: 7! 2711 :L
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) _-...~.t_.:5--' ... 5_.:,i __
Cell 4A: (a)Pond Solution Elevation 55 Cf :1 I b
(b)FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) 37.D 1
Cell4B: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) :).. i ... 7D
( d)Elevation of Beach Area with Highest Elevation
(monthly) N.A
Roberts
Pond: (a)Pond Solution Elevation
(b )FML Bottom Elevation __ 56f2.3_
(c)Depth of Water above FML ((a)-(b)) _____ _
2. Leak Detection Systems
Observation:
New Decon Padl New Decon Pad2 New Decon Pad
Portall Portal2 Portal3
Is LDS (Pottal) __ wet__tL_dry __ wet~dry __ wet .~Clry
wet or dry?
If wet, Record ,_... Ftto -Ft to -Ftto
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell 4B)? ~no __ yes
If Cell4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Milltnanager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 !.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denisonl2.1
Page 18 of26
Date: 8)3/2-.0l'L.
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: ~1'\tt., JJ. 11:~ 1 t.~"l~ P,.,.l~e~"
Celll: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597
(c) Depth of Water above FML ((a)-(b)) 1'3.~
Cell4A: (a)Pond Solution Elevation S S 1 ~ .. 18
(b)FML Botton1 Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) !)7 .. 6"'#
Cell4B: (a)Pond Solution Elevation
Roberts
(b )FML Bottom Elevation 5557 ~
(c)Depth of Water above FML ((a)-(b)) __ 2._1_ .. __ _
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation p
(b)FML Bottom Elevation iJ f'ro<t-
(c )Depth of Water above FML ((a)-(b )) ----.::d~-~-----
2. Leak Detection Systems
Observation:
New Decon Pad~ New Decon Pad~ New Decon Pad
Portal1 Portal2 Portal3
Is LDS (Portal) __ wet__{_ dry __ wet~ dry __ wet~dry
wet or dry?
If wet, Record -Ftto -Ftto -Ftto
liquid level: Liquid Liquid Liquid
If wet, Rep01t to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible me~rane liner (solution
elevation of 5556.14 atnsl for Cell4A and 5558.50 for Cell4B)? __ no __ yes
If Cell4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denison12.1
Page 18 of26
Date: tlaoiU>I'2.
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation .S 'IO · .,o
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) _1_..;;.~-=-·~-=--o __ _
Cell4A: (a)Pond Solution Elevation SS,~ .. }fl..
(b)FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) S, .. V
Cell4B: (a)Pond Solution Elevation SS7,. ''
Robe1ts
(b )FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) al. ~-,.
( d)Elevation of Beach Area with Highest Elevation
(monthly) ,....
Pond: (a)Pond Solution Elevation
(b )FML Bottom Elevation 2.3_
(c)Depth of Water above FML ((a)-(b)) _____ _
2. Leak Detection Systems
Observation:
New Decon Padl New Decon Padl New Decon Pad
Pottall Pmtal2 Portal3
Is LDS (Portal) __ wet v'dry __ wet~dry __ wet -'dry
wet or dry?·
If wet, Record -Ftto -Ft to .,.. Ftto
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible mep1brane liner (solution
elevation of 5556.14 mnsl for Cell4A and 5558.50 for Cell .. 4B)? _/ __ no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 an1sl), notify supervisor or Mill manager in1mediately.
E:\Mill SOP Master Copy\Book l L_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denison 12.1
Page 18 of26
Date: i'/11/~CI2-
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: <IAI'lC r J.l. n;J~, ' (,,..,,.~ ~/1"9er
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) 4;(..1( 1~.~
Ce114A: (a)Pond Solution Elevation SS,2.. 0,
(b)FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) 3,.CIJ~
Cell4B: (a)Pond Solution Elevation SS71.l2..
Robetis
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) ~. C:.2..
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation
(b )FML Bottom Elevation ~.3_ (c)Depth of Water above FML ((a)-(b))
2. Leak Detection Systems
Observation:
New Decon Padl New Decon Padl New Decon Pad
Potiall Portal2 Pmial3
/ /
Is LDS (Potial) __ wet~ dry __ wet _Ldry __ wet ./dry
wet or dry?
If wet, Record Ft to Ftto Ftto
liquid level: Liquid Liquid Liquid
If wet, Repoti to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible meybrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell4B)? __ ·_no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
n1embrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denisonl2.1
Page 18 of26
Date: g/7...tjiUJJ2
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: ~IJftt" J/.~~'//.Jffl£1 ~,-.~ i>e.IAWI"
Cell 1: (a) Pond Solution Elevation .6' I(). t.f':i...
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) ---=-'~-· Lrf_;t __ _
Cel14A: (a)Pond Solution Elevation 55Cf2. .. '11
(b )FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b)) _'!.;:;_7..;:..._•__;'-S~---
Cell4B: (a)Pond Solution Elevation
Robetts
(b )FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) g.J.;a.3
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation 5' 1"7.10
(b)FML Bottom Elevation ___ 5612.3_
(c)Depth of Water above FML ((a)-(b)) _......;.Crf_ .. I _____ _
2. Leak Detection Systems
Observation:
New Decou Pad~ New Decou Pad2 New Decou Pad
Pmtal1 Portal2 Portal3
Is LDS (Portal) __ wet~dry __ wet ./dry __ wet ..l'dry
wet or dry?
