DRC-2013-001441 - 0901a06880354877

EN^YFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels com
X
February 28, 2013
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 4th Quarter of 2012
Dear Mr. Lundberg: D R C " 2 0 1 3 - Q 0 1 4 4 1
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell 4A
BAT Performance Standards Monitoring Report for the 4th 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].
Yours vi
ENMbV FujiLs RESOURCES (USA) INC.
^ Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Kathy Weinel
February 28, 2013
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
3039742140
www.energyfuels.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 4th 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 4th 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].
Manager, Compliance and Licensing
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
4th Quarter
October through December
2012
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
February 28, 2013
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 ......................................................................................................................... 5
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 ................. 6
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ................................................................ 6
8.0 DECONTAMINATION PADS .................................................................................................................... 7
8.1 SUMMARY OF WEEKLY INSPECTIONS ........................................................................................................... 7
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ....................................................................... 8
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................................................. 9
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 ................................. ll
9.1.3 Measurement of the Volume of Fluids Pumpedfrom the LDS ............................................................... 11
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4B ................................................. 12
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... 12
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING FOR THE QUARTER ......................................... 12
10.1 OPERATIONAL STATUS OFLDS PUMPING AND MONITORING EQUIPMENT ................................................. 13
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ....................................................... 13
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1,2, AND 3 ................................................. 13
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... 13
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2011 .. 14
11.1 INDIVIDUAL SLIMES DRAIN RECOVERY HEAD FOR 2012 ............................................................................ 14
11.2 AVERAGE SLIMES DRAIN RECOVERY HEAD FOR 2012 ............................................................................... 14
11.3 TIME SERIES CHART ................................................................................................................................... 14
11.4 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION ................................................................... 14
11.5 DEMONSTRATION OF COMPLIANCE STATUS WITH THE REQUIREMENTS OFPARTLD.3(B) AND LE.7(B) OF
THE PERMIT ................................................................................................................................................ 15
11. 5.1 Permit Requirements ......................................................................................................................... 15
11.5.2 Demonstration of Compliance with Permit Requirements ................................................................ 16
12.0 SIGNATURE AND CERTIFICATION ..............................................................•..................................... 19
i
LIST OF TABLES
Table I -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 Quarterly Cell 2 Slimes Drain Monitoring Data
D Graph of Cell 2 Slimes Drain Water Levels Over Time
E Cell Liner Repair Reports and Notices
F Cell 4A and Cell 4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables IA and IB, Cell4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.12)
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 4th QUARTER OF 2012
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the fourth 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:
• Weeldy tailings wastewater pool elevations for tailings Cells 1 and 3 (Part
I.E.7(a));
• Quarterly slimes drain water levels in Cell 2 (Part I.D.3(b)(1) 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.7(d); and
(e));
• Any tailings cell and pond liner system repairs (Part I.E.7 (t) and Part I.E.(S)(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 Cell 4A and 4B BAT performance standards monitoring
was performed, or addressed, as applicable and as required by Parts I.E.S and I.E.12 of the
GWDP:
• Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.S.(a)), and Cell
4B (Part I.E.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.S (a))
and Cell4B (Part I.E.12 (a)).
1
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 this quarter, 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 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 Ce1l4A 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, 2011 letter, 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 Ce1l4B
O&M Plans effectively eliminated the former freeboard elevation requirements for tailings Cell
4A, which was replaced by a freeboard limit for Cell 4B that will accommodate the freeboard
requirements of Cells 1, 4A, and 4B. The approvals of the DMT and Cell 4A and 4B O&M
2
Plans also resolved previous freeboard exceedance issues and further stated that former issues
regarding the freeboard 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 Ce1l4A 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 (fmsl) the GWDP (fmsl)
CellI 5613.64 5,615.40 5,615.50
Cell 3 Not Measured -No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in Q 1 2011
Cell4A 5593.49 -freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Q12011.
Cell4B 5578.82 5594.60 5597.40
* The DIrector approved the removal of the Cell 3 freeboard lmllt and authonzed 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 4 A limit and authorized the use of Cell 4 B 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 Cell4A was set out in a letter
from the Director dated November 20, 2008. The approved DMT Plan, Revision 11.1 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
3
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.
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
Cell 2 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 Cell 4B 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, are included in Section 11 of this report.
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 included the
depth to wastewater in the Cell 2 slimes drain access pipe in previous DMT reports. The
information was included based on a request . from DRC for completeness. 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 the third quarter report. As noted in the third quarter
DMT report, EFRI is providing quarterly DMT reports addressing only the GWDP DMT
requirements beginning with this fourth quarter 2012 report. The data for the weekly depth to
wastewater measurements in the Cell 2 slimes drain are no longer included in this report. The
weekly depth to wastewater measurements for the Cell 2 slimes drain are available at the Mill for
inspection.
4
Attachment B includes a Notice regarding missed depth to wastewater measurements in the Cell
2 slimes drain. The measurements were missed due to weather related complications due to
prolonged freezing temperatures during the last two weeks of the fourth quarter 2012. As noted
above, this notice and the reporting of the missed measurements are not required to be included
in this DMT report. The Notice is included for information purposes only.
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
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, the
2011 monthly (through June) and quarterly (July forward), and the quarterly 2012 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. Stable water levels have decreased by one
foot in 2012 and four feet since 2009.
5.0 WEEKL Y 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 5,617.89
fmsl, which did not exceed the maximum permitted elevation of 5,624 fms!. The results of such
monitoring are included in Attachment A.
5
6.0 WEEKL Y 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 October 12, and December 14,
2012 standing water was noted in the 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 weekly 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. 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.
The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached only single digits highs on December 19, 2012. On December 19, 2012 a
transformer supplying power to the Cell 1 area failed. The mill managed this power interruption
by temporary installation of two portable generators on December 20, 2012. This incident was
described in EFRI's telephone notification to DRC on December 19, 2012, and written notices of
December 21, December 26, 2012, and January 8, 2013 which are included in Attachment B.
The written notices submitted are related to other issues incurred at the Mill, but are included
here to document the weather conditions present at the Mill during the latter part of December
2012. Several times on December 20, 2012, power to several of the tailings cells was temporarily
interrupted and restored. The interruptions, which were of brief duration, did not last long
enough to interrupt required monitoring activities or require reporting to DRC under DMT or
BAT. However the interruptions required considerable additional maintenance activity on and
near the cell dikes. In the late afternoon of December 20, 2012, maintenance identified minor
tears in the liner of Cell4A near the center of the north dike, above the level of any tailings. Mill
maintenance personnel immediately repaired and tested the Cell4A liner on December 20, 2012.
Prolonged periods of cold temperatures prevented performance of representative vacuum tests
until January 30, 2013.
During a regular update of Mill power loss response activities on December 21, 2012, Mill
environmental personnel advised Corporate Environmental personnel of the liner tear and repair.
6
In accordance with Part I.E.8(c) of the GWDP, all repairs to the liner in Ce1l4A were completed
in accordance with Section 9.4 of the approved June 2007 Geosyntec Consultants Cell 4A
Construction Quality Assurance Plan ("CQAlQC Plan"). Repairs were performed by qualified
liner repair personnel. Pursuant to Part I.F.3 a Liner Repair Report is included with this DMT
Report as Attachment E.
In addition, any leak, hole or other damage to the liner will be reported to the Director pursuant
to the requirements found in Part I.G.3. Pursuant to Part I.G.3 of the GWDP, a notification was
submitted to the Director on December 26, 2012. A copy of the December 26, 2012 Notice is
included in Attachment B of this DMT report.
The second quarter 2012 DMT report included the CellI 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 fourth 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 GWDP. The weekly measurements are included in Attachment A.
As noted in Attachment A, the fluid level in Cell 1 was greater than 5613.1 fmsl during the last
two weeks of the fourth quarter 2012. The DRC requirements for closure of the Cell 1 liner
repair is that a fluid level above 5613.1 be held for 30 days and the leak detection system yield
results supporting a finding of successful repair. The leak detection system for Cell 1 did not
report any fluid levels during the reporting period and the level above 5613.1 was held, but not
for the prerequisite amount of time as of the fourth quarter 2012. These open items 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.
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
7
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.
Table 2 -New Decontamination Pad Inspection Portal Level for the Fourth Quarter 2012
Portal 1 Portal 2 Portal 3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
10/5/2012 0.00 0.00 0.00
10/12/2012 0.00 0.00 0.00
10/19/2012 0.00 0.00 0.00
10/25/2012 0.00 0.00 0.00
1112/2012 0.00 0.00 0.00
1119/2012 0.00 0.00 0.00
11116/2012 0.00 0.00 0.00
11123/2012 0.00 0.00 0.00
11130/2012 0.00 0.00 0.00
12/7/2012 0.00 0.00 0.00
12114/2012 0.00 0.00 0.00
12/2112012 0.00 0.00 0.00
12/28/2012 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
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
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 except as noted below.
