DRC-2014-003601 - 0901a068804400b0

ENERGYFUELS DRC-2014-003601
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
May 21, 2014
Sent VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") April 10, 2014 Request for Information
("RFI"), the EFRI December 23, 2013 White Mesa Mill Proposal for Remediation of Nitrate
Contaminated Soils Phase I of the Final Nitrate Corrective Action Plan
Dear Mr. Lundberg:
This letter responds to DRC's above-named letter dated April 10, 2014, which Energy Fuels Resources
(USA) Inc. ("EFRI") received on April 17, 2014, regarding the DRC review ofthe December 23, 2013 White
Mesa Mill Proposal for Remediation of Nitrate Contaminated Soils Phase I of the Final Nitrate Corrective
Action Plan.
For ease of review, this letter provides each of DRC's comments verbatim, below, followed by EFRI's
response.
Request for Information
DRC Comment — Page 2, Second Full Paragraph
Nitrate concentrations extend northeast from the ammonium sulfate crystal tanks toward the area ofthe grizzly
with relatively high concentrations extending as far northeast as P9C-01 (12.4 mg/kg, Lab Sample ID 1306183-
031). DRC notes that these areas are located on a sloped area which drains south towards the mill building. In
order to provide corrective action to prevent infiltration from these areas with higher than surrounding soil
nitrate concentrations, DRC recommends that the plotted area for concrete installation be extended north to
include these areas (concrete to extend north to soil boring P9C-01) or that other engineering solutions be
employed to ensure that no surface water is impounded in this area (e.g. temporary impoundment from storm
water runoff). This would essentially address all areas with nitrate soil concentrations greater than 10 mg/kg.
EFRI Response
As noted during the April 8, 2014 conference call and in the comment above, the area in question is sloped
toward the Mill building at approximately an 8% grade. Due to the existing topography, impounding or
infiltration is not likely to occur. EFRI will maintain the exiting grade and has integrated the runoff from the
existing slope into the cover design (see revised Figures 1 and 2). Storm water from the slope will be managed
by directing it to the northern border of the concrete pad where it will flow onto the concrete pad and be
directed either into the Mill building or to the storm water inlet located on the southern end of the concrete pad.
Letter to Rusty Lundberg
May 21, 2014
Page 2
DRC Comment -Page 2. Third Full Paragraph
Attachment 4-1 of the Phase 1 Study is an aerial map depicting the area of the proposed concrete cover and
areas of existing asphalt which are proposed to be left in place. Per DRC review of the Phase 1 Report and
proposed area of concrete cover it was noted that several improvements regarding engineering specifications,
engineering annual inspections, and additional area of concrete cover (based on high soil concentrations of
nitrate) need to be included.
EFRI Response
Changes to Figures 1 and 2 have been made in response to on-site meetings and discussions between DRC
Personnel and EFRI Personnel. The updated Figures 1 and 2 are included as Appendix 1 to this letter.
DRC Comment -Page 2. Fourth Full Paragraph
It was noted during DRC inspections of the existing concrete and asphalt that significant erosion, cracking and
spalling has occurred and it has been noted during past inspections that the storm drain located on the east
side of the Mill building does not drain correctly. It appears that drainage moves from south to north and that
storm water and wash water pool around the north portion of the drain system. Based on these findings the
concrete drainage needs to be replaced or repaired/reconstructed such that these drainage issues are
corrected.
EFRI Response
The existing concrete and asphalt that will be retained (as shown on Figures 1 and 2) will be inspected for
spalling and erosion. Repairs will be made as necessary and as practicable. Areas that cannot be repaired will
be replaced. Inspections and repair/replacement will be completed during the field work associated with the
installation of the new concrete cover.
The storm drain was surveyed to determine the elevation and grade of the existing concrete channel. The
survey indicated that the drainage moves from north to south but at a very shallow grade. Additional concrete
will be placed on the existing channel to increase the slope to approximately 1.0% to improve the drainage.
DRC Comment -Page 2. Fifth Full Paragraph
Per DRC review of the Phase I Report, EFR will provide grading such that drainage from the concrete cover is
interior to the mill building process drains, however, the Phase I Report does not clearly identify how storm
water and process water drainage within this area will be managed to provide efficient drainage and ensure
that ponding does not occur. Additionally, as discussed above, areas of existing concrete and asphalt with are
planned to be kept are in disrepair and are incorrectly graded for efficient drainage as discussed above.
EFRI Response
As shown on Figures 1 and 2, only a small portion of the drainage from the concrete cover will be managed by
diversion into the Mill building. Drainage from the concrete cover to the interior of the Mill building will be
managed in the areas directly under the ammonium sulfate tanks and across the existing concrete under the pulp
storage tanks. The sumps in the Mill building have sufficient capacity to accept this runoff. Once inside the
Mill building, the water is collected in sumps and is used as process water.
Letter to Rusty Lundberg
May 21, 2014
Page 3
As discussed above, the eXlstmg concrete and asphalt will be inspected and repaired and/or replaced as
necessary. The concrete cover will address any drainage issues previously identified.
DRC Comment -Page 3
The Phase I Report needs to include the following items.
• Elevation contours for the concrete cover need to be included,
• Elevation contours for soil areas need to be included,
• Drainage direction arrows (for the concrete pad) need to be included,
• Drainage inlets and discharge locations need to be included,
• Specifications for concrete seam sealing needs to be included with the attachment
• Specifications for curbing around the margin of the concrete (or other design) needs to be
included,
• Specifications for storm water run-on control needs to be included.
EFRI Response
• Elevation contours were added to the concrete cover shown in Figures 1 and 2, included as Appendix 1
of this letter.
