DRC-2013-001784 - 0901a0688035f9ca

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
March 21, 2013
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 - Response to Division of Radiation Control ("DRC") comments on
Operations and Maintenance Plan Nitrate Pumping System Revision 1.0 ("Nitrate O&M Plan")
dated January 11, 2013 ^
Dear Mr. Lundberg: 4
This letter responds to the Division of Radiation Control ("DRC") conmient letter dated February 21,
2013 which Energy Fuels Resources (USA) Inc ("EFRF') received February 25, 2013 regarding
requested modifications to the above referenced plan. For ease of review, each DRC comment to the
Nitrate O&M Plan or request is provided verbatim in italics, below, followed by EPTlFs response.
Based on discussions with DRC on February 11, 2013 and March 7, 2013 (documented by e-mail on
February 13, 2012), EFRI is interpreting the Nitrate Corrective Action Plan ("CAP") requirements to
transfer pumped groundwater to the tailings cells as including pumping and re-use in the Mill process,
which discharges to the tailings cells. This change has been made to the Plan which is attached. Parallel
changes have been made to the Chloroform Operations and .Maintenance Plan ("Chloroform O&M
Plan") which is also attached.
We have attached a clean copy and an edited redline copy of the Nitrate O&M Plan as well as the
Chloroform O&M Plan for your convenience in which EFRFs modifications or additional language are
indicated in color.
DRC Comment #1
1. In the second sentence in Section 2.1 add the following wording (added wording underlined):
Pumped water will be disposed in the tailings cells or maybe used for the Mill process water.
EFRI Response #1
The wording has been added as requested. Additionally, similar wording has been added to the second
bullet in Section 1.0 and the second bullet in Section 4.0 which also describe the disposition of the
N:\WMM\Nitrate Investigation and CIRXCorrective Action Plan (CAP)\Nitrate O&M Plan\Revision 2.0X03.25.13 response
to 02.21.13 comment Itr.doc
Letter to Rusty Lundberg
March 21, 2013
Page 2 of 5
pumped water.
DRC Comment #2
Add a section that defines the pumping system with the following wording:
Definition of Pumping System:
• Structure of the pumping wells including: well casing, well slotted screen casing, sand/gravel pack,
bentonite seal,cement grout seal, protective steel surface casing;
• Pump
• All structural materials that hold the pump in place;
• Electrical power for the pump and well heat lamps;
• Electrical wiring to the pump and well head heat lamps;
• All hosing, piping, and associated hose and pipe fittings from the pump, including sampling ports, to
discharge hose at the tailings cells;
• Temporary water storage tanks;
• Protective boxes over the well heads lined with insulating foam.
EFRI Response #2
The requested language has been added as Section 3.0 and subsequent sections have been re-numbered
as necessary.
In response to the potential for EFRI to use the pumped water for Mill process water, EFRI has added a
clarification and definition of a system failure to Section 5.0 Maintenance. The above definition of the
pumping system requested by DRC defines the pumping system as including "A// hosing, piping, and
associated hose and pipe fittings from the pump, including sampling ports, to discharge hose at the
tailings cells". EFRI believes that it was not DRC's intent to require reporting of Mill process
stoppages, but to require EFRI to report pumping system failures that resulted in the cessation of the
pumping of the designated pumping wells that are not made fully operational within 24 hours of
discovery. The definition of a system failure clarifies that reporting is only required when pumping is
interrupted for more than 24 hours. EFRI anticipates that if a Mill process stoppage occurs, the pumped
water can be re-routed and pumping resumed with minimal impact to the pumping schedules.
Letter to Rusty Lundberg
March 21, 2013
Page 3 of 5
If you have any questions, please contact me at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
CC David C. Frydenlund
Phil Goble, Utah DRC
Dean Henderson, Utah DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Kathy Weinel
Attachments
Letter to Rusty Lundberg
March 21, 2013
Page 4 of 5
APPENDIX 1 !
Clean and Redline Copies of
Nitrate Pumping System Operations and Maintenance Plan
CLEAN
White Mesa Mill
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
State of Utah
Stipulation and Consent Order Docket Number UGW12-04
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 21,2013
Table of Contents
1 0 INTRODUCTION 1
2 0 OPERATIONS 2
2 1 Groundwater Pumping 2
2 2 Water Level Monitoring .... 2
2 3 Water Quality Monitonng .. 2
3 0 DEFINITION OF THE PUMPING SYSTEM 2
4.0 WINTEBOZATION FOR LONG-TERM OPERATIONS 3
5.0 MAINTENANCE 3
6.0 MONITORING AND REPORTING 4
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2 0
March 21, 2013
1.0 INTRODUCTION
The Utah Department of Environmental Quality ("UDEQ") Division of Radiation Control
("DRC") noted in a Request dated September 30, 2008 (the "Request"), for a Voluntary Plan and
Schedule to Investigate and Remediate Nitrate Contamination at the White Mesa Uranium Mill
(the "Mill") (the "Plan"), that nitrate levels have exceeded the State water quality standard of 10
mg/L in certain monitonng wells m.the perched groundwater zone. As a result of the Request,
Energy Fuels Resources (USA) Inc ("EFRF') entered into a Stipulated Consent Agreement (the
"Consent Agreement") with the Utah Water Quality Board in January 2009 which directed the
preparation of a Nitrate Contanunation Investigation Report ("CIR"). A subsequent letter dated
December 1, 2009, among other things, recommended that EFRI also address elevated chloride
concentration in the CIR The Consent Agreement ("CA") was amended in August 2011. Under
the amended Consent Agreement, EFRI submitted a Corrective Action Plan ("CAP"), pursuant
to the requirements of the Utah Groundwater Quality Protection Rules [UAC R317-6-6 15(C -
E)] on November 29, 2011 and revised versions of the CAP on February 27, 2012 and May 7,
2012 On December 12, 2012, DRC signed the Stipulation and Consent Order ("SCO"), Docket
Number UGW12-04, which approved the EFRI CAP, dated May 7, 2012. The SCO ordered
EFRI to fiilly implement all elements of the May 7, 2012 CAP.