If wet, Record Ftto -Ftto -Ftto -liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible mzbrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell4B)? no __ yes
If Cell4A leak detection systen1level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7112 Revision: Denison 12.1
Page 18 of26
Date: g I l'jo/.z.or~
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __
(c) Depth of Water above FML ((a)-(b)) _ __,1:....::;;~..;.;_."1.;.:../tt __ _
Cell 4A: (a)Pond Solution Elevation 5512. .. 1"1
(b)FML Bottom Elevation 5555.14_
( c )Depth of Water above FML ( ( a)-(b)) --''l!::...:"f~ ....... S'""""")'-----
Cell4B: (a)Pond Solution Elevation
Robe tis
(b )FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) --=2.:o.;:..l."-'"'...,_l __ _
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation S'J1 .. O"f
(b )FML Bottom Elevation ___ 5612.3_
(c)Depth of Water above FML ((a)-(b)) _ ____;"1:.:.. .. 1;:.....JttL----
2. Leak Detection Systems
Observation:
New Decon Pad. New Decon Padl New Decon Pad
Pmiall Portal2 Portal3
Is LDS (Portal) __ wet~ dry __ wet~ dry __ wet /dry
wet or dry?
If wet, Record -Ftto -Ftto -Ft to
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible m/brane liner (solution
elevation of 5556.14 an1sl for Cell4A and 5558.50 for Cell4B)? __ no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7112 Revision: Denison 12.l
Page 18 of26
Date: q (7 / :?-o t ;?..
1. Pond and Beach
elevations (msl, ft)
2. Leak Detection Systems
Observation:
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) ----4-I ........ J..::.....:. ~'""'-s...L.tj __
Cel14A: (a)Pond Solution Elevation .s:sqJ.SI
(b)FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) 3~. 37
Cell4B: (a)Pond Solution Elevation __ 5$78. q '1
(b )FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) ~~-~Y
( d)Elevation of Beach Area with Highest Elevation
(monthly) AI A
Robe tis
Pond: (a)Pond Solution Elevation ~S617 .. S2
(b)FML Bottom Elevation ___ 5612.3_
(c)Depth of Water above FML ((a)-(b)) _ ___..5~.1~2.~-
Ne_w Decou Pad2 New Decou Padl New Decon Pad
Potiall Potial2 Potial3
Is LDS (Potial) __ wet-i.L(lry __ wet __ dry t/ wet~dry
wet or dry?
If wet, Record -Ft to ___,.,. Ftto ..-.... Ftto
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell4B)? ~no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7 I 12 Revision: Denison 12.1
Page 18 of26
Date: 9 /t Y / Q. D f :2
1. Pond and Beach
elevations (1nsl, ft)
2. Leak Detection Systems
Observation:
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) _--!.,.;l->::;;._....,.,;__· 4..t...::2=. __
Cell 4A: (a)Pond Solution Elevation 5/::_; q 3 , c..S Y
(b)FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) ~1 8'. Y
Cell4B: (a)Pond Solution Elevation
Robe1ts
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) ;?..t. ;?3
( d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation
(b )FML Bottom Elevation __ 5612.3_
..,:S. 3f (c)Depth of Water above FML ((a)-(b))
New Decon Pad~ New Decon Pad2 New Decon Pad
Portall Pmtal2 Portal3
Is LDS (Pmtal) __ wet_Ldry __ wet_Ldry __ wet_Ldry
wet or dry?
If wet, Record ---Ftto -Ft to _....,..--· Ftto
liquid level: Liquid Liquid Liguid
If wet, Report to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible tnembrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell4B)? no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager in1mediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewai\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7112 Revision: Denison12.1
Page 18 of26
Date: 9/.?-V/1 ~
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) _ ___,_1;;:;:;....3.;....:;~ ::S;;;;;_-· 1..1---
Cell4A: (a)Pond Solution Elevation _-s._')q~··L t--i;2
(b)FML Botton1 Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) _.....;;.3~'6__,. ?.;...._;___~--
Cell4B: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) .21-.)f
(d) Elevation of Beach Area with Highest Elevation
(monthly) tVA
Roberts
Pond: (a)Pond Solution Elevation /) 6 i /.I L-f
(b)FML Bottom Elevation __ 5612.3_
( c )Depth of Water above FML ( ( a)-(b)) ----"-'· c_"""") .'--•_,_-i __,':f..___
2. Leak Detection Systems
Observation:
New Decon Pad2 New Decon Pad! New Decou Pad
Portal! Pmtal2 Portal3
Is LDS (Pmtal) __ wet_Ldry __ wet .,/"'dry __ wet_L.dry
wet or dry?
If wet, Record -Ft to -· Ftto -Ft to
liquid level: Liquid Liquid Liquid
If wet, Repmt to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cel14A and 5558.50 for Cell4B)? ----t.L no __ yes
If Cel14A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 mnsl), notify supervisor or Mill manager immediately.
E:\Mill SOP MasterCopy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denisonl2.1
Page 18 of26
Date: Of f gt / :2o I 2.