Ce1l4A
During the quarter, there were no failures of any pumping or monitoring equipment which were
not repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.8(a)(1) for CeIl4A.
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
October 15, 2012 Mill Personnel noted that the flow meter was not reading gallons pumped.
Based on the daily fluid level measurements recorded by the Mill Personnel manually as well as
the computerized level recordings downloaded from the electronic data measurement system no
gallons of fluid were pumped and no data were lost. The flow meter was replaced within several
hours of noticing the malfunction, and full function was restored. No notifications to DRC were
required as the issue was rectified within 24-hours as required by Part I.E.8(a)(l) for CeIl4A.
9
It is important to note that these periodic malfunctions of the flow meter are due to the super-
saturated nature of the fluids in the LDS system, which crystallize on the electronic components
and cause the components to fail prematurely. EFRI maintains spare parts to replace the
components on an as needed basis.
Ce1l4B
During the quarter, there were no failures of any pumping or monitoring equipment which were
not repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.12(a)(1) for CeIl4B.
During the quarter there were two failures of the Cell 4B monitoring equipment which were
made operational within 24-hours of discovery, as required by Part I.E.12(a)(1) for Cell 4B as
discussed below.
On October 15, 2012 Mill Personnel noted that the flow meter was not reading gallons pumped.
Based on the daily fluid level measurements recorded by the Mill Personnel manually as well as
the computerized level recordings downloaded from the electronic data measurement system no
gallons of fluid were pumped and no data were lost. The flow meter was replaced within several
hours of noticing the malfunction, and full function was restored. No notifications to DRC were
required as the issue was rectified within 24-hours as required by Part I.E. 12(a)(l) for CeIl4B.
It is important to note that these periodic malfunctions of the flow meter are due to the super-
saturated nature of the fluids in the LDS system, which crystallize on the electronic components
and cause the components to fail prematurely. EFRI maintains spare parts to replace the
components on an as needed basis.
On December 14,2012 Mill Personnel noted that an alarm sounded on theCell4B LDS system.
The alarm indicated that there was a transducer failure in the Cell 4B LDS system. Mill
Personnel investigated the alarm and checked the transducer. The transducer was completely
functional and was operating properly. It was noted that there was no fluid in the Cell 4B LDS
and that the system was reading a negative fluid level. The negative fluid level was due to the
LDS having no fluid which the transducer "reads" as a negative value because of barometric
pressure differences. The system was returned to full function. The system continued proper
operation until December 17,2012, when the alarm again sounded indicating a transducer error.
Again the transducer was inspected and found to be operating properly. The manufacturer was
contacted to address the repeat alarms. The manufacturer noted that consistent negative values
caused by the lack of fluid in the system, caused the system to alarm. These negative level alarm
settings are the default settings programmed from the factory. The manufacturer recommended
reprogramming the system to remove the alarm prompts for prolonged negative readings. The
system was reprogrammed to allow the system to operate without alarming after prolonged
negative readings. Both of these alarm situations were fixed within several hours of discovery,
and no notifications to DRC were required, as the issue was rectified within 24-hours as required
by Part I.E. 12(a)(1) for CeIl4B.
10
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 I-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring this I-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 Cell4A LDS sump did not exceed 14.4 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 4B LDS sump exceed a I-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 I-foot distance equates to 2.25 feet (27 inches) above the LDS system. During
the quarter the fluid head in the Cell 4B sump did not exceed 1.85 inches above the LDS
transducer.
9.1.3 Measurement of the Volume of Fluids Pumpedfrom the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment F.
Ce1l4A
As can be seen from a review of Attachment F, 6,017 gallons of fluid were pumped from the Cell
4A LDS for the fourth quarter of 2012. Based on this, the average daily LDS flow volume in
Cell4A 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 CeIl4B, 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 (24,160 gallons/day for the cell), 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 Cell4A did not exceed the calculated
flow volume of 24,160 gallons/day. As mentioned above, during fourth quarter of 2012, a total
of 6,017 gallons of fluid were pumped from the Cell 4A LDS during the period and did not
11
exceed the calculated flow volume. The fourth quarter allowable flow rate calculation for Cell
4A is included in Attachment F of this report.
Cell4B
As can be seen from a review of Attachment F, 93 gallons of fluids were pumped from the Cell
4B LDS for the fourth 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 (17,202 gallons/day for the cel), 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 fourth quarter 2012, 93
gallons of fluids were pumped from Cell 4B LDS and therefore did not exceed the calculated
flow volume. The fourth quarter allowable flow rate calculation for Cell 4B is included in
Attachment F of this report.
9.2 Measurement of Weekly Wastewater Fluids in Cells 4A and 4B
Weekly 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 Ce1l4A or Ce1l4B 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 LE.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, 2, and 3 is a
requirement of the License, is not a DMT performance monitoring standard required by Parts
I.D.3 or LE.7 of the GWDP, and hence is not required to be included in the routine DMT
Performance Standards Monitoring Report under Part LF.2 of the GWDP. EFRI revised the
DMT Plan by preparing two separate plans for the GWDP and the License requirements and
submitted the revised plans to DRC for review. DRC requested in their review comments that
the LDS monitoring for Cells 1, 2, and 3 be included on the DMT inspection forms and that the
results of the monitoring be reported in the quarterly DMT reports. EFRI agreed to include the
Cells 1, 2, and 3 LDS monitoring in the quarterly DMT reports. The Cells 1, 2, and 3 LDS
monitoring data are included in Attachment F.
12
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 except as noted below.
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. The Mill experienced
freezing temperatures for most of the week of December 17, 2012. Temperatures reached only
single digits highs on December 19, 2012. On December 19, 2012 a transformer supplying
power to the Cell 1 area failed. EFRI Corporate Environmental personnel notified DRC via
telephone and follow-up e-mail correspondence (Attachment B) that pursuant to the Tailings
Management Plan, EFRI would use the blow tube for LDS level monitoring in Cell 1 until the
transformer was replaced and power was restored to the area. Portable generators were placed
sooner than expected on December 20, 2012. The mill managed this power interruption by
temporary installation of two portable generators, and the blow tube method of LDS monitoring
was not necessary or implemented.
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.
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 Cell 3 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.
13
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2011
This Section constitutes the annual slimes drain recovery head report for calendar year 2012 (the
"Period"), as required under Parts I.D.3 (b) and I.F.11 of the Permit and Section 8.2 of the DMT
Plan.
11.1 Individual Slimes Drain Recovery Head for 2012
The individual slimes drain recovery head monitoring data for calendar year 2012, 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, is included as Attachment C to this Report. The equivalent
recovery water level elevation is determined by subtracting the final depth to stable water
measurement (as recorded on the sheets in Attachment C) from the elevation of the measuring
point. Those elevations are set out in Tables 4, 5, and 6 below.
11.2 Average Slimes Drain Recovery Head for 2012
The slimes drain recovery head for Cell 2 for calendar year 2009, 2010, 2011, and 2012 are
shown in Tables 4, 5, 6, and 7 below.
11.3 Time Series Chart
Included in Attachment D is a time series chart that shows trends in the monthly recovery water
level elevations in the Cell 2 slimes drain over time, using data that meet the test performance
standards found in Part I.D.3(b)(2) of the Permit. See Section 11.4 below.
11.4 Quality Assurance Evaluation and Data Validation
Denison management has evaluated all data collected, data collection methods, and all related
calculations required by the Permit, and has verified the accuracy and reliability of both the data
and calculations reported. As a result of its quality assurance evaluation and data validation
review, Denison has concluded that:
1. All of the 2009 monthly slimes drain tailings fluid elevation measurements meet the
test performance standards found in Part I.D.3(b )(2) of the Permit and can be used for
purposes of determining compliance with the requirements of Part I.D.3(b )(2) of the
Permit.
2. All of the 2010 monthly slimes drain tailings fluid elevation measurements meet the
test performance standards found in Part I.D.3(b )(2) of the Permit and can be used for
purposes of determining compliance with the requirements of Part I.D.3(b )(2) of the
Permit.
3. All of the 2011 slimes drain tailings fluid elevation measurements (monthly through
June 2011 and quarterly thereafter) meet the test performance standards found in Part
I.D.3(b)(2) of the Permit and can be used for purposes of determining compliance
with the requirements of Part I.D.3(b)(2) of the Permit.
14
4. All of the 2012 quarterly slimes drain tailings fluid elevation measurements meet the
test performance standards found in Part LD.3(b )(2) of the Permit and can be used for
purposes of determining compliance with the requirements of Part LD.3(b)(2) of the
Permit.