• Elevation contours were added to the soil areas shown in Figures 1 and 2, included as Appendix 1 of this
letter.
• Drainage direction arrows (for the concrete pad) were added to the concrete pad shown in Figures 1 and
2, included as Appendix 1 of this letter.
• The existing storm water inlet and associated discharge will be retained and will remain in place with no
changes. The current discharge to Cell 1 will be retained.
• Specifications for concrete seam sealing are included as Appendix 2 to this letter. The seam sealing
product used during construction will be the same as, or equivalent to, the product specified in Appendix
2, depending upon availability. The number and location of the expansion joints in the proposed concrete
cover will be provided in the engineering drawings submitted to DRC for approval prior to construction.
• Curbing will not be placed around the margins of the concrete to allow for the unrestricted flow of
surface water onto the concrete cover to preclude pooling of surface water at the margins of the concrete.
The retaining walls shown on Figure 2 at the Old Decontamination Pad and the VPL storage tanks will
be 8-inch thick reinforced concrete, 4 feet in height. Specific details regarding the retaining walls will
be provided in the engineering drawings submitted to DRC for approval prior to construction.
• Storm water run-on controls -up gradient storm water will be allowed to flow onto the concrete cover
and continue to the storm water inlet. No storm water run-on controls are necessary (excluding the VPL
secondary containment structureslbasin).
DRC Comment -Page 3. Second Full Paragraph
Attachment 5 of the Phase I Report includes EFR redline changes to the White Mesa Mill Discharge Monitoring
Technology ("DMT") Plan for Concrete and Asphalt Inspection and Maintenance (EFR Revision 12.2).
Attachment 5 also includes changes to the DMT inspection form for the annual decontamination lammonium
sulfate inspection to include the new concrete cover area. DRC had the following request for information
regarding the DMT inspections:
Letter to Rusty Lundberg
May 21, 2014
Page 4
• The frequency of the proposed DMT Plan changes is annually as included on the revised DMT
inspection form, per discussion during an April 8,2014 conference call the frequency needs to be
quarterly (at least initially to determine concrete and seam integrity and to insure that drainage is
occurring per specifications of the plan).
EFRI Response
The frequency of the inspections will be quarterly for the first eight quarters and annually thereafter. A revised
redline version of the DMT Plan, Revision 12.2 dated May 2014, which includes revised Inspection Forms is
included as Appendix 3 to this letter.
Please contact me if you have any questions or require any further information.
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
Appenclix 1
01 ~ "'C .n
c ,g
§! a o x CD
~ E 5 c o .,
§! a II CD
~ ~ ~ c '0. Q. a E ~ ? .B ~ II)
I
30
I
existing Contour
1 and 5 fool
Ammonia Contc: I lina\ic)n
(bhallow Middl~l clfld Dt1Bp)
~ LxlSI1I1g J\sptl~ II (Keep)
~ Exl~lh Ig A phail (Ilernov·.)
EXIsting Concrete (Keep)
I:::'>USlll1g Concrete (nernove)
N
s 15 o 30
1 ! 1
SCALE I N FEET
60
!
>5I!F Energy Fuels Resources (USA) Inc.
REVISIONS Project White Mesa Mill
Date By County: San Juan tate: Utah
Location:
Figure 1
Ammonia Contaminated Area
Existing Conditions
? ~ ~ ______________________________________________________________________________________________________________________________________________ J __ ~~ __ .. ~A_ut_ho_r·~R~JE~ __ ~ __ ~~~ __ ~Dr_aft_OO_B_y:~RJ~E __ ~
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'-" ...... ~'''.,ium Sulfate Tanks
-----------..... =------
~,0r:)t(OI Station
-2,2%
-2,2%
---~/o
o Tanks Secontl ry Co tainment
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5240
30 15
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Existing Contours
1 and 5 foot
Ammonia ContalTl irlation
(Shall ow, Middle and Deep)
Existing Asphalt U<eep)
Existing Concrete (Keep)
F)lanned Concrete
N
VI I!.
s o 30
! !
SCALE IN FEET
60
!
~ Energy Fuels Resources (USA) Inc.
White Mesa Mill
tate: Utah
Figure 2
Ammonia Contaminated Area
Planned Concrete Placement t L ./ ~--------- - - -Aulhor. RJE ale: 5/8/14 Drafted BY:RJE ~ L-____________________________________________________________________________________________________________________________________________ ~ __ ~~ __ ~~ ____ ~~~~ __ ~ ________ ~
Appendix 2
WATERS TOP -RX® -Expanding Waterstops for Concrete Construction Joints
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WATERSTOP -RX®
Expanding Waterstops for Concrete Construction Joints
Waterslop-RX is a flexible strip concrete construction joint waterstop that provides a
positive seal by expanding upon contact with water. Walerstop-RX is an aclive waterstop
that functionally replaces conventional passive PVC dumbbell waterstops. Waterstop-RX
is designed for both continuous and intermittenl hydroslatic conditions and has been
successfully tested to resist 231 feet (70 m) of hydrostatic pressure.
The key to the effectiveness of Waterstop-RX is its high sodium bentonite content which
provides superior expansion to seal cracks and fill small voids. Proven effective on
projects worldwide for over 20 years, Waterstop-RX is a reliable and cost-effeclive
solution to preventing water infiltration through concrete joints.
Installation is fast and easy, Simply adhere Waterstop-RX to the concrete. steel, or PVC
(pipes) with CETSEAL Adhesive and then pour the concrete. Waterslop-RX reduces labor
cosls by eliminaling lhe workmanship rigors of welding the joints or split-fanning
associaled wilh lraditional PVC dumbbell type waterstops Walerslop-RX can also be
used to provide protection when conventional PVC waterstop has been installed wilhout
the joints welded.