1. Pond and Beach
elevations (msl, ft)
2. Leak Detection Systems
Observation:
ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation .S61D. 61.-f
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b)) ----'-''·=-3.J... • ...,_6--t.t..{ __
Cell4A: (a)Pond Solution Elevation ~:;_r;q3 1..-13
(b )FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b)) ~8-;2q
Cell4B: (a)Pond Solution Elevation
(b )FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) 2l ~ yq
( d)Elevation of Beach Area with Highest Elevation
(monthly) AlA
Roberts
Pond: (a)Pond Solution Elevation .5617. 'I
(b)FML Bottom Elevation ___ 5612.3_
(c)Depth of Water above FML ((a)-(b)) --~-5~41:.~--
New Decon Pad~ New Decon Pad~ New Decon Pad
Portall Portal2 Portal3
Is LDS (Portal) __ wet--1LQry __ wet_L_dry __ wet_L__dry
wet or dry?
If wet, Record --Ftto -Ftto -Ftto
liquid level: Liquid Liquid Liquid
If wet, Rep011 to
RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible men1brane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell4B)? ~no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 an1sl), notify supervisor or Mill manager immediately.
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
Attachment D
Feet Below Top of Standpipe
N N N ~ ~ ~ ~ N 0 00 en ~ 0 0 0 0 0 0 0 0 0 0 0 0
1/30/2009
3/30/2009
5/30/2009
7/30/2009
n 9/30/2009
tD --11/30/2009
N
+ ~ -· 1/31/2010
(./) 3 ro :::::!. ro tD VI "' N
c
3/31/2010
5/31/2010 ..,
QJ -· 7/31/2010
::::s
I 9/30/2010
N 0 0 c:
::J U) ro ~ OJ ., N Vl 0 ro
11/30/2010
1/31/2011
., ~ ii)" 3/31/2011
VI 0 ~ ~
N 5/31/2011
0 ~
~
S20
7/31/2011 -, I
9/30/2011
N
0
~ 11/30/2011
N
1/31/2012
3/31/2012
5/31/2012
7/31/2012
Attachment E
WHITE MESA MILL
REPAIR REPORT
ROBERTS POND
DECEMBER 2012
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill-2012 Repair Report, Roberts Pond
Page 2 of 12
WHITE MESA MILL
REPAIR REPORT
ROBERTS POND
TABLE OF CONTENTS
1. IN"TRODUCTION .................................................................................................................. 3
2. IN"CIDENT HISTORY AND CHRONOLOGY .................................................................... 4
3. ROOT CAUSE ANALYSIS .................................................................................................. 4
4. REPAIR NARRATIVE ......................................................................................................... 5
5. REPAIR MATERIAL TYPE AND DESCRIPTION ............................................................ 6
6. POST-REPAIR TEST SPECIFICATIONS AND TEST METHODS ................................... 6
7. DAILY REPORTS DURIN"G THE REPAIR WORK ........................................................... 6
8. REPAIR TEST RESULTS/QUALITY ASSURANCE/QUALITY CONTROL ................... 7
9. CONCLUSIONS .................................................................................................................... 7
10. CERTIFICATION .................................................................................................................. 8
Appendix 1
Appendix 2
Appendix 3
Appendix 4
APPENDICES
Letters and Correspondence Regarding Robert Pond Liner
Liner Repair Daily Reports
Repair Photographs
Liner Maintenance Provisions
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White Mesa Mill-2012 Repair Report, Roberts Pond
Page 3 of 12
1. INTRODUCTION
Energy Fuels Resources (USA) Inc. ("EFRI''), formerly named Denison Mines (USA) Corp.,
operates White Mesa Mill's (the "Mill's") Roberts Pond as a collection and return basin for spills or
process solution overflows. Performance standards, monitoring and maintenance requirements for
Roberts Pond are specified in the Discharge Minimization Technology requirements in the Mill's
Groundwater Discharge Permit (the "Permit").
Per Parts I.E.7 f) and I.F.2 of the Mill's Permit, ifEFRI identifies any damage to the liners of any
tailings cell or Roberts Pond, EFRI is required to repair the damage in accordance with the Mill's
Liner Maintenance Provisions, and provide a liner Repair Report to the Director of the Division of
Radiation Control.
EFRI performed repairs to the Roberts Pond Flexible Membrane Liner ("FML") on July 12, 2012, as
discussed below. As a result of those repairs, this Roberts Pond Liner Repair Report (the "Report")
is being submitted to comply with the Mill's Liner Maintenance Provisions, Revision 1, dated
October 18,2009 and with Part I.F.2 of the Mill's Groundwater Discharge Permit ("GWDP"). The
Liner Maintenance Provisions require that the Repair Report be signed by a Utah licensed
professional engineer and contain the following information:
• Repair narrative describing the nature of the damage and the repair work completed to repair
the damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM D5641)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
Accordingly, the sections of this Repair Report, below, are organized consistent with the items
above.
Part I.F.2 of the RML requires that following the repairs, the
"Repair Report shall be included with the next quarterly DMT Report".
Repairs resulting from the event above were completed during the third quarter of 2012. This Repair
Report has been included with the third quarter 2012 DMT Report, being submitted on December 1,
2012.
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White Mesa Mill-2012 Repair Report, Roberts Pond
Page 4 of 12
Due to Senate Bill21 of the 2012 Utah Legislative Session, references to the Executive Secretary of
the Utah Radiation Control Board in the Utah Radiation Control Act have been modified to refer to
the Director of Radiation Control. This Report and the correspondence in its appendices utilize both
titles interchangeably.