The CAP addresses nitrate + nitnte (as nitrate) (heretofore referred to as "mtrate") contanunation
in the shallow perched groundwater zone at the Mill site It should be noted that while the CAP
requires monitonng of chlonde concentrations, the CAP does not specify measures for
controlling chlonde levels per se, because there is no health standard for chlonde in
groundwater. However, as discussed and agreed to with DRC dunng meetings in October 2011,
chlonde appears to be co-located with nitrate in groundwater at the Mill and hydrogeological
measures to contain mtrate will also contain chlonde
The CAP descnbes a phased approach to the nitrate conective actions The Phases descnbed in
the CAP are as follows:
• Phase I will involve source control in the vicinity of the Mill's ammonium sulfate tanks,
• Phase n will involve active remediation of the nitrate contamination. The active
remediation will be accomplished by pumping contaminated water, into the Mill's
tailings cells for disposal or into the Mill as process water, combined with monitored
natural attenuation,
• Phase ni, if necessary, will be at the discretion of EFRI and would involve a long term
solution for the mtrate contamination, in the event that the continuation of Phase n is not
considered adequate or appropnate
Phases I and n are addressed in the CAP and will commence as required by the schedule
delineated in the CAP. Phase HI is not covered in detail in the CAP and, if determined to be
necessary, will be addressed in a separate CAP revision
1
operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
This Operations and Maintenance ("O&M") Plan has been prepared to meet the requirements of
Phase n as descnbed m the CAP, Section 7 2 2 to address operations (including wintenzation
procedures), maintenance (including inspection forms and response to and documentation of
system failures), monitoring and data reporting
2.0 OPERATIONS
2.1 Groundwater Pumping
Wells TW4-22, TW4-24, TW4-25, and TWN-2 will be pumped at the maximum practical rates
Pumped water will be disposed in the tailmgs cells or may be used for the Mill process water.
The wellfield will be maintained as noted herein. Monitonng will include pumping rates and
volumes for each well Monitonng will be documented on the Weekly Inspection Form included
as Attachment A to this O&M Plan
2.2 Water Level Monitoring
Water level monitonng will consist of weekly water level monitonng of pumping wells TW4-22,
TW4-24, TW4-25, and TWN-2, and, for the first twelve months after approval of the CAP,
monthly water level monitonng of non-pumped wells MW-27, MW-30, MW-31, TW4-21,
TWN-1, TWN-3, TWN-4, TWN-7, and TWN-18. Thereafter, water level momtonng of the non-
pumping wells will continue quarterly. Water level monitonng will be documented on the
Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A and B
to this O&M Plan. Water level contour maps of the data will be generated quarterly.
2.3 Water Quality Monitoring
Water quality monitonng for pumped wells TW4-22, TW4-24, TW4-25, and TWN-2 will be
quarterly. Samples will be analyzed for mtrogen (nitrate and nitrite as N) and chlonde. Field
parameters will be recorded during the sampling as descnbed m the Mill's DRC-approved
Groundwater Quality Assurance Plan ("QAP") Water quality monitonng will be reported and
documented in the quarterly nitrate reports subnutted as descnbed in Section 5.0 of this O&M
Plan Water quality monitonng for nitrate, chlonde, and field parameters for all other wells at the
site will continue at the frequency required under the Groundwater Discharge Permit ("GWDP")
or chloroform investigation, as applicable.
3.0 DEFINITION OF THE PUMPING SYSTEM
The pumping system used for Phase II is defined as follows:
• Structure of the pumping wells including, well casing, well slotted screen casing,
sand/gravel pack, bentonite seal, cement grout seal, protective steel surface casing,
• Pump
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2 0
March 21, 2013
• All structural matenals that hold the pump m place,
• Electncal power for the pump and well heat lamps;
• Electncal wmng to the pump and well head heat lamps;
• All hosing, piping, and associated hose and pipe fittings from the pump, including
sampling ports, to discharge hose at the tailmgs cells,
• Temporary water storage tanks;
• Protective boxes over the well heads lined with insulating foam
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS
The following actions are implemented to provide continuous operations of the pumping well
system at the White Mesa Mill dunng cold weather conditions.
1) Protective boxes are placed around the wellheads of the pumping wells The
protective boxes are lined with insulating foam and heat lamps are installed to
maintain the intenor of the box at a temperature above freezing dunng the winter
months. Winter months are generally defined as the months of November
through March, but wmtenzation of the pumping wells is maintained at any time
the outside air temperature is forecast to fall below 20° F for a duration of one (1)
day or more
2) The pump discharge from each of the pumping wells is connected to a 2-inch
polypropylene drain line, which discharges to the Mill process or to the tailings
cells 1. Lines are protected from freezing by covenng them with a nunimum of 3
feet of soil to prevent freezing dunng the winter months
3) Dunng winter weather with potentially freezing conditions (i e less than 20°F),
the radiation safety department staff observe the pumping daily to venfy that the
heat lamps remain functional The Mill maintenance department is immediately
notified if anything unusual is noted with the system, or if a specific well has
encountered a problem
4) The protective features, discharge line placement and winter inspections descnbed
m Items 1), 2), or 3) above will apply to not only the pumping wells currently in
operation, but will apply also to any fiiture pumping wells associated with the
nitrate pumping system
5.0 MAINTENANCE
The operation of each of the pumping wells is monitored on a daily basis dunng the winter under
potentially freezing conditions by the Environment, Health and Safety Department. Any
malfunction or abnormal operation of the pumping wells is immediately reported to the
Environment, Health and Safety Manager. Environment, Health and Safety Department
Operations and Maintenance Plan
Nitrate Pumping System
Revision 2 0
March 21, 2013
personnel will penodically inspect the pumps, flow meters and operational controls and perform
preventative maintenance to reduce the frequency of unscheduled down time of the pumping
system. Spare pumps are maintained in the Mill warehouse. If a pump is replaced in any of the
wells a new spare is promptly ordered. When a system failure occurs and is not repaired and
fully made operational within 24 hours of discovery, EFRI will call the Director of the Division
of Radiation Control ("Director"), or the Director's staff, to verbally report the system failure
and will report to the Director in a wntten report within 5 days of the failure. A system failure is
defined as any downtime of a system component (as descnbed m Section 3.0) that (a) causes
cessation of the pumping of groundwater from the designated pumping wells, and (b) the
pumping of groundwater from the designated pumping well is not restored and fully made
operational within 24 hours of discovery of the system failure. A failure of any system
component which does not cause the cessation of pumping of groundwater from the designated
pumping wells or where pumping of groundwater from the designated pumping well is restored
and fully made operational within 24 hours of discovery, will not be considered a failure that is
reportable under this requirement. For example, and without limiting the generality of the
foregoing, a failure of a component that can be rectified by re-routing the pumped water from the
tailings to the Mill process or vice versa, or by transporting the pumped water via portable tank
rather than pipeline, and which does not cause the pumping activities to be halted for more than
24-hours, would not be considered a reportable system failure.