Three different sizes and profiles are available to match to you specific project needs: RX-
101, RX-IOtT, and RX-I02. Waterstop-RX 101 is the largest profile with a rectangular
crosS section of I" by'"," (25 x 19 mm). Waterstop-RX 10tT is a I-'!." by 'h" lrapezoidal
shape profile with a reinforcing poly scrim embedded in lhe surface. The patented
trapezoidal shape of RX-IOIT distributes the expansion pressures over a greater area
and the reinforcing scrim provides additional product slability when concrete is placed.
Waterslop-RX 102 is a half-round profile measuring 0/." by %". requiring only 2" of
concrete coverage, RX-I02 is designed for concrete less than 8" (200 mm) thick.
Waterstop-RX offers a low cost opportunity to enhance the perfonnance of a sound
external waterproofing system, by sealing the areas of highest probability ofwaler
infiltration through the concrete, and should lherefore be implemented as part of lhe
waterproofing design
Waterstop-RX Advantages Over PVC Dumbbell Waterstops
Easy to Install -Waterstop-RX can be installed by one person wilhout split-fonning
or splice welding roll ends.
Positive Seal-Waterstop-RX swells and forms a positive seal
No Special Transition Parts -Waterstop-RX does not require special cross, comer,
or "L" parts to transition from horizontal to vertical.
Safe -Waterstop-RX is non-toxic and requires no special handling.
Flexible -Waterstop-RX has excellent flexibility so it can be installed around
irregular penetrations like steel H-Piles.
New-to-existing Concrete -Installs without chipping or saw-cu~ing existing
concrete
Applications
Construction joints in foundation slabs or below grade walls
Around pipes, steel H-piles, and other penetrations
New-to-existing concrete work
Septic lanks, sanitary and stonn sewer manholes
Utility and burial vaults
Box culverts
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WATERSTOP -RX® -Expanding Waterstops for Concrete Construction Joints
FOOTING AND WALL
JOINTS
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WATERSTOP .. TECH DATA SHEETS
WATERSTOP· PRODUCT SPECIFICATIONS
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WATERSTOP RX .. MSDS (US)
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WA TERSTOP RX • LEED LETTERS
WA TERSTOP RX • PRODUCT MANUALS
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STRUCTURAL PENETRATIONS
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WATERSTOp·RX®
EXPANDING CONCRETE JOINT WATERSTOP
DESCRIPTION
WATERSTOP-RX is a hydrophilic strip
waterstop designed to stop water infiltration
through cast-in-place concrete construction
joints by expanding upon contact with water
to form a positive seal against the concrete.
The key to WATERSTOP-RX's effectiveness is
its superior expansion to seal and fill voids
and cracks in the concrete. WATERSTOP-RX
is an active bentonite/butyl-rubber based
waterstop that is designed to replace passive
PVC/Rubber dumbbell waterstops, thereby
eliminating the requirement of special
pieces, split-forming and seam welding.
WATERSTOP-RX has been successfully
tested by independent testing firms to over
60 meters (200 feet) of hydrostatic water
pressure, under both continuous immersion
and wet/dry cycling.
WATERSTOP-RX is available in three
sizes and shapes (see Product Table).
WATERSTOP-RX 101 is produced in a
rectangular shape measuring 25 x 19 mm
(1" x 3/4"). WATERSTOP-RX 10n is produced
in a trapezoidal shape measuring 31 x 12 mm
(1-1/4" x 1/2") with a reinforcing plastic scrim
embedded in the top surface for high tensile
strength. The patented trapezoidal shape
distributes the expansive force over a greater
area and allows the concrete to flow more
readily over the product during placement.
WATERSTOP-RX 102 is produced in a half-
circle (Crescent) shape measuring 19 x 9 mm
(3/4" x 3/8").
Though WATERSTOP-RX possesses good
resistance to many chemicals, the waterstop
is not intended to be used as the primary joint
sealant for chemical containment vessels.
Consult manufacturer for guidance regarding
chemical compatibility for secondary
chemical containment applications.
Additionally, WATERSTOP-RX is not an
expansion joint sealant; contact CETCO for
expansion joint applications.
APPLICATIONS
Applications include both vertical and
horizontal non-moving concrete construction
joints, new to eXisting concrete construction,
irregular surfaces, and around through-wall
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penetrations, such as plumbing and utility
pipes. Additionally WATERSTOP-RX can seal
around concrete pilings and steel H-piles
passing through the slab. WATERSTOP-RX
works in both continuous hydrostatic and
intermittent hydrostatic conditions.
WATERSTOP-RX products are designed
for reinforced structural concrete with
a minimum of 20N/mm2 (3,000 psi)
compressive strength. RX-l01 and RX-l0iT
are designed for concrete 200 mm (8") thick
or greater with two rows of reinforcing steel.
RX-l02 is designed for vertical concrete
150 mm (6") thick or greater; and horizontal
concrete no less than 100 mm (4") thick.
RX-l02 should be used in concrete with one
row of steel reinforcement, concrete curbs,
planter walls, fountains, and lightweight
structural concrete.
WATERSTOP-RX Is a reliable, cost-effective
means to stop water Infiltration through
concrete cold joints. It can also be used
around pipe and structural penetrations
INSTALLATION
Surface preparation: Surfaces should be
clean and dry. Remove all dirt, rocks, rust
or other construction debris. Do not install
WATERSTOP-RX in standing water or on an
iced substrate.
Adhesive: Apply a continuous bead of
CETSEAL along the substrate where
WATERSTOP-RX will be installed. Assure
proper 75 mm (3") concrete coverage will
be maintained. Keep the nozzle tip pressed
against the concrete at a 45° angle during
application.