2. INCIDENT HISTORY AND CHRONOLOGY
Roberts Pond was empty and out of service from June to August 2012 for routine maintenance and
preparation for Mill startup. Roberts Pond underwent cleanout of accumulated sediment during the
month of July 2012. The long-arm bucket excavator used for solids removal created a tear in the
flexible membrane liner ("FML") of Roberts Pond at approximately 1:30pm on July 5, 2012. The
liner damage occurred, and was immediately identified, at 1:30pm on July 5, 2012, apart from a
liner maintenance inspection. The damage incident occurred as a result of maintenance activities,
when Roberts Pond was in empty condition during above-mentioned planned maintenance outage.
Roberts Pond was empty of solutions or wastewaters at the time of the incident, and remained empty,
for the duration of the maintenance outage.
Repairs to the liner were performed and completed on July 12,2012, in accordance with the Mill's
Liner Maintenance Provisions. The Mill returned Roberts Pond to service during the week of August
6, 2012. It has resumed receiving washdown and/or process fluids from time to time since late
August 2012.
Upon receipt of the initial identification, the Mill's Environmental Coordinator notified the Mill
Manager by 2:00pm that day. Mill operations notified EFRI Corporate environmental management
on Tuesday, July 31, 2012, during a review of the readiness of environmental equipment for the
upcoming Mill startup.
EFRI provided initial notification to Mr. Philip Goble of the Division of Radiation Control ("DRC")
by telephone at approximately 2:00pm on Tuesday, July 31, 2012 (within 24 hours of the readiness
determination), as contemplated by Parts I.E.7 f) and I.G.3 of the Permit. Consistent with Parts I.E.7
f) and I.G.3 of the Permit, EFRI submitted a written notice to the Director (the "Notice") on August
6, 2012.
3. ROOT CAUSE ANALYSIS
Roberts Pond had not gone undergone any cleanouts from its initial startup in 2002 until the July
2012 maintenance outage. The volume of solids accumulated in that time period exceeded what
could easily be removed by small equipment or manual methods and required use of the Mill's
extended boom or "~ong-arm" bucket excavator. The long-arm excavator is equipped with a straight-
edged bucket with no teeth.
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White Mesa Mill-2012 Repair Report, Roberts Pond
Page 5 of 12
Due to the length of the bucket arm, the spotter assigned to watch the excavation from the ground
level was not in a position to fully see the bucket and its contact with the pond sediment. Below the
sediment being excavated was an apparent wrinkle or buckle in the liner. As the excavator bucket
was pulled across this irregularity, it snagged and damaged the liner.
The August 6, 2012 Notice committed that EFRI would take the following actions to prevent future
damage to the Roberts Pond liner:
a) The Mill will perform cleanouts of Roberts Pond on a more frequent basis, to minimize the
volume of solids accumulated, and reduce the size of equipment needed for solids removal.
b) If heavy equipment is required for solids removal from Roberts Pond, the Mill will use
equipment smaller than the long-arm bucket excavator used in July 2012, where possible.
c) A repair report containing a root cause analysis and further documentation of the repairs
will be submitted to the Director with the quarterly DMT Report following the incident, as
discussed in Section 4, below.
4. REPAIR NARRATIVE
As discussed above, Roberts Pond contains a single 60 mil HDPE FML constructed of heat welded
seams.
Repairs to the Cell 1 FML occurred on July 12, 2012, as indicated on the daily repair report in
Appendix 2. Repairs required the following steps:
• Removal of the remaining sediments/solids from the pond to expose the liner for inspection
and repair,
• Visual inspection of each section of the FML,
• Installation of repair patches over each damaged location,
• Vacuum testing of each installed repair patch, and
• Replacement and/or regluing and retesting of repaired areas if necessary.
The liner was patched with sections cut from 60 mil HDPE roll stock remaining from the lining of
Cell4B. Prior to placement of the new lining material repair patch, the soil surface was compacted
and swept clean of any protruding rocks that might damage the lining material. Prior to seaming, the
lining material was cleaned with methyl ethyl ketone (MEK). The patch material was seamed to the
existing liner material via extrusion welding. The repaired seams were then 100% vacuum box tested
according to the procedures in the attached report. Testing results are included in the attached daily
reports of the repair activities.
EFRI completed the inspection and all repairs to the liner inside slope areas on July 12, 2012.
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White Mesa Mill-2012 Repair Report, Roberts Pond
Page 6 of 12
5. REPAIR MATERIAL TYPE AND DESCRIPTION
Vacuum testing used the following equipment:
• soapy water solution
• vacuum check sheets
• vacuum testing equipment (vacuum box) consistent with ASTM Standard D5461.
Liner repairs used the following equipment:
• Personnel protective equipment appropriate for protection from cell solutions and safety
along banked sidewalls of the cell
• Various sized sections of 60 mil HDPE geomembrane.
• HDPE Extrusion Welder Feed Rod
• Extrusion Welder
• methyl ethyl ketone ('2-butanone" or "MEK") as a surface and glue cleaner
• wire brushes
• TSP/Manu-Tech Service Projects vacuum testing device (referred to as the "vacuum box")
• Liner Daily Repair Forms
6. POST-REPAIR TEST SPECIFICATIONS AND TEST METHODS
As mentioned above, each repaired location was tested using a "vacuum box" and soapy water to
identify any remaining leaks by observation of air bubbles through the repair seam.