11.5 Demonstration of Compliance Status with the Requirements of part I.D.3(b) and
I.E.7 (b) of the Permit
11.5.1 Permit Requirements
Part LD.3 of the Permit provides that annual slimes drain compliance shall be achieved when the
average annual wastewater recovery elevation in the slimes drain access pipe, as determined
pursuant to the DMT Plan, meets the conditions in Equation 1, below:
Equation 1:
[LEy + LY-I + L y-2] / Ny + N y-I + N y-2] < [LEy-1 +Ly-2+ L y-3] / N y-I + N y-2+ N y-3]
Where:
LEy-l =
Ny-1 =
Ny-2 =
Sum of all monthly slimes drain tailings fluid elevation measurements that meet
the test performance standards found in Part LD.3(b)(2), during the calendar year
of interest. Hereafter, these water level measurements are referred to as slimes
drain recovery elevations (SDRE). Pursuant to the DMT Plan, these recovery
tests are to be conducted monthly and the SDRE values reported in units of feet
above mean sea level (amsl).
Sum of all SDRE measurements made in the year previous to the calendar year of
interest.
Sum of all SDRE measurements made in the second year previous to the calendar
year of interest.
Sum of all SDRE measurements made in the third year previous to the calendar
year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part LD.3(b )(2), conducted during the calendar year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part LD.3(b )(2), conducted in the year previous to the calendar year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b)(2), conducted in the second year previous to the calendar year of
interest.
15
Ny-3 = Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b )(2), conducted in the third year previous to the calendar year of
interest.
Part I.D.3 further provides that prior to January 1, 2013, the following values for E and N in
Equation I shall be based on SDRE data from the following calendar years.
Table 3 -SDRE Data to be Used for Certain Years
Report Source of Data By Calendar Year for Equation 1 Variables (right
for side)
Calendar Ey-1 Ey-2 Ey-3 Ny-1 Ny-2 Ny-3
Year
2010 2009 2009 2009 2009 2009 2009
2011 2010 2009 2009 2010 2009 2009
2012 2011 2010 2009 2011 2010 2009
Part I.D.3 provides that failure to satisfy conditions in Equation 1 shall constitute DMT failure
'and non-compliance with the Permit, and that for Cell 3, this requirement shall apply after
initiation of de-watering operations.
11.5.2 Demonstration of Compliance with Permit Requirements
2012 SDRE values that meet the test performance standards found in Part I.D.3(b)(2), reported in
units of FMSL are as follows:
Table 4 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2012
Elevation of Reported Level SDRE Values (Reported as
2012 Test Closing Measurement Point (feet) fmsl)
Date (fmsl)**
3/15/2012 5618.73 20.90 5597.83
5/2112012 5618.73 21.10 5597.63
9/27/2012 5618.73 21.84 5596.89
12117/2012 5618.73 21.84 5596.89
LE2012 = 67167.72*
N2012=12*
*Per the reqUIrement of the GWDP Part I.D.3 when monthly and quarterly measurements are combmed m the GWDP reqUIred
equation, the quarterly values shall be multiplied by a coefficient of three (3). ** The standpipe elevation was extended and surveyed in 2011. This change in elevation has no effect on the resulting slimes
drain elevation values listed in and used in the calculations below.
16
Table 5 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2011
Elevation of Reported Level SDRE Values (Reported as
2011 Test Closing Measurement Point (feet) fmsl) * *
Date (fmsl)**
112112011 5611.76 13.15 5598.61
2/28/2011 5611.76 10.42 5601.34
3/18/2011 5611.76 11.31 5600.45
4/25/2011 5611.76 11.57 5600.19
5/20/2011 5611.76 13.17 5598.59
6/23/2011 5611.76 12.18 5599.58
7/19/2011 *** 5611.76 12.59 5599.17*
12119/2011 *** 5618.73 19.83 5598.90*
LE2011 = 67,192.97
N2011=12*
*Per the reqUIrement of the GWDP Part I.D.3 when monthly and quarterly measurements are combined in the GWDP required
equation, the quarterly values shall be multiplied by a coefficient of three (3). ** The standpipe elevation was extended and surveyed in 2011. This change in elevation has no effect on the resulting slimes
drain elevation values listed in and used in the calculations below.
***Per the Permit Part I.D.3.(b).2 effective July 11, 2011, the frequency of the Cell 2 slimes drain recovery tests was changed
from monthly to quarterly.
2010 SDRE values that meet the test performance standards found in Part I.D.3(b)(2), reported in
units ofFMSL are as follows:
Table 6 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2010
Elevation of Reported Level SDRE Values (Reported as
2010 Test Closing Measurement Point (feet) fmsl)
Date (fmsl)
1115/2010 5611.76 13.96 5597.80
2/2112010 5611.76 12.50 5599.26
3115/2010 5611.76 11.04 5600.72
4/12/2010 5611.76 10.40 5601.36
5/19/2010 5611.76 10.43 5601.33
6/30/2010 5611.76 10.13 5601.63
8/2/2010 5611.76 10.74 5601.02
8/25/2010 5611.76 10.65 5601.11
9/24/2010 5611.76 11.50 5600.26
10/25/2010 5611.76 12.35 5599.41
11/23/2010 5611.76 10.81 5600.95
12/22/2010 5611.76 11.58 5600.18
LE2010 = 67,205.03
N2010=12
2009 SDRE values that meet the test performance standards found in Part I.D.3(b )(2), reported in
units of FMSL are as follows:
17
Table 7 -SDRE Values for 2009
2009 Test Closing Elevation of Reported Level SDRE Values (Reported
Date Measurement Point (feet) as fmsl)
(fmsl)
1130/2009 5611.76 11.25 5600.51
2/27/2009 5611.76 9.35 5602.41
3/28/2009 5611.76 8.84 5602.92
4/27/2009 5611.76 11.98 5599.78
5/20/2009 5611.76 10.28 5601.48
6/22/2009 5611.76 13.00 5598.76
7/30/2009 5611.76 13.00 5598.76
8/31/2009 5611.76 11.04 5600.72
9/28/2009 5611.76 11.46 5600.3
10/30/2009 5611.76 13.35 5598.41
11123/2009 5611.76 12.49 5599.27
12/14/2009 5611.76 13.12 5598.64
LE2009 =67,201.96
N2009 = 12
Based on the foregoing, it is evident that LE2012 = 67,167.72 fmsl, and N2012 = 12, LE2011 =
67,192.97 fmsl, and N2011 = 12, LE2010 = 67,205.03 fmsl, and N2010 = 12, and that LE2009 =
67,201.96 fmsl, and N2009= 12
Also, based on Table 3 above, for year 2012,
Ey-1 = 2011, Ey-2 = 2010, Ey-3 = 2009 and Ny-1 = 2011, Ny-2 = 2010, and Ny-3 = 2009.
Based on these values, equation 1 can be applied as follows:
[LEy + LEy-1 + LEy-2 ] 1 [Ny + Ny-1 + Ny-2] = [67,167.72 + 67,192.97 + 67,205.03]/[12 + 12
+ 12] = 5599.05 fmsl
and
[LEy-1 + LEy-2 + LEy-3 ] 1 [Ny-1 + Ny-2 + Ny-3 ] =[67,192.97+67,205.03 + 67,201.96]/[12 + 12 +
12] = 5600.00 fmsl
Based on the above equation, the annual slimes drain compliance has been achieved for Cell 2 in
2012, in accordance with Part I.D.3 of the Permit.
18
12.0 SIGNATURE AND CERTIFICATION
This document was prepared by Energy Fuels Resources (USA) Inc. on February 28,2013.
::~fg}j Res fces (USA) Inc.
David C. Frydenlund
Senior Vice President, General Counsel and Corporate Secretary
19
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for sUbmitting false information,
including t e po sibility of fine and imprisonment for knowing violations.
Senior Vice President, General Counsel and Corporate Secretary
Energy Fuels Resources (USA) Inc.
20
Attachment A
Date Cell 1 Cell 3 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
10/5/2012 5610.99 No Longer Required 5593.40 5578.82 5617.82
10/12/2012 5611.13 No Longer Required 5593.49 5578.78 5617.79
10/19/2012 5611.42 No Longer Required 5592.80 5578.74 5617.79
10/25/2012 5611.62 No Longer Required 5592.29 5578.48 5617.77
11/2/2012 5611.82 No Longer Required 5591.95 5578.43 5617.66
11/9/2012 5611.54 No Longer Required 5591.93 5578.23 5617.88
11/16/2012 5612.04 No Longer Required 5591.96 5578.39 5617.89
11/23/2012 5612.08 No Longer Required 5592.03 5578.34 5617.80
11/30/2012 5612.42 No Longer Required 5592.04 5578.38 5616.97
12/7/2012 5612.80 No Longer Required 5592.23 5578.29 5616.28
12/14/2012 5613.06 No Longer Required 5592.37 5578.23 5616.69
12/21/2012 5613.38 No Longer Required 5592.89 5578.25 5617.11
12/28/2012 5613.64 No Longer Required 5593.16 5578.28 5617.20
1 The freeboard limit as permitted under License condition 10.3 is no longer applicable to Cell 3 or CeIl4A.
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, 2011 letters 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
Cell4B 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 CeIl4A.