Installation: After applying a continuous bead
of CETSEAL, remove release paper, then firmly
press the entire length of WATERSTOP-RX
onto the adhesive. For vertical and overhead
applications, firmly press a minimum of 15
seconds to assure adhesion. For best results
apply WATERSTOP-RX within 15 minutes of
adhesive installation. WATERSTOP-RX must
be placed into adhesive prior to CETSEAL
skinning over and curing. CETSEAL may be
applied to damp surfaces, but not in standing
water.
North America: 847.851.1800 I 800.527.9948
Tightly butt coil ends together to form a
continuous waterstop -do not overlap coil
ends. Place in maximum practical lengths to
minimize coil end joints. Where required, cut
coils with a sharp knife or utility blade to fit
coil ends together. Make horizontal to vertical
transitions by abutting product coil sections
together, no special accessory pieces are
required.
At structural and pipe penetrations, cut into
strips to fit around the penetration. Apply to
adhesive and abut coil ends together.
On irregular surfaces such as stone or rough
concrete, make sure WATERSTOP-RX remains
in direct contact with the substrate along the
entire installation. There should not be any
air gap between the WATERSTOP-RX and the
substrate.
Footing/Wail Joint
WATERSTOP-RX
Place WATERSTOP-RX
inside of outer most
reinforcing dowels
Minimum 75 mm (3")
to exterior surface of
wall
General Application Detail
WATERSTOp·RX®
EXPANDING CONCRETE JOINT WATERSTOP
Installat/on with REVO-FIX: REVO-FIX is a
steel mesh used to mechanically secure
WATERSTOP-RX 101 into position using the
accompanying supplied fasteners. Remove
release paper and place the WATERSTOP-RX
on the concrete substrate. Then place REVO-
FIX strips over the WATERSTOP-RX, lapping
the strip ends by 25 mm (1") maximum. Nail
through LAP with fastener supplied, and install
one fastener 300 mm (12") on center along
the REVO-FIX.
End-to-end or end-to-side REVO-FIX junctions
are created by simple butt joints pressed
firmly together. Start at junctions; do not
stretch WATERSTOP-RX to fit. Do not overlap
waterstop.
LIMITATIONS
WATERSTOP-RX is not a self-adhering
product. CETSEAL or REVO-FIX is required
to secure WATERSTOP-RX to concrete,
metal, or PVC (Pipe) surfaces. Mechanical
fasteners should be used with REVO-FIX to
secure WATERSTOP-RX 101; and fasteners
can be used in conjunction with CETSEAL.
Mechanical fasteners should not be used to
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secure WATERSTOP-RX alone. Do not use any
other adhesive or construction sealant, except
CETSEAL, to secure WATERSTOP-RX.
WATERSTOP-RX is not designed, nor intended
to function as an expansion joint sealant.
For precast concrete applications, contact
manufacturer for product suitability and for
any special installation requirements.
WATERSTOP-RX products are designed
for structural concrete with a minimum of
20N/mm2 3,000 psi compressive strength.
WATERSTOP-RX 101 and RX-l0lT require a
minimum of 3" (75 mm) of concrete coverage.
WATERSTOP-RX 102 requires a minimum
concrete coverage of 2" (50 mm). WATERSTOP-
RX should only be used in applications where
the product is completely encapsulated within
the concrete.
WATERSTOP-RX should not be prehydrated
by being subjected to submersion or
remain in extended contact with water
prior to encapsulation in concrete. If the
product exhibits considerable swell prior to
encapsulation in the concrete, it must be
replaced with new material.
North America: 847.851.1800 I 800.527.9948
In conditions where severe ground water
chemical contamination exists, or is expected,
consult manufacturer for product chemical
compatibility information.
PACKAGING
RX-l0l: 30 m (100 ft./box)
RX-l0lT: 36 m (120 ft./box)
RX-l02: 60 m (200 ft./box)
CETSEAL and REVO-FIX are packaged
separately.
ACCESSORY PRODUCTS
CETSEAL is a multi-purpose, single component
polyether moisture cure adhesive used to
secure WATERSTOP-RX into position. Apply
a continuous bead of CETSEAL to substrate
then install WATERSTOP-RX before CETSEAL
skins over and cures. Adhesive yield will vary
with use, substrate and application.
50mm(2")
WATERSTOp·RX®
EXPANDING CONCRETE JOINT WATERSTOP
APPLY
ADHESIVE
PLACE
WATERSTOP
BUTT COIL ENDS
POUR
CONCRETE
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REMOVE ALL DIRT AND DEBRIS
APPLY CETSEAL
REMOVE RELEASE PAPER THEN PRESS
FIRMLY AGAINST CETSEAL. MAINTAIN
MIN. CONCRETE COVERAGE DEPTH
TIGHTLY BUTT COIL ENDS TO FORM A
CONTINUOUS WATERSTOP. DO NOT
OVERLAP COIL ENDS
North America: 847.851.1800 I 800.527.9948
,
,'.
-_' __ I ... _ .. _
LIMITED WARRANTY
Specifications and other information contained herein supersedes all
previously printed matter and are subject to change without notice.
All goods sold by seller are warranted to be free from defects in
material and workmanship. The foregoing warranty is in lieu of and
excludes all other warranties not expressly set forth herein, whether
expressed or implied by operation of law or otherwise, including but
not limited to any implied warranties of merchantability or fitness.