Tests were conducted in accordance with ASTM Standard D5461 utilizing the Manu-tech Service
Projects vacuum box referred to above. Per this standard, tests were conducted such that test areas
overlapped by at least 10% of the minimum vacuum chamber length or at least 2 inches, whichever
is greater, until the entire seam was tested. Per D5461, 4 to 8 psi vacuum was applied and the seam
was observed for air bubbles. If any air bubbles were observed during vacuum testing of the seam,
the test was considered to indicate a seam failure, and the repair and vacuum test repeated.
Specifically, the regulated pressure to the vacuum box was maintained at 15 psig during the test
process and vacuum pressure within the box was recorded in inches of mercury. Test results are
provided with the Liner Repair Daily Reports in Appendix 2.
7. DAILY REPORTS DURING THE REPAIR WORK
Liner Repair Daily Reports have been provided in Appendix 2. Photo documentation is provided in
Appendix 3.
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White Mesa Mill-2012 Repair Report, Roberts Pond
Page 7 of 12
8. REPAIR TEST RESULTS/QUALITY ASSURANCE/QUALITY CONTROL
Results from vacuum testing of patch seams was recorded on the Liner Repair Daily Reports.
As discussed above, the quality control standard applied to testing assumed that any single
appearance of a bubble in any part of a tested patch would be considered to be a failure of the patch,
requiring replacement and reattachment of the entire patch.
Following the testing, each day's test results were listed by date and test number on the last Liner
Repair Daily Report of the period in which the repairs and tests for that segment were completed.
Vacuum tests results are provided in Appendix 2.
9. CONCLUSIONS
On July 12, 2012, Roberts Pond liner repair activities were completed by EFRI maintenance
personnel. Utah Registered Professional Engineer SteveR. Snyder, the Mill's Facility Engineer
reviewed the Liner Repair Report and discussed the repairs made to Roberts Pond with maintenance
personnel directly involved.
EFRI believes that the Robert Pond liner repair has been performed consistent with the Liner
Maintenance Provisions.
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White Mesa Mill-2012 Repair Report, Roberts Pond
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10. CERTIFICATION
I, SteveR. Snyder, a Utah Registered Professional Engineer, was present at the Mill during the
repairs of the Roberts Pond liner. I reviewed the foundation preparation activities, liner patch
placement, cleaning and seaming of the liner, and vacuum box testing of the repaired seams with
EFRI maintenance personnel. I subsequently inspected a representative area of repaired liner to
confirm the repairs were consistent with the results described by the maintenance personnel.
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White Mesa Mill-2012 Repair Report, Roberts Pond
Page 9 of 12
APPENDIX 1
LETTERS AND CORRESPONDENCE
REGARDING
CELL 1 LINER REPAIRS
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Energg F ue/s Resources IUSRJ Inc.
August6,2012
VIA PDF AND EXPRESS DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Dear Mr. Lundberg·:
Re: Utah Ground Water Discharge Permit No. UGW3700004
White Mesa Uranium Mill-Notice Pursuant to Parts I.E.7 f) and I.G.3 of the Permit
Please take notice pursuant to Parts I.E.7 f) and I.G.3 of the White Mesa Mill's (the "Mill's") State of Utah
Groundwater Discharge Permit No. UGW370004 (the "Permit"), that Energy Fuels Resources (USA) Inc.
("EFR"), (formerly named Denison Mines (USA) Corp.), as operator of the Mill and holder of the Permit,
identified and repaired damage to the Roberts Pond Liner System as described in more detail below.
Roberts Pond has been empty and out of service since June 2012 for routine maintenance and
preparation for Mill startup. Roberts Pond underwent cleanout of accumulated sediment during the month
of July 2012. The long-arm bucket excavator used for solids removal created a tear in the flexible
membrane liner ("FML") of Roberts Pond at approximately 1:30 pm on July 5, 2012. Roberts Pond was
empty of solutions or wastewaters at the time of the incident, and remains empty, due to the maintenance
outage.
Repairs to the liner were performed and completed during the weeks of July 5 and July 12, 2012, in
accordance with the Mill's Liner Maintenance Provisions. The Mill will return Roberts Pond to service
during the week of August 6, 2012, and it may receive process fluids, as necessary, at any time
afterwards.
Mill operations notified EFR Corporate environmental management on Tuesday, July 31, 2012, during a
review of the readiness of environmental equipment for the upcoming Mill startup. EFR provided initial
notification to the Division of Radiation Control ("DRC") by telephone at approximately 2:00 pm on
Tuesday, July 31, 2012 {within 24 hours of the readiness determination), as contemplated by Parts I.E.7
f) and I.G.3 of the Permit.
1. Facts and Background Information
a) Part I.E. 7 f) of the Permit requires that the licensee conduct daily inspections for each of the
tailings cells and weekly inspections of Roberts Pond. According to Part I.E.? f):
"In the event that any liner defect or damage is identified during a liner system
inspection, the Permittee shall: 1) report and repair said defect or damage pursuant
to Part I.G.3 by implementation of the currently approved Liner Maintenance
Provisions, and 2) report all repairs made pursuant to Part I.F.2."
..