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
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Dean,
Jo Ann Tischler
Wednesday, December 19, 20123:58 PM
dhenderson@ utah.gov
Rusty Lundberg ([e-mail]); Phillip Goble ([e-mail]); Russell
Topham <[e-mail]> ([e-mail]); David Turk; David Frydenlund; Harold
Roberts; Kathy Weinel
Phone notification 12.19.12 regarding: Cell 1 Use of alternate LDS measurement; Chloroform
pumping well outage
This email documents our phone call today 12/19/12 at 3:40 PM regarding two effects from the freezing weather during
the past several days at White Mesa Mill.
1. Due to a transformer failure and power line outage today, 12/19/12 at 10:30 AM, resulting from the freeze,
power to Celli LOS monitoring equipment is out. Per the Tailings Management Plan, Energy Fuels Resources
(USA) Inc. is notifying you that we will return to use of the blow tube for LOS level monitoring in Celli until the
transformer is replaced and power is restored to the area. We anticipate at least 7 days from today before the
replacement transformer will be on site at the Mill.
2. Due to the transformer failure, pumping wells MW-26 and TW4-20 have temporarily shut down due to loss of
power at approximately 10:30 AM this morning. Although the Chloroform Operations and Maintenance Plan
has not been approved by DRC, we notified you within 24 hours consistent with the maintenance section. Per
your instructions during our phone call, EFRI will describe the incident in the 4th Quarter 2011 Chloroform
Report, and will address the report items listed in the Maintenance section of the Draft Chloroform O&M Plan.
Thank you,
Jo Ann Tischler
'~'eF Energy Fuels Resources (USA) Inc,
Jo Ann Tischler
Director, Compliance and Permitting
t: 303-389-4132 I f: 303-389-4125
225 Union Blvd., Suite 600
Lakewood, CO, US, 80228
http://www.energvfuels.com
This e-mail is intended for the exclusive usetheofperson(s) mentioned astherecipient(s). This message and any attached files with it are confidential and may
contain privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute
print or copy this message if you are not the intended recipient(s).
1
VIA EMAIL AND OVERNIGHT DELIVERY
December 21, 2012
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
3039742140
www.energyfuels.com
Re: White Mesa Uranium Mill-Notice of Violation and Corrective Action Order
UDEQ Docket No. UGW-20-01
Notice Pursuant to the Chloroform Pumping Well Operations and Maintenance Plan
Dear Mr. Lundberg:
Pursuant to the White Mesa Mill's (the "Mill's") Chloroform Pumping System Operations and
Maintenance Plan ("Chloroform O&M Plan") Energy Fuels Resources (USA) Inc., ("EFRI") as operator
of the Mill, is providing written Notice to the Utah Division of Radiation Control ("DRC") of a
temporary outage in two chloroform capture pumps, as described in more detail below.
The Mill's Chloroform Pumping O&M Plan states that EFRI will notify DRC of system failures that
cannot be made operational within 24 hours of discovery. It was determined on Wednesday, December
19, 2012 that a transformer failure had occurred which would require more than 24 hours to be repaired.
The failure shut down electrical power to two chloroform continuous pumping wells which will be off
(not pumping) until the transformer is replaced or an interim source of power is provided. Initial notice
of this outage was given by telephone to Mr. Dean Henderson of DRC at approximately 3:40 pm on
Wednesday December 19,2012 (within 24 hours of the discovery).
1. Description of the Pumping System Failure
a) The Mill's Chloroform O&M Plan, submitted on October 25,2010 and currently under review
by UDEQ, states that Denison will notify UDEQ of system failures that cannot be "repaired
and fully made operational within 24 hours of discovery."
b) The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached single digits oh December 19, 2012.
Letter to Rusty Lundberg
December 21, 2012
Page 2 of 4
c) One of the power circuits to the Cell 1 area supplies power to MW-26 and TW4-20. This
circuit includes a transformer near the Mill's truck shop.
d) Mill personnel discovered, at approximately 10:30 am on December 19, 2012, that the truck
shop transformer had failed when power to several areas of the Mill, including the tailings
area, failed.
e) MW-26 and TW4-20 pumps stopped when power was lost. There was no apparent damage to
the pumps or flow measurement instrumentation; however pumping will cease until power can
be restored to the affected circuit.
f) During the morning of December 20, 2012, Mill management determined that a replacement
for the damaged transformer would require up to 2 weeks or longer for delivery to the Mill
site.
g) On December 20,2012, Mill management began moving gasoline driven generators to supply
the Cell 1 area and reactivate the well pumps until the replacement transformer arrives and is
installed. Installation of the generators was completed during the night shift on December 20,
2012. The well heat lamps were turned on to thaw any frozen well water.
h) Immediately following confirmation that no frozen areas remained in the pumping system, the
well pumps were turned back on at approximately 3:00 pm on December 21,2012.
2. Root Cause
The root cause analysis is as follows:
a) A failed transformer caused a loss of power to the circuit which includes MW-26 and TW4-
20.
b) The replacement transformer could not be acquired and installed within 24 hours of the initial
power loss.
c) The installation of the temporary generator and thawing of the well piping pnor to
resumption of pumping required longer than 24 hours.
3. Period of Time the System Was Not in Operation
At the time of writing of this Notice, the pumps ceased operation for approximately 54 hours from
December 19 to 21, 2012.
Letter to Rusty Lundberg
December 21, 2012
Page 3 of 4
4. Date By Which the Pumping System Will Be Repaired and Operational
Pumping was resumed on December 21, 2012.
5. Steps taken to Repair and Have the System Fully Operational
a) Mill maintenance personnel isolated the failed electrical circuits on December 19, 2012.
b) Mill maintenance personnel located on site several portable gasoline-driven electric
generators throughout the day on December 20, 2012.
c) Two generators were placed at the Cell 1 area on December 20, 2012. One generator was
wired to supply both of the affected pumping well pump motors.
d) Maintenance personnel set up the heat lamps to thaw any potential frozen piping around the
two affected well pumps.
e) The two affected well pumps were turned on and resumed pumping at approximately 3:00
pm on the morning of December 21, 2012.
f) The portable generator supplying the two affected well pumps will be left in place until the
replacement transformer arrives, is installed, and power is restored to the Cell 1 area
electrical circuit.
6. Additional Factors to Be Taken into Account
Although this incident does not fall within U AC R317 -6-6.16, EFRI believes that the following should
be taken into account by DRC in evaluating this incident.
a) Notification
By virtue of the initial oral notification given to DRC at 3:40pm on Wednesday December 19, 2012
(within 24 hours of the discovery) and this written notice, EFRI has submitted notification according
within five days.
b) Failure was not Intentional or Caused by EFRI's Negligence
The failure of the pumping system was not due to negligence on the part of EFRI or Mill personnel.
The failure resulted from an unavoidable condition, specifically, failure of a transformer occurring
during continued freezing weather.
c) EFRI has Taken Adequate Measures to Meet the Conditions of the Chloroform 0 & M Plan
EFRI has taken adequate measures to meet Permit conditions in a timely manner. Mill personnel
notified Corporate Compliance personnel within hours of the incident. DRC was notified on the same
Letter to Rusty Lundberg
December 21, 2012
Page 4 of 4
day as the incident, and within 24 hours. Mill personnel immediately located and ordered a
replacement transformer. Mill personnel located and moved temporary generators to the Cell 1 and
well pump area within hours of determining that delivery time for the replacement transformer.
Hookup of the generator for the two affected pumps, thawing of the line, and restart of the well pumps
was performed within less than three days from the initial power loss.
d) The Provisions ofUCA 19-5-107 Have Not Been Violated
The provisions of Utah Code 19-5-107 have not been violated. There has been no discharge of a
pollutant into waters of the state. EFRI has not caused pollution which constitutes a menace to public
health and welfare, or is harmful to wildlife, fish or aquatic life, or impairs domestic, agricultural,
industrial, recreational, or other beneficial uses of water, nor has EFRI placed or caused to be placed
any waste in a location where there is probable cause to believe it will cause pollution.