Each wntten subnussion shall contain the following information:
a) A description of the pumping system failure(s) and their root causes
b) The penod of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational;
d) Steps taken or that will be taken to repair and have the system fiilly operational,
e) Steps taken or that will be taken to eliminate and prevent reoccurrence of system
failure (s)
In addition, all system failures will be reported in the next quarterly nitrate monitonng report
6.0 MONITORING AND REPORTING
Monitonng of the system by the Mill's Environment, Health and Safety Department occurs
weekly other than as noted above except for cold weather checks which are done daily dunng
freezing weather. Monitonng includes well depths, flow rates, pump operating times and gallons
pumped. These items are recorded on a weekly basis on the Weekly Inspection Report included
as Attachment A to this Plan
On a quarterly basis, the mtrate investigation wells designated in the CAP are sampled for nitrate
and chlonde These data, including copies of chain of custody forms and laboratory analytical
reports are included m the Quarterly Nitrate Reports, and are reported to the DRC according to
the following schedule
operations and Maintenance Plan
Nitrate Pumping System
Revision 2.0
March 21, 2013
First Quarter - June 1
Second Quarter - September 1
Third Quarter - December 1
Fourth Quarter - March 1
In addition to the quarterly sampling information, the nitrate pumping system information
specifled in the CAP will be included in the quarterly reports
ATTACHMENT A
Weekly Inspection Form
Date
Weekly Inspection Form
Name
Time Well Depth* Comments
System Operational (if no note
any Drobiems/corrective actions)
MW-4 Flow Yes No
Meter Yes No
MW-26 Flow Yes No
Meter Yes No
TW4-19 Flow Yes No
Meter Yes No
TW4-20 Flow Yes No
Meter Yes No
TW4-4 Flow Yes No
Meter Yes No
TWN-2 Flow Yes No
Meter Yes No
TW4-22 Flow Yes No
Meter Yes No
TW4-24 Flow Yes No
Meter Yes No
TW4-25 Flow Yes No
Meter Yes No
Operational Problems (Please list well number).
Corrective Action(s) Taken (Please list well number).
* Depth IS measured to the nearest 0.01 feet
ATTACHMENT B
Monthly Depth Check Form
Monthly Depth Check Form
Date Name
Time Well Depth* Time Well Depth^
MW-4 TWN-1
TW4-1 TWN-2
TW4-2 TWN-3
TW4-3 TWN-4
TW4-4 TWN-7
TW4-5 TWN-18
TW4-6 MW-27
TW4-7 MW-30
TW4-8 MW-31
TW4-9 -
TW4-10
TW4-11
TW4-12
TW4-13
TW4-14
TW4-15
TW4-16
TW4-17
TW4-18
TW4-19
TW4-20
TW4-21
TW4-22
TW4-23
TW4-24
TW4-25
TW4-26
TW4-27
Comments: (Please note the well number for any comments)
Depth is measured to the nearest 0.01 feet
REDLINE
White Mesa MUl
Operations and Maintenance Plan
Nitrate Pumping System
Revision 4-2.0
State of Utah
Stipulation and Consent Order Docket Number UGW12-04
Prepared by
Energy Fuels Resources (USA) Inc.
225 Umon Boulevard, Suite 600
Lakewood, CO 80228
Jonuorv llMarch 21.2013
Table of Contents
1 0 INTRGDUCnON 1
2 0 OPERATIONS 2
2 1 Groundwater Pumping 2
2 2 Water Level Momtonng 2
2 3 Water Ouahtv Momtonng 2
3 0 DEFINrnON OF THE PUMPING SYSTEM
4 0 WINTERIZATION FOR LONG-TERM OPERATIONS
5 0 MAINTENANCE
6 0 MONITORING AND REPORTING
Operations and Maintenance Plan
Nitrate Pumping System
Revision 4-2 0
January llMarch21. 2013
1.0 INTRODUCTION
The Utah Department of Environmental Quality ("UDEQ") Division of Radiation Control
("DRC") noted in a Request dated September 30, 2008 (the "Request"), for a Voluntary Plan and
Schedule to Investigate and Remediate Nitrate Contamination at the White Mesa Uranium Mill
(the "Mill") (the "Plan"), that mtrate levels have exceeded the State water quality standard of 10
mg/L in certam momtonng wells m the perched groundwater zone As a result of the Request,
Energy Fuels Resources (USA) Inc ("EFRI") entered into a Supulated Consent Agreement (the
"Consent Agreement") with the Utah Water Quality Board in January 2009 which directed the
preparation of a Nitrate Contamination Investigation Report ("CIR") A subsequent letter dated
December 1, 2009, among other things, recommended tfiat EFRI also address elevated chlonde
concentration in the CIR The Consent Agreement ("CA") was amended in August 2011 Under
the amended Consent Agreement, EFRI submitted a Corrective Action Plan ("CAP"), pursuant
to the requu-ements of the Utah Groundwater Quality Protection Rules [UAC R317-6-6 15(C -
E)] on November 29, 2011 and revised versions of the CAP on February 27, 2012 and May 7,
2012 On December 12, 2012, DRC signed the Stipulation and Consent Order ("SCO"), Docket
Number UGW12-04, which approved the EFRI CAP, dated May 7, 2012 The SCO ordered
EFRI to fully implement all elements of the May 7, 2012 CAP
The CAP addresses mtrate + mtnte (as mtrate) (heretofore referred to as "mtrate") contamination
in the shallow perched groundwater zone at the Mill site It should be noted that while the CAP
requires momtonng of chlonde concentrations, the CAP does not specify measures for
controlling chlonde levels per se, because there is no health standard for chlonde in
groundwater However, as discussed and agreed to with DRC dunng meetings m October 2011,
chlonde appears to be co-located with mtrate in groundwater at the Mill and hydrogeological
measures to contam mtrate will also contain chlonde
I -The CAP descnbes a phased approach to the mtrate corrective actions The Phases descnbed m
the CAP are as follows
• Phase I will involve source control in the vicimty of the Mill's ammomum sulfate tanks,
• Phase n will mvolve active remediation of the mtrate contamination The active
remediation will be accomplished by pumping contaminated water^ into the Mill's
tailmgs ceUs for disposal or into the Mill as process water, combined with momtored
natural attenuation,
• Phase in, if necessary, will be at the discretion of EFRI and would involve a long term
solution for the mtrate contanunation, m the event that the contmuation of Phase n is not
considered adequate or appropnate
Phases I and n are addressed m the CAP and will commence as required by the schedule
delineated in the CAP Phase IE is not covered in detail in die CAP and, if determined to be
necessary, will be addressed in a separate CAP revision
1
Operations and Maintenance Plan
Nitrate Pumping System
Revision 42 0
Jonuorv llMarch21.2013
This Operations and Mamtenance ("O&M") Plan has been prepared to meet the requu-ements of
Phase n as descnbed m the CAP, Section 7 2 2 to address operations (including wintenzation
procedures), maintenance (mcluding inspection forms and response to and documentation of
system failures), momtonng and data reporting
2.0 OPERATIONS
2.1 Groundwater Pumping
Wells TW4-22, TW4-24, TW4-25, and TWN-2 will be pumped at the maximum practical rates
I Pumped water will be disposed m the taihngs cells or may be used for the Mill process water
The wellfield will be maintained as noted herem Momtonng will include pumping rates and
volumes for each well Monitonng will be documented on the Weekly Inspection Form included
as Attachment A to this O&M Plan
2.2 Water Level Monitoring
Water level momtonng will consist of weekly water level momtonng of pumping wells TW4-22,
TW4-24, TW4-25, and TWN-2, and, for the first twelve months after approval of the CAP,
monthly water level monitonng of non-pumped wells MW-27, MW-30, MW-31, TW4-21,
TWN-1, TWN-3, TWN-4, TWN-7, and TWN-18 Thereafter, water level momtonng of the non-
pumping wells will continue quarterly Water level momtonng will be documented on the
Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A and B
to this O&M Plan Water level contour maps of the data will be generated quarterly
2.3 Water Oualitv Monitoring
Water quality monitonng for pumped wells TW4-22, TW4-24, TW4-25, and TWN-2 will be
quarterly Samples will be analyzed for mtrogen (mtrate and nitnte as N) and chlonde Field
parameters will be recorded dunng the sampling as descnbed in the Mill's DRC-approved
Groundwater Quahty Assurance Plan ("QAP") Water quality momtonng will be reported and
documented in the quarterly nitrate reports submitted as descnbed in Section 5 0 of this O&M
Plan Water quahty momtonng for mtrate, chlonde, and field parameters for all other wells at the
site will continue at the frequency required under the Groundwater Discharge Permit ("GWDP")
or chloroform investigation, as apphcable
3.0 DEFINITION OF THE PUMPING SYSTEM
The pumping svstem used for Phase II is defined as follows
• Structure of the pumping wells includmg well casing, well slotted screen casing. •
sand/gravel pack, bentomte seal, cement grout seal, protective steel surface casing.