Notice to Director
8/6/2012
Page2
b) Although Part 1.G.3 of the Permit is stated to apply to circumstances where the Permittee fails
to maintain Discharge Minimization Technology {"DMT") or Best Available Technology {"BAT")
standards, Part I.E.7 f) requires that the notification provisions of Part I.G.3 also apply to liner
defects or damage, regardless of whether or not the liner defect or damage constitutes a failure
of DMT or BAT. Under Part I.G.3, the Permittee is required to submit to the Executive
Secretary1 a notification and description of the defect or damage orally within 24-hours of the
Permittee's discovery, followed by written notification within five calendar days.
c) The liner damage occurred, and was immediately identified, at 1:30pm on July 5, 2012, apart
from a liner maintenance inspection. The damage incident occurred as a result of
maintenance activities, when Roberts Pond was in empty condition during a planned
maintenance outage. The liner was repaired during the weeks of July 5 and July 12, 2012, in
accordance with the Mill's Liner Maintenance Provisions, which describe the types of repairs
that will be implemented, as well as requirements for a repair report describing the nature of
the damage and the repairs.
d) As contemplated by Parts I.E.7 f) and I.G.3 of the Permit, EFR provided notification to Mr. Phil
Goble of DRC at 2:00 pm on July 31, 2012, within 24 hours of corporate environmental staff
receiving information from Mill personnel regarding the incident, as part of a readiness
determination prior to Mill start up and use of the pond.
e) This Notice constitutes the 5-day written notice contemplated by Parts I.E.7 f) and I.G.3 of the
Permit.
2. Actions Taken
Upon receipt of the initial identification, the Mill's Environmental Coordinator notified the Mill Manager by
2:00 pm that day. The following plan of action was immediately put into place in accordance with the
Liner Maintenance Provisions and Section 3.1 of the Mill's Environmental Protection Manual:
a) The Roberts Pond liner was repaired during the weeks of July 5 and July 12, 2012.
b) Mill personnel prepared daily liner maintenance reports and collected data required for
submittal consistent with the Liner Maintenance Provisions and Part I.F.2 of the Permit.
c) Corporate Environmental Staff received notification that the Liner Maintenance Provisions had
been implemented.
3. Actions That Will be Taken to Prevent a Reoccurrence of this Incident
The following actions will be taken to prevent a reoccurrence of this incident:
a)
b)
The Mill will perform cleanouts of Roberts Pond on a more frequent basis, to minimize the
volume of solids accumulated, and reduce the size of equipment needed for solids removal.
If heavy equipment is required for solids removal from Roberts Pond, the Mill will use
equipment smaller than the long-arm bucket excavator used in July 2012, where possible.
1 The Executive Secretary is currently referred to as the Director as a result of revisions to R317 passed
during the Utah 2012 legislative session.
Notice to Director
8/6/2012
Page3
c) A repair report containing a root cause analysis and further documentation of the repairs will be
submitted to the Director with the quarterly DMT Report following the incident, as discussed in
Section 4, below.
4. Required Reporting
As required by Part I.F.2 of the permit and by the Mill's Liner Maintenance Provisions, a repair report will
be submitted to the Director with the next quarterly DMT Report following completion of the repairs.
Repairs were completed during the third quarter of 2012. The repair report will be submitted with the third
quarter 2012 DMT Report on or before December 1, 2012. The repair report will contain, in addition to a
root cause analysis, the following elements:
• Repair narrative describing the nature of the damage and the repair work completed to repair the
damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
5. Affirmative Defense
EFR does not believe that identification of a defect or damage to the Roberts Pond liner caused by
maintenance activities and repair of such defect or damage in accordance with the Mill's Liner
Maintenance Provisions constitutes a failure of DMT under the Permit. Further, at the time of the incident,
Roberts Pond was not in use and was empty. As a result, EFR is not making a claim for an affirmative
defense under Part I.G.3 of the Permit.
Please contact me if you have any additional questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC. Q,£2/~~~~ vf;~~~ischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Katherine A. Weinel
'i I
White Mesa Mill-2012 Repair Report, Roberts Pond
Page 10 of 12
APPENDIX2
LINER REPAIR DAILY REPORTS
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Cell # Roberts Pond
Date: 12 July. 2012
Start Time: 7:OOam
End Time: 5:30pm
Liner Repair Report
Linear feet exposed for inspection: __ ...:;0::.....' ___ _
Description of damage or clear of any defects:
Slope on West side two areas where repair was needed!
Description of the repair work utilized to repair the damage:
Used the Extrusion Machine to fuse patch and Vacuum.
Material used to complete the repairs:
MEK (cleaner)
Wire Brush
Paint Brushes
Repair Material-(describe in detail):
Extrusion Machine. HDPE made weld passes to replace damaged areas.
Weather Conditions:
67 Degrees.
Personnel performing the repair work:
*HDPE Extrusion Welders-Kendall and Truitt.
*Vacuum Testers-Kendall and Truitt.
Vacuum Checks if conducted: Conducted Vacuum Checks. See Below
Notes: N/A.
4 Vacuum Tests-12th of July 2012.
1) 15hg.
2) 15 hg.
3) 16 hg.
4) 15 hg.
NOTE: All testing of the repaired material will be in compliance with ASTM D5641
White Mesa Mill-2012 Repair Report, Roberts Pond
Page 11 of 12
APPENDIX3
REPAIR PHOTOGRAPHS
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Roberts Pond Liner Repair
Post Repair View Facing West
White Mesa Mill-2012 Repair Report, Roberts Pond
Page 12 of 12
APPENDIX4
LINER MAINTENANCE PROVISIONS
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Liner Maintenance Provisions-Cells 1, 2, 3 and Roberts Pond Rev. 1 (10-18-09)
Inspections
Tailings cells 1, 2, and 3 are the subject of cotnprehensive daily inspections which are
conducted by either the Environmental Technician or the Radiation Technician, as well
as once per shift Daily Operations Inspections which are conducted by the Mill Shift
Foreman or other trained persotlllel designated by the Shift Foreman. The details of these
daily inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
h1 each case, these inspections are recorded on inspection forms (Daily Inspection Data
,Fonn and Operating Foreman's Daily Inspection Form, respectively). In addition, non-
recorded Daily Operations Patrols are conducted twice per shift by operations persollllel.