If you have any questions, please contact me at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
JoAnn Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble
Dean Henderson, DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
VIA EMAIL AND OVERNIGHT DELIVERY
December 26,2012
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: White Mesa Uranium Mill
Utah Ground Water Discharge Permit No. UGW3700004
Energy Fuels Resources (USA) Inc.
2~5 Union Blvd. Suite eoo
Lakewood, CO, US, '80228
3039742140
www.energyfuels.com
.• -~', * (' .
White Mesa Uranium Mill-Notice Pursuant to Parts LE.8.c) and I.G.3 of the Permit
Dear Mr. Lundberg:
Please take notice pursuant to Parts I.E.8.c) and I.G.3 of the White Mesa Mill's (the HMill's") State of
Utah Groundwater Discharge Permit No. UGW370004 (the "Permit"), that Energy Fuels Resources
(USA) Inc. C'EFRI"), as operator of the Mill and holder of the Permit, identified and repaired damage to
the Ce114A Liner System as described in more detail below.
Repairs to the liner were completed and tested on December 20 and 21, 2012, in accordance with
Section 9.4 of the approved June 2007 Geosyntec Consultants Cell 4A Construction Quality Assurance
Plan. The cell remained in service during and after the repairs.
1. Facts and Background Information
a) Part I.E.8.c) 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.8.c):
" ... all repairs to the liner shall be completed in accordance with Section 9.4 of the
approved June 2007 Geosyntec Consultants Cell 4A Construction Quality Assurance
Plan as found in Table 5 of this Permit. The Liner Repair Report shall be subrnitted
to for [sic] Director approval in accordance with Part I.F.3 of the Permit. Repairs
shall be performed by qualified liner repair personnel and shall be reported in a Liner
Repair Report, certified by a Utah licensed Professional Engineer. Any leak, hole or
other damage to the liner will be reported to the Director pursuant to the requirements
found in part I.G.3."
b) Although Part 1.0.3 of the Permit is stated to apply to circumstances where the Permittee
Letter to Rusty Lundberg
December 26, 2012
Page 20f 4
fails to maintain Discharge Minimization Technology ("DMT") or Best Available
Technology ("BAT") standards, Part I.E.8.c) 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 Director 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 Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached single digits on December 19, 2012.
d) On December 19, 2012 a transformer supplying power to the Cell 1 area failed. The mill
managed this power interruption by temporary installation of two portable generators on
December 20,2012. This incident was described in EFRI's telephone notification to DRC on
December 19, 2012, and written notice of December 21,2012. .
e) Several times on December 20, 2012, power to several of the tailings cells was temporarily
interrupted and restored several times. The interruptions, which were of brief duration, did not
last long enough to interrupt required monitoring activities or require reporting to DRC~
However the interruptions required considerable additional maintenance activity on and near
the cell dikes to
(i) inspect transformers,
(ii) inspect and replace power lines on and near the cells,
(iii) inspect ~monitoring devices and transfer lines for potential freezing during the brief,
recurring power outages.
f) In the late afternoon of December 20, 2012, maintenance identified a minor tear in the liner of
Cell 4A near the center of the north dike, above the level of any tailings sands.
2. Actions taken
The following actions were taken following identification of the liner tear.
a) Mill maintenance personnel immediately repaired and tested the Cell 4A liner on December
20,2012.
b) On December 21, 2012, during the morning status update addressing power issues and repair
activities in the tailings area, Mill maintenance advised Mill environmental personnel that a
liner tear had been identified and had been repaired late on December 20,2012.
c) During a regular update of Mill power loss response activities on December 21, 2012, Mill
environmental personnel advised Corporate Environmental personnel of the liner tear and
repair.
Letter to Rusty Lundberg
December 26,2012
Page 3 of 4
d) Initial notice of this outage was given by telephone to Mr. Ryan Johnson of DRC at
approximately 3:25pm on Friday December 21, 2012 (within 24 hours of Corporate personnel
receiving notice, and within 24 hours of Mill environmental personnel receiving notice).
3. Actions Taken to Prevent a Recurrence of This Incident
The following actions will be taken to prevent a reoccurrence of this incident:
As discussed above, the liner tear was identified, and likely occurred due to, the period of increased
maintenance activity associated with response to freeze-related failures of older power equipment. The
older power transformers have be~n replaced with new andlor upgraded equipment. Affected older
( power lines installations have been 'upgraded by re-installing the power lines inside HDPE pipe conduit
for additional protection from traffic and weather.
It is anticipated that these provisions will prevent a recurrence of the multiple simultaneous failures that
required traffic on the liner during December 19 through 21, 2012.
4. Required Reporting
As required by Part I.E.8.c) of the permit and by the approved June 2007 Geosyntec Consultants Cell 4A
Construction Quality Assurance Plan, 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 fourth
quarter of 2012. The repair report will be submitted with the fourth quarter 2012 DMT Report on or
before March 1, 2013. The repair report will contain, in addition to a root cause analysis, the following
elements:
• Repair narrative describing the nature of the damage and th~ 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 Inforniation
5. Affirmative Defense
EFR does not believe that identification of a defect or damage to the Cell 4A 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 BAT under the Permit. Further, the damage to the Cell
4A liner was above the level of any tailings contained in the cell. As a result, EFR is not making a claim
for an affirmative defense under Part 1.0.3 of the Permit.
Letter to Rusty Lundberg
December 26,2012
Page 4 of4
If you have any questions, please contact me at [phone].
Yours very truly,
~
ENERGY FUELS RESOURCES (USA) INC.
JoAnn Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phil Goble, DRC
Dean Henderson, DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Kathy Weinel
/
January 8, 2013
Sent VIA E-MAIL AND 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
3039742140
www.energyfuels.com
Re: Status Update and Follow-up to Notification Regarding Cell 2 Slimes Drain Freeze
Dear Mr. Lundberg:
This letter is a follow-up to Energy Fuels Resources (USA) Inc.' s ("EFRI's") telephone calls to the
Utah Division of Radiation Control ("DRC") on January 3, 2013 regarding the effects of freezing
weather conditions on the Cell 2 slimes drain transfer pipeline at theWhite Mesa Mill (the "Mill").
The Mill's Tailings Management System program commits that EFRI will repair the slimes drain
pumping system within 15 days, if it is observed not to be working properly.
As discussed below, the Mill experienced an abnormally extended period of cold conditions during the
last two weeks of December and first week of January, which resulted in freeze damage to a number
of areas at the Mill, including power transformers supplying Cell 2. During the period of ongoing low
temperature, the slimes drain pump and monitoring equipment remained intact, and power was
available to the area via a portable generator. However, the transfer line to Cell 4A became frozen on
December 19, 2012, and due to the extended period of freezing weather, could not be thawed and
returned to operation until January 7, 2013.
Although not required by the Tailings Management System program applicable to Cell 2, EFRI has
chosen to make the telephone notifications and this follow-up letter for information purposes, to keep
DRC apprised of the Mill's efforts to restore the transfer line to operation, and to inform DRC that the
line has been thawed and the system has been returned to service.
Letter to R. Lundberg
January 8, 2013
Page 2
1. Facts and Background
a) The Mill's Tailings Management System Plan revision 2.1 states that:
"Cell 2 slimes drain pump is checked weekly to observe that it is operating and that
the water level probe and float mechanism are working properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed to be not
working properly, it will be fixed or replaced within 15 days."
b) The Cell 2 slimes drain solutions are transferred through a 3-inch pipeline to Cell 4A. Prior
to December 19, 2012, the pipeline was above ground atop the dikes and/or sands of Cell 2
and Cell 3, discharging into Cell4A near the dike of CeIl4A.
c) Mill personnel conducted the Cell 2 slimes drain quarterly pump test, required by Part I.D.3
of the GWD P, from December 11 to December 17, 2012. The pump and transfer line
operated properly until after the test was concluded. Following shutdown of the pump test,
the line froze during the evening of December 17, 2012.
d) Mill personnel thawed the line with heating torches and returned it to service during
December 18 and 19, 2012. On December 19, 2012, Mill personnel buried the horizontal
sections of pipe in 12 inches of borrow soil atop Cell 3 for insulation against potential future
freezing weather.
e) The Mill experienced an extended period of abnormally cold weather beginning on
December 19, 2012. During the evening of December 19, 2012, the Cell 2 slimes drain
transfer pipeline froze, even though it had been buried in 12 inches of soil. It remained frozen
through January 3, 2013 despite additional efforts to thaw the line with heating torches
during that period.
2. Action Taken
a) EFRI contacted Mr. Phil Goble of DRC on January 3, 2013 to advise DRC that due to the
persistence of the abnormally cold weather and the Mill's inability to thaw the Cell 2 slimes
drain pipe, EFRI was unable to perform the Cell 2 slimes drain pump check tests, required by
the Tailings Management System program applicable to Cell 2, during the weeks of
December 21 and 28,2012 and January 4,2013.
b) EFRI committed to advise DRC as soon as weather conditions supported thawing of the
discharge pipeline.
c) EFRI committed to resume the weekly testing as soon as the pipeline was thawed.