Seller shall not be liable for incidental or consequential losses,
damages or expenses, directly or indirectly arising for the sale,
handling or use of goods, or from any other case relating thereto,
and seller's liability hereunder in any case is expressly limited to the
replacement (in the form originally shipped) of goods not complying
with the agreement or at seller's election, to the repayment of, or
crediting buyer with, an amount equal to the purchase price of such
goods, whether such claims are for breach of warranty or negligence.
Any claim by buyer with reference to the goods sold hereunder for any
cause shall be deemed waived by buyer unless submitted to seller in
writing within thirty (30) days from the date buyer discovered or should
of discovered, any claimed breach.
Materials should be inspected and tested by purchaser prior to
their use if product quality is subject to verification after shipment.
Performance guarantees are normally supplied by the applicator.
TYPICAL PROPERTIES
P-A0PER1"Y 1'fiSl' MetrHoo VAtUE
Hydrostatic Head Resist-Independent Test 70 m (231 Ft.)
ance
Wet / Dry Cycling Independent Test No Effect
(25 Cycles @ 231 ft)
Adhesion to Concrete Independent Test Excellent
Using CETSEAL .-
WATERSTOP-RX®
EXPANDING CONCRETE JOINT WATERSTOP
TYPICAL PRODUCT APPLICATIONS
WATERSTOP-RX 101 and RX 101T
Vertical and horizontal concrete 200 mm (8") thick or greater
Concrete with two rows of steel reinforcement
Shotcrete Foundation Walls
High hydrostatic pressures
Tie-back plates and penetrations
Install WATERSTOP-RX at all
slab pour joints and connect
with wall joint installation to
Install WATERSTOP-RX
inside of oLiter most
reinforcing steel
I •
WATERSTOP-RX 102
Vertical concrete 150 mm (6") thick or greater.
Horizontal concrete 100 mm (4") thick or greater
Concrete with one row of steel reinforcement
Slabs containing only wire mesh
Fountains / Planter Boxes / Curbs
Penetrations
Install WATERSTOP-RX at all
wall pour joints
Install WATERSTOP-RX at
footing/wall joint
SLAB JOINT SECTION DETAIL
75 mm (3") min
concrete coverage
WATERSTOP-RX
(min 75 mm (3") coverage)
Reinforced slab
Typical WATERSTOP-RX Foundation Detailing
WATERSTOP-RX
(min 75 mm (3") coverage)
WATERSTOP-RX I
(min 75 mm (3") coverage) Non-shrink grout
..
Concrete
Concrete Pipe Pipe sleeve Pipe
Cast-in-Place Penetration Sleeved Penetration Detail
North America: 847.851.1800 I 800.527.9948
© 2014 CETCO. IMPORTANT: The information contained herein supersedes all previous printed versions. and is believed to
be accurate and reliable. For the most up-to.<Jate information. please visit www.CETCO.com. CETCO accepts no responsibility
for the results obtained throught application of this product. CETCO reserves the right to update information without notice.
APRIL 2014 TDS_WATERSTOp·RX AM EN 201404_vl www.CETCO.com
This guide specification was issued February 2009 and may be superseded without notice at any
time. Therefore, please confirm that this specification is still current and has not been superseded
by checking at www.cetco.com or by calling 1-847-851-1800.
CAST-IN-PLACE CONCRETE CONSTRUCTION SPECIFICA TION
This guide specification has been prepared according to the principles established in the Manual
of Practice published by the Construction Specification Institute and is intended for use with cast-
in-place concrete structures. This specification is not intended for use with shotcrete, masonry
block, or precast concrete construction. Contact CETCO regarding installation guidelines for
applications not covered herein. CETCO, Building Materials Group -1-800-527-9948.
SECTION 032500 -FEBRUARY 2009 (Supersedes All Previous Versions)
WATERSTOP-RX@ BENTONITE WATERSTOP
MASTER GUIDELINE SPECIFICATION FOR CAST-IN-PLACE CONCRETE
PART 1 -GENERAL
1.01 RELATED DOCUMENTS
A. All of the Contract Documents, including General and Supplementary Conditions, and Division 1
General requirements, apply to the work of this section.
1.02 WORK SUMMARY
A. Furnish and install expanding bentonite-based waterstop as specified herein, illustrated on project
drawings, or as required to complete the work to comply with waterproofing warranty requirements
in Section 071000.
1.03 RELATED SECTIONS
A. Other specification Sections which directly relate to the work of this section include, but are not
limited to, the following:
1. Division 7: Waterproofing
1.04 QUALITY ASSURANCE
A. Verification of Details: Contractor to notify the Architect immediately of any detail, note, or
specification which does not comply with current manufacturer's installation requirements
B. Adhesion: Waterstop-RX is not a self-adhering product. Cetseal is required to secure Waterstop-RX.
No other adhesive should be used. Mechanical fasteners can be used in conjunction with Cetseal
adhesive, but should not be used solely to secure the waterstop.
C. Installation Instructions: Components and installation procedures shall be in accordance with current
manufacturer's printed specifications and recommendations. Verify technical data submittals are the
most current with manufacturer -[phone].
D. Expansion Joints: WATERSTOP-RX is not designed, nor intended for waterproofing or sealing
expansion joints. Responsibility of waterproofing expansion joints is of others.
E. Concrete: Concrete shall be structural grade quality with a minimum 3000 psi tensile strength. For
RX-101 and RX-10H a minimum thickness of 8" (200 mm) with two rows of reinforcing steel is
required. For RX-102 a minimum thickness of 5" (125 mm) with a single row of reinforcing steel is
required.
032500 -1
1.05 SUBMITTALS
A. Product Data: Submit manufacturer's product data, with complete general and specific installation
instructions, recommendations, and limitations.