With regard to Roberts Pond, this facility is observed on a weekly basis when the
Environmental or Radiation Technician visits the facility for the recording of water levels
at that location.
Training
All individuals pe1forming inspections described in Sections 2.1 and 2.2 of the DMT
Monitoring Plan must have Tailings Management System Training as described in
Appendix C to the DMT Monitoring Plan (Tailings Inspection Training). As and element
of the "Operational Systems" inspection, inspectors are trained and required to observe
the conditions of the PVC liner. Because the PVC liners in Tailings Cells 1, 2 and 3 are
sensitive to sunlight and can degrade as a result of prolonged exposure, inspectors are
cautioned to observe any situation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are trained to cover
small areas of exposure immediately, whereas, larger areas are reported to the radiation
Safety Officer to prompt the issuance of a work order to the Maintenance Department. In
keeping with this inspection requirement, inspectors are trained to observe any
degradation of exposed liners. Such degradation can be that caused by exposure to
sunlight, abrasion due to erosive wave action and/or any rips or tears in the liner materiaL
Given the fact that the liner material is provided with an earthen cover, erosive damage
and/or rips and tears are unlikely. Inspectors are trained to record all observations of
liner exposure or disrepair on the inspection report, as well as the date and nature of any
repair activity.
Roberts Pond is lined with Hi Density Polyethylene (HDPE) material which is not
sensitive to sun damage and, as such, is not covered with earthen material. In this case
the inspector observes the conditions of the liner to the extent that visual observation is
possible (i.e. above the water level and any visually observable near surface condition).
As is the case for the tailing cell inspections, the liner will be observed for any abrasion
due to erosive wave action and/or any rips or tears in the liner material.
Repairs
Repairs to PVC liners in Cells 1, 2 and 3 and to the HDPE liner in Roberts Pond are made
on a case by case basis and usually involves the installation of a repair patch over the
damaged location. PVC patches require the use of glues or adhesive solvents to fuse the
patch to the repair location. HDPE repairs are accomplished by use of an extrusion
welder. Subsequent to any repair of a liner, the repair location wilt be tested using a
"vacuum box" and soapy water to assure that the repair is acceptable. Tests are
conducted such that test areas overlap by at least 1 Oo/o of the minimum vacuum chamber
length or at least 2 inches, whichever is greater until the entire seam has been tested.
The observation of bubbles through the repair seam while vacuum ( 4-8 psi per ASTM
D5641) is being applied to the seam constitutes seam failure and the repair must be
redone until all seams are acceptable. In the case of Cells 1, 2, and 3, after a patch has
been applied, the repair location must be covered with earthen material, again to avoid
exposure to sunlight. Adequate supplies of PVC and HOPE liner material, repair
n1aterial and vacuun1 test equipn1ent are maintained either in the Mill warehouse or the
maintenance departn1ent. The continued availability of these supplies will be verified as
an element of the Quarterly Tailings Inspection conducted by the Radiation Safety
Officer or his designee.
Any leak, hole or other damage to the liners in Cells 1, 2, 3 and the Roberts Pond will be
reported orally to the Executive Secretary within 24 hours of the discovery and in writing
within 5 days of the discovery. The oral and written notifications will include a
notification and description of the failure in accordance with Part I.G.3.(a) of the GWDP
and be in accordance with R317-6-6.16.C(l) of the regulations. In addition to the
descriptive information about the failure, a plan and schedule for the FML repair will be
included with the notification to the Executive Secretary (in accordance with Part
I.G.3.(c) of the Permit).
Repair Repott
Each report will be signed by a Utah licensed professional engineer and will address the
following elements as they apply to the case-by-case repairs which are implemented:
• Repair narrative describing the nature of the damage and the repair work
completed to repair the damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM 05641)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
Attachment F
July 2012
Date
7/5/2012
7/12/2012
7/19/2012
7/26/2012
Cell 4A LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
8.5
6.0
8.0
9.7
Flow Meter in Gallons
272228
272228
272228
272228
Highest level for the month based on the daily data was 12.1 inches and the lowest level for the month
was 2.2 inches. Total number of gallons pumped was 2.
Note: on July 30, 2012 two gallons were manually pumped to verify that all sysytems were operational.
No problems were noted, but systems are checked periodically as a QC measure.
August 2012
Date
8/2/2012
8/9/2012
8/16/2012
8/23/2012
8/30/2012
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
5.7
7.0
9.6
9.3
9.0
Flow Meter in Gallons
272230
272230
272284
272284
272284
Highest level for the month based on the daily data was 11.4 inches and the lowest level for the month
was 4.8 inches. Total number of gallons pumped was 54.
Note: on August 15, 2012 54 gallons were manually pumped to collect samples for the annual tailings
and LOS sampling event.