• Pump
-( Formatted Heading 1
Fomatted List Paragraph, Bulleted -i- Level 1
-I-Aligned at 0 25" + Indent at 0 5"
Operations and Maintenance Plan
Nitrate Pumping System
Revision 4-2 0
January llMarch21,2013
All structural matenals that hold the pump in place.
Electncal power for the pump and well heat lamps.
Electncal winng to the pump and well head heat lamps.
All hosmg. piping, and associated hose and pipe fittings from the pump, including
sampling ports, to discharge hose at the tailings cells.
• Temporary water storage tanks.
• Protective boxes over the well heads hned with msulatmg foam
4MS WINTERIZATION FOR LONG-TERM OPERATIONS
The foUowmg actions are implemented to provide continuous operations of the pumping well
system at the White Mesa Mill dunng cold weather conditions
1) Protective boxes are placed around the wellheads of the pumping wells The
protective boxes are hned with insulating foam and heat lamps are installed to
maintain the intenor of the box at a temperature above freezmg dunng the wmter
months Winter months are generally defined as the months of November
through March, but wintenzation of the pumpmg wells is maintained at any time
the outside air temperature is forecast to fall below 20° F for a duration of one (1)
day or more
2) The pump discharge from each of the pumping wells is connected to a 2-inch
polypropylene drain line, which discharges to the Mill process or to the tailings
cellsGeH-l Lines are protected from freezing by covenng them with a minimum
of 3 feet of soil to prevent freezing dunng the winter months This Imo is plooed m
on excovotod trench and tho linos ore covered with o mimmum of 3 foot of soil to
prevent froozmg dunng the wmtor months
3) Dunng winter weather with potentially freezing conditions (i e less than 20°F),
the radiation safety department staff observe the pumping daily to venfy that the
heat lamps remain ftinctional The Mill maintenance department is immediately
notified if anything unusual is noted with the system, or if a specific well has
encountered a problem
4) The protective features, discharge line placement and wmter inspections descnbed
m Items 1), 2), or 3) above will apply to not only the pumping wells currently m
operation, but will apply also to any fiiture pumping wells associated with the
mtrate pumpmg system
Operations and Maintenance Plan
Nitrate Pumping System
Revision 42 0
January llMarch21.2013
405.0 MAINTENANCE
The operation of each of the pumping wells is momtored on a daily basis dunng the winter under
potentially freezing conditions by the Envu-onment, Health and Safety Department Any
malfunction or abnormal operation of the pumping wells is immediately reported to the
Environment, Health and Safety Manager _Environment, Health and Safety Department
personnel will penodically inspect the pumps, flow meters and operational controls and perform
preventative maintenance to reduce the frequency of unscheduled down time of the pumpmg
system Spare pumps are maintamed m the Mill warehouse If a pump is replaced in any of the
wells a new spare is promptiy ordered When a system failure occurs and is not repaired and
fiilly made operational within 24 hours of discovery, EFRI will call the Du-ector of the Division
of Radiation Control ("Director"), or the Director's staff, to verbally report the system failure
and will report to the Director in a wntten report within 5 days of the failure A svstem failure is
defined as any downtime of a svstem component (as descnbed in Section 3 0) that (a) causes
cessation of the pumping of groundwater from the designated pumping wells, and (b) the
pumping of groundwater fi'om the designated pumping well is not restored and fully made
operational within 24 hours of discovery of the system failure A failure of any svstem
component which does not cause the cessation of pumping of groundwater from the designated
pumping wells or where pumping of groundwater from the designated pumping well is restored
and fiilly made operational within 24 hours of discovery, will not be considered a failure that is
reportable under this requirement For example, and without limiting the generality of the
foregoing, a failure of a component that can be rectified by re-routing the pumped water from the
tailings to the Mill process or vice versa, or by transporting the pumped water via portable tank
rather than pipeline, and which does not cause the pumping activities to be halted for more than
24-hours. would not be considered a reportable svstem failure
.Each wntten submission shall contain the following information
a) A descnption of the pumping system failiire(s) and their root causes
b) The penod of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational,
d) Steps taken or that will be taken to repair and have the system fully operational,
e) Steps taken or that will be taken to eliminate and prevent reoccurrence of system
failure (s)
In addition, all system failures will be reported m the next quarterly mtrate momtonng report
5,06:0 MONITORING AND REPORTING
Momtonng of the system by the Mill's Environment, Health and Safety Department occurs
weekly other than as noted above except for cold weather checks which are done daily dunng
freezing weather Monitonng includes well depths, flow rates, pump operating times and gallons
pumped These items are recorded on a weekly basis on the Weekly hispection Report included
as Attachment A to this Plan
Operations and Maintenance Plan
Nitrate Pumping System
Revision 4-2 0
January llMarch21.2013
On a quarterly basis, the mtrate investigation wells designated m the CAP are sampled for mti-ate
and chlonde These data, including copies of chain of custody forms and laboratory analytical
reports are included in the Quarterly Nitrate Reports, and are reported to the DRC according to
the following schedule
First Quarter - June 1
Second Quarter - September 1
Third Quarter - December 1
Fourth Quarter - March 1
In addition to the quarterly sampling mformation, the mtrate pumping system information
specified in the CAP will be included in the quarterly reports
ATTACHMENT A
Weekly Inspection Form
Date
Weekly Inspection Form
Name
Time Well Depth* Comments
Svstem Operational (if no note
anv problems/corrective actions)
MW-4 Flow Yes No
Meter Yes No
MW-26 Flow Yes No
Meter Yes No
TW4-19 Flow Yes No
Meter Yes No
TW4-20 Flow Yes No
Meter Yes No
TW4-4 Flow Yes No
Meter Yes No
TWN-2 Flow Yes No
Meter Yes No
TW4-22 Flow Yes No
Meter Yes No
TW4-24 Flow Yes No
Meter Yes No
TW4-25 Flow Yes No
Meter Yes No
Operational Problems (Please list well number)
Corrective Action(s) Taken (Please list well number)
* Depth IS measured to the nearest 0 01 feet
ATTACHMENT B
Monthly Depth Check Form
Monthly Depth Check Form
Date Name
Time Well Depth* Time Well Depth Well
MW-4
Depth* Time Well
TWN-1
TW4-1 TWN-2
TW4-2 TWN-3
TW4-3 TWN-4
TW4-4 TWN-7
TW4-5 TWN-18
TW4-6 MW-27
TW4-7 MW-30
TW4-8 MW-31
TW4-9
TW4-10
TW4-11
TW4-12
TW4-13
TW4-14
TW4-15
TW4-16
TW4-17
TW4-18
TW4-19
TW4-20
TW4-21
TW4-22
TW4-23
TW4-24
TW4-25
TW4-26
TW4-27
Comments: (Please note the well number for any comments)
Depth is measured to the nearest 0.01 feet
Letter to Rusty Lundberg
March 21, 2013
Page 5 of 5
APPENDIX 2
Clean and Redlme Copies of
Chloroform Pumping System Operations and Maintenance Plan
CLEAN
White Mesa Mill
Operations and Maintenance Plan
Chloroform Pumping System
Revision 2.2
Prepared by.