B. NSF Standard 61 Certification: Submit Official NSF Listing for waterstop confirming that the products
conforms to the requirements of NSF Standard 61 -Drinking Water System Components -Health
Effects.
1.06 PRODUCT DELIVERY, STORAGE AND HANDLING
A. Deliver materials in factory sealed and labeled packaging. Sequence deliveries to avoid delays,
while minimizing on-site storage. Handle and store following manufacturer's instructions,
recommendations and material safety data sheets. Protect from construction operation related
damage, as well as, damage from weather, excessive temperatures and prolonged sunlight.
Remove damaged material from site and dispose of in accordance with applicable regulations.
PART 2 -PRODUCTS
2.01 MANUFACTURER
A. Provide Waterstop-RX bentonite waterstop and Cetseal adhesive as manufactured by Colloid
Environmental Technologies Company (CETCO), 2870 Forbs Ave, Hoffman Estates, IL 60192,
USA. Phone: [phone]; Fax: [phone]; Web-site: http://www.cetco.com.
2.02 MATERIALS
A. Waterstop shall consist of sodium bentonite and butyl rubber compound formed into uniform coils.
B. NSF Certified: Bentonite waterstop shall be certified by NSF International to conform to the
requirements of NSF Standard 61 -Drinking Water System Components -Health Effects.
C. BENTONITE WATERSTOPS
1. WATERSTOP-RX 101: 1" x 3/4" x 16'8'" rolls of a flexible strip of bentonite and butyl rubber
compound for use in concrete construction joints -not designed for expansion joints.
2. WATESTOP-RX 101T: 1-1/4" x 1/2" x 20" trapezoidal rolls of flexible strip of bentonite and butyl
rubber compound with a reinforcing poly scrim for use in concrete construction joints -not
designed for expansion joints.
3. WATERSTOP-RX 102: 3/4" x 3/8" x 33'4" rolls of flexible strip of bentonite and butyl rubber
compound for use in concrete construction joints -not designed for expansion joints.
D. ADHEISIVE
1. CETSEAL: A mUltipurpose UV stable single component polyether moisture cure sealant I
adhesive.
PART 3 -EXECUTION
A. Comply with contract documents and manufacturer's product data, including product application
and installation instructions.
032500-2
3.01 SUBSTRATE INSPECTION AND CONDITIONS
A. The installer shall examine conditions of substrates and other conditions under which this section
work is to be performed and notify the contractor, in writing, of circumstances detrimental to the
proper completion of the work. Do not proceed with work until unsatisfactory conditions are
corrected and are acceptable for compliance with manufacturer's warranty requirements.
B. Installation shall not proceed when work areas are flooded or wet to the extent that would cause
bentonite waterstop to hydrate prior to concrete encapsulation.
3.02 SURFACE PREPARATION
A. Remove dirt, debris, oil, grease, cement laitance, or other foreign matter which will impair or
negatively affect the installation of the waterstop. Protect adjacent material surfaces from damage
or contamination from during installation operations.
3.03 GENERAL INSTALLATION GUIDELINES
A. Install WATERSTOP-RX in all applicable vertical and horizontal cast-in-place concrete construction
joints; and around applicable penetrations and structural members. Place WATERSTOP-RX to
allow for minimum 3" (75 mm) concrete coverage on all sides (2" (50 mm) coverage for RX-102).
B. Apply continuous bead of CETSEAL (typical bead diameter 3/16" (5 mm)) to dry, smooth concrete
surface maintaining a minimum 3" (75 mm) depth within the concrete joint.
C. Remove release paper from coil of WATERSTOP-RX. Firmly press the entire length of
WATERSTOP-RX into the CETSEAL adhesive bead; resulting in the adhesive bead spreading to
coat most of the bottom of the waterstop. Verify 3" (75 mm) minimum concrete coverage will be
maintained over entire placement of waterstop. Place in maximum practical lengths to minimize coil
end joints.
D. Tightly butt coil ends together to form continuous waterstop. Do not overlap coil ends. Where
required, cut coils with sharp knife or utility blade to fit coil ends together without overlapping.
E. Following Steps 1-3, install waterstop around all applicable through wall pipes and mechanical
penetrations; and around all applicable structural elements like metal H-Piles through the slab.
F. Protect installed waterstop from prehydration prior to concrete placement and product encapsulation.
Replace any waterstop material that exhibit Significant expansion prior to concrete encapsulation.
3.04 CLEAN UP
A. Clean areas where adjacent finished surfaces are soiled by work of this Section. Remove all tools,
equipment and remaining product on-site. Dispose of section work debris and damaged product
following all applicable regulations.
End of Section 032500
Appendix 3
WHITE MESA MILL DISCHARGE MINIMIZATION
TECHNOLOGY (DMT) MONITORING PLAN
Revision 12.12
Jaly 2012May 2014
Prepared by:
Denison Mine.sEnergy Fuels Resource (USA) COFplnc.
1050 17th StFeet225 Union Boulevard, Suite %0600
DeByeFLakewood, CO 802(;580228
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WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. 1NTROD
1.1.
2.
2.1. Daily In, peclion ................................................................................................................ 4
3. WEEKLY TAILINGS AND DMT INSPECTION ................................................................. 5
3.1. Weekly Tailings Inspections .............. _ ... _.uom •• _ ..... _ ............ u ..... _ ........................... 5
Nor1hin~ .................................................................................................................................. 9
Eastin2: ..................................................................................................................................... 9
32. Weekly Inspection of So1ution Levels in Roberts Pond ................................................. 12
.3. W ekly Feed rock Storage A rea Tn mecllOn .................................................................. 12
4. ANNUAL EV ALUATIONS ................................................................................................. 13
5.
6.
7.