2
Letter to R. Lundberg
January 8,2013
Page 3
d) Mr. Goble instructed EFRI to document the efforts to date, and to advise DRC when a more
definitive date for returning the system to service was known.
e) EFRI successfully thawed the discharge pipeline and returned the slimes drain pumping
system to service on January 7,2013.
f) EFRI has determined that for future potential freeze situations, a backup transfer procedure
involving pumping the Cell 2 slimes drain fluids a shorter distance to exposed tailings sands
areas in Cell 3, could be used if weather conditions may prevent performance of the weekly
slimes drain pump check. The shorter length of transfer line may permit easier thawing and
maintenance of slimes drain fluid flow.
3. Root Cause
The slimes drain transfer pump operates on a float system which turns the transfer pump on when
sufficient fluid has accumulated in the slimes drain system. As a result, the pump, and transfer line,
experience intermittent, not constant, flow. During most of the year, and during typical winters, the
intermittent flow is sufficient to prevent freezing of the 3-inch transfer line. During the prolonged
cold period in which the ambient temperature remained below freezing during the day and as low as
single digits during some nights, the intermittent flow was not sufficient to keep the line from
freezing, even below the 12 inches of insulating soil.
·4. Actions Taken to Maintain Compliance
EFRI has taken the following steps to return the Cell 2 slimes drain transfer system to compliance in
as short a time as possible.
a) Notification
By virtue of the initial oral notification given to DRC at on Thursday, January 3, 2013, and this
written status letter, EFRI has ,made good faith efforts to keep DRC apprised of the situation
resulting in loss of three rounds of pump checks, as well as efforts to restore the system to operation.
b) Failure was not Intentional or Caused by EFRI's Negligence
The failure to conduct the three missed weekly slimes drain pump checks was not due to EFRI's
negligence, either in action or in failure to act. The prolonged cold did not afford any opportunity to
get the slimes drain discharge line thawed and keep it thawed long enough to put the P.ump system
back in service.
c) EFRI I-Ias Taken Adequate Measures to Meet Requirements of the Tailings Management
System Program
3
Letter to R. Lundberg
January 8, 2013
Page 4
EFRI immediately thawed and returned the slimes drain transfer line to service when it first froze
During December 18, and 19, 2012. When it became evident that it would not be possible to
maintain the system in a thawed and operative condition, EFRI advised DRC and sought DRC's
input on what DRC would require. EFRI complied with DRC's requirements as enumerated in
Section 2, above.
If you should have any questions regarding this status report please contact me.
Yours very tml y,
ENERGY 'UE ,S RESOURCES (USA) INC.
D· . rydenlund
Senior Vice President, General Counsel and Corporate Secretary
CC: Scot Christianson
JoAnn Tischler
Dan Hillsten
N. Tanner Holliday
Garrin Palmer
Harold R. Roberts
David E. Turk
Kathy Weinel
4
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 3/12/2012
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
3/5/12 3/6/12 3/7/12 3/8/12 3/9/12 3/10/12 3/11/12 3/12/12
600
700 35.70 26.74 24.15 23.43 22.79
800 34.55 25.62 24.11 23.42 22.77 20.90
900 33.82 26.45 24.08 23.41 22.74 20.90
1000 33.09 26.29 24.05 23.40 22.71 20.90
1100 32.53 26.17 24.02 23.37 22.67
1200 32.01 25.95 23.98 23.33 22.63
1300 31.63 25.77 23.95 23.30 22.59
1400 31.05 25.60 23.92 23.25 22.52 21.78
1500 30.65 25.44 23.90 23.21 22.46 21.20
1600
Comments: Readings were taken Saturday the 10th and Sunday the 11th.
The final reading for the quarter is 20.90.
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 5/29/2012
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
5/21/12 5/22/12 5/23/12 5/24/12 5/25/12 5/26/12 5/27/12 5/28/12 5/29/12
600 21.55
700 35.19 27.25 24.71 23.63 22.85
800 34.54 27.12 24.65 23.60 22.80 21.82 21.10
900 33.80 26.99 24.60 23.58 22.75 21.10
1000 33.31 26.85 24.55 23.54 22.70 21.10
1100 32.69 26.74 24.27 23.50 22.65 22.06
1200 32.04 26.65 24.40 23.45 22.60
1300 31.60 26.46 24.31 23.39 22.57
1400 31.18 26.28 24.26 23.35 22.53
1500 30.77 26.11 24.20 23.30 22.50
1600
Comments: Only single readings were taken Saturday the 26th, Sunday the 27th and Monday the 28th
because the environmental staff were out of the office those days.
The final number for the quarter is 21.10
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
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 12/17/2012
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
12/11/12 12/12/12 12/13/12 12/14/12 12/15/12 12/16/12 12/17/12
600
700 27.47 24.98 23.55 21.84
800 27.35 24.94 23.50 21.84
900 34.96 27.22 24.83 24.45 21.84
1000 34.22 27.06 24.79 23.37
1100 33.61 26.92 24.78 23.33
1200 33.06 26.77 24.67 23.29
1300 32.48 26.63 24.60 23.26
1400 31.77 26.45 24.54 23.23 22.65 21.98
1500 31.34 26.37 24.47 23.21
1600
Comments: Final reading for 4th quarter 2012 is 21.84.
Attachment D
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Feet Below Top of Standpipe
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00
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..... ..... 0"'1 ~ (:) (:)
0 0
1/30/2009
3/30/2009
5/30/2009
7/30/2009
9/30/2009
11/30/2009
1/31/2010
3/31/2010
. 5/31/2010
7/31/2010
9/30/2010
11/30/20i o
1/31/2011
3/31/2011
5/31/2011
7/31/2011
9/30/2011
11/30/2011
1/31/2012
3/31/2012
5/31/2012
7/31/2012
9/30/2012
11/30/2012
Attachment E
WHITE MESA MILL
REPAIR REPORT
CELL4A
March 2013
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill-2013 Repair Report, Ce1l4A
Page 2 of 10
WHITE MESA MILL
REPAIR REPORT
CELL4A
TABLE OF CONTENTS
1. IN"TRODUCTION .................................................................................................................. 3
2. IN"CIDENT HISTORY AND CHRONOLOGY .................................................................... 4
3. ROOT CAUSE ANALySIS .................................................................................................. 5
4. REPAIR LOCATION AND DIMENSIONS ......................................................................... 5
5. REPAIR TYPE AND DATE ................................................................................................. 5
6. REPAIR PERSONNEL ......................................................................................................... 6
7. NON-DESTRUCTIVE TESTIN"G ......................................................................................... 6
8. CONCLUSIONS .................................................................................................................... 6
9. CERTIFICATION .................................................................................................................. 7
Appendix 1
Appendix 2
Appendix 3
APPENDICES
Letters and Correspondence Regarding Ce1l4A Liner
Liner Repair Daily Reports
Repair Photographs
N:\WMM\Ce1l4A\Ce1l4A Liner repair December 20 12\Steve Snyder files\Ce1l4A Liner Repair Rpt to Drctr 03.01.13 rev SS clean.doc
White Mesa Mill-2013 Repair Report, Ce1l4A
Page 3 of 10
1. INTRODUCTION
Energy Fuels Resources (USA) Inc. ("EFRI"), formerly named Denison Mines (USA) Corp.,
operates White Mesa Mill's (the "Mill's") Cell 4A as a part of the Mill's tailings management
system. Cell 4A consists of an impermeable 60 mil high density polyethylene (HDPE) primary
flexible membrane liner ("primary FML" or "FML") that extends across the entire cell floor and the
inside side-slopes. The FML is underlain by a leak detection system ("LDS") consisting of a geonet
fabric. The LDS is underlain by a secondary FML of impermeable 60-mil HDPE. The secondary
FML is underlain by a geosynthetic clay liner consisting of a manufactured geosynthetic clay liner
consisting of a layer of bentonite clay centered and stitched between two layers of geotextile. The
Performance standards, monitoring and maintenance requirements for Cell4A are specified in the
Best Available Technology requirements in the Mill's Groundwater Discharge Permit (the "Permit").
Per Parts LE.8 c) and LF.3 of the Mill's Permit, ifEFRI identifies any damage to the liners of any
tailings cell, EFRI is required to repair the damage in accordance with Section 9.4 of the approved
June 2007 Geosyntec Consultants Cell4A Construction Quality Assurance Plan, and provide a Liner
Repair Report to the Director of the Division of Radiation Control.
EFRI performed repairs to the Cell4A FML on December 20,2012, as discussed below. As a result
of those repairs, this Cell 4A Liner Repair Report (the "Repair Report") is being submitted to comply
with Parts LF.3 and LE.8 c) of the Mill's Groundwater Discharge Permit ("GWDP"). Section 9.4.5.4
of the Geosyntec Consultants Ce1l4A Construction Quality Assurance Plan require that the Repair
Report contain the following information:
• Panel containing repair and approximate location on panel
• Approximate dimensions of repair
• Repair type, i.e. fusion weld or extrusion weld
• Date of repair
• Seamer making the repair
• Results of repair non-destructive testing (pass or fail)
Accordingly, the sections of this Repair Report, below, are organized consistent with the items
above.
Part LF.3 of the RML requires that following the repairs, the
"Repair Report shall be included with the next quarterly BAT Report".
Repairs resulting from the event above were completed during the fourth quarter of 2012. This
Repair Report has been included with the fourth quarter 2012 DMT Report, being submitted on
March 1,2013.
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White Mesa Mill-2013 Repair Report, Ce1l4A
Page 4 of 10
Due to Senate Bill 21 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
Part I.E.8.c) of the Permit requires that:
" ... all repairs to the liner shall be completed in accordance with Section 9.4 of the
approved June 2007 Geosyntec Consultants Cell 4A Construction Quality Assurance
Plan as found in Table 5 of this Permit. Repairs shall be performed by qualified liner
repair personnel and shall be reported in a Liner Repair Report, certified by a Utah
licensed Professional Engineer. The Liner Repair Report shall be submitted to for [sic]
Director approval in accordance with Part I.F.3 of the Permit. Any leak,hole or other
damage to the liner will be reported to the Director pursuant to the requirements found in
part I.G.3."
Although Part I.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.8.c) requires that the notification provisions of Part I.G.3 also apply to liner
defects or <;iamage, 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 Director 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."
The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached single digits on December 19,2012.
On December 19,2012 a transformer supplying power to the CellI area failed. The mill managed
this power interruption by temporary installation of two portable generators on December 20,2012.
This incident was described in EFRI's telephone notification to DRC on December 19, 2012, and
written notice of December 21,2012.
Several times on December 20, 2012, power to several of the tailings cells was temporarily
interrupted and restored several times. The interruptions, which were of brief duration, did not last
long enough to interrupt required monitoring activities or require reporting to DRC. However the
interruptions required considerable additional maintenance activity on and near the cell dikes to:
(i) inspect transformers,
(ii) inspect and replace power lines on and near the cells,
(iii) inspect monitoring devices and transfer lines for potential freezing during the brief,
recurring power outages.
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White Mesa Mill-2013 Repair Report, Ce1l4A
Page 5 of 10
In the late afternoon of December 20,2012, maintenance identified a minor tear in the primary FML
of Cell 4A near the center of the north dike, above the level of any tailings sands.
Repairs to the FML were performed and completed on December 20, 2012, in accordance with
Section 9.4 of the Geosyntec Consultants Cell4A Construction Quality Assurance Plan. As the liner
tear and repair area was above the level of any cell contents, it was not required to remove Cell4A
from service.
On December 21, 2012, during the morning status update addressing power issues and repair
activities in the tailings area, Mill maintenance advised Mill environmental personnel that a liner tear
had been identified and had been repaired late on December 20,2012.
During a regular update of Mill power loss response activities on December 21, 2012, Mill
environmental personnel advised Corporate Environmental personnel of the liner tear and repair.
Initial notice of the Cell4A tear and repair was given by telephone to Mr. Ryan Johnson ofDRC at
approximately 3:25pm on Friday December 21, 2012 (within 24 hours of Corporate personnel
receiving notice, and within 24 hours of Mill environmental personnel receiving notice) as
contemplated by Parts I.E.8c) and I.G.3 of the Permit. Consistent with Parts I.E.8c) and I.G.3 of the
Permit, EFRI submitted a written notice to the Director (the "Notice") on December 26, 2012.
3. ROOT CAUSE ANALYSIS
As discussed above, the liner tear was identified, and likely occurred due to, maintenance on the pipe
drops in cell4A in conjuction with freezing surface temperatures. The maintenance on the pipe was
required because the pipes had frozen due to tailings area power outages resulting from an old
underground power line ground fault. The damaged underground power line has been replaced.
It is anticipated that these provisions will prevent a recurrence of the multiple simultaneous failures
that required increased traffic on the Cell4A liner during December 19 through 21, 2012.
4. REPAIR LOCATION AND DIMENSIONS
The repairs are located on panel P34 as shown by the photos in Appendix 3. There are three
individual repairs; all of which are on the same panel with two of the repairs being at the crest of
the slope and one being roughly 10' below the crest. Two of the repairs are patches over the
defects and one is a spot weld. The patches are roughly 12" square with rounded edges. The
spot weld consists of a single extrusion seam approximately 6" long.
5. REPAIR TYPE AND DATE
All repairs were made via extrusion welding. Two holes were patched with sections cut from 60 mil
HDPE roll stock remaining from the lining of Cell 4B (whose FML is constructed of the same
material as CeIl4A), and the other was repaired with single seam. Prior to placement of the new
lining material repair patch, the surface was swept clean of all soils and debris and cleaned with
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White Mesa Mill-2013 Repair Report, Ce1l4A
Page 6 of 10
acetone. The patch material was seamed to the existing liner material via extrusion welding. The
other hole was small enough that a seam repair was sufficient. All repairs were accomplished on
December 20th, 2012. Non-destructive vacuum testing was accomplished on January 30t\ 2013.
The continued low temperatures during the intervening period prevented the conduct of a valid
vacuum test.
6. REPAIR PERSONNEL
Repairs were accomplished by the Mill's maintenance HDPE Liner Repair Crew. Personnel
include Kendall Benally, Jaymes Benally, and Truit ashley. Vacuum testing was accomplished
by Kendall Benally and Jaymes Benally.
7. NON-DESTRUCTIVE TESTING
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 Report in Appendix 2.
8. CONCLUSIONS
On December 20, 2012, Cell 4A liner repair activities were completed by EFRI maintenance
personnel. On January 30t\ 2013, the non-destructive testing was completed on the subject repairs.
Utah Registered Professional Engineer Steve R. Snyder, the Mill's Facility Engineer reviewed the
Liner Repair Report and discussed the repairs made to Cell4A with maintenance personnel directly
involved.
EFRI believes that the Cell 4A liner repair has been performed consistent with the requirements
of the Cell 4A Construction Quality Assurance Plan.
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White Mesa Mill-2013 Repair Report, Ce1l4A
Page 7 of 10
9. CERTIFICATION
I, Steve R. Snyder, a Utah Registered Professional Engineer, was present at the Mill during the
repairs of the Ce1l4A 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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01 13 FINAL.doc
White Mesa Mill-2013 Repair Report, Ce1l4A
Page 8 of 10
APPENDIX 1
LETTERS AND CORRESPONDENCE
REGARDING
CELL 4A LINER REPAIRS
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VIA EMAIL AND OVERNIGHT DELIVERY
Deeember26, 2012
Mr. Rusty Lundberg·
DireCtor of the Utah DivisiQDOf Radiation Control
State-of Utah Department of Environm~ntat QUality
195 North 1950 West
P.O. Box 144850
Salt Lake City, ut&4116-4850
Re: White Me$a J]tarutim Mill
Utah Gtoutid Water Discharge Permit No. UGW3700004
Ertergy'i=tie,f~ Re$ources (USA) fne.
225 Union: ,Blvd. 'Stiite'SOO
Lakew$oo; 00., US', ,80228
. 3Q3 97421"40
www.ener~yfuels .. com
White Me&a U~a.niuPl Mill ~ Notice 'PurS\Ulnt to Parts l.E.8~c)and 1.0.3 of the Perm.it
Dear Mr. Lundberg:'
Pl~ase take' notice pursuant to Parts-I.E .. S.c) and IG.3 of the White Mesa Mill~s (the \~Milr·s'-') State of
Utah Groundwater Discharge PerQl.\t No. UGW370004 (the ~Pertnit'''), that Energy Fuels Resource$
(USA) Inc: r'EFRl'), as operator of the Mill and holder-of the p¢rtnit, identified ,and'repaired damage to
the Cell 4A Liner System as described in, mOte detailbelQw.
Repairs to tbe liner were completed ~d tested-on. December 20 and 21, 2012, in accordance with
Section ;9~4 of the approved 1une 2001 Geo.syntec Con~ultants ceil 4A Constructiql1Quality Assurance
Plan. The C,ell remained in ~rvi9t' during and after the repairs.
1~ F.ci$ and BackgrOimd Info.rmation
a): Part tE.8.c,) ofthePennit :requit~ that the licensee ,conduct daily inspections fer each of tbe
tailings ceUs and weekly inspections of Roberts Pond. According to Part IB.S.c):
~\ .. ~ repairs. to th¢ liner shall be completed in ac~rdance with Section 9.4 of the'
approved IUIle 2007 GeosynteoCQn.sultants Cell 4A Construction Quality Assurance:
Plan as found in Table 5. of this Permit. The Liner Repair Report shall be,suluilitted
,tQ for [sic] Ditec~orapPtova1 in-accordance, with, Part I.F."3 of the Permit" Repairs
shall be performed by ql;l~ified liller repair personnel and shall pe reported'in a: Liner
Repair Report, certified by a Utah licemed ProfessiQnal Engin~r. Any l~ak~ hol~ or
other damage to the liner will be reported to the Director pursuant to the requirements
found in part lG.~*,"
b) Although Part 1.0.3 of the, Peomtis, stated to apply to circumstances where tbe'Pennittee
! ,
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Letter to Rusty Lundbetg
December 26, 2012
Page40f4
if you have atiyquestions, ple,ase contact meat. (303) 389;..4132~
Yours very trulyJc
.
"' . / ... #;~;f /J /J~.:: ·~~r . .:' .. ': ~~to/~~i
, -
ENEllGY FtIELS RESOURCEs (USA) INC ..
Jo A.nn Tischl~r
Manager, Co~plianceaod: Ucensing
'cc David C. Fry~nIund
PlrllOob1e, DRC
pean llende-f.son~ PRe
Dan llillsten
Harold It Roberts
David E., Turk
~thyW~mel
White Mesa Mill-2013 Repair Report, Ce1l4A
Page 9 of 10
APPENDIX 2
LINER REPAIR DAILY REPORTS
N:\WMM\Ce1l4A\Ce1l4A Liner repair December 2012\Steve Snyder files\Ce1l4A Liner Repair Rpt to Drctr 03.01.13 rev SS clean.doc
Cell # Cell #4a
Date: 30 Jan. 2013
Start Time: 7 :OOam
End Time: 5:30pm
Liner Repair Report
Linear feet exposed for inspection: _---=l::....;:O'--'....:..;x:.....;l::....;O:.....;' ___ _
Description of damage or clear of any defects:
Slope on West side 3 areas where repair was needed!
Description of the repair work utilized to repair the damage:
Upper portion of liner.
Material used to complete the repairs:
Acetone ( cleaner)
Repair Material-(describe in detail):
Extrusion Machine added HDPE liner.
Weather Conditions:
*21 Deg.
Personnel performing the repair work:
*HDPE Liner Repair Crew-Kendall, Jaymes, and Truit.
*Vacuum Testers-Kendall and Jaymes.
Vacuum Checks if conducted: Conducted Vacuum Checks. See Below
Notes: 3 Minor patches were repaired around a 10' x 10' area.
S Vacuum Tests-30th of Jan 2013.
1) 17 hg.
2) 17 hg.
3) 17 hg.
4) 17 hg.
5) 17 hg.
6) 17 hg.
7) 17 hg.
8) 17 hg.
NOTE: All testing of the repaired material will be in compliance with ASTM D5641
White Mesa Mill-2013 Repair Report, Ce1l4A
Page 10 of 10
APPENDIX 3
REPAIR PHOTOGRAPHS
N:\WMM\CeIl4A\CeIl4A Liner repair December 2012\Steve Snyder files\Cell4A Liner Repair Rpt to Drctr 03.01.13 rev SS clean.doc
Attachment F
October 2012
Date
10/5/2012
10/12/2012
10/19/2012
10/26/2012
Cell 4A LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
10.3
11.6
11.3
5.4
Flow Meter in Gallons
274917
274917
274946
278054
Highest level for the month based on the daily data was 13.3 inches and the lowest level for the month
was 5.4 inches. Total number of gallons pumped was 3137.
Note: on October 18, 2012 29 gallons were manually pumped to verify that all systems were operational.
No problems were noted, but systems are checked periodically as a QC measure.
November 2012
Date
11/2/2012
11/9/2012
11/16/2012
11/23/2012
11/30/2012
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
7.4
8.1
8.0
9.7
10.4
Flow Meter in Gallons
278054
278054
278054
278054
278054
Highest level for the month based on the daily data was 10.4 inches and the lowest level for the month
was 6.5 inches. No gallons were pumped.
December 2012
Date
12/7/2012
12/14/2012
12/21/2012
12/28/2012
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
10.7
12.5
6.2
9.3
Flow Meter in Gallons
278054
278054
280934
280934
Highest level for the month based on the daily data was 14.4 inches and the lowest level for the month
was 6.0 inches. Total number of gallons pumped was 2880.
For the 4th Quarter 2012, the highest level was 14.4 inches and the lowest level was 5.4 inches and
6017 gallons were pumped.
October 2012
Date
10/5/2012
10/12/2012
10/19/2012
10/26/2012
Cell 48 LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
1.02
1.30
1.02
1.02
Flow Meter in Gallons
25
25
82
82
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 57.
Note: on October 16, 2012 57 gallons were manually pumped to verify that all systems were
operational. No problems were noted, but systems are checked periodically as a QC measure.
November 2012
Date
11/2/2012
11/9/2012
11/16/2012
11/23/2012
11/30/2012
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
1.30
1.57
1.85
1.02
1.30
Flow Meter in Gallons
82
82
82
82
82
Highest level for the month based on the daily data was 1 .85 inches and the lowest level for the month
was 0.46 inches. Total number of gallons pumped was O.
December 2012
Date
12/7/2012
12/14/2012
12/21/2012
12/28/2012
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
0.46
-0.10
-0.29
-0.29
Flow Meter in Gallons
82
82
118
118
Highest level for the month based on the daily data was 1 .30 inches and the lowest level for the month
was -1.24 inches. Total number of gallons pumped was 36.
For the 4th Quarter 2012, the highest level was 1.85 inches and the lowest level was -1.24 inches and
93 gallons were pumped.
I
S..,"l!cConsultfl,." Tdbfe 1A
Cilcufated Action La.kII ..... fbr VarioUs flead emdltlQfts
Celf 4~i WhJteMIiI Mill
Head AttOV8 LIner
~VJtam (feet,
5
. 15
20 . 2S
35
.. 17
BJamlrn,.Utah
Q~"Acllon""","
(pl1on'/an/dlY) . . ...... .,,:, ".
GIDIYnr.t: ConlUittl. Tilble 11
cafculated ActIon Lalcage Rata'for Various Held ConditIons
cell 48, ,Wlltte Mlli MDI
•• ndllil; U-'fJ
HI.d_VI u .. rsystem . ''''1 . 5
,2.5
c.rca'ltId.onlA*_ Rate . ,fI.no.rtt/.~til".,J '
422.7 . , 475.6 "
510.0
,581 •. a ,
Max head on Cell 4A FML
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 -Q4 2012
5593.49
5555.55
37.94
604.0
40
24160
Max head on Cell 4B 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 -Q4 2012
5578.82
5557.50
21.32
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 I-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 lA (for CeIl4A) or Table
IB (for Cell 4B) 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 lA or IB) X Acres of Tailings Cell Fluids =
Maximum Daily Allowable Flow Volume
Cell 1, Cell 2, and Cell 3 LOS Monitoring Information -Fourth Quarter 2012
Cell 1 Cell 2 Cell 3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the LDS sump.
10/5/2012 Dry 10/5/2012 Dry 10/5/2012 Dry
10/12/2012 Dry 10/12/2012 Dry 10/12/2012 Dry
10/19/2012 Dry 10/19/2012 Dry 10/19/2012 Dry
10/26/2012 Dry 10/26/2012 Dry 10/26/2012 Dry
Cell 1 Cell 2 Cell 3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the LDS sump.
11/2/2012 Dry 11/2/2012 Dry 11/2/2012 Dry
11/9/2012 Dry 11/9/2012 Dry 11/9/2012 Dry
11/16/2012 Dry 11/16/2012 Dry 11/16/2012 Dry
11/23/2012 Dry 11/23/2012 Dry 11/23/2012 Dry
11/30/2012 Dry 11/30/2012 Dry 11/30/2012 Dry
Cell 1 Cell 2 Cell 3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the LDS sump.
12/7/2012 Dry 12/7/2012 Dry 12/7/2012 Dry
12/14/2012 Dry 12/14/2012 Dry 12/14/2012 Dry
12/21/2012 Dry 12/21/2012 Dry 12/21/2012 Dry
12/28/2012 Dry 12/28/2012 Dry 12/28/2012 Dry
Attachment G
This attachment has been deliberately left blank.
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