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 21,2013
Contents
1.0 INTRODUCTION
2 0 OPERATIONS
2.1 Groundwater Pumping
2 2 Water Level Monitoring
2.3 Water Quality Monitonng
3.0 DEFINITION OF THE PUMPING SYSTEM
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS.
5.0MAINTANENCE
6 0 MONITORING AND REPORTING
... 1
2
2
. . . 2
2
3
. . .3
4
.. 5
) Operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
1.0 INTRODUCTION
The presence of chloroform was initially identified in groundwater at the White Mesa
Mill (the "Mill") as a result of split sampling performed in May 1999. The discovery
resulted in the issuance of State of Utah Notice of Violation ("NOV") and Groundwater
Corrective Action Order ("CAO") State of Utah Department of Environmental Quality
("UDEQ") Docket No UGW-20-01, which required that Energy Fuels Resources (USA)
Inc. ("EFRI") subnut a Contamination Investigation Plan and Report pursuant to the
provisions of UAC R317-6-6 15(D).
EFRI developed a Conective Action Plan ("CAP") for the chloroform investigation area.
The CAP specified the removal of chloroform by pumping areas that have higher
concentration of chloroform and high productivity
Beginning m Apnl of 2003 a long-term pumping test was started in the area of the
chloroform investigation with the pumping from wells MW-4 and TW4-19 Initially the
pump discharge was routed to temporary holding tanks located next to each well. Water
pumped to the tanks was penodically removed and transported to Tailings Cell 1 for
disposal. Later, discharge lines were extended directly to Cell 1
On August 8, 2003, pumping was started from MW-26 (formeriy TW4-15). To date,
water from this well has been routed to Cell 1
In late November 2003, pumping from all of the wells was stopped suddenly due to the
freezing of the discharge pipelines. The long term pumping test was essentially complete
when the system was shut down in November 2003. Pumping from all three of the wells
was restarted in August of 2004
After re-start of the pumping, preparations were made to winterize the installations in
order to prevent a re-occurrence of the problems encountered dunng the winter of 2003.
In August 2005, pumping of well TW4-20 was started and to date, the water from this
well has been pumped to Cell 1.
In January, 2010, pumping was started from TW4-4. Water from this well has also been
routed to Cell 1.
Based on discussions with DRC on February 11, 2013 (documented by e-mail on
February 13, 2012) and March 7, 2013 the requirements to transfer pumped groundwater
to the tailings cells includes pumping and re-use in the Mill process which discharges to
the taihngs cells This Operations and Maintenance Plan (O&M Plan) has been revised
to include transfemng pumped groundwater to the Mill process followed by discharge to
the tailings cells.
1
operations and Maintenance Plan
Chloroform Pumping System Revision 2 2
March 21, 2013
This operations and maintenance plan is required for all pumpmg wells approved by the
Director associated with the chloroform pumping system.
2.0 OPERATIONS
2.1 Groundwater Pumping
Wells MW-04, MW-26, TW4-04, TW4-19, and TW4-20, will be pumped at the
maximum practical rates Pumped water will be disposed in the tailings cells or may be
used for the Mill process water. The wellfield will be maintained as noted herein
Monitoring will include pumping rates and volumes for each well Monitonng will be
documented on the Weekly Inspection Form included as Attachment A to this O&M
Plan.
2.2 Water Level Monitoring
Water level monitonng will consist of weekly water level monitonng of pumping wells
MW-04, MW-26, TW4-04, TW4-19, and TW4-20 and monthly water level momtonng in
dl chloroform program wells. Water level monitonng will be documented on the
Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A
and B to this O&M Plan Water level contour maps of the data will be generated
quarterly
2.3 Water Quality Monitoring
Water quality monitonng for for all wells m the chloroform program will be quarterly
Samples will be analyzed for Volatile chloroform, dichloromethane, chloromethane, and
carbon tetrachlonde, nitrogen (nitrate and nitnte as N) and chlonde. Field parameters will
be recorded dunng the sampling as descnbed m the Mill's DRC-approved Groundwater
Quality Assurance Plan ("QAP"). Water quality monitonng will be reported and
documented in the quarterly reports submitted as descnbed in Section 5.0 of this O&M
Plan. Water quality monitonng for the foregoing constituents and field parameters for all
other wells at the site will continue at the frequency required under the Groundwater
Discharge Permit ("GWDP") or nitrate program, as applicable.
operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
3.0 DEFINITION OF THE PUMPING SYSTEM
The pumping system used for the chloroform program is defined as follows*
• Structure of the pumping wells including* well casing, well slotted screen casing,
sand/gravel pack, bentonite seal, cement grout seal, protective steel surface
casing;
• Pump
• All structural matenals that hold the pump in place,
• Electncal power for the pump and well heat lamps,
• Electrical winng to the pump and well head heat lamps;
• All hosing, piping, and associated hose and pipe fittings from the pump, mcluding
sampling ports, to discharge hose at the tailings cells;
• Temporary water storage tanks;
• Protective boxes over the well heads lined with insulating foam.
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS
The following actions are implemented to provide continuous operations of the pumpmg
well system at the White Mesa Mill dunng cold weather conditions.
1) Protective boxes are placed around the wellheads of the five (5) pumping
wells The protective boxes are lined with insulating foam and heat lamps
are installed to ensure that the intenor of the box is maintained at a
temperature above freezing dunng the winter months Winter months are
generally defined as the months of November through March, but
wintenzation of the pumping wells is maintamed at any time the outside
air temperature is forecast to fall below 20° F for a duration of one (1) day
or more.
2) The pump discharge from each of the pumping wells is connected to a 2-
inch polypropylene drain line, which discharges to the Mill process or the
tailings cells Lines are protected from freezing by covenng them with a
mimmum of 3 feet of soil to prevent freezing dunng the winter months
3) Dunng winter weather with potentially freezing conditions (i.e less than
20°F), the radiation safety department staff, observe the pumping daily to
ensure that the heat lamps remain functional. The Mill maintenance
department is immediately notified if anything unusual is noted with the
system, or if a specific well has encountered a problem.
operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
4) The protective features, discharge line placement and winter inspections
descnbed m items 1), 2), or 3) above will apply to not only the (5)
pumping wells cunently in operation, but will apply also to any future
pumping wells associated with the chloroform pumping system
5.0 MAINTANENCE
The operation of each of the pumping wells is monitored on a daily basis dunng the
winter under potentially freezing conditions by the Environmental Health and Safety
Department. Any malfunction or abnormal operation of the pumping wells is
immediately reported to the Environmental Health and Safety Department.
Environmental Health and Safety Department personnel will penodically inspect the
pumps, flow meters and operational controls and perform preventative maintenance to
reduce the frequency of unscheduled down time of the pumping system. Spare pumps
are maintained m the Mill warehouse If a pump is replaced in any of the wells a new
spare is promptly ordered. When a system failure occurs and is not repaired and fully
made operational within 24 hours of discovery, DUSA shall call the Director or the
Director's staff, to verbally report the system failure and will report to the Director in a
wntten report within 5 days of the failure. A system failure is defined as any downtime
of a system component (as descnbed in Section 3.0) that (a) causes cessation of the
pumping of groundwater from the designated pumping wells, and (b) the pumping of
groundwater from the designated pumping well is not restored and fully made operational
within 24 hours of discovery of the system failure A failure of any system component
which does not cause the cessation of pumping of groundwater from the designated
pumping wells or where pumping of groundwater from the designated pumping well is
restored and fully made operational within 24 hours of discovery, will not be considered
a failure that is reportable under this requirement For example, and without liimting the
generality of the foregoing, a failure of a component that can be rectified by re-routmg
the pumped water from the tailings to the Mill process or vice versa, or by transporting
the pumped water via portable tank rather than pipeline, and which does not cause the
pumping activities to be halted for more than 24-hours, would not be considered a
reportable system failure.
Each wntten submission shall contain the following information:
a) A descnption of the pumping system failure(s) and their root causes
b) The penod of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational;
d) Steps taken or that will be taken to repair and have the system fully
operational,
e) Steps taken or that will be taken to ehminate and prevent reoccurrence of
system failure (s)
operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
f) Each system failure and corrective actions, listed above, will be summanzed
in the corresponding quarterly chloroform groundwater monitonng reports
In addition, all system failures will be reported in the following quarterly chloroform
groundwater monitonng report.
6.0 MONITORING AND REPORTING
Momtonng of the system by the Mill's Environmental Health and Safety Department
occurs weekly and includes well depths, flow rates, pump operating times and gallons
pumped These items are recorded on a weekly basis on the Weekly Inspection Form
included as Attachment A.
On a quarterly basis, all chloroform investigation wells are sampled for chloroform,
mtrate+mtnte, dichloromethane, chloromethane, chlondeand carbon tetrachlonde. These
data, including copies of chain of custody forms and laboratory analytical reports, are
reported to the DRC concurrent with the schedule for subnussion of Quarterly
Groundwater Momtonng Reports, and according to the following schedule.
First Quarter - June 1
Second Quarter - September 1
Third Quarter - December 1
Fourth Quarter - March 1
In addition to the quarterly sampling information, the following information regarding the
chloroform pumping system, is included m the quarterly reports
1) Description of the pumping operations mcluding any operational problems
encountered during the quarter.
2) Flow rates and total gallons pumped for the quarter.
3) Histoncal gallons pumped to date.
4) Updated water level contour map for the site indicating cones of depression
from the pumping and an evaluation of the potential of the pumping to
hydraulically capture the chloroform plume.
5) Any additions, modifications or observations dunng the quarter
6) Suggestions for changes or modifications to the pumping system.
7) Weekly Inspection Form.
operations and Maintenance Plan
Chloroform Pumping System Revision 2 2
March 21, 2013
ATTACHMENT A
Weekly Inspection Form
Date
Weekly Inspection Form
Name
Svstem Operational (if no note
MW-4 Flow Yes No
Meter Yes No
MW-26 Flow Yes No
Meter Yes No
TW4-19 Flow Yes No
Meter Yes No
TW4-20 Flow Yes No
Meter Yes No
TW4-4 Flow Yes No
Meter Yes No
TWN-2 Flow Yes No
Meter Yes No
TW4-22 Flow Yes No
Meter Yes No
TW4-24 Flow Yes No
Meter Yes No
TW4-25 Flow Yes No
Meter Yes No
Operational Problems (Please list well number)
Corrective Action(s) Taken (Please list well number)
Depth IS measured to the nearest 0 01 feet
operations and Maintenance Plan
Chloroform Pumping System Revision 2.2
March 21, 2013
ATTACHMENT B
Monthly Depth Check Form
Monthly Depth Check Form
Date Name
Time Well Depth* Time Well Depth^
TWN-1
Well
MW-4
TW4-•1
TW4-•2
TW4-•3
TW4-•4
TW4-•5
TW4-•6
TW4-•7
TW4-•8
TW4-•9
TW4-•10
TW4-•11
TW4-•12
TW4-•13
TW4--14
TW4-•15
TW4-•16
TW4-•17
TW4-•18
TW4-•19
TW4-•20
TW4-•21
TW4-•22
TW4-•23
TW4-•24
TW4-•25
TW4-•26
TW4-•27
TWN-2
TWN-3
TWN-4
TWN-7
TWN-18
MW-27
MW-30
MW-31
Comments: (Please note the well number for any comments)
Depth is measured to the nearest 0.01 feet
REDUNE
White Mesa Mill
Operations and Maintenance Plan
Chloroform Pumping System
Revision 2.2
Prepared by
Energy Fuels Resources (USA) Inc.
225 Umon Boulevard, Suite 600
Lakewood, CO 80228
March 21,2013
Contents
10 INTRODUCTION , 1
2 0 OPERATIONS 2
2 1 Groundwater Pumping 2
2 2 Water Level Momtonng 2
2 3 Water Ouahtv Monitonng , 2
3 0 DEFINITION OF THE PUMPING SYSTEM 3
4 0 WINTERIZATION FOR LONG-TERM OPERATIONS 3
5 0 MAINTANENCE , 5
6 0 MONITORING AND REPORTING 6
Operations and Maintenance Plan
Chloroform Pumping System Revision 2 2
March 21.2013
1.0 INTRODUCTION
The presence of chloroform was initially identified in groundwater at the White Mesa
Mill (the "Mill") as a result of split samphng performed in Mav 1999 The discovery
resulted in the issuance of State of Utah Notice of Violation ("NOV") and Groundwater
Corrective Action Order ("CAO") State of Utah Department of Environmental Quality
("UDEQ") Docket No UGW-20-0L which required that Energy Fuels Resources (USA)
Inc ("EFRI") submit a Contamination Investigation Plan and Report pursuant to the
provisions of UAC R317-6-6 15(D)
EFRI developed a Corrective Action Plan ("CAF') for the chloroform investigation area •
The CAP specified the removal of chloroform bv pumping areas that have higher
concentration of chloroform and high productivity
Beginmng in Apnl of 2003 a long—term pumping test was started in the area of the
chloroform investigation with the pumping from wells MW-4 and TW4-19 Imtially the
pump discharge was routed to temporary holding tanks located next to each well Water
pumped to the tanks was penodically removed and transported to Taihngs Cell 1 for
disposal Later, discharge lines were extended durectly to Cell 1
On August 8, 2003, pumping was started from MW-26 (formeriy TW4-15) To date.
Wwater from this well M-atsehas been routed to Cell 1 through a dischorgo pipolmo
In late November 2003, pumping from all of the wells was stopped suddenly due to the
freezmg of the discharge pipehnes The long term pumping test was essentially complete
when the system was shut down m November 2003 Pumping from all three of the wells
was restarted in August of 2004
After re-start of the pumpmg, preparations were made to wintenze the installations in
order to prevent a re-occurrence of the problems encountered dunng the winter of 2003
In August 2005, pumping of well TW4-20 was started wife-and to date, the water fi-om
this well has been also being pumped to Cell 1
In January, 2010, pumping was started from TW4-4 Water from this well ts-has also
been €^se-routed to Cell 1 through a discharge pipohno
Based on discussions with DRC on February 11. 2013 (documented bv e-mail on
February 13.2012) and March 7.2013 the requu-ements to transfer pumped groundwater
to the tailings cells includes pumping and re-use in the Mill process which discharges to
the taihngs cells This Operations and Maintenance Plan (O&M Plan) has been revised
to include transfemng pumped groundwater to the Mill process followed bv discharge to
the taihngs cells
1
-(Formatted Justified
-( Formatted Left
Operations and Maintenance Plan
Chloroform Pumping Svstem Revision 2 2
March 21.2013
This operations and maintenance plan is required for all pumpmg wells approved by the*-
ExooutivG SocrctarvDirector associated with the chloroform pumping system
2.0 OPERATIONS
-{ Formatted Justified
2.1 Groundwater Pumping
Wells MW-04. MW-26. TW4-04. TW4-19. and TW4-20. will be pumped at the
maximum practical rates Pumped water will be disposed m the tailings cells or mav be
used for the Mill process water The wellfield vyill be maintained as noted herein
Momtonng will include pumping rates and volumes for each well Monitonng will be
documented on the Weekly Inspection Form included as Attachment A to this O&M
Plan
2.2 Water Level Monitoring
Water level momtonng will consist of weekly water level monitonng of pumping wells
MW-04. MW-26. TW4-04. TW4-19. and TW4-20 and monthly water level momtonng in
all chloroform program wells Water level momtonng will be documented on the
Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A
and B to this O&M Plan Water level contour maps of the data will be generated
quarterly
2.3 Water Quality Monitoring
Water quahtv monitoring for for all wells in the chloroform program will be quarterly
Samples will be analyzed for Volatile chloroform, dichloromethane. chloromethane, and
carbon tetrachlonde. mtrogen (nitrate and nitnte as N) and chlonde Field parameters will
be recorded dunng the samphng as descnbed in the Mill's DRC-approved Groundwater
Quality Assurance Plan ("QAP") Water quality momtonng will be reported and
documented m the quarterly reports submitted as descnbed in Section 5 0 of this Q&M
Plan Water quality momtonng for the foregoing constituents and field parameters for all
other wells at the site will continue at the frequency required under the Groundwater
Discharge Permit ("GWDF') or mti-ate program, as apphcable
-( Formatted Space Before 12 pt
Operations and Maintenance Plan
Chloroform Pumping System Revision 2 2
March 21.2013
3.0 DEFINITION OF THE PUMPING SYSTEM
The pumping system used for the chloroform program is defined as follows
• Structure of the pumpmg wells including well casing, well slotted screen casing,
sand/gravel pack, bentonite seal, cement grout seal, protective steel surface
casing,
• Pump
• All structural matenals that hold the pump in place,
• Electncal power for the pump and well heat lamps,
• Electncal winng to the pump and well head heat lamps,
• All hosing, piping, and associated hose and pipe fittings from the pump, including
samphng ports, to discharge hose at the tailings cells.
• Temporary water storage tanks.
• Protective boxes over the well heads hned with insulating foam
4.0 WINTERIZATION FOR LONG-TERM OPERATIONS * -(Forniatted Heading i
The followmg actions are implemented to provide continuous operations of the pumping
well system at the White Mesa Mill dunng cold weather conditions
1) Protective boxes are placed around the wellheads of the five (5) pumping
wells The protective boxes are hned with msulating foam and heat lamps
are installed to ensure that the intenor of the box is maintained at a
temperature above freezing dunng the winter months Winter months are
generally defined as the months of November through March, but
wintenzation of the pumping wells is maintained at any time the outside
air temperature is forecast to fall below 20° F for a duration of one (1) day
or more
2) The pump discharge from each of the pumping wells is connected to a 2-
mch polypropylene drain line, which discharges to CeH-khe Mill process
or the tailings cells This-flimes w-are protected from freezing by ^aeed
m an excavated trench and tho hnes oro covered covenng them with a
mimmum of 3 feet of soil to prevent freezing dunng the winter months
3) Dunng vvinter weather with potentially freezing conditions (i e less than
20°F), the radiation safety department staff, observe the pumping daily to
ensure that the heat lamps remain functional —The Mill maintenance
department is immediately notified if anything unusual is noted with the
system, or if a specific well has encountered a problem
4) The protective features, discharge hne placement and winter inspections
descnbed in items 1), 2), or 3) above will apply to not only the (5)
Operations and Maintenance Plan
Chloroform Pumping Svstem Revision 2 2
March 21.2013
pumping wells currently in operation, but will apply also to any future
pumpmg wells associated with the chloroform pumping system
OPERATIONS — - H Fonnatted Heading 1
Pumping wells MWl, MW 26, TW1 19 and TW'I 20 were onginolly opcmtod dunng the
long term pumping test at a constant flow rote adjusted to allow for maximum drawdown
of tho well This noccssitatod that each of tho pumps bo volvcd back to maintain thc
drawdown at a pro determined level This resulted in opomtmg tho pumps ot a very low
flow rote, which subsequently caused each of the pumps to pro maturely foil
When the pumps were re started m August of 2004, coeh of thc pumpo wos allowed to
opemte at a higher flow mtc, which allowed for full draw down, at which time thc pump
was shut down by thc mtomol safety fcaturoo After thc well hod recharged tho pump
outomaUcolly rc started Thc pump for TW^ 1, mstoUcd and started up m January 2010,
operates similarly
Operations and Maintenance Plan
Chloroform Pumping Svstem Revision 2 2
March 21,2013
5.0 MAINTANENCE *- - - -{ Fonnatted Heading 1
The operation of each of the pumping wells is momtored on a daily basis dunng the
winter under potentially freezing conditions by the Envu-onmental Health and Safety
Department Any malfunction or abnormal operation of the pumping wells is
immediately reported to the Environmental Health and Safety Department—
Envu-onmental Health and Safety Department personnel will penodically inspect the
pumps, flow meters and operational controls and perform preventative maintenance to
reduce the frequency of unscheduled down time of the pumping system A-sSpare pumps
<s-are maintained in the Mill warehouse If a pump is replaced in any of the wells a new
spare is promptly ordered When a system failure occurs and is not repau-ed and fully
made operational withm 24 hours of discovery, DUSA shall call the Executive
SecrotorvDirector or the Director's staff, to verbally report the svstem failure and will
report to the Director in a wntten report within 5 days of the failure A svstem failure is
defined as any downtime of a system component (as descnbed m Section 3 0) that (a)
causes cessation of the pumping of groundwater from the designated pumping wells, and
(b) the pumping of groundwater from the designated pumping well is not restored and
fully made operational withm 24 hours of discovery of the svstem failure A failure of
anv system component which does not cause the cessation of pumping of groundwater
from the designated pumping wells or where pumping of groundwater from the
designated pumping well is restored and fully made operational within 24 hours of
discovery, will not be considered a failure that is reportable under this requirement For
example, and without lirmting the generality of the foregoing, a failure of a component
that can be rectified by re-routing the pumped water from the tailings to the Mill process
or vice versa, or bv transporting the pumped water via portable tank rather than pipehne.
and which does not cause the pumping activities to be halted for more than 24-hours,
would not be considered a reportable svstem failure to vorbollv report tho svstem failure
and will report to the Executive secretory in a wntten report within 5 days of thc fmlurc
Each wntten submission shall contain the following information
a) A descnption of the pumping system failure(s) and theu- root causes
b) The penod of time that the system was not or will not be in operation
c) The date by which the pumping system will be repaired and fully operational,
d) Steps taken or that will be taken to repau- and have the system fully
operational,
e) Steps taken or that will be taken to ehnunate and prevent reoccurrence of
system failure (s)
f) Each system failure and corrective actions, hsted above, will be summanzed
in the corresponding quarterly chloroform groundwater momtonng reports
In addition, all system failures will be reported in the following quarterly chloroform
groundwater momtonng report
Operations and Maintenance Plan
Chloroform Pumping System Revision 2 2
March 21.2013
6.0 MONITORING AND REPORTING • -( Formatted Heading 1
Momtonng of the system by the Mill's Envu-onmental Health and Safety Department
occurs weekly and includes well depths, flow rates, pump operating times and gallons
pumped These items are recorded on a weekly basis on the Weekly Inspection
RepOFtForm included as Attachment A
On a quarterly basis, all chloroform investigation wells are sampled for chloroform,
mtrate+mtiite, dichloromethane, chloromethane, chlonde-and carbon tetrachlonde This
These data, includmg copies of chain of custody forms and laboratory analytical reports,
ts-are reported to the DRC concurrent with the schedule for submission of Quarterly
Groundwater Momtonng Reports, and according to the following schedule
First Quarter - June 1
Second Quarter - September 1
Third Quarter - December 1
Fourth Quarter - March 1
In addition to the quarterly samphng information, the following information regarding the
chloroform pumping system, is included in the quarterly reports
1) Descnption of the pumping operations including any operational problems
encountered dunng the quarter
2) Flow rates and total gallons pumped for the quarter
3) Histoncal gallons pumped to date
4) Updated water level contour map for the site indicating cones of depression
from the pumping and an evaluation of the potential of the pumping to
hydraulically capture the chloroform plume
5) Any additions, modifications or observations dunng the quarter
6) Suggestions for changes or modifications to the pumping system
7) Weekly Chloroform-Inspection Form
ATTACHMENT A * ~ ~ -{ Formatted Vertical Alignment CenteT
Weekly Inspection Form
Date
Weekly Inspection Form
Name
Time Well Depth^ Comments
Svstem Operational (if no note
anv problems/corrective actions)
MW-4 Flow Yes No
Meter Yes No
MW-26 Flow Yes No
Meter Yes No
TW4-19 Flow Yes No
Meter Yes No
TW4-20 Flow Yes No
Meter Yes No
TW4-4 Flow Yes No
Meter Yes No
TWN-2 Flow Yes No
Meter Yes No
TW4-22 Flow Yes No
Meter Yes No
TW4-24 Flow Yes No
Meter Yes No
TW4-25 Flow Yes No
Meter Yes No
Operational Problems (Please list well number).
Corrective Action(s) Taken (Please list well number)
Depth IS measured to the nearest 0 01 feet
ATTACHMENT B
Monthly Depth Check Form
Monthly Depth Check Form
Date Name
Time Well Depth* Time Well Depth^
MW-4 TWN-1
TW4-1 TWN-2
TW4-2 TWN-3
TW4-3 TWN-4
TW4-4 TWN-7
TW4-5 TWN-18
TW4-6 MW-27
TW4-7 MW-30
TW4-8 MW-31
TW4-9
TW4-10
TW4-11
TW4-12
TW4-13
TW4-14
TW4-15
TW4-16
TW4-17
TW4-18
TW4-19
TW4-20
TW4-21
TW4-22
TW4-23
TW4-24
TW4-25
TW4-26
TW4-27
Comments: (Please note the well number for any comments)
* Depth is measured to the nearest 0.01 feet