4.1. Freeboard Limits ............................................................................................................ 13
4.1.1. Roberts Pond ........................................................................................................... 13
4.2. Annual Leak Detection Fluid Samples ........................................................................... 13
4.3.
7.1. DMT Reports .................................................................................................................. 14
Attachment A
Attachment B
Attachment C
ATTACHMENTS
Forms
Feedstock Storage Area
Tables
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1. INTRODUCTION
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This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
White Mesa Mill's (the "Mill's") Groundwater Discharge Permit ("GWDP") Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT 1900479 (the "RML") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 ofthe Mill's Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill's Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that Denison EFRI develop the initial DMT Plan in
response to GWDP requirements. In developing the initial DMT Plan, Den:ison EFRI combined the
existing Tailings Management System procedure set out as Chapter 3.1 of the Mill's Environmental
Protection Manual with a number of new DMT requirements from the GWDP to form the initial
DMT Plan. The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the
requirements from the RML (i.e., Chapter 3.1 of the Mill's Environmental Protection Manual) and
the DMT requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, Denison EFRI concluded that it is
preferable to separate the RML portions of the DMT Plan from the GWDP portions of the DMT
Plan, into two separate documents. This DMT Plan continues to be a stand-alone plan that contains
the DMT requirements from the GWDP except for the daily recording of the Cells 1,2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
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RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
This division of the requirements was discussed with DRC on October 26,2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1,2, and 3 Leak Detection Systems ("LDSs") has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1,2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1,2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1,2,3, 4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-I to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
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2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2.1q).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (CeIl4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Ce1l4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKL Y TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell's LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1, 2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Ce1l4A and CeIl4B) and indicates the presence of solution with a warning light.
The Cell4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-I of this DMT Plan. For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill's environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
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If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
For Cells 1, 2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C of the
RML as described in the Tailings Management System procedure.
For Cell4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a I-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell4A or 26,145 gallons/day for CeIl4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table lA and IB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) Denison EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the re-grading
of the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
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Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe .. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5618.73 fmsl), and made to the nearest 0.01 foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5618.73 -Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11, 2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii)If at any time the most recent average annual head in the Cell 2 slimes drain is found
to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(viii) Because Cell 3, CeIl4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, CeIl4A, or CeIl4B, a similar procedure will be developed for
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ensuring that average head elevations in the Cell 3, CeIl4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, CeIl4A, and Cell4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 4A, and 4B and Roberts Pond are to be taken by
survey on a weekly basis. The beach area in Cell 4B with the maximum elevation is to be
taken by survey on a monthly basis when beaches are first observed, as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee (the
"Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The Reference Points for Cells 1, Cell 4A, and 4B, and Roberts Pond are known
points established by professional survey. For Cell 1 and Roberts Pond, the
Reference Point is a wooden stake with a metal disk on it located on the southeast
corner of Cell 1. The elevation of the metal disk (the "Reference Point Elevation")
for CellI and Roberts Pond is at 5,623.14 feet above mean sea level ("FMSL"). For
Cell4A and 4B, the Reference Point is a piece of stamped metal monument located
next to the transformer on the south side of Cell 4 A and 4 B. The elevation at the top
of this piece of rebar (the Reference Point Elevation for Cell4A and 4B) is 5600.49
fmsl. The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible.
(iv)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell IlRoberts Pond Reference Point on the top of the rebar on the
Cell4A and 4B Reference Point. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established a
level reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1, Ce1l4A, CeIl4B, or
Roberts Pond, or the area of the beach in Cell 4B with the highest elevation, as the
case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
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For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typicall y zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
I. Ce1l4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
n. Ce1l4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
Ill. CellI
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
IV. Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northin!! Eastin!!
Roberts Pond 323,041 2,579,697
CellI 322,196 2,579,277
Ce1l4A 320,300 2,579,360
Ce1l4B 320,690 2,576,200
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These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Cell4B Beach Elevation
Beach elevations in Cell4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
~ The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
fij(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale
on the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
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of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RS 01.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill's maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
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Management System Procedure.
e) Summary
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In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Robelts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
11·-!-1
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Freeboard Limits
4.1.1 . Roberts Pond
+f..l.2.5/14 Revision: DeHisoH12EFRI
Page 13 of25
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0 feet above mean sea
level, as specified in the GWDP.
4.2. Annual Leak Detection Fluid Samples
Pursuant to Part I.E.1O(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.3. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
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Page 14 of25
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
5. 5.0 ARRUttl Inspection of the Ammonium Sulfate PadCover Area
Btlring lhe !iee:ooo (Il:Htfle£ ofaacb yca±';-I:Ihe Ammonium Sulfate Pad-Cover Area will be inspected
to ensure the integrity of the '. xposed concrete and asphalt surface§,. If any abnormalities are
identified, i.e. cracks in the concrete or asphalt with greater than 1/8 inch separation (width) or any
significant deterioration or damage of the con 'ret pad or asphalt surface§" repairs will be made
within 7 calendar days of the inspection. All inspection findings and any repairs required shall be
documented on the AHHUa-l Decontamination Padl Ammonium Sulfate Pad--Cover Area Inspection
form. The inspection findings, any repairs required and repairs completed shall be summarized in
the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year. The first inspection
of the Ammonium Sulfate Pad-Cover Area will be conducted during the second quarter in the year
following installation/completion of the pad.