September 2012
Date
9/6/2012
9/13/2012
9/20/2012
9/27/2012
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
6.4
7.0
8.8
9.9
Flow Meter in Gallons
274917
274917
274917
274917
Highest level for the month based on the daily data was 12.0 inches and the lowest level for the month
was 4.3 inches. Total number of gallons pumped was 2633.
For the 3rd Quarter 2012, the highest level was 12.1 inches and the lowest level was 2.2 inches and
2689 gallons were pumped.
July 2012
Date
7/3/2012
7/10/2012
7/17/2012
7/24/2012
7/31/2012
Ceii4B LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
1.85
2.13
2.13
1.85
2.20
Flow Meter in Gallons
0
0
0
0
0
Highest level for the month based on the daily data was 2.41 inches and the lowest level for the month
was 1.08inches. Total number of gallons pumped was 0.
August 2012
Date
8/7/2012
8/14/2012
8/21/2012
8/28/2012
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
1.02
0.74
0.74
0.74
Flow Meter in Gallons
0
0
25
25
Highest level for the month based on the daily data was 1.85 inches and the lowest level for the month
was 0.74 inches. Total number of gallons pumped was 25.
Note: on August 15, 2012 25 gallons were manually pumped to collect samples for the annual tailings
and LOS sampling event.
September 2012
Date
9/4/2012
9/11/2012
9/18/2012
9/25/2012
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
1.30
1.30
1.02
1.02
Flow Meter in Gallons
25
25
25
25
Highest level for the month based on the daily data was 2.08 inches and the lowest level for the month
was 0.74 inches. Total number of gallons pumped was 0.
For the 3rd Quarter 2012, the highest level was 2.41 inches and the lowest level was 0. 7 4 inches and
25 gallons were pumped.
I
GtDIJIJtf!C Consutm~s Table 1A
Cafcufated Actkm La•"-• Rites for Various Hud Condition•
CeJI4~~ WhlteMfil MIJI
BJan4rnr. Utah
Head Ataove trner OiddJtatAdfanlldlplbU
Sy1tem (feet) {ptfont/ac:te/day) .
5 222•04
UJ . S14~0
15 ''4~Ss.·
20 444•08
25 496.5
JG 54!1,11
35 587.S
37 604•0
GBfiiYnte CoiiiUitlllffl Tible1B
calculated Action Lfakage Rates for Various Head Conclftrons
Clll48, White Mua Mill
Blandltas, Uflft
111111 Atmve UtMrSpttm c.rcalttld Actfon Ltauplllte -,,.,, (lttBo.n.t/aare/~avl
5 Jl1a4
10 117~P --15 •••• 9
zo 422.7
25 475.6
3() 528.4
IS 570.0 ., 581.2 -·-.
Max head on Cell 4A FM L
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1A (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4A-Q3 2012
5593.54
5555.55
37.99
604.0
40
24160
Max head on Ceii4B FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1B (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B-Q3 2012
5579.65
5557.50
22.15
475.6
36.17
17202
Calculation of Maximum Daily Allowable LDS Flow Volume for Varying Head Conditions in
Cells 4A and 4B
The equation for the calculation of maximum daily allowable flow volume in Cells 4A and 4B is
as follows:
Step 1)
Where:
Step 2)
Step 3)
Step 4)
Elevation 1-Elevation 2 =Head (ft.)
Elevation 1 is the maximum elevation in feet measured during the reporting
period.
Elevation 2 is the FML elevation in feet.
Determine Calculated Action Leakage Rate from Table 1A (for Cell4A) or Table
1B (for Cell4B) using the head calculated in Step 1 above. If the head calculated
in step 1 above falls between two values in the Head Above Liner System (feet)
column, then the closer of these two values will be used to determine the
Calculated Action Leakage Rate.
Calculate the acres of tailings cell fluids based on the area of the base of the cell,
the head, and the angle of the sideslopes of the cell.
Action Leakage Rate (from Table 1A or 1B) X Acres of Tailings Cell Fluids =
Maximum Daily Allowable Flow Volume
Celll, Cell 2, and Cell 3 LOS Monitoring Information -Third Quarter 2012
Celll Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottum of the LDS sump. bottum of the LOS sump. bottum of the LDS sump .
•
7/6/2012 Dry 7/6/2012 Dry 7/6/2012 Dry
7/13/2012 Dry 7/13/2012 Dry 7/13/2012 Dry !
7/20/2012 Dry 7/20/2012 Dry 7/20/2012 Dry
7/27/2012 Dry 7/27/2012 Dry 7/27/2012 Dry
I
Celll Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottum of the LDS sump. bottum of the LOS sump. bottum of the LDS sump.
8/3/2012 Dry 8/3/2012 Dry 8/3/2012 Dry
8/10/2012 Dry 8/10/2012 Dry 8/10/2012 Dry
8/17/2012 Dry 8/17/2012 Dry 8/17/2012 Dry
8/24/2012 Dry 8/24/2012 Dry 8/24/2012 Dry
8/31/2012 Dry 8/31/2012 Dry 8/31/2012 Dry
Celll Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottum of the LDS sump. bottum of the LDS sump. bottum of the LOS sump.
9/7/2012 Dry 9/7/2012 Dry 9/7/2012 Dry
9/14/2012 Dry 9/14/2012 Dry 9/14/2012 Dry
9/21/2012 Dry 9/21/2012 Dry 9/21/2012 Dry
9/28/2012 Dry 9/28/2012 Dry 9/28/2012 Dry
Attachment G
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