6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7.1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 of the GWD P
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
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Page IS of25
Monitoring), Section 3.1(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3.1 (d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2 (Weekly Inspection of Solution
Levels in Roberts Pond) .. aftEl-3.3 (Weekly Feedstock Storage Area Inspections)
5.0 (lnspection 0 lh Ammonium Sulfate Cover Area [for 8 guaneI' in .Juclil1c=
any repair ' required, and repair completed]);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section &M.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section &M.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year; aBEl
)
dtf) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
11.-l-~
ATTACHMENT A
FORMS
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Page 16 of25
White Mesa Mill -Discharge Minimization Technology Monitoring Plan +f.HS/14 Revision: DeRtsoR12EFRI 12.-!-2.
Page 17 of 25
ATTACHMENT A-I
DAIL Y INSPECTION DATA
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
CellI Cell 2 Cell 3 Cell4A
Inspecror. ______ _
Date; ________ _
Accompanied by: ___ _
Time: ________ _
Cell4B
Leak Checked Checked Checked Checked Checked
Detection
System Wet Dry Wet Dry Wet Dry Wet Dry Wet
Checked
Initial level Initial level Initial level Initial level Initial level
Final Final Final Final Final
level level level level level
Gal. pumped Gal. pumped Gal. pumped Gal. pumped Gal. pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-l)
Dry
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
12.+~
+/RS/14 Revision: DeHisoH12EFRI
Date: _______ _
1. Pond and Beach
elevations (msl, ft)
2. Leak Detection Systems
Observation:
ATTACHMENT A-2
DENISON MINES (US}· ... ) CORP.
WEEKLY TAILINGS INSPECTION
Page 18 of25
Inspectors: ____________ _
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML «a)-(b)) _____ _
CeIl4A: (a)pond Solution Elevation
(b )FML Bottom Elevation _-,5555.14_
(c)Depth of Water above FML «a)-(b)) _____ _
CeIl4B: (a)Pond Solution Elevation
Roberts
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML «a)-(b)) _____ _
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation
(b )FML Bottom Elevation __ ,5612.3_
(c )Depth of Water above FML « a)-(b)) _____ _
New Decon Pad, Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or __ wet __ dry __ wet __ dry __ wet __ dry
dry?
If wet, Record liquid Ft to Liquid Ft to Liquid Ft to Liquid
level:
If wet, Report to RSO
* Does Level exceed 12 mches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Ce1l4B)? no __ yes
If Cell4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
..12.4-.£
+f.RS/14 Revision: DeRlsoR12EFRI
Page 19 of25
ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through ____ .Date of Inspection: _______ _
Inspector: ___________ _
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no: ___ _
con~ment : __________________________________ _
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
ye: 110: __ _
comments (e.g., conditions of containers): _________________ ~
Are all sumps and low lying areas free of standing solutions?
Yes: No: __ _
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No: __ _
Comments: __________________________________ _
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
il·-l-l
Ore Pad Stormwutcr Transfer Line:
Is the transfer line visible?
Yes: No:
Comments:
Comments:
Other comments:
Page 20 of25
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
1l·-l-1
ATTACHMENT A-4
+.l-H5/14 Revision: DeHisoH12EFRI
Page 21 of25
ANNUAL DECONTAMINATIONJ.~!\"lMONIUl\·J SULFATE PAD-)NSPECTION
Date of Inspection: _______ _
Inspector: __________ _
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 118 inch of separation?
_Yes_No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? __ Yes __ No
Findings:
Repair Work Required:
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
11,+2.
+J+.aj/14 Revision: Deaisoa12EFRI
Page 22 of 25
ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
_Yes __ No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Ammoniunl Sui fat Asphalt Cover:
Are-the re any f _'cparaliol1'?
Yes No
Is there any significant deterioration or damage of the asphalt surface? Yes No
Findings:
Repair Work Required:
Note: r (he quart j'ly in pc 'li)1 or til Ammonium ulfale Cover ArM. 111 quarterly im;pectiol'l
findinE!s. any re[lRil required. and repni rs completed. hall be di L1 'sed in [he illi. ocia(ed quarter!) DMT
Report.. For the annual inspection of the Existing, New Decontamination Pads and the Ammonium
Sulfate ~Cov r Area, the annual inspection findings, any repairs required, and repairs completed, along
with a summary of the weekly inspections of the Decontamination Pads, shall be discussed in the 2nd
Quarter report, due September 1 of each calendar year~
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ll·+~
ATTACHMENT B
FEEDSTOCK STORAGE AREA
N
1. --
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Page 23 of 25
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ll·-l-l.
ATTACHMENT C
TABLES
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Page 24 of25
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ll·-l-l
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa_Mill
Blanding, Utah
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Page 25 of25
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day)
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Dear Mr. Lundberg,
Kathy Weinel
Monday, May 19, 2014 7: 15 AM
'Rusty Lundberg'
'Phillip Goble'; Thomas Rushing'; Harold Roberts; David Frydenlund; Frank Filas, P.E; Dan
Hillsten; David Turk; Jaime Massey
Transmittal of CSV Files White Mesa Mill 2014 01 Groundwater Monitoring
GW 01 2014 Data.csv
Attached to this e-mail is an electronic copy of laboratory results for groundwater monitoring conducted at the White
Mesa Mill during the first quarter of 2014, in Comma Separated Value (CSV) format.
Please contact me at 303-389-4134 if you have any questions on this transmittal.
Yours Truly
Kathy Weinel
1
May 19,2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
Re: Transmittal of 1st Quarter 2014 Groundwater Monitoring Report
Groundwater Quality Discharge Permit UGW370004 White Mesa Uranium Mill
Dear Mr. Lundberg:
Enclosed are two copies of the White Mesa Uranium Mill Groundwater Monitoring Report for the 1st
Quarter of 2014 as required by the Groundwater Quality Discharge Permit UGW370004, as well as
two CDs each containing a word searchable electronic copy of the report.
If you should have any questions regarding this report please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten