DRC-2014-003822 - 0901a068804467b8

W ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvt'uels.com
June 5, 2014 DRC-2014-003822
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
Re: Response to Utah Division of Radiation Control ("DRC") March 19, 2014 Request for
Information ("RFI"), regarding the DRC review of the July 2012 Revised Renewal Application
for the White Mesa Mill Groundwater Discharge Permit UGW370004
Dear Mr. Lundberg:
This letter responds to DRC's above-named letter dated March 19, 2014, which Energy Fuels
Resources (USA) Inc. ("EFRI") received on March 20, 2014, regarding the DRC review of the July
2012 Revised Renewal Application for the White Mesa Mill Groundwater Discharge Permit
UGW370004.
For ease of review, this letter provides each of DRC's comments verbatim, in italics, below,
followed by EFRI's response.
The redline text of the GWDP Renewal Application and a complete, revised, clean copy of the entire
Application are both attached to this letter for your convenience.
Request for Information
DRC Comment
SECTION: 1.1 and many subsequent sections
INTERROGATORY STATEMENT(S): Page 5 of the Renewal Application (RA) refers to the mill
operator as Denison Mines (USA) Corp. Because the owner and operator of the mill has changed,
please use the new name here and throughout the RA.
BASIS FOR INTERROGATORY: The names of the owner and operator of the mill need to be
changed throughout the RA text to the new name of Energy Fuels Resources (USA) Inc.
June 5, 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
303 974 2140
www.energyfuels.com
Re: Response to Utah Division of Radiation Control ("DRC") March 19, 2014 Request for
Information ("RFI"), regarding the DRC review of the July 2012 Revised Renewal Application
for the White Mesa Mill Groundwater Discharge Permit UGW370004
Dear Mr. Lundberg:
This letter responds to DRC's above-named letter dated March 19, 2014, which Energy Fuels
Resources (USA) Inc. ("EFRI") received on March 20, 2014, regarding the DRC review of the July
2012 Revised Renewal Application for the White Mesa Mill Groundwater Discharge Permit
UGW370004.
For ease of review, this letter provides each of DRC's comments verbatim, m italics, below,
followed by EFRI' s response.
The redline text of the GWDP Renewal Application and a complete, revised, clean copy of the entire
Application are both attached to this letter for your convenience.
Request for Information
DRCComment
SECTION: 1.1 and many subsequent sections
INTERROGATORY STATEMENT(S): Page 5 of the Renewal Application (RA) refers to the mill
operator as Denison Mines (USA) Corp. Because the owner and operator of the mill has changed,
please use the new name here and throughout the RA.
BASIS FOR INTERROGATORY: The names of the owner and operator of the mill need to be
changed throughout the RA text to the new name of Energy Fuels Resources (USA) Inc.
Letter to Rusty Lundberg
June 5, 2014
Page 2 of20
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6.3.A
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
The name of the owner/operator has been updated throughout the document, except when the
organization name is part of the titles of previously submitted reports. The owner/operator names on
documents provided as appendices which are still in effect (i.e. are the most recent DRC-approved
versions) have also not been changed.
DRCComment
SECTION: 1.2
INTERROGATORY STATEMENT(S): Page 5 of the Renewal Application (RA) states that
In accordance with discussions between Denison management and State of Utah Division of
Radiation Control ("DRC") staff on March 12, 2009, this Application includes the information
required under R313-6-6.3.
Similarly, Page 6 refers to R313-6-6.4C. However, the Utah Code designations applied in these cases
are not correct. Please correct them.
BASIS FOR INTERROGATORY: The code that provides language identical or nearly identical to
that quoted in the RA is found in UAC R317-6-6.4C. No rules labeled as R313-6-6.3 or R313-6-6.4C
exist in the UAC.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6
REGULATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
The references have been corrected.
DRCComment
SECTION: 1.2 (cont'd)
INTERROGATORY STATEMENT(S): On Page 6, the following wording from R317-6-6.4C is
quoted (but misattributed):
The Director may issue (or renew) a ground water discharge permit for an existing facility,
such as the Mill, provided:
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June 5, 2014
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a) The applicant demonstrates that the applicable class total dissolved solids ("TDS")
limits, ground water quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) The applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by
facilities that produce similar products or services with similar production process
technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
Please demonstrate within the renewal application (and summarize here) that all four conditions
listed above are being met as is required for the Director to renew a groundwater discharge permit.
BASIS FOR INTERROGATORY: Currently, there are two groundwater plumes identified at the
White Mesa Mill property. Please explain how these plumes are being addressed and justify why a
groundwater discharge permit should be renewed for the facility in light of these conditions.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
Section 1.2 has been revised to address the conditions in R317 -6-6.4C.
DRCComment
SECTION: 2.1
INTERROGATORY STATEMENT(S): Please update the Applicant and Owner name and address.
BASIS FOR INTERROGATORY: Since the company has recently changed ownership, please
provide the following information required by UAC R317-6-6.3.A:
The name and address of the applicant and the name and address of the owner of the facility if
different than the applicant. A corporate application must be signed by an officer of the
corporation. The name and address of the contact, if different than above, and telephone
numbers for all listed names shall be included.
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6.3.A
REGULATORY GUIDANCE REFERENCE(S): N/A
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June 5, 2014
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EFRI Response:
The owner/applicant name and contact information have been updated.
DRC Comme nt
SECTION: 2.3
INTERROGATORY STATEMENT(S): Page 14 says,
The name of the facility is the White Mesa Uranium Mill. The facility is a uranium milling and
tailings disposal facility, which operates under a Radioactive Materials License issued by the
Director of the Utah Division of Radiation Control under UAC R313-24. In addition to
uranium in the form of U30s, the Mill also produces vanadium, in the form of vanadium
pentoxide (V20s), ammonia metavanadate (AMV) and vanadium pregnant liquor (VPL), from
certain conventional ores and has produced other metals from certain alternate feed materials.
Alternate feed materials are uranium bearing materials other than conventionally mined ores.
Please describe what "other metals from certain alternate feed materials" have been produced.
BASIS FOR INTERROGATORY: The license granted under UAC R313-24 limits production of
minerals to certain specified types.
APPLICABLE RULE(S) OR REGUIATION(S): UAC R313-24; License UT1900479
REGUlATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
NRC License SUA-1358, Amendment 4, Part 10.9, authorized the receipt and processing of source
material from Cabot Performance Materials ("CPM") facility in Boyertown, Pennsylvania. As noted
in the Technical Evaluation Report, included as Appendix A, EFRI (formerly International Uranium
(USA) Corporation) was authorized to receive and process the CPM for the recovery of uranium,
tantalum and niobium. The text has been changed to reflect the additional metals allowed for receipt,
processing and recovery from CPM alternate feed.
DRCComment
SECTION: 2.7.1
INTERROGATORY STATEMENT(S): It is stated on Page 27 that "Immediately below the FML,
each Cell has a nominal 6-inch thick layer of crushed sandstone that was prepared and rolled smooth
as an FML sub-base layer." Please correct this statement to include the other two types of sub-base
reported by EFR to exist in places beneath the tailings cells.
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June 5, 2014
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BASIS FOR INTERROGATORY: Materials underlying the FML of Cells 2 and 3 apparently consist
of crushed sandstone in most locations. However, characterization of all sub-base or underlay
materials beneath the cell liners in Cells 2 and 3 as crushed sandstone is not correct. In some
locations, the underlay materials are said to consist of either concrete sand or bare rock.
Page 23 of 58 in Denison Mines (2012) says of the underlay materials:
The material installed beneath the liners in Cells 2 and 3 consists of crushed Dakota sandstone
that was compacted with a smooth drum roller, but in some locations, in which a smooth base
grade was available, portions of the liner were placed over in-situ Dakota sandstone (H.
Roberts, 2012) (emphasis added).
This same document also states that
The Second Phase Tailings Management system Construction Report generally is consistent
with this observation: Energy Fuels Nuclear Inc. (1983) noted that a gravel-sand mixture
derived from crushing of loose [Dakota] sandstone, with some washed concrete sand in some
areas, was used to construct the compacted bedding layer immediately beneath the liner in
Cell 3; and that a similar process and materials were used for the liner bedding material in
Cell 2" (emphasis added).
Thus, it is seen that the thickness of crushed sandstone is appreciably less than six inches, being, in
fact, zero, in some locations. In some locations, FML is laid directly upon the Dakota Sandstone. In
other locations, washed concrete sand is substituted for or added to crushed sandstone.
Acknowledgment of these variant types of materials used in the sub-base of the liner in the RA is
important since each type of material potentially has different hydraulic properties and has a bearing
on the modeling of whether or not "the discharge can be controlled and will not migrate into or
adversely affect the quality of any other waters of the state."
APPLICABLE RULE(S) OR REGULATION(S): UAC R317-6-6.3.G
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
The sentence "Immediately below the FML, each Cell has a nominal 6-inch thick layer of crushed
sandstone that was prepared and rolled smooth as an FML sub-base layer." has been replaced with the
following text:
The criterion for placement of the FML in Cells 1, 2 and 3 was a smooth sub base with no
rocks protruding that could potentially damage the FML. The cells were excavated by
ripping the in-place Dakota Sandstone with a large dozer. Where the rock could not be
efficiently ripped, explosives were used to loosen the rock. The cell bottom was then
graded to the final design contours and rolled with a smooth drum vibrating roller. The
smooth drum roller effectively crushed the loose sandstone, filling in small holes, and
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Letter to Rusty Lundberg
June 5, 2014
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allowed for a smooth surface suitable for liner placement. Due to the excavation methods
(ripping and blasting) there were some areas that required little or no fill to meet final
grades, while other areas required placement of additional crushed sandstone to meet the
final grade. The cell bottom was sometimes re-worked several times to accomplish the
desired result. The majority of the cell bottom is covered with a layer (1 to 6 inches) of
crushed sandstone while the liner in some areas is placed directly on a smooth rolled
surface of Dakota Sandstone with only a thin veneer of re-compacted sandstone. In
places where the surface was rough or contained small holes, washed concrete sand was
used to fill or smooth the imperfections, and the area was then rolled one last time before
FML placement. Areas of crushed sandstone filled sub base versus areas with little or no
crushed sandstone base were not documented during construction. Areas filled or
smoothed with washed concrete sand is likely less than 0.1% of the cell bottoms.
DRCComment
SECTION: 2. 7.2.4
INTERROGATORY STATEMENT(S): Page 29 indicates that "Denison submitted an Infiltration
and Contaminant Transport Modeling ("ICTM") Report, White Mesa Mill Site, Blanding, Utah ... to
fulfill the requirements of Part I.H.ll of the Permit."
Please revise the sentence above to show the correct part of the Permit.
BASIS FOR INTERROGATORY: The requirements for the ICTM in the Permit are found in Part
I.H.2 in the current version of the Permit.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
The reference has been corrected.
DRCComment
SECTION: 2. 7.6
INTERROGATORY STATEMENT(S): Relative to Roberts Pond, Page 35 says that "an appropriate
DMT operation standard", as referenced in Permit, includes "a stipulation that the Mill maintain a
minimal wastewater head in this pond based on a 2joot freeboard limit and a ljoot additional
operating limit. " Please rewrite this statement to correct it and render it consistent with provisions in
the Permit.
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June 5, 2014
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BASIS FOR INTERROGATORY: The statement quoted above uses the phrase "minimal wastewater
head, " but this is incorrect. In the existing context, that phrase neither makes sense nor corresponds
to the Permit language.
What would work in the statement would be language similar to either "minimum distance between
the wastewater suiface and the pond-bank crest" or "maximal wastewater head." The minimum
distance between the wastewater suiface and the pond-bank crest is equal to the minimum freeboard
of two feet, as required by the Permit, plus an additional one foot of freeboard as determined by the
Pennittee, these together constituting the operating limit employed by the Permittee for safety
purposes. The maximal wastewater head should not exceed the elevation of the pond-bank crest minus
three feet, which is the sum of the two feet of freeboard and the one foot of additional operating
distance.
The language of the Permit itself is as follows:
The Pennittee shall operate this wastewater pond so as to provide a minimum 2-footfreeboard
at all times. Under no circumstances shall the water level in the pond exceed an elevation of
5,624 feet amsl. In the event that the wastewater elevation exceeds this maximum level, the
Permittee shall remove the excess wastewater and place it into containment in Tailings Cell 1
within 72-hours of discovery.
It is important to make the distinctions above since a literal interpretation of the existing language
would constrain the level in the pond to exceed the limits set by the Pennittee and possibly exceed the
limits stated in the Permit.
APPLICABLE RULE(S) OR REGUIATION(S): See Permit No. UGW370004
REGUlATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
The text has been changed to reflect the requirements from the GWDP ..
DRCComment
SECTION: 2.7.7.1
INTERROGATORY STATEMENT(S): On Page 35, it says
The Permit requires the Mill to continue its existing practice of limiting open air storage of
feedstock materials to the historical storage area found along the eastern margin of the Mill
site (as defined by the survey coordinates found in Permit Table 4); and one of the following
three practices: 1) Store feedstock materials in water-tight contains, or 2) Place feedstock
containers in water-tight overpack containers, or 3) place feedstock containers on a hardened
suiface that conforms to the requirements spelled out in the permit part l.D.ll d) 1 through 5.
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Please correct that part of the statement following the phrase "one of the following three practices"
since that is at variance with the Permit.
BASIS FOR INTERROGATORY: The Permit, portions of which are now quoted, actually requires
two practices (see Part l.D.ll ), as follows: (1) "Feedstock materials will be stored at all times in
water-tight containers, and" (2) compliance with one of the following options is required:
(b) Aisle ways will be provided at all times to allow visual inspection of each and every
feedstock container, or
(c) Each and every feedstock container will be placed inside a water-tight overpack prior to
storage, or
(d) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical requirements . . .
[emphasis added]
which physical requirements are listed specifically in the Permit.
Thus, the Permit requires two practices. This is a different requirement from (and twice the number of)
"one of ... three practices", which is incorrectly referenced in the RA. The first of the required two
practices included in the Permit is that ''feedstock materials will be stored at all times in water-tight
containers. " This first practice is thus mandatory regardless of which option is selected for a second
practice.
As indicated in the Permit, a second required practice is then selected from one of three available
options. These three are the options labeled as (b), (c) and (d) shown above.
An additional significant point is that only two of the three options for the second practice stated in the
Permit as being available are currently listed in the RA. The option about "(b) Aisle ways will be
provided at all times to allow visual inspection of each and every feedstock container" is not listed in
the RA. It needs to be, since that is one of the options provided in the referenced Permit.
Using a different, somewhat more symbolic approach, the RA perspective of (the first practice listed
or cor d) needs to be replaced by Permit perspective of (the first practice listed and (b or cor d)).
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
EFRI agrees that Part I.D.ll of the GWDP is poorly worded and should be clarified. However, EFRI
disagrees with DRC's interpretation as set out in the foregoing Interrogatory, which is inconsistent
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June 5, 2014
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with the intent of DRC as reflected in the September 2009 Statement of Basis that accompanied the
applicable revisions to the GWDP. On page 28 of that Statement of Basis, DRC wrote:
"On June 20, 2008, DUSA submitted a White Mesa Mill-Containerized Alternate
Feedstock Material Storage Procedure. After reviewing the submittal, the DRC found
that the procedure again failed to address all of the DRC concerns listed in the April 29,
2008 DRC Request for Additional Information Letter. In order to expedite resolution
of these concerns, the DRC has modified Part I.D.11 with new performance
requirements for storing feedstock material outside of the ore storage area, with an eye
to the following goals: 1) containers are maintained in a water tight condition to
prevent soil and groundwater pollution, and 2) aisleways are provided between
containers to allow physical entry and visual inspection, early detection, and timely
remediation of leakage. In the event that DUSA cannot meet goals 1 and 2, options are
provided in Part I.D.ll for DUSA to seek out DRC approval and perform said storage
over an engineered surface of concrete or asphalt with certain other performance
criteria. Related BAT monitoring requirements were also added at Part I.E.7(d) and
(e)."
Accordingly, the intention of Part I.D.11 is to provide the Mill with the following three options:
1. Store feedstock materials in water-tight containers, and aisle ways will be provided at all times
to allow visual inspection of each and every feedstock container; or
2. Each and every feedstock container will be placed inside a water-tight overpack prior to
storage; or
3. Feedstock containers shall be stored on a hardened surface to prevent spillage onto subsurface
soils, and that conforms with the following minimum physical requirements ...
As currently drafted, Part I.D.11. of the GWDP is confusing because the word "and" between
subparagraphs a) and b) is intended to refer to those two subparagraph only, and the word "or" is used
to distinguish the other two options. However, the wording is ambiguous because, without knowing
the intent, other interpretations are possible.
The intention was clearly to avoid the contents from any damaged 55-gallon drums from making
contact with the surface of the ground when stored outside the ore storage area. As stated earlier on
page 28 of the Statement of Basis:
"On May 9, 2007, DRC and NRC staff performed an inspection at the Mill site. During
the inspection DRC staff found several hundred 55-gallon drums containing alternate
feedstock material; many of which were bent, dented, and rusting at the perimeter of
the drum pile. While none were found to be leaking, the DRC staff observed that the
drums were triple stacked at least ten deep, with less than a 3-inch spacing between
rows of drums, which made it impossible to physically enter and visually inspect the
condition of each of the drums."
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June 5, 2014
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Each of the three options delineated above were considered satisfactory to address DRC's
concerns relating to bent, dented and rusting drums. The aisle ways were intended to allow the
Mill and DRC to determine by inspection that the 55-gallon drums are themselves watertight.
Placing bent, dented and rusted drums in water-tight overpacks or on an impermeable surface
was also considered satisfactory to address those concerns. There is no need to require water
tight containers to also be placed in water-tight overpacks or on an impermeable surface. That
would be redundant.
Accordingly, EFRI requests that Part I.D.11 of the renewed GWDP be revised to read as
follows:
"11. BAT Requirements for Feedstock Material Stored Outside the Feedstock
Storage Area-the Permittee shall store and manage feedstock materials outside
the ore storage pad in accordance with the following minimum performance
requirements:
a) Feedstock materials will be stored at all times in water-tight containers, and
aisle ways will be provided at all times to allow visual inspection of each and
every feedstock container, or
b) Each and every feedstock container will be placed inside a water-tight overpack
prior to storage, or
c) Feedstock containers shall be stored on a hardened surface to prevent spillage
onto subsurface soils, and that conforms with the following minimum physical
requirements ... [remainder of Section remains unchanged]"
DRCComment
SECTION: 2. 7. 7.2
INTERROGATORY STATEMENT(S): On Page 35, the RA states "For new facilities constructed at
the Mill, or reconstruction of existing facilities, Part l.D.3( e) requires the higher standard of
secondary containment that would prevent contact of any potential spill with the ground suiface. "
Please correct the reference made in this sentence to the Permit.
BASIS FOR INTERROGATORY: The correct reference should be Part l.D.3(g).
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
The reference has been corrected.
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June 5, 2014
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DRCComment
SECTION: 2.9.1.3
INTERROGATORY STATEMENT(S): Page 39 of the RA says
Part l.E.1 (d) of the Permit requires that each point of compliance well must be sampled for the
constituents listed in Table 2.9.1.3-1.
Further, Part l.E.1.(d)l) of the Permit, requires that, in addition to pH, the following field
parameters must also be monitored:
• Depth to groundwater
• Temperature
• Specific conductance
The Permittee needs to add to the list of parameters referenced with respect to Part I.E.1(d)(1) the
following parameter: redox potential (Eh).
BASIS FOR INTERROGATORY: Part 1.E.1(d) of the Permit states the following:
d) Compliance Monitoring Parameters -all groundwater samples collected shall be analyzed
for the following parameters:
1) Field Parameters -depth to groundwater, pH, temperature, specific conductance, and
redox potential (Eh).
From this, it is seen that redox potential (Eh) is a field parameter currently left out of the description
in the RA. It is important to include Eh as a field parameter in order to estimate redox conditions in
the perched water zone.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
Redox potential has been added to the list of required field parameters.
DRCComment
SECTION: 2.12.1
INTERROGATORY STATEMENT(S): Reference is made to the Tailings and Slimes Drain Sampling
Program, Revision 0, November 20, 2008 as Appendix H. Please change the appendix name to
Appendix I.
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BASIS FOR INTERROGATORY: Appendix H is not the correct appendix name for this document.
The correct appendix name is Appendix I. The name needs to be changed to correspond with the
actual paper and electronic copies of the RA.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
The Appendix reference has been changed. It is important to note that additional appendices have
been added to the document and all subsequent appendix references have been changed accordingly.
DRC Comment
SECTION: 2.15.2.2
INTERROGATORY STATEMENT(S): As stated in the RA, "Part I.D.3(b)(1) of the Permit requires
that Denison must at all times maintain the average wastewater head in the slimes drain access pipe
to be as low as reasonable achievable (ALARA) in each tailings cell, in accordance with the approved
DMT Plan." However, no data are provided in the RA in support of a demonstration of compliance to
this objective.
In addition, the RA states in Part I.D.3(b )( 3) that
Compliance will be achieved when the average annual wastewater recovery elevation in the
slimes drain access pipe, determined pursuant to the currently approved DMT Plan meets the
conditions in Equation 1 specified in Part I.D.3(b )( 3) of the Permit.
Again, the RA provides no relevant information about the current approach to compliance. For each
cell, accordingly please provide the following, where feasible:
(1) Historical records over the past four years (2009 to 2012, inclusive) chronicling measurements of
"the average wastewater head in the slimes drain access pipe" for Cells 2 and 3, listed by date.
Elevations can be obtained by subtracting quarterly measurements of depth to the wastewater, as
required by Part I.E. 7(b) of the Permit, from the reference elevation (e.g., top of pipe elevation).
(2) Data demonstrating how well, to date, "the average annual wastewater recovery elevation in the
slimes drain access pipe, determined pursuant to the currently approved DMT Plan meets the
conditions in Equation 1 specified in Part I.D.3(b )( 3) of the Permit." This Equation basically tests
each current year's 3-year average slime drain elevation against the previous year's to see if the
current year's is less.
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( 3) Plans for decreasing "the average wastewater head in the slimes drain access pipe" for Cells 2
and 3 in the future, along with a planned schedule for reducing the head to the closure goal of no
more than three feet above the FML within the next several years. These plans should include efforts
to accelerate drawdown to meet AIARA criteria.
BASIS FOR INTERROGATORY:
Part I.E. 7(b) of the Permit states
Quarterly Slimes Drain Water Level Monitoring: Cells 2 and 3 -the Permittee shall monitor
and record quarterly the depth to wastewater in the slimes drain access pipes as described in
Part I.D.3 of this Permit and the currently approved DMT Monitoring Plan at Tailings Cells 2
and 3 to determine the recovery head. For purposes of said monitoring, the Permittee shall at
each tailings cell:
1) Perform at least 1 separate slimes drain recovery test at each disposal cell in each
quarterly period of each calendar year that meets the requirements of Part I.D.3,
2) Designate, operate, maintain, and preserve one water level measuring point at the
centerline of the slimes drain access pipe that has been surveyed and certified by a Utah
licensed engineer or land surveyor,
3) Make all slimes drain recovery head test (depth to fluid) measurements from the same
designated water level measuring point, and
4) Record and report all fluid depth measurements to the nearest 0.01 foot.
5) For Cell 3 these requirements shall apply upon initiation of tailings de-watering
operations.
Part l.D.3(b)(3) states that
Annual Slimes Drain Compliance -shall be achieved when the average annual
Wastewater recovery elevation in the slimes drain access pipe, as determined pursuant
to the currently approved DMT Monitoring Plan, meets the conditions in Equation 1 below:
Equation 1:
[ IEy + IEy-t + IEy-2] I [Ny + Ny-t + Ny-2] < [ IEy-1 + IEy-2 + IEy-3] I [Ny-1 + Ny-2 + Ny-3]
Where:
IEy = Sum of all monthly and quarterly slimes drain tailings fluid elevation measurements that
meet the test performance standards found in the sub-paragraphs of Part I.D.3(b)(2), during the
calendar year of interest. Hereafter, these water level measurements are referred to as slimes drain
recovery elevations (SDRE). Pursuant to the applicable frequency and method of the approved DMT
Monitoring Plan at the time of each SDRE test, these recovery tests are to be conducted and the SDRE
values reported in units of feet above mean sea level (amsl). However, when monthly and quarteriy
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June 5, 2014
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measurements are combined in the above equation, the quarterly values shall be multiplied by a
coefficient of three ( 3 ).
IEy-1 = Sum of all SDRE measurements made in the year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three ( 3 ).
IEy-2 = Sum of all SDRE measurements made in the second year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three ( 3 ).
IEy-3 = Sum of all SDRE measurements made in the third year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three ( 3 ).
Ny = Total number of SDRE tests that meet the test performance standards found in Part
I.D.3(b)(2), conducted during the calendar year of interest. However, when monthly and quarterly
measurements are used in the equation above, each quarterly test shall be counted as three (3) separate
tests.
Ny-l = Total number of SDRE tests that meet the test performance standards found in Part
I.D.3(b)(2), conducted in the year previous to the calendar year of interest. However, when monthly
and quarterly measurements are used in the equation above, each quarterly test shall be counted as
three ( 3) separate tests.
Ny-2 = Total number of SDRE tests that meet the test performance standards found in Part I.D.3( b )(2 ), conducted
in the second year previous to the calendar year of interest. However, when monthly and quarterly measurements
are used in the equation above, each quarterly test shall be counted as three ( 3) separate tests.
Ny-3 = Total number of SDRE tests that meet the test performance standards found in Part
l.D.3( b )(2 ), conducted in the third year previous to the calendar year of interest. However, when
monthly and quarterly measurements are used in the equation above, each quarterly test shall be
counted as three ( 3) separate tests.
Prior to January 1, 2013, the following values forE and N values in Equation 1 shall
be based on SDRE datafrom the following calendar years.
Report for Calendar Year
2010
2011
2012
Source of Data bv Ct.dendar Year {o1· EquaLion 1 Variable-s (right side)
Ey Ey-1 Ey-2 Ny Ny-1 Ny-2
2009 2009 2009 2009 2009 2009
2010 2009 2009 2010 2009 2009
2011 2010 2009 2011 2010 2009
Failure to satisfy conditions in Equation 1 shall constitute DMT failure and noncompliance
with this Permit. For Cell 3, this requirement shall apply after initiation of de-watering
operations [Emphasis added].
If recent performance on reducing the wastewater heads in the cells indicates that the current rate of
drawdown may not be sufficient to attain dewatering performance objectives within the next several
years, as has recently been indicated by the DRC during ICTM and REC Plan discussions, then plans
14
Letter to Rusty Lundberg
June 5, 2014
Page 15 of 20
for remedial activities for the slimes drain will be needed. Equation 1 above will be used to address
requirement (2) above.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
At this time, de-watering of Cell 3 has not commenced and no data are available at this time. A
statement has been added to Section 2.15.2.2 noting that de-watering of Cell 3 has not started.
DRC Comment ( 1) above
Measurements of the Cell 2 slimes drain wastewater head are documented in each quarterly DMT
report submitted to DRC pursuant to the requirements of Part I.F.1, Table 7 of the GWDP. The
quarterly measurement forms and a graphical representation of the Cell 2 slimes data are included
each quarter.
The requested data has been summarized and included in Appendix J of the GWDP Application.
DRC Comment (2) above
Annual compliance calculations pursuant to Part I.D.3(b)(3) of the GWDP are submitted to DRC on or
before March 1 of the following year.
A summary of the annual compliance data, although presented elsewhere, have been added to
Appendix J of the GWDP Application
DRC Comment (3) above
As noted in Appendix J of the GWDP Application, annual slimes drain compliance was not achieved
for 2010, in accordance with Part I.D.3 of the Permit. As noted in correspondence with DRC, the
monthly monitoring requirements specified in Part I.D.3(b)(2) of the February 2011 revision of the
GWDP seriously interfered with EFRI's ability to comply with Parts I.D.3(b)(i) and I.D.3 (b)(3) of the
GWDP. The monthly testing requirement resulted in the slimes drain pump being off (not pumping) an
average of 6.42 days per month every month which is equivalent to 77 days (11 weeks) per year or 20
percent of the year for performance of the measurements.
The GWDP was amended in July 2011 to change the frequency of the slimes drain testing from
monthly to quarterly. The average annual wastewater recovery elevation in the slimes drain pipe has
been in compliance, that is, less than the previous year's running average since the monitoring
frequency changed from monthly to quarterly in July 2011.
15
Letter to Rusty Lundberg
June 5, 2014
Page 16 of 20
At the time Equation 1 was added to Part I.D.3(b)(3) of the GWDP, EFRI and DRC had extensive
discussions as to what dewatering activities would satisfy the ALARA goal specified in Part
I.D.3(b )(i). After reviewing the available options, taking into consideration the design of the cells and
their slimes drain systems, DRC and EFRI agreed that operation of the slimes drain systems in a
manner that complies with Equation 1 would satisfy the ALARA goal. As can be seen from the data
in Appendix J to the GWDP Application, the slimes drain head levels have decreased in compliance
with Equation 1, and at a faster rate since the change in monitoring frequency from monthly to
quarterly. The Cell2 de-watering results are in compliance with the GWDP requirements and with the
ALARA goals and no changes are required to the program at this time.
DRCComment
SECTIONS: 2.15.3.1, 2.15.3.2, 2.15.4
INTERROGATORY STATEMENT(S): Please fix the wording in these sections in reference to Part
I.H.19.
BASIS FOR INTERROGATORY: I.H. sections only extend to Part I.H.7. There is no Part I.H.19 in
the current Permit. Similar problems appear in other parts of Section 2.15.3.1 and in Sections 2.15.3.2
and 2.15.4. Please adjust the references so they are consistent with the current Permit.
APPLICABLE RULE(S) OR REGULATION(S): See Permit No. UGW370004
REGULATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
The text has been modified to reference the DRC-approved BAT Operations and Maintenance Plan.
DRCComment
SECTIONS: 2.19.2 and 2.19.3
INTERROGATORY STATEMENT(S): Page 78 of the RA states in Part 2.19.2 that: "The Mill's
Reclamation Plan, Revision 4.0, was approved by the DRC under the Mill License in January 2011."
This statement is incorrect. The currently approved reclamation plan is 3.2B, which was approved by
the DRC on January 26, 2011.
Section 2.19.2 and 2.19.3 also describe the Denison Mines submittal of Revision 5.0 of the
Reclamation Plan in September 2011" and that "submission of responses to all first round
interrogatory questions will be completed by August 14, 2013." Additional information about the
Reclamation Plan is provided in Section 2.19.3 on Page 79. Please update this information to include
concepts and data in a new version of the Reclamation Plan modified in response to information
shared at recent meetings between the Permittee and the DRC.
16
Letter to Rusty Lundberg
June 5, 2014
Page 17 of20
BASIS FOR INTERROGATORY: A meeting was held in Denver Colorado on April 29, 2013
concerning the version of the Reclamation Plan and the related version of the Infiltration and
Contaminant Transport Model report then extant. Participating in the meeting were representatives of
the Permittee, its consultant (MWH Americas), the DRC, and its consultant (URS Professional
Solutions). A number of issues concerning the then-extant version of the Reclamation Plan were raised
at this meeting, many were resolved verbally, and others were left as being yet to be resolved.
Decisions were made at the meeting related to the Permittee undertaking additional work and
responding to questions raised by the DRC. These issues, their resolutions and additional work to be
done will help finalize a new version of the Reclamation Plan. The changes in the new version of the
Reclamation Plan have need of being discussed in the RA to make it current.
APPLICABLE RULE(S) OR REGULATION(S): NIA
REGULATORY GUIDANCE REFERENCE(S): N/A
EFRI Response:
The text of Section 2.19 .2 of the Renewal Application has been updated to reference the current
approved Reclamation Plan as Version 3.2B approved by DRC on January 26, 2011.
The text of Sections 2.19.2 and 2.19.3 of the Renewal Application have been revised to provide
updated information on the status of Revision 5.0 of the Reclamation Plan.
DRCComment
SECTION: Appendix A
INTERROGATORY STATEMENT(S): A number of apparent discrepancies exist between well
locations shown in San Juan County plats in Appendix A and well locations shown in Figure 10, White
Mesa Site Plan Showing Locations of Perched Wells and Piezometers. Please reconcile these, or
provide explanations, if information provided is believed to be correct as is.
BASIS FOR INTERROGATORY: There are several types of discrepancies noted when comparing
well locations in San Juan County plats in Appendix A of the RA and well locations shown in Figure
10 of the RA, entitled White Mesa Site Plan Showing Locations of Perched Wells and Piezometers.
• A San Juan plat for Section 22, T37S, R22E is missing. This plat is important, and it needs
to be included in the RA, because wells TWN-12, TWN-16 and TWN-19 are located in
Section 22.
• The San Juan plats show what appear to be duplicate locations for each of the following
pairs of wells, in which each well in each pair is placed in different sections.
TW4-19 (two locations: one in Section 28 and one in Section 33 ofT27S, R22E.)
TW4-22 (two locations: one in Section 28 and one in Section 33 ofT27S, R22E.)
17
Letter to Rusty Lundberg
June 5, 2014
Page 18 of 20
MW-21 (two locations: one in Section 32 of T37S, R22E and one in Section 5 of T38S,
R22E.)
Please work with San Juan County to correct these apparent discrepancies, in case a mis-
mapping could otherwise cause legal or other problems down the road, or even if it only
might cause confusion. If the San Juan County plats are corrected, then please include the
correct plats in the RA once this is accomplished.
• The following abandoned wells are shown as wells in San Juan County plats but are not
shown in Figure 10:
MW-16 (Section 32 ofT37S, R22E)
DR-2 (Section 32 ofT37S, R22E)
DR-16 (Section 5 ofT38S, R22E)
DR-18 (Section 5 ofT38S, R22E)
DR-25 (Section 5 ofT38S, R22E)
While it is not necessary from the perspective of the DRC for EFR to take any action on
mapping of these wells, since they are abandoned, the DRC does point out the apparent
discrepancy between the county plats and Figure 10 with respect to their apparent
existence.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
EFRI contacted San Juan County to address the discrepancies noted in this comment. San Juan
County does not record well locations on plat maps.
Pursuant to a telephone conversation with DRC on April 30, 2014, EFRI has provided maps in
Appendix B showing land ownership, well locations, surface water features, and structures to address
the appropriate GWDP Renewal Application requirements.
DRCComment
SECTION: Appendix L
INTERROGATORY STATEMENT(S): The first listing of "Aluminum Powder" in Appendix Lis out
of order alphabetically, and the quantity shown for it, 0 g, is incorrect. Please remove this first listing,
inasmuch as there is also a later listing that is ordered alphabetically, which has an entry for the
correct quantity.
18
Letter to Rusty Lundberg
June 5, 2014
Page 19 of20
BASIS FOR INTERROGATORY:): In the alphabetical listing of laboratory chemicals on site, the
item "Aluminum Powder", when first introduced, is listed between "Aluminum Metal, granular" and
"Aluminum Nitrate, Nona hydrate. " Furthermore, the quantity given, 0 g, appears to be incorrect,
since a subsequent listing for "Aluminum Powder", the one that is listed between "Aluminum
Potassium Sulfate 12 Hydrate Crystal" and "Aluminum Reagent 2," has an entry for quantity of 300
g.
APPLICABLE RULE(S) OR REGULATION(S): N/A
REGULATORY GUIDANCE REFERENCE(S): NIA
EFRI Response:
The first listing of aluminum powder in the laboratory chemical inventory has been deleted.
DRCComment
SECTION: Appendix L
INTERROGATORY STATEMENT(S): Is the chemical inventory list provided in the RA (Appendix
L) complete, listing every chemical either stored or used (either now or in the past) at the facility? If
not, then please discuss each exception and indicate why it is not listed, or, alternatively, add it to the
inventory list.
BASIS FOR INTERROGATORY: The text of the RA refers to Part l.H.l of the Permit. The text
states that Part /.H. I "requires that Denison" (now EFR) "complete a historical review and conduct
an inventory of all chemical compounds or reagents stored, used, or current in use at the facility,
including the types of chemicals and the total volumes present, and historically used, as data is
available." It says that, in application to renew the Permit, the Permittee "shall submit an updated
inventory report. "
However, while the requirements are stated, the list currently submitted as Appendix L of the RA is
entitled simply "Laboratory Chemical Inventory." This title by itself conveys the impression, whether
rightly or wrongly, of possible insufficient compliance with Permit requirements. Part I.H.l of the
Permit refers not to a "laboratory chemical inventory " (which might exclude chemicals used in places
at the facility other than in a laboratory) but refers to an "on-site chemicals inventory." The latter
title suggests an inventory potentially more comprehensive than simply a laboratory chemical
inventory. The Permit says of this on-site chemicals inventory that it must report the names of "all
chemical compounds and reagents stored, used or currently in use at the facility". The text of the
Permit later specifies that the Permittee "identify all chemicals used in the milling and milling related
processes at White Mesa" (emphasis added). If there are chemicals that are currently being used, or
that have been used in the past, at the facility, that are not that are not listed in the "Laboratory
Chemical Inventory", then these need to be specified at this point by the Permittee in an updated
inventory.
19
Letter to Rusty Lundberg
June 5, 2014
Page 20 of20
The current submittal does not discuss chemicals formerly used at the facility but not currently found
in the laboratory nor does it mention their estimated volumes. This needs to be done.
Furthermore, as part of the new inventory to be submitted, the Permittee needs to include a statement
attesting that, according to the best information to be had, the listing contained therein includes the
names and quantities of every chemical either stored or used (either now or in the past) at the facility.
Such a statement is needed to confirm that the requirements of the Permit that names and quantities of
all chemicals are being reported.
EFRI Response:
The 2012 GWDP Renewal Application did include a current chemical inventory for other areas of the
Mill and was not limited to only laboratory chemicals as implied by the comment. The 2012 GWDP
Renewal Application included the following tables in Appendix L:
• L-1 Laboratory Chemical Inventory
• L-2 Current Mill Chemical Inventory
• L-3 Cleaners
• L-4 Chemicals Formerly Used/No Longer Used or Present on Site
Appendices L-1 through L-3 have been updated (moved to Appendix 0) to include historic quantities
of the chemicals that were used. Appendix L-4 (now 0-4) as submitted with the 2012 GWDP
Renewal Application, already included an estimation of the maximum quantity that was historically
present/used, and therefore no changes were made to that Appendix. Additional chemicals have been
added as necessary.
Please contact me if you have any questions or require any further information.
Your very lrU I y
~ iN~E
Kathy Weinel
•S (USA) INC.
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
20
White Mesa Mill
Renewal Application
State of Utah Groundwater Discharge
Permit No. UGW370004
Energy Fuels Resources (USA) Inc.
June 2014
1.0 INTRODUCTION
1.1 Background
1.2 Applicable Standards for Review and Approval of this Application
1.3 Background Groundwater Reports and Re-opening of Permit
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
2.2 Legal Location of the Facility (R317-6-6.3B)
2.3 Name and Type of Facility (R317-6-6.3.C)
5
5
5
9
17
17
18
18
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well,
Drinking Water Source Protection Zones, Topography, Springs, Water Bodies, Drainages,
And Man-Made Structures Within A One-Mile Radius Of The Discharge. (R317-6-6.3.D)19
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317 -6-
6.3.E) 19
2.5.1 Groundwater Characteristics 19
2.5.1.1 Geologic Setting 19
2.5.1.2 Hydrogeologic Setting 20
2.5.1.3 Perched Zone Hydrogeology 20
2.5.1.4 Perched Groundwater Flow 23
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient Of The Tailings Cells 24
2.5.2 Groundwater Quality 26
2.5.2.1 Entrada/Navajo Aquifer 26
2.5.2.2 Perched Groundwater Zone 26
2.5.3 Springs and Seeps 26
2.5.4 Topography 27
2.5.5 Soils 27
2.5.6 Bedrock 28
2.5.7 Agricultural and Land Use Description of the Area 29
2.5.8 Well Logs 29
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of
the Effluent or Leachate to be Discharged (R317-6-6.3.F) 30
2. 7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate
Into or Adversely Affect the Quality of any Other Waters of the State (R317-6-6.3.G) 30
2. 7.1 General 30
2.7.2Cells1,2and3 31
2. 7 .2.1 Design and Construction of Cells 1, 2 and 3 31
1
2.7.2.2 Improved Groundwater Monitoring
2.7.2.3 Operational Changes and Improved Operations Monitoring
2.7.2.4 Evaluation of Tailings Cell Cover System Design
2.7.3 Cell4A
2.7.4 Cell4B
2. 7.5 Future Additional Tailings Cells
2.7.6 Roberts Pond
2.7.7 Other Facilities and Protections
2.7.7.1 Feedstock Storage
2.7.7.2 Mill Site Reagent Storage
2.7.7.3 New Construction
2.7.7.4 Other
2.7.8 Surface Waters
2.7.9 Alternate Concentration Limits
32
33
33
34
36
39
39
39
39
40
40
40
41
41
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information
of the Quality of the Receiving Ground Water (R317-6-6.3.H) 41
2.8.1 Existing Wells at the Time of Original Permit Issuance 42
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit 42
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.1) 43
2.9.1 Groundwater Monitoring to Determine Groundwater Flow Direction and Gradient,
Background Quality at the Site, and the Quality of Groundwater at the Compliance Monitoring
Point 43
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit 43
2.9.1.2 Issuance of the Permit 43
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit 44
2.9.1.4 Groundwater Flow Direction and Gradient 45
2.9.1.5 Background Quality at the Site 45
2. 9 .1.6 Quality of Ground Water at the Compliance Monitoring Point 46
2.9.2 Installation, Use and Maintenance of Monitoring Devices 47
2.9.2.1 Compliance Well Monitoring 47
2.9.2.2 Leak Detection System in Cell4A and Cell4B 47
2.9.2.3 Other DMT Monitoring Requirements 47
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring
Pcin~ ~
2.9.4 Monitoring of the Vadose Zone 48
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation,
Including Post-Operational Monitoring 48
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation
48
2.9.5.2 Post-Operational Monitoring
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where
Applicable to Specified Guidance
2.9.6.1 Monitoring Well Construction
2.9.6.2 Ground Water Sampling
2.9.7 Description and Justification of Parameters to be Monitored
2
48
48
48
52
53
2.9.8 Quality Assurance and Control Provisions for Monitoring Data 53
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of
Discharge Systems (R317-6-6.3.J) 54
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-
6-6.3.K) 54
2.11.1 General 54
2.11.2 Background Ground Water Quality in the Perched Aquifer 55
2.11.3 GWCL Determination for Field pH 60
2.11.4 Quality of Ground Water at the Compliance Monitoring Point 62
2.12 Compliance Sampling Plan (R317-6-6.3.L) 62
2.12.1 Tailings Cell Wastewater Quality Sampling Plan 62
2.12.2 White Mesa Seeps and Springs Sampling Plan 63
2.12.3 Monitoring of Deep Wells 64
2.13 Description of the Flooding Potential of the Discharge Site (R317-6-6.3.M) 64
2.13 .1 Surface Water Characteristics 64
2.13.2 Flood Protection Measures 65
2.14 Contingency Plan (R317-6-6.3.N) 65
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting
Failure of the System (R317-6-6.3.0) 65
2.15.1 Existing Tailings Cell Operation 66
2.15.2 Existing Facility DMT Performance Standards 66
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3 66
2.15.2.2 Slimes Drain Monitoring 66
2.15.2.3 Maximum Tailings Waste Solids Elevation 67
2.15.2.4 Wastewater Elevation in Roberts Pond 67
2.15.2.5 Inspection of Feedstock Storage Area 67
2.15.2.6 Monitor and Maintain Inventory of Chemicals 68
2.15.3 BAT Performance Standards for Cell4A 69
2.15 .3 .1 BAT Operations and Maintenance Plan 69
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan 69
2.15.4 BAT Performance Standards for Cell4B 70
2.15.4.1 BAT Operations and Maintenance Plan 70
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan 70
2.15.5 Stormwater Management and Spill Control Requirements 71
2.15.6 Tailings and Slimes Drain Sampling 72
2.15.7 Additional Monitoring and Inspections Required Under the Mill License 72
2.15.7.1 Daily Inspections 72
2.15.7.2 Weekly Inspections 73
2.15.7.3 Monthly Reports 73
3
2.15.7.4 Quarterly Tailings Inspections
2.15.7.5 Annual Evaluations
74
74
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to
Remedy any Violation of Applicable Ground Water Quality Standards (R317-6-6.3.P) 75
2.16.1 Chloroform Investigation 7 5
2.16.2 Nitrate Investigation 76
2.17 Other Information Required by the Director (R317-6-6.3.Q)
2.17 .1 Chemical Inventory Report
2.17 .2 Southwest Hydrogeologic Investigation
79
79
79
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-
6.3.R) 80
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent
Ground Water Contamination During the Closure and Post Closure Phases of Operation
(R17 -6-6.3.S) 80
2.19.1 Regulatory Requirements for Uranium Mills 80
2.19.1.1 Long Term Custodian 80
2.19 .1.2 Responsibility For And Manner Of Clean Up 80
2.19.1.3 Surface 81
2.19.1.4 Groundwater 81
2.19 .1.5 License Termination 82
2.19.2 Current Reclamation Plan 82
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan 83
2.19 .4 Post -Operational Monitoring 85
3.0 CONCLUSIONS 85
4.0 SIGNATURE AND CERTIFICATIONS 86
5.0 REFERENCES 87
4
1.0 INTRODUCTION
1.1 Background
Energy Fuels Resources (USA) Inc.1 ("EFRI") operates the White Mesa Uranium Mill (the
"Mill"), located approximately six miles south of Blanding, Utah, under State of Utah Ground
Water Discharge Permit No. UGW 370004 (the "Permit" or "GWDP"). The Permit was
originally issued by the Co-Executive Secretary of the Utah Water Quality Board on March 8,
2005, for 5 years, expiring on March 8, 2010, and was up for timely renewal in accordance with
Utah Administrative Code ("UAC") R317-6-6.7. A renewal application was submitted
September 1, 2009. At the request of the Director of the Utah Division of Radiation Control,
EFRI submitted an updated version of the September 1, 2009 renewal application on July 13,
2012. At the request of the Director of the Utah Division of Radiation Control, EFRI is
submitting this updated version of the July 2012 renewal application.
Prior to July 1, 2012, the Director of the Utah Division of Radiation Control ("Director") was
referred to as the Executive Secretary of the Utah Radiation Control and Board Co-Executive
Secretary of the Utah Water Quality Board. Documents referenced in this Application,
published prior to that date, refer to the Director, by one or both of these previous titles.
In accordance with R317-6-6.7, this is an updated application (the "Application") to the Director
for renewal of the Permit for another 5-years under R313-6-6.7.
The Mill is also subject to State of Utah Radioactive Materials License No. UT 1900479 (the
"Mill License"), which was issued on March 31, 19972 for 10-years and is currently in the
process of timely renewal under R313-22-363, and State of Utah Air Quality Approval Order
DAQE-AN0112050018-11 (the "Air Approval Order") which was re-issued on March 2, 2011
and is not up for renewal at this time. While the Mill License is referred to in this Application
from time to time in order to allow the Director to better understand Mill operations and
compliance with applicable regulatory requirements, this is not an application for renewal of the
Mill License or Air Approval Order.
1.2 Applicable Standards for Review and Approval of this Application
In accordance with discussions between EFRI and State of Utah Division of Radiation Control
("DRC") staff on April 1, 2014, this Application includes the information required under R317-
6-6.3.
1 Prior to July 25, 2012, Energy Fuels Resources (USA) Inc. was named "Denison Mines (USA) Corp ("Denison")". Prior to
December 16, 2006, Denison was named "International Uranium (USA) Corporation."
2 The Mill License was originally issued by the United States Nuclear Regulatory Commission ("NRC") as a source
material license under 10 CFR Part 40 on March 31, 1980. It was renewed by NRC in 1987 and again in 1997.
After the State of Utah became an Agreement State for uranium mills in August 2004, the Mill License was re-
issued by the Executive Secretary as a State of Utah Radioactive materials license on February 16, 2005, but the
remaining term of the Mill License did not change.
3 A Mill License renewal application was submitted to the Executive Secretary on February 28, 2007, pursuant to
R313-22-36.
5
In accordance with R317-6-6.4C, the Director may issue (or renew) a ground water discharge
permit for an existing facility, such as the Mill, provided:
a) The applicant demonstrates that the applicable class total dissolved solids ("TDS")
limits, ground water quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) The applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by
facilities that produce similar products or services with similar production process
technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
This Permit Application demonstrates how ex1stmg facilities continue to meet applicable
regulatory criteria and the monitoring strategies employed to prevent impairment of present and
future beneficial uses of the groundwater. EFRI conducts various kinds of environmental
monitoring at the White Mesa Mill including but not limited to groundwater, surface water, soil,
sediment, tailings waste water, air, and vegetation. Specific groundwater monitoring activities
employed are summarized below.
Energy Fuels' ground water monitoring program is comprehensive in that it includes all of the 72
monitoring wells at the facility, as described above, although not every well is sampled every
quarter. Samples are taken and analyzed for a large number of groundwater contaminants
including heavy metals, nutrients, general chemistry analytes, radiologies, and volatile organic
compounds ("VOCs"). Exceedences of standards found during this monitoring program have
been addressed as described throughout this GWDP Application.
Under the License, the Permit, and the Corrective Action Plans, EFRI has completed and is
monitoring the 72 groundwater monitoring wells described below.
• 27 monitoring wells placed to detect any leaks from the cells. Because the leak detection
systems for Cells 1, 2, and 3 utilized older, less sophisticated technology, the DRC
required eight new wells be installed adjacent to the tailings cells in 2005. These wells
were to be used as a first line of defense to detect any tailings cell leakage. These
supplemented the original seven required by NRC. An additional12 wells have been
constructed in association with the construction of Cells 4A and 4B.
• 34 monitoring wells associated with characterizing the chloroform groundwater
contamination.
• 12 monitoring wells associated with characterizing the nitrate groundwater
contamination.
The monitoring results for each well that is sampled are evaluated for compliance with standards
for 38 different constituents and, regardless of whether standards are met, for trends in the data
that may show a need for further action.
6
Four indicator parameters (chloride, uranium, fluoride, and sulfate) are used at the site to
determine if there has been any cell leakage. These constituents were chosen because they are
the most mobile and are expected to be seen first with any upward trend in consistent
concentrations. If a cell were leaking, it is expected that all four parameters would show
increasing trends within two years, based on Kd values and other transport characteristics for the
contaminants and site.
During a DRC split sampling event in May, 1999, excess chloroform concentrations were
discovered in monitoring well MW -4, which is located along the eastern margin of the site.
Because these concentrations were above the Utah Ground Water Quality Standard of 70 !lgiL,
the DRC initiated enforcement action against EFRI on August 23, 1999 by issuing a Ground
Water Corrective Action Order. The Order required completion of: 1) a contaminant
investigation report to define and delineate boundaries for the contaminant plume, and 2) a
groundwater corrective action plan to clean it up. Twenty new monitoring wells (since increased
to 34 wells) were installed at the site as part of the investigation. Table 1.2-1 lists the 34
chloroform monitoring wells.
The Director and EFRI determined that the laboratory wastewater sent to sewage leach fields,
and not potential leaking from tailings cells, was the most likely source of the chlorof01m plume.
As with every groundwater corrective action, the corrective action plan is developed based on
assumptions about the source, and those assumptions are tested continuously with groundwater
monitoring as corrective action proceeds.
With DRC concurrence, EFRI began to pump chloroform contaminated groundwater in April,
2003. Groundwater monitoring results show this initial remediation effort has been effective
based on reduction of contaminant concentrations. Reductions of the contaminant concentrations
indicates both that the pumping program is working and that there is no continuous source for the
contaminants, as would be the case if the cells were leaking.
During a review of the EFRI April 30, 2008 New Wells Background Report and other EFRI
reports, Nitrate +Nitrite (as N) (hereafter Nitrate) concentrations were observed above the Utah
Ground Water Quality Standard (10 mg/L) in five monitoring wells in the mill site area.
After the Nitrate Plume was identified, the Executive Secretary and EFRI entered into a January
28, 2009 Stipulated Consent Agreement that required EFRI to complete a Contaminant
Investigation Report to determine the potential sources of the Nitrate contamination. Nineteen
additional wells were installed to determine the extent of the contamination; nine of these wells
have since been abandoned. Table 1.2-2 lists the current and former nitrate wells installed as
part of the nitrate corrective actions.
EFRI has submitted two reports to DRC regarding the elevated Nitrate concentrations. The
reports identify the extent of the Nitrate plume but EFRI and DRC disagreed about what the
reports indicated about the likely source of the plume. EFRI does not believe that the results
adequately demonstrated an on-site source.
7
EFRI agreed to implement a corrective action plan to clean up the plume. EFRI completed and
submitted the Nitrate Corrective Action Plan to the DRC on May 7, 2012. The Corrective
Action Plan was approved following a public comment period, and was incorporated into a
December 12, 2012 Stipulation and Consent Order, Docket Number UGW12-04. The approval
is subject to conditions, stipulated penalties and timelines outlined in the Stipulation and Consent
Order. The remediation plan requires EFRI to pump the groundwater and treat it by evaporation
and/or use as process water. Pumping under the remediation plan began in January, 2013.
Groundwater monitoring results show this initial remediation effort has been effective based on
reduction of the plume mass to date.
When the DRC began oversight of the Mill, it noted that ground water monitoring had showed
elevated concentrations of metals, primarily uranium, in wells MW-3, MW-3A, MW-14, MW-
15, MW-22 on the Mill site. The DRC was concerned about whether the observations meant
that tailings cells were leaking. To address its concerns, the DRC commissioned the University
of Utah to investigate the elevated concentrations in July 2007. The University completed its
study and published a report in May 2008 (the "2008 University Report").
After review of the 2008 University Report, the DRC determined that downgradient wells with
elevated total uranium concentrations (including well MW -22) were not being impacted by
potentially leaking tailings cells. This conclusion was based on at least three lines of isotopic
evidence:
1. Tritium Signature. Wells MW-3, MW-3A, MW-14, MW-15, MW-22 had tritium signatures
in groundwater at or below the limit of detection of 0.3 Tritium Units (2008 University
Report p. 26). These values are more than an order of magnitude below the corresponding
surface water results found in either the tailings cells or the wildlife ponds. This means that
the groundwater in these five downgradient wells is older than water in the tailings cells, and
is of a different origin than the tailings wastewater.
2. Stable Isotopes of Deuterium and Oxygen-18 in Water. The Deuterium and Oxygen-18
content of the groundwater matrix and tailings wastewater matrix was tested in all of the
water sources studied. The 2008 University Report results showed that wells MW-3, MW-
3A, MW-14, MW-15, and MW-22, all downgradient wells with elevated uranium
concentrations, had Deuterium and Oxygen-18 signatures that were almost twice as negative
as any of the surface water results. (2008 University Report, p. 42.) This shows that
groundwater in these downgradient wells had a different geochemical origin than the tailings
cell wastewater.
3. Stable Isotopes on Dissolved Sulfate. The University Study evaluated two stable isotopes
found in sulfate minerals dissolved in the water samples, Oxygen-18 and Sulfur-34. The
evaluation showed that the sulfate solutes in groundwater from downgradient wells MW -3,
MW-3A, MW-14, MW-15, and MW-22 had a different isotopic signature than the sulfate
minerals dissolved in the tailings wastewater. In the case of Oxygen-18 in sulfate, the
downgradient wells showed more negative values than the tailings cells wastewater. For
Sulfur-34, the results were inversed, with groundwater showing more positive values than the
8
negative values seen in the tailings wastewater (2008 University Report p. 46.). This shows
that the sulfate dissolved in the downgradient wells, with elevated uranium concentrations,
has a different origin than the tailings wastewater.
In summary, the University Study concluded that wells with high concentrations of metals (MW-
3, MW-14, MW-15, MW-18, and MW-22) bear very different isotopic fingerprints than those of
the surface water sites (e.g. wildlife ponds, and tailings cells) (2008 University Report p. 58).
Regarding uranium concentrations in well MW -22, the University Study stated that 11
•• .it does
not appear that the elevated uranium values are the result of leakage from tailings cells .... 11 (2008
University Report p. 45).
The 2008 University Report further theorized that the cause of the increasing contaminant
concentrations on the site was artificial recharge from wildlife ponds constructed in 1995,
described in Part 1.5.1. This recharge likely leached and mobilized natural uranium and other
constituents as a result of new saturation of zones beneath the site that had previously been
unsaturated. The Mill drained the wildlife ponds in 2012.
As a result, the Mill meets the requirements set out in R317-6-6.4(c).
This Application has been prepared under the direction, and bears the seal, of a professional
engineer qualified to practice engineering before the public in the state of Utah and
professionally registered as required under the Professional Engineers and Professional Land
Surveyors Licensing Act rules (UAC 156-22).
1.3 Background Groundwater Reports and Re-opening of Permit
In the December 1, 2004 Statement of Basis (the "2004 Statement of Basis") prepared by DRC
in connection with the original issuance of the Permit, three monitoring wells (MW-14, MW-15,
and MW-17) located downgradient of the Mill's tailings cells were found to have long-term
increasing concentration trends for total uranium. These three wells and downgradient well
MW-3, had total uranium concentrations above the Utah Ground Water Quality Standard
("GWQS"), found in UAC R317-6-2 (see the 2004 Statement of Basis, pp. 6-7). These findings
were of concern to the DRC because they appeared to indicate that the tailings cells had possibly
discharged wastewater into the underlying shallow aquifer.
To resolve this concern, the Director required EFRI to evaluate groundwater quality data from
the thirteen existing wells on site, and submit a Background Ground Water Quality Report for
Director approval. The existing wells are those wells which were installed prior to the issuance
of the original GWDP on March 8, 2005 and include: MW-1, MW-2, MW-3, MW-5, MW-11,
MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-26 (formerly called TW4-15 and
installed as part of the chloroform corrective action order), and MW-32 (formerly called TW4-17
and installed as part of the chloroform corrective action order). It is important to note that MW -4
was installed prior to the issuance of the original permit; however, MW -4 is monitored under the
chloroform program and was not included in the Existing Background Report. GWCLs have not
been established for this well, and MW -4 is not a POC well under the GWDP. One of the
purposes of the background report was to provide a critical evaluation of historic groundwater
quality data from the facility, and determine representative background quality conditions and
reliable groundwater compliance limits ("GWCLs") for the Permit.
9
As required, EFRI submitted the following reports:
• Revised Background Groundwater Quality Report: Existing Wells For Denison Mines
(USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, October 2007, prepared by
INTERA, Inc. (the "Existing Well Background Report"); and
• Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, November
16, 2007, prepared by INTERA, Inc. (the "Regional Background Report").
The Existing Well Background Report and the Regional Background Report included a detailed
quality assurance evaluation of all existing groundwater quality data collected prior to the date of
issuance for the thirteen existing wells, in accordance with criteria established by DRC and
United States Environmental Protection Agency ("EPA") guidance. This resulted in a database
suitable for statistical and other analyses. Based on an analysis of this updated database, the
Existing Well Background Report and Regional Background Report concluded that there had
been no impacts to groundwater from Mill activities, based on a number of factors, including the
following:
• There were a number of exceedances of GWQSs in upgradient and far downgradient
wells at the site, which cannot be considered to have been impacted by Mill operations to
date. Exceedances of GWQSs in monitoring wells nearer to the site itself are therefore
consistent with natural background in the area.
• There were numerous cases of both increasing and decreasing trends in constituents in
upgradient, far downgradient, and Mill site wells, which provide evidence that there are
natural forces at work that are impacting groundwater quality across the entire site.
• In almost all cases where there were increasing trends in constituents in wells at the site,
there were increasing trends in those constituents in upgradient wells. Furthermore, in no
case was there any evidence in the wells in question of increasing trends in chloride,
which is very mobile and a good indicator of potential tailings cell leakage at the site.
See Section 2.11.2 below for a more detailed discussion of the Existing Well Background Report
and Regional Background Report and their conclusions.
The Permit also required nine new monitoring wells to be installed around tailings Cells 1 and 2,
followed by groundwater sampling and analysis, and later submittal of another Background
Ground Water Quality Report to determine reliable background conditions and groundwater
compliance limits for the new wells. The new wells are those wells which were installed after the
issuance of the original GWDP on March 8, 2005 and include: MW-3A, MW-23, MW-24, MW-
25, MW-27, MW-28, MW-29, MW-30, and MW-31. In response to this requirement, EFRI
installed the nine new wells, and submitted to the Director a Revised Addendum: --Background
Groundwater Quality Report: New Wells For Denison Mines (USA) Corp.'s White Mesa Mill
Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc. (the "New Well
10
Background Report"), and together with the Existing Well Background Report and the Regional
Background Report, are referred to as the "Background Reports").
The New Well Background Report concluded that the sampling results for the new wells confirm
that the groundwater at the Mill site and in the region is highly variable naturally and has not
been impacted by Mill operations and that varying concentrations of constituents at the site are
consistent with natural background variation in the area. See Section 2.11.2 below for a more
detailed discussion of the New Well Background Report and its conclusions.
During the course of discussions with EFRI staff, and further DRC review, DRC decided to
supplement the analysis provided in the Background Reports by commissioning the University of
Utah to perform a geochemical and isotopic groundwater study at White Mesa. This resulted in
the University of Utah completing a study entitled Summary of work completed, data results,
interpretations and recommendations for the July 2007 Sampling Event at the Denison Mines,
USA, White Mesa Uranium Mill Near Blanding Utah, May 2008, prepared by T. Grant Hurst and
D. Kip Solomon, Department of Geophysics, University of Utah (the "University of Utah
Study"). The purpose of the University of Utah Study was to determine if the increasing and
elevated trace metal concentrations (such as uranium) found in the monitoring wells at the Mill
were due to potential leakage from the on-site tailings cells. To investigate this potential
problem, the study examined groundwater flow, chemical composition, noble gas and isotopic
composition, and age of the on-site groundwater. Similar evaluations were also made on
samples of the tailings wastewater and nearby surface water stored in the northern wildlife ponds
at the facility. Fieldwork for the University of Utah Study was conducted from July 17 -26 of
2007. The conclusions in the University of Utah Study supported EFRI's conclusions in the
Background Reports
As stated above, EFRI prepared Background Reports that evaluated all historic data for the
thirteen existing wells and nine new wells for the purposes of establishing background
groundwater quality at the site and developing GWCLs under the GWDP. Prior to review and
acceptance of the conclusions in these Background Reports, the GWCLs were set on an interim
basis in the GWDP. The interim limits were established as fractions of the state GWQSs for
drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells and the nine new wells based primarily on the conclusions and
analysis in the Background Reports. It should be noted, however, that, because the GWCLs have
been set at the mean plus second standard deviation, or the equivalent, un-impacted groundwater
would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
In addition to the thirteen existing wells and the nine new wells there are an additional 7
monitoring wells at the site which are included in the routine groundwater monitoring program.
Those 7 wells are: MW-20, MW-22, MW-33, MW-34, MW-35, MW-36, and MW-37.
The GWDP dated January 20, 2010 required the completion of eight consecutive quarters of
groundwater sampling and analysis of MW-20 and MW-22, and later submittal of another
11
Background Report to determine if wells MW-20 and MW-22 should be added as point of
compliance ("POC") monitoring wells. Data from MW-20 and MW-22 were analyzed in the pre-
operational and regional background addendum (INTERA 2007a); however there was not a
complete data set at the time. Although wells MW-20 and MW-22 were installed in 1994, they
were not sampled regularly until the second quarter of 2008. The eighth full round of sampling
was completed during the first quarter of 2010, and EFRI submitted to the Director the
Background Groundwater Quality Report for Wells MW-20 and MW-22 for Denison Mines
(USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, June 1, 2010, prepared by
INTERA, Inc. (the "MW-20 and MW-22 Background Report"). DRC classified MW-20 and
MW-22 as general monitoring wells, and GWCLs have not been established for these wells.
MW-20 and MW-22 are sampled semiannually.
Part I.H.6 of the GWDP dated June 21, 2010 required the installation of three hydraulically
downgradient wells adjacent to Tailings Cell 4B (MW-33, MW-34, and MW-35) prior to
placement of tailings and/or wastewater in Cell 4B. The purpose of these monitoring wells was
to provide early detection of tailings cell contamination of shallow groundwater from Tailings
Cell 4B. EFRI installed MW-33, MW-34, and MW-35 as required. Of these three wells
installed near tailings Cell4B, only MW-35 was hydraulically acceptable, with five feet or more
of saturated thickness. MW-35 was sampled quarterly since fourth quarter 2010 to collect eight
statistically valid data points for the completion of the Background Report and calculation of
GWCLs. MW-33 and MW-34 had insufficient water for sampling, with saturated thicknesses
less than five feet. MW-33 is completely dry, and no samples or depth to water measurements
are collected from this well. Quarterly depth to water is measured in MW -34, but no sampling or
analysis is required.
Pmt I.H.4 of the February 15, 2011 GWDP required the installation of two wells hydraulically
downgradient of Tailings Cell 4B as replacements for MW-33 and MW-34. EFRI installed
MW-36 and MW-37 as required. MW-36 and MW-37 were sampled quarterly since third
quarter 2011 to collect eight statistically valid data points for the completion of the Background
Report and calculation of GWCLs.
The Background Report for wells MW-35, MW-36, and MW-37 was submitted to the Director
on May 1, 2014. The findings of the Background Analysis for wells MW-35, MW-36, and MW-
37 support previous conclusions that the groundwater at the Mill is not being affected by any
potential tailings cell seepage. At the time of this application, EFRI was awaiting a response
from the Director regarding the Background Report for wells MW-35, MW-36, and MW-37.
1.4 Documents Referenced in This Application
The following documents are referenced in this Application.
a) The following Permits, Licenses, Statement of Basis, Plans and Related Reports:
(i) State of Utah Ground Water Discharge Permit No. UGW370004 dated August 24,
2012, (the "Permit") and previous versions of the Permit dated Janum·y 10, 2010,
June 21, 2010, February 15, 2011, and July 14, 2011.
12
(ii) State of Utah Radioactive Materials License No. UT 1900479 (the "Mill
License");
(iii) Statement of Basis For a Uranium Milling Facility at White Mesa, South of
Blanding, Utah, Owned and Operated by International Uranium (USA)
Corporation, December 1, 2004, prepared by the State of Utah Division of
Radiation Control (the "2004 Statement of Basis");
(iv) Reclamation Plan White Mesa Mill Blanding, Utah, Source Material License No.
SUA-1358 Docket No. 40-8681 Revision 3.2B, January 14, 2011 (the "Reclamation
Plan"); and
(v) UMETCO Minerals Corporation: White Mesa Mill Drainage Report for Submittal
to NRC, January 1990;
b) The following Background Groundwater Quality Reports and Related Studies:
(i) Revised Background Groundwater Quality Report: Existing Wells For Denison
Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, October 2007,
prepared by INTERA, Inc. (the "Existing Well Background Report");
(ii) Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah,
November 16, 2007, prepared by INTERA, Inc. (the "Regional Background
Report");
(iii) Revised Addendum: --Background Groundwater Quality Report: New Wells For
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, April
30, 2008, prepared by INTERA, Inc. (the "New Well Background Report" and
together with the Existing Well Background Report and the Regional Background
Report, the "Background Reports"); and
(iv) Summary of work completed, data results, interpretations and recommendations
for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa
Uranium Mill Near Blanding Utah, May 2008, prepared by T. Grant Hurst and D.
Kip Solomon, Department of Geophysics, University of Utah (the "University of
Utah Study");
(v) Background Groundwater Quality Report for Wells MW-20 and MW-22 for
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, June
1, 2010, prepared by INTERA, Inc. (the "MW-20 and MW-22 Background
Report");
13
(vi) Background Groundwater Quality Report for Monitoring Wells MW-35, MW-36
and MW-37 White Mesa Mill Blanding, Utah, May 1, 2014, prepared by INTERA,
Inc. (the "MW-35, MW-36, and MW-37 Background Report".
c) The following environmental reports and analyses:
(i) Environmental Report, White Mesa Uranium Project San Juan County, Utah,
January 30, 1978, prepared by Dames & Moore (the "1978 ER"); and
(ii) Final Environmental Statement related to operation of White Mesa Uranium
Project Energy Fuels Nuclear, Inc., May 1979, Docket No. 40-8681, prepared by
the United States Nuclear Regulatory Commission (the "FES");
d) The following engineering, geological and hydrogeological reports:
(i) Umetco Groundwater Study, White Mesa Facilities, Blanding, Utah, 1993,
prepared by Umetco Minerals Corporation (the operator of the Mill at the time)
and Peel Environmental Services;
(ii) Hydrogeological Evaluation of White Mesa Uranium Mill, July 1994, prepared by
Titan Environmental Corporation (the "1994 Titan Report");
(iii) Evaluation of Potential for Tailings Cell Discharge-White Mesa Mill, November
23, 1998, prepared by Knight-Piesold LLC;
(iv) Investigation of Elevated chlorofonn concentrations in Perched Groundwater at
the White Mesa Uranium Mill Near Blanding, Utah, 2001, prepared by Hydro Geo
Chern, Inc.;
(v) Letter Report dated August 29, 2002, prepared by Hydro Geo Chern, Inc.;
(vi) Hydrogeology White Mesa Uranium Mill Site Near Blanding, Utah, June 6, 2012,
prepared by Hydro Geo Chern, Inc.;
e) The following plans and specifications relating to construction and operation of the
Mill's tailings cells:
(i) Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
(ii) Engineer's Report: Second Phase Design-Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by
D' Appolonia Consulting Engineers, Inc.;
14
(iii) Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia
Consulting Engineers, Inc.;
(iv) Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc. (the
operator of the Mill at the time);
(v) Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation (the operator of the Mill at the time);
(vi) Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by International Uranium (USA)
Corporation (the operator of the Mill at the time);
(vii) Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants;
(viii) Cell4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah,
July 2008, prepared by Geosyntec consultants;
(ix) Cell 4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007,
prepared by Geosyntec Consultants; and
(x) Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants.
f) The following documents relating to the chloroform investigation at the site:
Preliminary Corrective Action Plan, White Mesa Mill Near Blanding, Utah, August 20, 2007,
prepared by Hydro Geo Chern, Inc.;
(i) Contamination Investigation Report TW4-12 and TW4-27 Areas White Mesa
Uranium Mill, Near Blanding Utah, January 23, 2014 prepared by Hydro Geo
Chern, Inc.;
g) The following documents relating to the pH and other Out of Compliance
investigations at the site:
(i) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for
Constituents in the First, Second, Third and Fourth Quarters of 2010 and First
Quarter 2011, June 13, 2011;
(ii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for
15
Constituents in the Second Quarter of 2011, September 7, 2011;
(iii) Plan and Time Schedule for Assessment of pH Under Groundwater Discharge
Permit UGW370004, April13, 2012 prepared by Hydro Geo Chern, Inc;
(iv) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of2012, December 13, 2012;
(v) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Fourth Quarter of2012, March 15, 2013;
(vi) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the First Quarter of2013, August 28, 2013;
(vii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Second Quarter of2013, September 20, 2013;
(viii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of2013, December 5, 2013;
(ix) Source Assessment Report, White Mesa Uranium Mill, Blanding Utah, October
10,2012 prepared by INTERA, Inc;
(x) pH Report White Mesa Uranium Mill, Blanding Utah, November 9, 2012
prepared by INTERA, Inc;
(xi) Investigatiof! of Pyrite in the Perched Zone, White Mesa Uranium Mill, Blanding
Utah, December 7, 2012 prepared by Hydro Geo Chern, Inc;
(xii) Source Assessment Report for TDS in MW-29, White Mesa Uranium Mill,
Blanding Utah, May 7, 2013 prepared by INTERA, Inc;
(xiii) Source Assessment Report for Selenium in MW-31, White Mesa Uranium Mill,
Blanding Utah, August 30, 2013 prepared by INTERA, Inc;
(xiv) Source Assessment Report for Tetrahydrofuran in MW-01, White Mesa Uranium
Mill, Blanding Utah, December 17, 2013; prepared by INTERA, Inc.
(xv) Source Assessment Report for Gross Alpha in MW-32, White Mesa Uranium Mill,
Blanding Utah, January 13,2014 prepared by INTERA, Inc;
16
(xvi) Source Assessment Report for Sulfate in MW-01 and TDS in MW-03A, White
Mesa Uranium Mill, Blanding Utah, March 19, 2014 prepared by INTERA, Inc;
h) The following documents relating to the nitrate investigations at the site:
(i) Stipulated Consent Agreement Docket No. UGW12-03 between Denison Mines
(USA) Corp. and the Director of the Division of Radiation Control, July 12, 2012.
(ii) Revised Tolling Agreement, Revision 3, between DUSA and the Director,
Revision 2, dated August 21, 2011.
(iii) Revised Phase 1 (A through C) Work Plan and Schedule for Phase 1 A -C
Investigation, May 11, 2011, prepared by INTERA, Inc;
(iv) Revised Phase 2 through 5 Work Plan and Schedule, June 3, 2011, prepared by
INTERA, Inc;
(v) Revised Phase 2 QAP and Work Plan, Revision 2.0, July 12, 2011; and
(vi) Nitrate Corrective Action Plan, May 7, 2012, prepared by Hydro Geo Chern, Inc;.
(vii) Nitrate Contamination Investigation Report, December 30, 2009, prepared by
INTERA, Inc.
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
The Applicant and Mill Operator is Energy Fuels Resources (USA) Inc. ("EFRI"). EFRI is the
current holder of the Permit. The Mill is owned by EFRI' s affiliate, EFR White Mesa LLC
("EFRWM").
The address for both EFRI and EFRWM is:
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Telephone: [phone] Fax: [phone]
Contacts at EFRI, all located at the aforementioned office:
Harold R. Roberts, Executive Vice President, and Chief Operating Officer.
Direct telephone: [phone]
hroberts @energyfuels.com
17
Frank J. Filas
Vice President, Permitting and Environmental Affairs
Direct telephone: [phone]
ffilas @energyfuels.com
Katherine A. Weinel
Quality Assurance Manager
Direct telephone: [phone]
kweinel @energyfuels.com
2.2 Legal Location of the Facility (R317-6-6.3B)
The Mill is regionally located in central San Juan County, Utah, approximately 6 miles (9.5 km)
south of the city of Blanding. The Mill can be reached by taking a private road for
approximately 0.5 miles west of Utah State Highway 191. See Figure 1.
Within San Juan County, the Mill is located on fee land and mill site claims, covering
approximately 5,415 acres, encompassing all or part of Sections 21, 22, 27, 28, 29, 32, and 33 of
T37S, R22E, and Sections 4, 5, 6, 8, 9, and 16 of T38S, R22E, Salt Lake Base and Meridian
("SLBM"). See Figure 2.
All operations authorized by the Mill License are conducted within the existing site boundary.
The milling facility currently occupies approximately 50 acres, and the tailings disposal cells
encompass another 250 acres. See Figure 2.
2.3 Name and Type of Facility (R317-6-6.3.C)
The name of the facility is the White Mesa Uranium Mill. The facility is a uranium milling and
tailings disposal facility, which operates under a Radioactive Materials License issued by the
Director of the Utah Division of Radiation Control under UAC R313-24. In addition to uranium
in the form of U30 8, the Mill also produces vanadium, in the form of vanadium pentoxide
("V 2Q 5 .. ), ammonia metavanadate ("AMV") and vanadium pregnant liquor ("VPL"), from
certain conventional ores and has produced other metals from certain alternate feed materials
(specifically niobium and tantalum as authorized under NRC license amendment number 4,
included as Appendix A). Alternate feed materials are uranium bearing materials other than
conventionally mined ores.
Construction of the Mill was completed and first operations commenced in May 1980. The Mill
does not have a set operating life, and can operate indefinitely, subject to available tailings
capacity and license and permit renewals. The conceptual and permitted total capacity is for the
quantity of Mill tailings produced from a 15-year operating period at a rate of 2,000 tons per day,
operating 340 days per year. Since it commenced operations in 1980, the Mill has operated on a
campaign basis, processing conventional ores and alternate feed materials as they become
available and as economic conditions warrant.
18
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well, Drinking
Water Source Protection Zones, Topography, Springs, Water Bodies, Drainages, And Man-Made
Structures Within A One-Mile Radius Of The Discharge. (R317-6-6.3.D)
There are five deep wells within a one mile radius of the Mill, two of which supply the Mill
facility. There are no Drinking Water Source Protection Zones or ordinances within this radius.
Routine groundwater monitoring wells have been established for monitoring under the Permit.
These monitoring wells are depicted on Figure 10 and in Appendix B to this Application. The
depth and purpose of each of these wells is as shown in Tables 1.2-1, 1.2-2, and 2.4-1.
See Section 2.9.1.3 below for a detailed description of the Mill's groundwater monitoring
program.
The surface topography and man-made structures are shown on Figures presented in Appendix
B. See Sections 2.5.4 and 2.5.7 below for a more detailed discussion on local topography and
land use.
The Mill area has several dry drainages, and the only nearby natural water bodies within one
mile are Westwater Creek, Corral Creek and Cottonwood Creek. In addition to these are Ruin
Spring and several other springs and seeps located within a 1.5 mile radius of the Mill. See
Sections 2.5.3 and 2.13 below for discussions relating to seeps and springs in the vicinity of the
site and to surface water and drainages, respectively.
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317 -6-6.3.E)
2.5.1 Groundwater Characteristics
This Section is based on the Report entitled: Hydrogeology of the White Mesa Uranium Mill,
Blanding Utah June 6, 2014, prepared by Hydro Geo Chern, Inc. ("HGC") (the "2014 HGC
Report" referred to as HGC, 2014).
2.5.1.1 Geologic Setting
The Mill is located within the Blanding Basin of the Colorado Plateau physiographic province.
Typical of large portions of the Colorado Plateau province, the rocks underlying the site are
relatively undeformed. The average elevation of the site is approximately 5,600 ft (1,707 m)
above mean sea level ("amsl").
The site is underlain by unconsolidated alluvium and indurated sedimentary rocks consisting
primarily of sandstone and shale. The indurated rocks are relatively flat lying with dips generally
less than 3°. The alluvial materials consist mostly of aeolian silts and fine-grained aeolian sands
with a thickness varying from negligible to as much as 25 to 30 feet across the site. In some
portions of the site the alluvium is underlain by a few feet to as much as 30 feet of Mancos
Shale. In other areas, the Mancos Shale is absent. The alluvium and Mancos (where present) are
underlain by the Dakota Sandstone and Burro Canyon Formation, which are sandstones having a
combined total thickness ranging from approximately 55 to 140 feet (17 to 43 m). Beneath the
Burro Canyon Formation lies the Morrison Formation, consisting, in descending order, of the
Brushy Basin Member, the Westwater Canyon Member, the Recapture Member, and the Salt
Wash Member. The Brushy Basin and Recapture Members of the Morrison Formation, classified
19
as shales, are very fine-grained and have a very low permeability. The Brushy Basin Member is
primarily composed of bentonitic mudstone, siltstone, and claystone. The Westwater Canyon
and Salt Wash Members are primarily sandstones but are expected to have a low average vertical
permeability due to the presence of interbedded shales. See Figure 3 for a generalized
stratigraphic column for the region.
Beneath the Morrison Formation lies the Summerville Formation, an argillaceous sandstone with
interbedded shales, and the Entrada Sandstone. Beneath the Entrada lies the Navajo Sandstone.
The Navajo and Entrada Sandstones constitute the primary aquifer in the area of the site. The
Entrada and Navajo Sandstones are separated from the Burro Canyon Formation by
approximately 1,000 to 1,100 feet (305 to 355 m) of materials having a low average vertical
permeability. Groundwater within this system is under artesian pressure in the vicinity of the site,
is of generally good quality, and is used as a secondary source of water at the site.
2.5.1.2 Hydrogeologic Setting
The site is located within a region that has a dry to arid continental climate, with average annual
precipitation of approximately 13.3 inches, and an average annual lake evaporation rate of
approximately 47.6 inches. Recharge to the principal aquifers (such as the Navajo/Entrada)
occurs primarily along the mountain fronts (for example, the Henry, Abajo, and La Sal
Mountains), and along the flanks of folds such as Comb Ridge Monocline.
Although the water quality and productivity of the Navajo/Entrada aquifer are generally good,
the depth of the aquifer (approximately 1,200 feet below land surface [ft bls]) makes access
difficult. The Navajo/Entrada aquifer is capable of yielding significant quantities of water to
wells (hundreds of gallons per minute [gpm]). Water in on-site wells completed within the
Navajo/Entrada rises approximately 800 feet above the base of the overlying Summerville
Formation.
The shallowest groundwater beneath the site consists of perched water hosted primarily by the
Burro Canyon Formation. Perched water is used on a limited basis to the north (upgradient) of
the site because it is much shallower and more easily accessible than the deep Navajo/Entrada
aquifer.
2.5.1.3 Perched Zone Hydrogeology
Perched groundwater originates mainly from precipitation and local recharge sources such as
unlined reservoirs (Kirby, 2008) and is supported within the Burro Canyon Formation by the
underlying, fine-grained Brushy Basin Member. Perched groundwater at the site is generally of
poor quality due to high total dissolved solids ("TDS") in the range of approximately 1,100 to
7,900 milligrams per liter ("mg/L"). Its relatively poor quality is one reason that perched water is
used primarily for stock watering and irrigation in areas up gradient (north) of the site. Figure 4 is
a contour map showing the approximate elevation of the contact of the Burro Canyon Formation
with the Brushy Basin Member, which essentially forms the base of the perched water zone at
the site. Based on Figure 4, the Burro Canyon Formation/Brushy Basin Member contact
generally dips to the south/southwest beneath the site.
20
Figure 5 is a perched groundwater elevation contour map for the first quarter, 2014. Based on the
contoured water levels, groundwater within the perched zone flows generally south to southwest
beneath the site. Beneath the tailings cells, perched groundwater flow is generally to the
southwest.
Perched groundwater discharges from outcrops of the Burro Canyon Formation in seeps and
springs along Westwater Creek Canyon and Cottonwood Canyon (to the west-southwest of the
mill site and tailings cells) and along Corral Canyon (to the east and northeast of the mill site and
tailings cells). Known discharge points include the seeps and springs shown in Figure 5 except
Cottonwood Seep. As discussed in (HGC, 2014), Cottonwood Seep is located more than 1,500
feet west of White Mesa in an area where the Dakota Sandstone and Burro Canyon Formation
(which hosts the perched water system) are absent due to erosion, and at an elevation
approximately 230 feet below the base of the perched zone defined by the contact between the
Burro Canyon Formation and the underlying Brushy Basin Member. Cottonwood Seep occurs
near the contact between the slope-forming Brushy Basin Member and the underlying Westwater
Canyon (sandstone) Member.
Contact elevations shown in Figure 4 are based on perched monitoring well drilling and
geophysical logs and surveyed land surface elevations, and the surveyed elevations of Westwater
Seep and Ruin Spring. The elevations of Westwater Seep and Ruin Spring are included in the
kriged contours because they occur at the contact between the Burro Canyon Formation and the
underlying Brushy Basin Member.
Groundwater elevations shown in Figure 5 include the surveyed elevations of all seeps and
springs except Cottonwood Seep. As discussed above, no evidence exists to connect Cottonwood
Seep to the perched water system. Although Cottonwood Seep may potentially receive some
contribution from perched water, its occurrence near the contact between the Brushy Basin
Member and the underlying Westwater Canyon Member indicates that its elevation is not
representative of the perched water system.
The permeabilities of the Dakota Sandstone and Burro Canyon Formation at the site are
generally low. No significant joints or fractures within the Dakota Sandstone or Burro Canyon
Formation have been documented in any wells or borings installed across the site (Knight
Piesold, 1998). Any fractures observed in cores collected from site borings are typically
cemented, showing no open space.
Porosities and water contents of the Dakota Sandstone have been measured in samples collected
during installation of former well MW-16 and well MW-17 (Figure 5). MW-16 was located
immediately downgradient of tailings Cell 3 and MW -17 is located south of tailings Cell 4A at a
location primarily cross-gradient with respect to perched water flow. Porosities of the Dakota
Sandstone range from 13.4% to 26%, averaging 20%, and water saturations range from 3.7% to
27.2%, averaging 13.5%. The average volumetric water content is approximately 3%. The
hydraulic conductivity of the Dakota Sandstone based on packer tests in borings installed at the
jte prior to 1994 ranges from 2.71 x 10-6 centimeters per second ("cm/s") to 9.12x 10-4 cm/s,
with· a geomelric average of 3.89 x 10-5 cm/s (TITAN, 1994).
21
The average porosity of the Burro Canyon Formation is similar to that of the Dakota Sandstone.
Based on samples collected from the Burro Canyon Formation at former well MW-16 porosity
ranges from 2% to 29.1 %, averaging 18.3%, and water saturations of unsaturated materials range
from 0.6% to 77.2%, averaging 23.4% (TITAN, 1994). These porosities are similar to those
reported by MWH (MWH, 2010) for archived samples from borings MW-23 and MW-30.
Extensive hydrogeologic characterization of the saturated Burro Canyon Formation has occurred
through hydraulic testing of perched monitoring wells and borings at the site. Hydraulic testing
of MW -series wells located up gradient, cross-gradient, downgradient, and within the millsite and
tailings cell complex, TW 4-series wells located cross-gradient to up gradient of the millsite and
tailings cells, TWN-series wells located primarily upgradient of the millsite and tailings cells,
and DR-series piezometers, located downgradient of the tailings cells, indicate that the hydraulic
conductivity of the perched zone ranges from approximately 2 x 10-8 to 0.01 cm/s.
TITAN (1994), reported that the hydraulic conductivity of the Burro Canyon Formation ranges
from 1.9 x 10-7 to 1.6 x 10 -3 cm/s, with a geometric mean of 1.01 x 10-5 cm/s, based on the
results of 12 pumping/recovery tests performed in monitoring wells and 30 packer tests
performed in borings prior to 1994. The range reported by TIT AN ( 1994) is within the hydraulic
conductivity range of approximately 2 x 10-8 to 0.01 cm/s reported by HGC (HGC, 2014).
In general the highest permeabilities and well yields are in the area of the site immediately
northeast and east (upgradient to cross gradient) of the tailings cells. A relatively continuous,
higher permeability zone (associated with poorly indurated coarser-grained materials in the
general area of the chloroform plume) has been inferred to exist in this portion of the site.
Analysis of drawdown data collected from this zone during long-term pumping of MW-4, MW-
26 (TW4-15), and TW4-19 (Figure 5) yielded estimates of hydraulic conductivity ranging from
approximately 4 X 10-5 to 1 X 10-3 cm/s (HGC, 2014). The decrease in perched zone permeability
south to southwest of this area (south of TW4-4), based on tests at TW4-6, TW4-26, TW4-27,
TW4-29 through TW4-31, and TW4-33 and TW4-34, indicates that this higher permeability
zone "pinches out".
Relatively high conductivities measured at MW-11, located on the southeastern margin of the
downgradient edge of tailings Cell 3, and at MW-14, located on the downgradient edge of
tailings Cell4A, of 1.4 x 10-3 cm/s and 7.5 x 10-4 cm/s, respectively, may indicate that this higher
permeability zone extends beneath the southeastern portion of the tailings cell complex.
However, based on hydraulic tests south and southwest of these wells, this zone of higher
permeability does not appear to exist within the saturated zone downgradient (south-southwest)
of the tailings cells.
Slug tests performed at groups of wells and piezometers located northeast (upgradient) of, in the
immediate vicinity of, and southwest (downgradient) of the tailings cells indicate generally lower
permeabilities compared with the area of the chloroform plume. The following results are based
on analysis of automatically logged slug test data using the KGS solution available in
AQTESOL VE (HydroSOLVE, 2000).
Testing of TWN-series wells installed in the northeast portion of the site as part of nitrate
investigation activities yielded a hydraulic conductivity range of approximately 3.6 x 10-7 to 0.01
22
cm/s, with a geometric average of approximately 6 x 10-5 cm/s. The value of 0.01 cm/s estimated
for TWN-16 is the highest measured at the site, and the value of 3.6 x 10-7 cm/s estimated for
TWN-7 is one of the lowest measured at the site. Testing of MW-series wells MW-23 through
MW-32 jn tl.l lled between and at the margins of the tailing ce1l i11 2005 (a.nd using the higher
estimate f, r MW-23) yie lded a bydrallJic condu tivi ty r~oe of npproxim·1tely 2 x 10-7 to 1 x 10-4
cm/s with a geometric average f approximately 2 x w-emf . Hydraulic test onducted at DR-
eries pj ez meteJ. in talJed as part of the southwest area investigation downgradient of the
taiJring · cell yielded hydraulic conductivities ranging from approximately 2 x 10-8 to 4 x 10-4
emf with a geometric average of 9.6 x 10-6 cm/s. The low permeabilities and shallow hydraulic
gradients downgradient of the tailings cells result in average perched groundwater pore velocity
estimates that are among the lowest on site (approximately 0.26 feet per year (ft/yr) to 0.91 ft/yr).
The extensive hydraulic testing of perched zone wells at the site indicates that perched zone
permeabilities are generally low with the exception of the apparently isolated zone of higher
permeability associated with the chloroform plume east to northeast (cross-gradient to
upgradient) of the tailings cells. The geometric average hydraulic conductivity (approximately 1
x 10-5 cm/s) of the DR-series piezometers which cover an area nearly half the size of the total
monitored area at White Mesa (excluding MW-22), is nearly identical to the geometric average
hydraulic conductivity of 1.01 x 10-5 cm/s reported by TITAN (1994), and is within the range of
5 to 10 feet per year (ft/yr) [approximately 5 x 10-6 cm/s to 1 x 10-5 cm/s] reported by Dames and
Moore (1978) [the 1978 ER] for the (saturated) perched zone during the initial site investigation.
Because of the generally low permeability of the perched zone beneath the site, well yields are
typically low (less than 0.5 gpm), although sustainable yields of as much as 4 gpm (for example,
at TW4-19, shown in Figure 5) are possible in wells intercepting the relatively large saturated
thicknesses within the higher permeability zone located east to northeast (cross-gradient to
upgradient) of the tailings cells at the site. Sufficient productivity can generally be obtained only
in areas where the saturated thickness is greater, which is one reason that 1) some perched zone
wells completed near the northern wildlife ponds are relatively productive and 2) the perched
zone has been used on a limited basis as a water supply to the north (upgradient) of the site.
2.5.1.4 Perched Groundwater Flow
Perched groundwater flow at the site has historically been to the south/southwest. Figure 5
groundwater elevations indicate that beneath and south of the tailings cells, in the west central
portion of the site, perched water flow is south-southwest to southwest. Flow on the western
margin of White Mesa is generally south, approximately parallel to the mesa rim (where the
Burro Canyon Formation [and perched zone] is terminated by erosion). On the eastern side of the
site, perched water flow is also generally southerly. Near the wildlife ponds, flow direction
ranges locally from westerly (west of the ponds) to easterly (east of the ponds) resulting in a
generally north-south perched water divide along a line connecting the ponds. Cones of
depression result from pumping of chloroform wells MW-4, TW4-4, TW4-19, TW4-20, and
MW-26 and nitrate wells TWN-02, TW4-22, TW4-24, and TW4-25. These wells are pumped to
reduce chloroform and nitrate mass in the perched zone east and northeast of the tailings cells.
23
In general, perched groundwater elevations have not changed significantly at most of the site
monitoring wells since installation, except in the vicinity of the wildlife ponds and the pumping
wells. For example, relatively large increases in water levels occurred between 1994 and 2002 at
MW-4 and MW-19, located in the east and northeast portions of the site. These water level
increases in the northeastern and eastern portions of the site are the result of seepage from
wildlife ponds located near piezometers PIEZ-1 through PIEZ-5 shown in Figure 5, which were
installed in 2001 for the purpose of investigating these changes. The mounding associated with
the wildlife ponds and the general increase in water levels in the northeastern portion of the/ site
have resulted in a local steepening of groundwater gradients over portions of the site.
Conversely, pumping of chloroform wells MW-4, TW4-4, TW4-19, TW4-20, and MW-26 and
nitrate wells TWN-02, TW4-22, TW4-24, and TW4-25 has depressed the perched water table
locally and reduced average hydraulic gradients to the south and southwest of these wells. At the
request of DRC, water has not been delivered to the northern wildlife ponds since March, 2012.
The perched water mound associated with recharge from these ponds is diminishing and is
expected to continue to diminish, thereby reducing hydraulic gradients downgradient of the
ponds, in particular to the south and southwest.
As discussed above, perched water discharges in springs and seeps along Westwater Creek
Canyon and Cottonwood Canyon to the west-southwest of the site, and along Corral Canyon to
the east of the site. The known discharge points located directly downgradient of the tailings
cells are Westwater Seep and Ruin Spring. These features are located more than 2,000 feet west-
southwest and more than 9,000 feet south-southwest of the tailings cells at the site as shown in
Figure 5.
DR-8, located approximately 4,000 feet southwest of the tailings cells, is located near the mesa
rim above Cottonwood Seep along a line between the tailings cells and Cottonwood Seep. There
is no evidence to connect Cottonwood Seep to the perched water system as it is separated from
the perched water by approximately 230 feet of low permeability shales and mudstones.
However, under hypothetical conditions that Cottonwood Seep receives some contribution from
perched water, perched water passing beneath the tailings cells would presumably pass by DR-8
before continuing on an unidentified potential pathway toward Cottonwood Seep.
Figure 5 shows perched water pathlines southwest of the tailings cells based on first quarter,
2014 perched water level data. Paths 1 and 3 represent the shortest pathlines to discharge points
Westwater Seep and Ruin Spring, respectively. Path 2 is the shortest pathline to DR-8, located
near the edge of the mesa above Cottonwood Seep. A potential pathline is drawn from DR-8 to
Cottonwood Seep. Although there is no evidence to connect Cottonwood Seep to the perched
water system, this potential pathline is represented to allow for the possibility of an as yet
unidentified connection. Westwater Seep is downgradient of tailings Cell 1 and the western
portions of Cells 2, 3, and 4B. DR-8 is downgradient of tailings Cells 2, 3 and 4B. Ruin Spring is
downgradient of Cell4A, and the eastern portions of Cells 2, 3, and 4B.
2.5.1.5 Perched Zone Hydrogeology Beneath And Down gradient Of The Tailings Cells
The perched zone hydrogeology southwest (downgradient) of the tailings cells is similar to other
areas of the site except that the saturated thicknesses are generally smaller, portions of the
perched zone are dry, and hydraulic gradients and hydraulic conductivities are relatively low.
24
The combination of shallow hydraulic gradients, relatively low permeabilities, and small
saturated thicknesses, results in rates of perched water movement that are among the lowest on-
site.
In the immediate vicinity of the tailings cells, perched water was encountered at depths of
approximately 53 to 117ft below the top of casing ("btoc") as of the first quarter of 2014 (Figure
7). Beneath tailings Cell 3, depths to water ranged from approximately 67 feet in the eastern
portion of the cell, to approximately 117 ft btoc at the southwest margin of the cell. Assuming an
average depth of the base of tailings Cell 3 of 25 feet below grade, this corresponds to perched
water depths of approximately 42 to 92 feet below the base of the cell, and an average depth of
approximately 65 feet beneath the base of the cell.
Beneath tailings Cell 4B, depths to water ranged from approximately 106 ft btoc in the
northeastern portion of the cell (at MW-5), to approximately 112ft btoc at the southwest margin
of the cell (at MW-35). Assuming an average depth of the base of tailings Cell 4B of 25 feet
below grade, this corresponds to perched water depths of approximately 81 to 87 feet below the
base of the cell, and an average depth of approximately 84 feet beneath the base of the cell.
The saturated thickness of the perched zone in the immediate vicinity of the tailings cells as of
the first quarter of 2014 ranges from approximately 80 feet to negligible (Figure 8). Beneath
tailings Cell 3, the saturated thickness varies from approximately 60 feet in the eastern portion of
the cell to approximately 7 feet in the western portion of the cell. Beneath tailings Cell 4B, the
saturated thickness varies from approximately 21 feet in the southeastern portion of the cell to
negligible in the southwestern portion of the cell, where a dry zone, defined by MW-33 and
former (his tori call y dry) well MW -16, is present.
Saturated thicknesses in the southwest area of the site are affected by the ridge-like high in the
Burro Canyon Formation/Brushy Basin Member contact (see Figure 4). As shown in Figures 5
and 8, dry to low saturated thickness conditions are associated with this paleoridge.
South-southwest of the tailings cells, the saturated thickness ranges from negligible at MW-21
(historically dry) to approximately 25 feet at DR-9. Small saturated thicknesses (less than 3 feet)
near DR-6, DR-7, and DR-9 (west and southwest of Cell 4B) result from the paleoridge. The
average saturated thickness based on measurements at MW-37, DR-13, MW-3, MW-20, and
DR-21, which lay close to a line between the southeast portion of tailings Cell 4B and Ruin
Spring, is approximately 8 feet. The average saturated thickness based on measurements at MW-
35, DR-7, and DR-6, which are the points closest to a line between the southeast portion of
tailings Cell 3 and Westwater Seep, is approximately 5 feet.
Perched zone hydraulic gradients currently range from a maximum of approximately 0.075 feet
per foot ("ft/ft") east of tailings cell 2 (near the eastern portion of the chloroform plume) to
approximately 0.0022 ft/ft in the northeast corner of the site (between TWN-19 and TWN-16).
Hydraulic gradients in the southwest portion of the site are typically close to 0.01 ft/ft, but the
gradient is less than 0.005 ft/ft west/southwest of tailings Cell 4B, between Cell 4B and DR-8.
The overall average site hydraulic gradient, between TWN-19 in the extreme northeast to Ruin
Spring in the extreme southwest, is approximately 0.011 ft/ft. A hydraulic gradient between the
25
west dike of tailings Cell 3 and Westwater Seep is approximately 0.0122 ft/ft, and between the
south dike of tailings Cell4B and Ruin Spring, approximately 0.0118 ft/ft
2.5.2 Groundwater Quality
2.5.2.1 Entrada/Navajo Aquifer
The Entrada and Navajo Sandstones are prolific aquifers beneath and in the vicinity of the site.
Water supply wells at the site are screened in both of these units, and therefore, for the purposes
of this discussion, they will be treated as a single aquifer. Water in the Entrada/Navajo Aquifer
is under artesian pressure, rising 800 to 900 ft above the top of the Entrada's contact with the
overlying Summervillle Formation; static water levels are 390 to 500 ft below ground surface.
Within the region, this aquifer is capable of yielding domestic quality water at rates of 150 to 225
gpm, and for that reason, it serves as a secondary source of water for the Mill. Additionally, two
domestic water supply wells drawing from the Entrada/Navajo Aquifer are located 4.5 miles
southeast of the Mill site on the Ute Mountain Ute Reservation. Although the water quality and
productivity of the Navajo/Entrada aquifer are generally good, the depth of the aquifer (>1,000 ft
bls) makes access difficult.
Table 2.5.2.1-1 is a tabulation of groundwater quality of the Navajo Sandstone aquifer as
reported in the FES and subsequent sampling. TDS ranges from 244 to 1,110 mg/liter in three
samples taken over a period from January 27, 1977, to May 4, 1977. High iron (0.057 mg/liter)
concentrations are found in the Navajo Sandstone. Because the Navajo Sandstone aquifer is
isolated from the perched groundwater zone by approximately 1,000 to 1,100 ft of materials
having a low average vertical permeability, sampling of the Navajo Sandstone is not required
under the Mill's previous NRC Point of Compliance monitoring program or under the Permit.
However, samples were taken at two other deep aquifer wells (#2 and #5) on site (See Figure 9
for the locations of these wells), on June 1, 1999 and June 8, 1999, respectively, and the results
are included in Table 2.5.2.1-1.
2.5.2.2 Perched Groundwater Zone
Perched groundwater in the Dakota/Burro Canyon Formation is used on a limited basis to the
north (upgradient) of the site because it is more easily accessible. The quality of the Burro
Canyon perched water beneath and downgradient from the site is poor and extremely variable.
The concentrations of TDS measured in water sampled from upgradient and downgradient wells
range between approximately 600 and 5,300 mg/1. Sulfate concentrations measured in three
upgradient wells varied between 670 and 1,740 mg/1 (Titan, 1994). The perched groundwater
therefore is used primarily for stock watering and irrigation. The saturated thickness of the
perched water zone generally increases to the north of the site. See Section 2.11.2 below for a
more detailed discussion of background ground water quality in the perched aquifer.
2.5.3 Springs and Seeps
As discussed in Section 2.5.1.4, perched groundwater at the Mill site discharges in springs and
seeps along Westwater Creek Canyon and Cottonwood Canyon to the west-southwest of the site,
and along Corral Canyon to the east of the site, where the Burro Canyon Formation outcrops.
26
Water samples have been collected and analyzed from springs and seeps in the Mill vicinity as
part of the baseline field investigations reported in the 1978 ER (See Table 2.6-6 in the 1978
ER).
During the period 2003-2004, EFRI implemented a sampling program for seeps and springs in
the vicinity of the Mill which had been sampled in 1978, prior to the Mill's construction. Four
locations were designated for sampling, as shown on Figure 9. These are Ruin Spring (G3R),
Cottonwood Seep (G4R), west of Westwater Creek (G5R) and Corral Canyon (G1R). During
the 2-year study period only two of the four locations could be sampled, Ruin Spring and
Cottonwood Canyon. The other two locations, Corral Creek and the location west of Westwater
Creek were not flowing (seeping), and samples could not be collected. With regard to the
Cottonwood seep, while water was present, the volume was not sufficient to complete all
determinations, and only organic analyses were conducted. Analysis of the Cottonwood Seep
water samples did not detect any organics.
Samples at Ruin Spring were analyzed for major ions, physical properties, metals, radionuclides,
volatile and semi-volatile organic compounds, herbicides and pesticides, and synthetic organic
compounds. With the exception of one chloromethane detection, all organic determinations were
at less than detectable concentrations. The detection of chloromethane is not uncommon in
groundwater and can be due to natural sources. In fact, chloromethane has been observed by
EFRI at detectable concentrations in field blank samples during routine groundwater sampling
events. The results of sampling for the other parameters tested are shown in Table 2.5.3-1. The
results of the 2003/2004 sampling did not indicate the presence of mill derived groundwater
constituents and are representative of background conditions.
As required by Part I.E.6 of the Permit, the Mill has implemented a Sampling Plan for Seeps and
Springs. Per Part I.E.6 of the Permit, sampling of seeps and springs in required annually. A copy
of the approved Sampling Plan for Seeps and Springs Revision 1, dated June 10, 2011, is
included as Appendix C to this Application. EFRI submitted Revision 1.0 on June 10, 2011.
Revision 1.0 is currently undergoing review by the Director. See Section 2.12.2 below for a
more detailed description of the Plan. The first sampling under the Plan was completed in
August, 2009. A summary of sampling results from the 2009through 2013 sampling events,
performed under the approved Sampling Plan for Seeps and Springs, is provided in Table 2.5.3-2
through Table 2.5.3-5.
2.5.4 Topography
The Mill site is located on a gently sloping mesa that, from the air, appears similar to a
peninsula, as it is surrounded by steep canyons and washes and is connected to the Abajo
Mountains to the north by a narrow neck of land. On the mesa, the topography is relatively flat,
sloping at less than one (1) percent to the south and nearly horizontal from east to west. See also
Figure 6.
2.5.5 Soils
The majority (99%) of the soil at the Mill site consists of the Blanding soil series (1978 ER,
Section 2.1 0.1.1 ). The remaining 1% of the site is in the Mellenthin soil series. Because the
27
Mellenthin soil occurs only on the eastern-central edge of the site (1978 ER, Plate 2.10-1), the
FES (Section 2.8) concluded that it should not be affected by Mill construction and operation.
The Mill and associated tailings cells are located on Blanding silt loam, a deep soil formed from
wind-blown deposits of fine sands and silts. Although soil textures are predominantly silt loam,
silty-clay-loam textures are found at some point in most profiles (See Appendix D to this
Application-Results of Soil Analysis at Mill Site). This soil generally has a 4 to 5 inch reddish-
brown, silt-loam A horizon and a reddish-brown, silt-loam to silty-clay-loam B horizon. The B
horizon extends downward about 12 to 16 inches where the soil then becomes calcareous silt-
loam or silty-clay-loam, signifying the C horizon. The C horizon and the underlying parent
material are also reddish-brown in color.
The A and B horizon both are non-calcareous with an average pH of about 8.0, whereas the C
horizon is calcareous with an average pH of about 8.5. Subsoil sodium levels range up to 12% in
some areas, which is close to the upper limit of acceptability for use in reclamation work (1978
ER, Sect. 2.1 0.1.1). Other elements, such as boron and selenium, are well below potentially
hazardous levels. Potassium and phosphorus values are high in this soil (1978 ER, Table 2.10-2)
and are generally adequate for plant growth. Nitrogen, however, is low (1978 ER, Sect. 2.10.1.1)
and may have to be provided for successful revegetation during final reclamation.
With well-drained soils, relatively flat topography (see Section 2.5.4), and limited annual
precipitation (see Section 2.5.1.2), the site generally has a low potential for water erosion.
However, the flows resulting from thunderstorm activity are nearly instantaneous and, without
the Mill's design controls, could result in substantial erosion. When these soils are barren, they
are considered to have a high potential for wind erosion. Although the soil is suitable for crops,
the low percentage of available moisture (6 to 9%) is a limiting factor for plant growth;
therefore, light irrigation may be required to establish native vegetation during reclamation.
2.5.6 Bedrock
Subsurface conditions at the Mill site area were investigated as part of the 1978 ER by drilling,
sampling, and logging a total of 28 borings which ranged in depth from 6.5 to 132.4 ft. Of these
borings, 23 were augured to bedrock to enable soil sampling and estimation of the thickness of
the soil cover. The remaining 5 borings were drilled through bedrock to below the perched water
table, with continuous in situ permeability testing where possible and selective coring in
bedrock. The soils encountered in the borings were classified, and a complete log for each
boring was maintained. See Appendix A of Appendix H of the 1978 ER.
Borings in the footprint of the existing tailings cells reported calcareous, red-brown sands and
silts from the surface to a depth of 15 ft, averaging over 7 ft. Borings in the general area of the
Mill site and the tailings cells reported calcareous, red-brown sands and silts from the surface to
a depth of 14 ft, averaging over 9 ft. Downgradient of the tailings cells, calcareous sands and
silts extend to a depth of 17 ft of the surface. The calcareous silts and sands of the near-surface
soils grade to weathered claystones or weathered sandstones, inter-layered with weathered
claystone and iron staining. At depth, the weathered claystone or weathered clayey sandstone
grade into sandstone with inter-layered bands of claystone, gravel, and conglomerate. Some
conglomerates are cemented with a calcareous matrix.
28
2.5.7 Agricultural and Land Use Description of the Area
Approximately 65.8% of San Juan County is federally owned land administered by the U.S.
Bureau of Land Management, the National Park Service, and the U.S. Forest Service. Primary
land uses include livestock grazing, wildlife range, recreation, and exploration for minerals, oil,
and gas. Approximately 22% of the county is Native American land owned either by the Navajo
Nation or the Ute Mountain Ute Tribe. The area within 5 miles of the Mill site is predominantly
range land owned by residents of Blanding. The Mill site itself, including tailings cells,
encompasses approximately 300 acres.
A more detailed discussion of land use at the Mill site, in surrounding areas, and in southeastern
Utah, is presented in the FES (Section 2.5). Results of archeological studies conducted at the site
and in the surrounding areas as part of the 1978 ER are also documented in the FES (Section
2.5.2.3).
2.5.8 Wen Logs
Well/boring logs for wells MW-1, MW-2, MW-3, MW-4 (not a compliance well under the
Permit), MW-5, MW-11, MW-12, MW-14, MW-15, MW-16 (not a compliance well under the
Permit and abandoned during the construction of Tailings Cell 4B), MW -17, MW -18, and MW-
19, are included as Appendix A to the 1994 Titan Report. A copy of the 1994 Titan Report was
previously submitted under separate cover.
Lithologic and core logs for wells MW-3A, MW-23, MW-24, MW-25, MW-27, MW-28, MW-
29, MW-30 and MW-31 are included as Appendix A to the Report: Perched Monitoring Well
Installation and Testing at the White Mesa Uranium Mill April Through June 2005, August 3,
2005, prepared by Hydro Geo Chern, Inc. A copy of that Report was previously submitted under
separate cover.
Lithologic and core logs for well MW-26 (previously named TW4-15) and well MW-32
(previously named TW4-17) are included as Appendix A to the Letter Report dated August 29,
2002, prepared by Hydro Geo Chern, Inc. and addressed to Harold Roberts.
Lithologic and core logs for well MW-33, MW-34 and well MW-35 are included as Appendix A
to the Installation and Hydraulic Testing of Perched Monitoring Wells MW-33, MW-34, and
MW-35 at the White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chern,
Inc. October 11, 2010. A copy of that Report was previously submitted under separate cover.
Lithologic and core logs for well MW-36 and well MW-37 are included as Appendix A to the
Installation and Hydraulic Testing of Perched Monitoring Wells MW-36 and MW-37 at the
White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chern, Inc. June 28,
2011. A copy of that Report was previously submitted under separate cover.
Installation logs for wells installed after 2011 are included in the As-Built Reports for each well.
29
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of the
Effluent or Leachate to be Discharged (R317 -6-6.3.F)
The Mill is designed not to discharge to groundwater or surface waters. Instead, the Mill
utilizes tailings and evaporation Cells for disposal or evaporation of Mill effluents as indicated
below:
• Cell 1: dedicated to evaporation of Mill waste solutions;
• Cell 2: contains Mill tailings, has an interim cover and is closed to future tailings
disposal;
• Cell 3: contains Mill tailings and is in the final stages of filling;
• Cell4A: receives Mill tailings and is used for evaporation of Mill solutions; and
• Cell 4B: authorized to receive Mill tailings but currently is used only for evaporation of
Mill solutions.
See Sections 2.7.2 through 2.7.4 below for a more detailed discussion of the Mill's tailings
cells.
The projected chemical and radiological characteristics of tailings solutions were assessed by
Energy Fuels Nuclear, Inc., a predecessor operator of the Mill, and NRC in 1979 and 1980,
respectively. In addition, early samples were assessed by D' Appolonia Engineering as the Mill
started operations to further evaluate and project the character of the solutions. Samples of
tailings after the Mill was fully operational were collected by NRC (1987), EFRI/UDEQ
(2003), and EFRI (2007 -2013),. Samples collected in 2003 were obtained under the oversight
of DRC personnel. The Samples collected in 2007 and 2008 were obtained by EFRI on a
voluntary basis as the then proposed Tailings and Slimes Drain Sampling Plan (the "Tailings
Sampling Plan") had not been approved by the Director at that time. The 2009 samples were
collected on August 6, 2009 under the Tailings Sampling Plan that was approved at that time.
Subsequent annual sampling has been performed in August 2010, 2011, 2012 and 2013 under
an approved Tailings Sampling Plan. A copy of the currently approved Tailings Sampling
Plan is included as Appendix L.
The chemical and radiological characteristics of the solutions held in the tailings cells, based on
the sample results described above, are provided in the tables included in Appendix E, which
list the concentration of parameters measured in accordance with the Permit.
There is no active discharge from the tailings Cells; therefore, an estimation of the flow rate
("gpd") is not applicable in this instance. However, when operating at full capacity, the Mill
discharges approximately 2000 tons per day of dry tailings and approximately 600 gpm of
tailings solutions to the Mill's tailings cells.
2.7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate Into or
Adversely Affect the Quality of any Other Waters of the State (R317-6-6.3.G)
2.7.1 General
The Mill has been designed as a facility that does not discharge to groundwater or surface water.
All tailings and other Mill wastes are disposed of permanently into the Mill's tailings system.
Excess waters are disposed of in the tailings or evaporation cells, where they are subject to
evaporation, or re-processed through the Mill circuit. See Section 2.6.
30
The Mill was also designed ;md constructed to prevent runon or runoff of storm water by a)
diverting runoff from precipitation on the Mill site to the tailings cells; and b) diverting runoff
from surrounding areas away from the Mill site.
The Permit therefore does not authorize any discharges to groundwater or surface water, but is
intended to protect against potential inadvertent or unintentional discharges, such as through
potential failure of the Mill's tailings system.
The Mill's tailings system is currently comprised of four tailings cells (Cells 2, 3 4A, and 4B)
and one evaporation pond (Cell 1). Diagrams showing the Mill facility layout, including the
existing tailings cells are included as Figures 10 and 11 to this Application. In addition, the Mill
has a lined catchment basin, used for temporary storage of Mill process upset fluids, known as
"Roberts Pond". Roberts Pond is about 0.7 acres in size, and located approximately 180 feet
west of the Mill building and about 200 feet east of the northeast corner of Cell 1.
The following sections describe the primary Discharge Minimization Technology ("DMT") and
Best Available Technology ("BAT") features of the Mill, which demonstrate that the wastes and
tailings at the Mill can be controlled so that they do not migrate into or adversely affect the
quality of any waters of the State, including groundwater and surface water.
2. 7.2 Cells 1, 2 and 3
2.7.2.1 Design and Construction of Cells 1, 2 and 3
Tailings Cells 1, 2 and 3 were each constructed more than 25 years ago. Construction of Cell 2
was completed on May 3, 1980, construction of Cell 1 was completed on June 29, 1981, and
construction of Cell3 was completed on September 15, 1982.
Each of Cells 1, 2 and 3 are constructed below grade. Each has a single 30 rnl PVC flexible
membrane liner ("FML") constructed of solvent welded seams on a prepared sub base. A
protective soil cover layer was constructed immediately over the FML with a thickness of 12-
inches on the cell floor and 18-inches on the interior sideslope. The criterion for placement of
the FML in Cells 1, 2 and 3 was a smooth sub base with no rocks protruding that could
potentially damage the FML. The cells were excavated by ripping the in-place Dakota
Sandstone with a large dozer. Where the rock could not be efficiently ripped, explosives were
used to loosen the rock. The cell bottom was then graded to the final design contours and rolled
with a smooth drum vibrating roller. The smooth drum roller effectively crushed the loose
sandstone, filling in small holes, and allowed for a smooth surface suitable for liner placement.
Due to the excavation methods (ripping and blasting) there were some areas that required little or
no fill to meet final grades, while other areas required placement of additional crushed sandstone
to meet the final grade. The cell bottom was sometimes re-worked several times to accomplish
the desired result. The majority of the cell bottom is covered with a layer (1 to 6 inches) of
crushed sandstone while the liner in some areas is placed directly on a smooth rolled surface of
Dakota Sandstone with only a thin veneer of re-compacted sandstone. In places where the
surface was rough or contained small holes, washed concrete sand was used to fill or smooth the
imperfections, and the area was then rolled one last time before FML placement. Areas of
31
crushed sandstone filled sub base versus areas with little or no crushed sandstone base were not
documented during construction. Areas filled or smoothed with washed concrete sand is likely
less than 0.1% of the cell bottoms. Beneath this underlay, native sandstone and other foundation
materials were graded to drain to a single low point near the upstream toe of the south cross-
valley dike. Inside this layer, is an east-west oriented pipe to gather fluids at the upstream toe of
the cross-valley dike. The crushed sandstone layer draining to the pipe at the upstream toe of the
dike of the cell was intended to be a leak detection system for each cell. However, because the
design of these leak detection systems does not meet current BAT standards, they are not
recognized as leak detection systems in the Permit.
Each of Cells 2 and 3 also has a slimes drain collection system immediately above the FML,
comprised of a nominal 12-inch thick protective blanket layer of soil or comparable material, on
top of which is a network of PVC perforated pipe laterals on a grid spacing interval of about 50-
feet. These pipe laterals gravity drain to a perforated PVC collector pipe which also drains
toward the south dike and is accessed from the ground surface via a non-perforated access pipe.
At cell closure, leachate head inside the pipe network will be removed via a submersible pump
installed inside the access pipe
See Part I.D.1 of the Permit for a more detailed description of the design of Cells 1, 2 and 3.
After review of the existing design and construction and consultation with the State of Utah
Division of Water Quality, the Director determined, in connection with the issuance of the
Permit in 2005, that the DMT required under the groundwater quality protection rules (UAC
R317 -6-6.4( c )(3)) for Cells 1, 2 and 3 that pre-dated those rules will be defined by the current or
existing disposal cell construction, with modifications that were included in the Permit (see page
25 of the 2004 Statement of Basis). These modifications focus on changes in monitoring
requirements, and on improvements to facility closure. The goal of these improvements is to
ensure that potential wastewater losses are minimized and local groundwater quality is protected.
The modifications are described in Sections 2.7.2.2, 2.7.2.3 and 2.7.2.4 below.
2. 7.2.2 Improved Groundwater Monitoring
Improvements were made to the Mill's groundwater monitoring network at the time of issuance
of the Permit, to meet the following goals:
a) Early Detection
Three monitoring wells (MW-24, MW-27 and MW-28) were added immediately adjacent to Cell
1, in order to detect a potential release as early as practicable.
b) Discrete Monitoring
In order to individually monitor each tailings cell and to be able to pinpoint the source of any
potential groundwater contamination that may be detected, the Permit required the addition of
three monitoring wells (MW-29, MW-30 and MW-31) between Cells 2 and 3, in addition to the
addition of wells MW-24, MW-27 and MW-28 immediately adjacent to Celli.
32
The addition of monitoring wells MW-24, MW-27, MW-28, MW-29, MW-30 and MW-31,
together with the existing monitoring wells at the site provides a comprehensive monitoring
network to determine any potential leakage from Cells 1, 2 and 3. See Figure 4 and Figure 10 for
a map showing the locations of the existing compliance monitoring wells for the site.
2. 7.2.3 Operational Changes and Improved Operations Monitoring
The Permit also required changes to disposal cell operation in order to increase efforts to
minimize potential seepage losses, and thereby improve protection of local groundwater quality.
Examples of these changes are:
c) Maximum Waste and Wastewater Pool Elevation
Part I.D.3 of the Permit requires that EFRI continue to ensure that impounded wastes and
wastewaters for all of the Mill's tailings Cells and Roberts Pond are held within an FML.
d) Slimes Drain Maximum Allowable Head
Part I.D.3(b) of the Permit requires that the Mill provide constant pumping efforts to minimize
the accumulation of leachates over the FML in Cell 2, and upon commencement of dewatering
activities, in Cell 3, and thereby minimize potential FML leakage to the foundation and
groundwater. See the discussion in Section 2.15.2.2 below.
2.7.2.4 Evaluation of Tailings Cell Cover System Design
EFRI submitted an Infiltration and Contaminant Transport Modeling Report, White Mesa Mill
Site, Blanding, Utah, November 2007, prepared by MWH Americas, Inc., in November, 2007.
EFRI submitted a revised Infiltration and Contaminant Transport Modeling Report, White Mesa
Mill Site, Blanding, Utah, March 2010 ("revised ICTM Report") in response to DRC comments.
The March 2010 report is currently being reviewed in conjunction with the Reclamation Plan,
Revision 5.0. DRC provided interrogatories for the revised ICTM Report in March 2012. EFRI
provided responses to these interrogatories in May and September 2012. DRC provided review
comments on EFRI's May and September 2012 responses in February 2013.
On April 30, 2013, a meeting was held in Denver, Colorado to discuss specific issues identified
in DRC's February 2013 review comments for Revision 5.0 of the Reclamation Plan and the
revised ICTM Report. As noted in Section 2.19 .2, included in the discussions at this meeting
was DRC's request for site-specific tailings data. EFRI proposed a tailings investigation to
address DRC's concerns. The tailings investigation was completed in October 2013 and
subsequent laboratory testing of samples collected was completed in April 2014. A Tailings
Data Analysis Report summarizing the results of the investigation is currently being prepared for
submittal to DRC in June 2014. Submission of responses to DRC's February 2013 review
comments on the revised ICTM Report are planned to be completed in 2014 after DRC's review
of the Tailings Data Analysis Report. The results provided in the Tailings Data Analysis Report
will be used to update technical analyses to address DRC's February 2013 review comments on
the revised ICTM report. The responses will also incorporate decisions made at the April 30,
2013 meeting on key issues related to the revised ICTM Report.
33
See Section 2.19 below for a more detailed discussion of post -closure requirements for the Mill.
2.7.3 Ce114A
Construction of Cell 4A was completed on or about November 1989. Cell 4A was used for a
short period of time after its construction for the disposal of raffinates from the Mill's vanadium
circuit. No tailings waste or wastewater had been disposed of in Cell 4A since the early 1990s.
This lack of waste disposal, and exposure of the FML to the elements, caused Cell 4A to fall into
disrepair over the years.
Although the original design of Cell4A was an improvement over the design of Cells 1, 2 and 3
(it had a one-foot thick clay liner under a 40 rn1 high density polyethylene ("HDPE") FML, with
a more elaborate leak detection system), it was constructed in 1989 and did not meet today's
BAT standards.
Cell 4A was re-lined in 2007-2008 and was re-authorized for use in November 2008. With the
reconstruction of Cell 4A, BAT was required, as mandated by Part I.D.4 of the Permit and as
stipulated by the Utah Ground Water Quality Regulations at UAC R317-6-6.4(A). With BAT
for Cell 4A, there are also new performance standards that require daily leak detection system
monitoring, weekly wastewater level monitoring, and slimes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Section 2.15.3 below for a more
detailed discussion relating to the BAT performance standards and monitoring requirements for
Cell4A.
Tailings Cell 4A Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part I.D.5 of the Permit and consist of
the following:
e) Dikes -consisting of existing earthen embankments of compacted soil, constructed by
a previous Mill operator between 1989-1990, and composed of four dikes, each
including a 15-foot wide road at the top (minimum). On the north, east, and south
margins these dikes have slopes of 3H to 1 V. The west dike has a slope of 2H to 1 V.
Width of these dikes varies. Each has a minimum crest width of at least 15 feet to
support an access road. Base width also varies from 89-feet on the east dike (with no
exterior embankment), to 211-feet at the west dike.
f) Foundation -including existing subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. The floor of Cell4A has an average
slope of 1% that grades from the northeast to the southwest corners.
g) Tailings Capacity-the floor and inside slopes of Cell 4A encompass about 40 acres
and have a maximum capacity of about 1.6 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
h) Liner and Leak Detection Systems -including the following layers, in descending
order:
34
(i) Primary FML -consisting of an impermeable 60 mil HDPE membrane that
extends across both the entire cell floor and the inside side-slopes, and is anchored
in a trench at the top of the dikes on all four sides. The primary FML is in direct
physical contact with the tailings material over most of the Cell 4A floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) Leak Detection System -includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4A, and drains to a leak
detection sump in the southwest corner. Access to the leak detection sump is via
an 18-inch inside diameter (ID) HDPE pipe placed down the inside slope, located
between the primary and secondary FML liners. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 10 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
(iii) Secondary FML-consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. This FML also extends across the
entire Cell 4A floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
(iv) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay liner
("GCL") composed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
i) Slimes Drain Collection System -including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
(i) Horizontal Strip Drain System -is installed in a herringbone pattern across the
floor of Cell 4A that drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated, two-part geo-composite drain material
(solid polymer drainage strip) core surrounded by an envelope of non-woven
geotextile filter fabric. The strip drains are placed immediately over the primary
FML on 50-foot centers, where they conduct fluids downgradient in a
southwesterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
fabric filled with well graded filter sand to protect the drainage system from
plugging.
(ii) Horizontal Slimes Drain Collection Pipe System -includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection ("SDC")
pipe found at the downgradient end of the strip drain lines. This pipe is in turn
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southwest corner of Cell 4A where it joins the slimes drain
access pipe.
35
(iii) Slimes Drain Access Pipe -consisting of an 18-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell 4A at the southwest corner, above the
primary FML. Said pipe then merges with another horizontal pipe of equivalent
diameter and material, where it is enveloped by gravel and woven geotextile that
serves as a cushion to protect the primary FML. A reducer connects the
horizontal 18-inch pipe with the 4-inch SDC pipe. At some future time, a pump
will be set in this 18-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
j) North Dike Splash Pads-three 20-foot wide splash pads have been constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings slurry.
These pads consist of an extra layer of 60 mil HDPE membrane that has been installed
in the anchor trench and placed down the inside slope of Cell 4A, from the top of the
dike, under the inlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope.
k) Emergency Spillway - a concrete lined spillway has been constructed near the
southwestern corner of the west dike to allow emergency runoff from Cell 4A to Cell
4B. At this time, all stormwater runoff and tailings wastewaters not retained in Cells
2, 3, and 4A will be managed and contained in Cell 4B, including the Probable
Maximum Precipitation and flood event.
1) BAT Performance Standards for Tailings Cell 4A-EFRI shall operate and maintain
Tailings Cell 4A so as to prevent release of wastewater to groundwater and the
environment in accordance with an Operations and Maintenance Plan, as currently
approved by the Director, pursuant to Part I.H.19. At a minimum these performance
standards shall include:
(i) Maximum Allowable Daily Head-on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer.
See Part I.D.5 of the Permit for a more detailed discussion of the design of Cell4A. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix F to this Application.
2. 7.4 Cell 4B
Construction of Cell4B was completed in November 2010.
Tailings Cell 4B Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part I.D.12 of the Permit and consist of
the following:
a) Dikes -consisting of newly constructed dikes on the south and west side of the cell,
each including a 20-foot wide road at the top (minimum). The exterior slopes of the
southern and western dikes have slopes of 3H to 1 V. The interior dikes have slopes of
2H to 1 V. Limited portions of the Cell 4B interior sidelopes in the northwest corner
and southeast corner of the cell (where the slimes drain and leak detection sump are
located) have a slope of 3H to 1 V. Width of these dikes varies. The base width of the
36
southern dike varies from approximately 92 feet at the western end to approximately
190 feet at the eastern end of the dike, with no exterior embankment present on any
other side of the cell.
b) Foundation -including existing sub grade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. The floor of Cell4B has an average
slope of 1% that grades from the northwest to the southeast corner.
c) Tailings Capacity-the floor and inside slopes of Cell 4B encompass about 40 acres
and the cell has a maximum capacity 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in descending
order:
(i) Primary FML -consisting of an impermeable 60 mil HDPE membrane that
extends across both the entire cell floor and the inside side-slopes, and is anchored
in a trench at the top of the dikes on all four sides. The primary FML is in direct
physical contact with the tailings material over most of the Cell 4B floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) Leak Detection System-includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4B, and drains to a leak
detection sump in the southeast corner. Access to the leak detection sump is via
an 18-inch inside diameter ("ID") HDPE pipe placed down the inside slope,
located between the primary and secondary FML liners. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 15 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
(iii) Secondary FML -consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. This FML also extends across the
entire Cell 4B floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
(iv) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay liner
("GCL") composed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
e) Slimes Drain Collection System -including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
(i) Horizontal Strip Drain System -is installed in a herringbone pattern across the
floor of Cell4B that drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated two-part geo-composite drain material
(solid polymer drainage strip) core surrounded by an envelope of non-woven
geotextile filter fabric. The strip drains are placed immediately over the primary
FML on 50-foot centers, where they conduct fluids downgradient in a
southeasterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
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fabric filled with well graded filter sand to protect the drainage system from
plugging.
(ii) Horizontal Slimes Drain Collection Pipe System -includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC)
pipe found at the downgradient end of the strip drain lines. This pipe is in turn
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southeast corner of Cell 4A where it joins the slimes drain
access pipe.
(iii) Slimes Drain Access Pipe -consisting of an 18-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell4B at the southeast corner, above the primary
FML. Said pipe then merges with another horizontal pipe of equivalent diameter
and material, where it is enveloped by gravel and woven geotextile that serves as
a cushion to protect the primary FML. A reducer connects the horizontal 18-inch
pipe with the 4-inch SDC pipe. At some future time, a pump will be set in this
18-inch pipe and used to remove tailings wastewaters for purposes of de-watering
the tailings cell.
f) North and East Dike Splash Pads -nine 20-foot wide splash pads have been
constructed on the north and east dikes to protect the primary FML from abrasion and
scouring by tailings slurry. These pads consist of an extra layer of 60 mil HDPE
membrane that has been installed in the anchor trench and placed down the inside slope
of Cell4B, from the top of the dike, under the inlet pipe, and down the inside slope to a
point 5-feet beyond the toe of the slope.
g) Emergency Spillway - a concrete lined spillway has been constructed near the
southeastern corner of the east dike to allow emergency runoff from Cell 4A into Cell
4B. This spillway is limited to a 6-inch reinforced concrete slab, with a welded wire
fabric installed within its midsection, set directly atop a cushion geotextile placed
directly over the primary FML in a 4-foot deep trapezoidal channel. A 100-foot wide,
60-mil HDPE membrane splash pad is installed beneath the emergency spillway. No
other spillway or overflow structure will be constructed at Cell 4B unless and until the
construction of Cells 5A and 5B. At this time, all stormwater runoff and tailings
wastewaters not retained in Cells 2, 3, and 4A will be managed and contained in Cell
4B, including the Probable Maximum Precipitation and flood event.
h) BAT Performance Standards for Tailings Cell 4B -EFRI shall operate and maintain
Tailings Cell 4B so as to prevent release of wastewater to groundwater and the
environment in accordance with the currently-approved Cell 4B BAT, Monitoring,
Operations and Maintenance Plan. At a minimum these performance standards shall
include:
(i) Maximum Allowable Daily Head-on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer,
38
(iv) Maximum Daily Wastewater Level -to ensure compliance with the minimum
freeboard requirements for Cell 4B, and prevent discharge of wastewaters via
overtopping.
See Part I.D.12 of the Permit for a more detailed discussion of the design of Cell 4B. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix F to this Application.
2. 7.5 Future Additional Tailings Cells
Future additional tailings cells at the Mill will require Director approval prior to construction and
operation. Future tailings cells at the Mill will be required to satisfy BAT standards at the time
of construction.
2.7.6 Roberts Pond
Roberts Pond receives periodic floor drainage and other wastewaters from Mill process upsets, is
frequently empty, and was re-lined with a new FML in May, 2002.
In order to minimize any potential seepage release from Roberts Pond, the Director required the
following in Part I.D.3(e) of the Permit:
(i) EFRI "shall operate this wastewater pond [Roberts Pond] so as to provide a minimum
2-foot freeboard at all times. Under no circumstances shall the water level in the pond
exceed an elevation of 5,624 feet amsl. In the event that the wastewater elevation
exceeds this maximum level, the Permittee [EFRI] shall remove the excess wastewater
and place it into containment in Tailings Cell 1 within 72-hours of discovery."
(ii) At the time of Mill site closure, EFRI will excavate and remove the liner, berms, and
all contaminated subsoils in compliance with an approved final reclamation plan under
the Mill License.
2.7.7 Other Facilities and Protections
2.7.7.1 Feedstock Storage
In order to constrain and minimize potential generation of contaminated stormwater or leachates,
Part I.D.ll of the Permit requires the Mill to continue its existing practice of limiting open air
storage of feedstock materials to the historical storage area found along the eastern margin of the
Mill site (as defined by the survey coordinates found in Permit Table 4). The intent of Section I.
D.ll, (based on the SOB for the 2009 GWDP), is to require that feedstock storage outside of the
area specified in Table 4 shall meet the following requirements:
a) Feedstock materials will be stored at all times in water-tight containers, and aisle ways will be
provided at all times to allow visual inspection of each and every
feedstock container, or
b) Each and every feedstock container will be placed inside a water-tight overpack prior to
storage, or
39
c) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical requirements:
1) A storage area composed of a hardened engineered surface of asphalt or concrete, and
2) A storage area designed, constructed, and operated in accordance with engineering
plans and specifications approved in advance by the Director. All such engineering plans
or specifications submitted shall demonstrate compliance with Part I.D.4,
3) A storage area that provides containment berms to control stormwater run-on and run-
off, and
4) Stormwater drainage works approved in advance by the Director, or
5) Other storage facilities and means approved in advance by the Director.
The language Section D.ll is currently ambiguous. Accordingly, EFRI requests that Part I.D.ll
of the renewed GWDP be revised as set out above.
2. 7. 7.2 Mill Site Reagent Storage
, Part I.D.3(g) of the Permit requires the Mill to demonstrate that it has adequate provisions for
spill response, cleanup, and reporting for reagent storage facilities. These provisions are
detailed in the Stormwater Best Management Practices Plan, which is designed to prevent
potential reagent tank spills or leaks that could release contaminants to site soils or groundwater,
and to provide proper spill prevention and control. Contents of this plan are stipulated in Part
I.D.8 of the Permit, and submittal and approval of the plan is required under Part I.H.17 of the
Permit. For existing facilities at the Mill, secondary containment is required, although such
containment may be earthen lined. For new facilities constructed at the Mill, or reconstruction of
existing facilities, Part I.D.3(g) requires a higher standard of secondary containment that would
prevent contact of any potential spill with the ground surface.
A copy of the Mill's Stormwater Best Management Practices Plan, Revision 1.5: September
2012 is attached as Appendix G to this Application.
2. 7. 7.3 New Construction
Part I.D.4 of the Permit requires submittal of engineering plans and specifications and Director
approval prior to the construction, modification, or operation of waste or wastewater disposal,
treatment, or storage facilities. In these plans and specifications, the Mill is required to
demonstrate how BAT requirements of the Groundwater Quality Protection Rules have been
met. After Director Approval, a construction permit may be issued, and the Permit modified.
2. 7. 7.4 Other
The White Mesa Mill Discharge Minimization Technology (DMT) Monitoring Plan, 7112
Revision: Denison-12.1 (the "DMT Plan"), and the White Mesa Mill Tailings Management
System, 7/2012 Revision 12.1 (the "Tailings Management Plan"), are attached as Appendix H
and Appendix I to this Application, respectively. These plans provide a systematic program for
40
constant surveillance and documentation of the integrity of the tailings system, including
monitoring the leak detection systems. The DMT Plan requires daily, weekly, quarterly,
monthly and annual inspections and evaluations and monthly reporting to Mill management. See
Section 2.15.2 below for a more detailed discussion of the requirements of the DMT Plan.
2. 7.8 Surface Waters
The Mill has been designed as a facility that does not discharge to surface waters. Tailings and
other Mill wastes are disposed of permanently into the Mill's tailings system. Further, as
mentioned above, the Mill was designed and constructed to prevent runon or runoff of storm
water by a) diverting runoff from precipitation on the Mill site to the tailings cells; and b)
diverting runoff from surrounding areas away from the Mill site. As a result, there is no pathway
for liquid effluents from Mill operations to impact surface waters.
Under the Mill License, the Mill is required to periodically sample local surface waters to
determine if Mill activities may have impacted those waters. The primary pathway would be
from air particulates generated during Mill operations that may have landed on or near surface
waters, or that may have accumulated in drainage areas that could feed into surface waters.
Sampling results since inception of Mill operations show no trends or other impacts of Mill
operations on local surface waters. See the Mill's Semi-Annual Effluent Report for the period
July 1 to December 31, 2013, a copy of which has previously been provided to the Director.
2.7.9 Alternate Concentration Limits
The Mill does not discharge to groundwater or surface water, nor is it designed to do so.
Therefore, no alternate concentration limits are currently applicable to the site.
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information of the
Quality of the Receiving Ground Water (R317-6-6.3.H)
Groundwater classification was assigned by the Director in the Permit on a well-by-well basis
after review of groundwater quality characteristics for the perched aquifer at the Mill site. A
well-by-well approach was selected by the Director in order to acknowledge the spatial
variability of groundwater quality at the Mill, and afford the most protection to those portions of
the perched aquifer that exhibited the highest quality groundwater. These groundwater
classifications are set out in Part I.A and Table 1 of the Permit.
The primary element used by the Director in determining the groundwater classification of each
monitoring well at the site, is the TDS content of the groundwater, as outlined in UAC 317-6-3.
Groundwater quality data collected by the Mill show the shallow aquifer at the Mill has a highly
variable TDS content, with TDS averages ranging from about 1100 to over 7900 mg/L. Another
key element in determination of groundwater class is the presence of naturally occurring
contaminants in concentrations that exceed their respective GWQS. In such cases, the Director
has cause to downgrade aquifer classification from Class II to Class III (see UAC R317-6-3.6).
Using all available TDS data and background data, for 24 of the POC and general monitoring
wells the Director determined that 4 of those wells exhibit Class II drinking water quality
groundwater. The remaining 20 wells exhibited Class III or limited use groundwater at the site.
The Director determined that MW-35 will be classified as having Class II drinking water quality
41
groundwater until sufficient background data have been collected and the applicable Background
Report is submitted. Wells MW-36 and MW-37 have not been classified at this time.
2.8.1 Existing Wells at the Time of Original Permit Issuance
The Director required EFRI to evaluate groundwater quality data from the thirteen existing wells
on site, and submit a Background Ground Water Quality Report for Director approval. One of
the purposes of that report was to provide a critical evaluation of historic groundwater quality
data from the facility, and determine representative background quality conditions and reliable
GWCLs for the Permit.
EFRI (then Denison) prepared the Existing Well Background Report that evaluated all historic
data for the thirteen existing wells for the purposes of establishing background groundwater
quality at the site and developing GWCLs under the GWDP. Prior to review and acceptance of
the conclusions in the Existing Well Background Report, the GWCLs were set on an interim
basis in the GWDP. The interim limits were established as fractions of the state GWQSs for
drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality for the
thirteen existing wells, based primarily on the analysis performed in the Existing Wellls Background
Report. It should be noted, however, that, because the GWCLs have been set at the mean plus two
standard deviations, or the equivalent, un-impacted groundwater would normally be expected to
exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are expected in
approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit
Because the Permit called for installation of nine new monitoring wells around the tailings cells,
background groundwater quality had to be determined for those monitoring points. To this end,
the Permit required the Mill to collect at least eight quarters of groundwater quality data, and
submit the New Well Background Report for Director approval to establish background
groundwater quality for those wells.
EFRI (then Denison) prepared the New Well Background Report that evaluated all historic data
for the nine new wells for the purposes of establishing background groundwater quality at the
site and developing GWCLs under the GWDP. Prior to review and acceptance of the conclusions
in the New Well Background Report, the GWCLs were set on an interim basis in the GWDP.
The interim limits were established as fractions of the state GWQSs for drinking water,
depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed in the New Well Background
Report. It should be noted, however, that, because the GWCLs have been set at the mean plus
second standard deviation, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
42
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.1)
The groundwater monitoring plan is set out in the Permit. All groundwater monitoring at the site
is in the perched aquifer. The following sections summarize the key components of the Mill's
sampling and analysis plan.
2.9.1 Groundwater Monitoring to Determine Groundwater Flow Direction and Gradient,
Background Quality at the Site, and the Quality of Groundwater at the Compliance Monitoring
Point
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit
At the time of renewal of the Mill license by NRC in March, 1997 and up until issuance of the
Permit in March 2005, the Mill implemented a groundwater detection monitoring program , in
accordance with 10 CFR Part 40, Appendix A and the provisions of the Mill License condition
11.3A. The detection monitoring program was implemented in accordance with the report
entitled, Points of Compliance, White Mesa Uranium Mill, prepared by Titan Environmental
Corporation, submitted by letter to the NRC dated October 5, 1994. Under that program, the
Mill sampled monitoring wells MW-5, MW-11, MW-12, MW-14, MW-15 and MW-17, on a
quarterly basis. Samples were analyzed for chloride, potassium, nickel and uranium, and the
results of such sampling were included in the Mill's Semi-Annual Effluent Monitoring Reports
that were filed with the NRC up until August 2004 and with the DRC subsequent thereto.
Between 1979 and 1997, the Mill monitored up to 20 constituents in up to 13 wells. That
program was changed to the Points of Compliance Program in 1997 because NRC had concluded
that:
• The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer; and
• The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
2.9.1.2 Issuance of the Permit
On March 8, 2005, the Director issued the Permit, which includes a groundwater monitoring
program that superseded and replaced the groundwater monitoring requirements set out in Mill
License Condition 11.3A. Condition 11.3A has since been removed from the Mill License.
Groundwater monitoring under the Permit commenced in March 2005, the results of which are
included in the Mill's Quarterly Groundwater Monitoring Reports that are filed with the
Director.
On September 1, 2009, EFRI filed a Groundwater Discharge Permit Renewal Application. At
the request of the Director of the Utah Division of Radiation Control, EFRI submitted an updated
version of the September 1, 2009 renewal application on July 13, 2012. At the request of the
Director of the Utah Division of Radiation Control, EFRI is submitting this updated version of
the July 2012 renewal application. The Permit remains in timely renewal status awaiting
completion of review of the Renewal Application by the Director.
43
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit
The current groundwater monitoring program at the Mill under is used to determine ground
water flow direction, gradient, and quality at the compliance monitoring points. This program
consists of monitoring at 25 point of compliance monitoring wells: MW-1, MW-2, MW-3, MW-
3A, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24,
MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31, MW-32, MW-35, MW-36, and
MW-37. The locations of these wells are indicated on Figure 10. Depth to water is measured
quarterly in MW-34, but due to limited water is not sampled for POC compliance. MW-33 is
completely dry and is not sampled for POC compliance.
Part I.E.l.(d) of the Permit requires that each point of compliance well must be sampled for the
constituents listed in Table 2.9.1.3-1.
Further, Part I.E.l.(d)1) of the Permit, requires that, m addition to pH, the following field
parameters must also be monitored:
• Depth to groundwater
• Temperature
• Specific conductance
• Redox potential ("Eh")
and that, in addition to chloride and sulfate, the following general organics must also be
monitored:
• Carbonate, bicarbonate, sodium, potassium, magnesium, calcium, and total anions and
cations.
Sample frequency depends on the speed of groundwater flow in the vicinity of each well. Parts
I.E.1 (b) and (c) provide that quarterly monitoring is required for all wells where local
groundwater average linear velocity has been found by the Director to be equal to or greater than
10 feet/year, and semi-annual monitoring is required where the local groundwater average linear
velocity has been found by the Director to be less than 10 feet/year.
Based on these criteria, quarterly monitoring is required at MW-11, MW-14, MW-25, MW-26
and MW-30, and MW-31, and semi-annual monitoring is required at MW-1, MW-2, MW-3,
MW-31\, MW-5,MW-12, MW-15, MW-17, MW-18, MW-19,MW-23,MW-24, MW-27, MW-
28, MW-29 and MW-32.
Geochemical and indicator parameter analysis during the initial SAA in October of 2012
concluded that upgradient monitoring wells MW -1, MW -18, and MW -19 have not been
impacted by Mill activities. i\t that time, EFRI proposed that these upgradient monitoring wells
be sampled routinely but not subject to GWCLs. In a letter dated i\pril25, 2013, DRC approved
this proposed change to take place at the time of the Permit renewal.
44
Wells MW-35, MW-36 and MW-37 were being sampled quarterly, to collect eight consecutive
quarters of background data. The Background Report for wells MW-35, MW-36, and MW-37
was submitted to the Director on May 1, 2014. After review by DRC, the Director will establish
groundwater compliance levels for those wells and determine their frequency of sampling.
Prior to the February 15, 2011 revision of the GWDP, EFRI collected quarterly groundwater
samples from MW-20 and MW-22 for development of background values and potential GWCLs.
Part I.E.l.c).3) in the currently approved August 24, 2012 revision of the GWDP now requires
that MW-20 and MW-22 be monitored on a semi-annual basis as "General Monitoring Wells,"
but they are not subject to GWCLs.
2.9.1.4 Groundwater Flow Direction and Gradient
Part I.E.3 of the Permit requires that, on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.1 and described in Section 2.9 .1.3 above, the Mill
shall measure depth to groundwater in the following wells and/or piezometers:
i) The point of compliance wells identified in Table 2 of the Permit, as described in
Section 2.9.1.3 above;
j) Piezometers P-1, P-2, P-3, P-4 and P-5;
k) Existing monitoring wells MW-20, MW-22, and MW-34;
I) Contaminant investigation wells -any well required by the Director as a part of a
contaminant investigation or groundwater corrective action (at this time this includes
the chloroform and nitrate investigation wells); and
m) Any other wells or piezometers required by the Director.
While it is not a requirement of the GWDP, EFRI also measures depth to water in the DR
piezometers which were installed during the Southwest Hydrogeologic Investigation. The Mill
uses these measurements to prepare groundwater isocontour maps each quarter that show the
groundwater flow direction and gradient. The isocontour map for the first quarter of 2014 is
attached as Figure 5.
2.9.1.5 Background Quality at the Site
A significant amount of historic groundwater quality data had been collected by EFRI and
previous operators of the Mill for some wells at the facility. In some cases these data extend
back more than 30 years to September 1979. A brief summary of the various studies that had
been performed prior to the original issuance of the Permit is set out in Section 2.0 of the
Regional Background Report.
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality assurance
issues. Such an examination needed to include such things as justification of any zero
concentration values reported, adequacy of minimum detection limits provided (particularly with
respect to the corresponding GWQS), adequacy of laboratory and analytical methods used,
consistency of laboratory units or reporting, internal consistency between specific and composite
45
types of analysis (e.g., major ions and TDS), identification and justification of concentration
outliers, and implications of concentration trends (both temporal and spatial).
As discussed in Section 2.11.2 below, the Director also noted several groundwater quality issues
that needed to be resolved prior to a determination of background groundwater quality at the site.
These were: 1) a number of constituents exceeded their respective GWQS (including nitrate in
one well and manganese, selenium and uranium in several wells); 2) long term trends in uranium
in downgradient wells MW-14, MW-15 and MW-17; and 3) a spatial high of uranium in those
three downgradient wells. See pages 5-8 of the 2004 Statement of Basis for a more detailed
discussion of these points.
As a result of the foregoing, the Director required that the Background Reports be prepared to
address and resolve these issues.
Further, because background groundwater quality at the Mill site had not yet been approved at
the time of original Permit issuance, the Director was not able to determine if any contaminant is
naturally occurring and therefore detectable or undetectable for purpose of selecting GWCLs in
each well. Consequently, the Director initially assigned GWCLs as if they were "undetectable"
(i.e., assuming that all natural background concentrations were less than a fraction of the
respective GWQS).
As discussed in Section 1.3 above and 2.11.2 below, EFRI submitted the Background Reports to
the Director. Both the Existing Well Background Report and the New Well Background Report
provided GWCLs for all of the constituents in the existing wells and new wells, respectively,
based on a statistical intra-well approach. The Director has approved the Background Reports.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells and the nine new wells based primarily on the analysis performed
in the Background Reports. It should be noted, however, that, because the GWCLs have been set
at the mean plus second standard deviation, or the equivalent, un-impacted groundwater would
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point
There are over 30 years of data for some constituents in some wells at the site, but not for all
constituents. However, with the exception of tin, which was added as a monitoring constituent in
2007, all currently required monitoring constituents have been sampled in the wells that were in
existence on the date of the original issuance of the Permit commencing with the first quarter of
2005. Further, all constituents in the new compliance monitoring wells have been sampled upon
installation of those wells, commencing either in the second or third quarters of 2005.
The analytical results from this sampling are reported quarterly in Groundwater Monitoring
Reports, which are filed with the Director pursuant to Part I.F.1 of the Permit.
46
2.9.2 Installation, Use and Maintenance of Monitoring Devices
Compliance monitoring at the Mill site is accomplished in three ways: the compliance well
monitoring program; the leak detection monitoring system in Cells 4A and 4B; and various DMT
monitoring requirements. Each of these are discussed below.
2.9.2.1 Compliance Well Monitoring
Compliance for tailings Cells 1, 2 and 3 and the remainder of the Mill site, other than Cells 4A
and 4B, is accomplished by quarterly or semi-annual sampling of the network of compliance
monitoring wells at the site. See Figure 10 for a map that shows the compliance monitoring well
locations, and Section 2.9 .1.3 for a description of the monitoring program.
2.9.2.2 Leak Detection System in Cell 4A and Cell 4B
BAT was required, as mandated in Part I.D.4 of the Permit and as stipulated by UAC R317 -6-
6.4(a) for the reconstruction of Cell 4A and the construction of Cell 4B. Because tailings Cells
1, 2 and 3 were constructed more than 25 years ago, and after review of the existing design and
construction, the Director determined that DMT rather than BAT is required for Cells 1, 2 and 3
(see the discussion in Section 2.7.2 above).
BAT for Cell4A and Cell4B included the construction of a modern leak detection system. See
Sections 2.7.3 and 2.7.4 above for a description of the key design elements of Cell 4A and Cell
4B respectively, including their leak detection systems. With BAT for Cell 4A and Cell 4B,
there are new performance standards in the Permit that require daily leak detection system
monitoring, weekly wastewater level monitoring, and slimes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Sections 2.15.3 and 2.15.4 below for a
more detailed discussion of the BAT monitoring requirements for Cell 4A and Cell 4B
respectively.
Because Cell4A and Cell4B have modern leak detection systems, that meets BAT standards and
are monitored daily, the leak detection systems in Cell 4A and Cell4B can be considered to be a
point of compliance monitoring devices.
2.9.2.3 Other DMT Monitoring Requirements
In addition to the foregoing, the additional DMT performance standard monitoring discussed in
detail in Section 2.15 below is required to be performed under the Permit
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring
Points
The compliance monitoring area at the site is the area covered by the groundwater compliance
monitoring wells. Figure 10 shows the current locations of the compliance groundwater
monitoring wells at the site.
47
At the time of original Permit issuance, the Director reviewed the then recent water table contour
maps of the perched aquifer. Those maps identified a significant western component to
groundwater flow at the Mill site, which the Director concluded appeared to be the result of
wildlife pond seepage and groundwater mounding (see page 23 of the 2004 Statement of Basis).
As a consequence, new groundwater monitoring wells were required, particularly along the
western margin of the tailings cells, in addition to the monitoring wells already in existence at
that time. The Director also concluded that new wells were also needed for DMT purposes and
to provide discrete monitoring of each tailings cell. This resulted in the addition of the following
compliance monitoring wells to the then existing monitoring well network: MW-23, MW-24,
MW-25, MW-26 (which was then existing chloroform investigation well TW4-15), MW-27,
MW-28, MW-29, MW-30, MW-31 MW-32 (which was then existing chloroform investigation
well TW4-17), MW-35, MW-36, and MW-37. As previously stated MW-33 and MW-34 were
installed but are not currently sampled due to limited water and saturated thickness. MW-20 and
MW-22 are not POC wells but are general monitoring wells and are sampled semiannually for
information purposes only.
Based on groundwater flow direction and velocity, the compliance monitoring network, with the
foregoing additional new wells, was considered to be adequate for compliance monitoring in the
perched aquifer at the site.
Further, as mentioned in Section 2.9.2.2 and 2.9.2.3 above, the leak detection systems in Cell4A
and 4B can also be considered to be compliance monitoring areas for these cells.
2.9.4 Monitoring of the Vadose Zone
Monitoring is not performed in the vadose zone at the site.
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation,
Including Post-Operational Monitoring
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation
Please see Section 2.19 below for a detailed discussion of the measures to prevent groundwater
contamination after the cessation of operations.
2.9.5.2 Post-Operational Monitoring
Groundwater monitoring will continue during the post-operational phase through final closure
until the Permit is terminated. EFRI understands that the final closure will take place and the
Permit will be terminated upon termination of the Mill License and transfer of the reclaimed
tailings cells to the United States Department of Energy pursuant to U.S.C. 2113. See Section
2.19.1.1 below.
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where
Applicable to Specified Guidance
2.9.6.1 Monitoring Well Construction
a) New Wells
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All new compliance monitoring wells installed after the original issuance of the Permit were
installed in accordance with the requirements of Part I.E.4 of the Permit. Part I.E.4 requires that
new groundwater monitoring wells installed at the facility comply with the following design and
construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other
potential origin of groundwater pollution;
b) Screened and completed in the shallow aquifer;
c) Designed and constructed in compliance with UAC R317-6-6.3(1)(6), including
the EPA RCRA Ground Water Monitoring Technical Enforcement Guidance
Document, 1986, OSWER-9950.1 (the "EPA RCRA TEGD"); and
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
As-built reports for all new groundwater monitoring wells were submitted to the Director for his
approval, in accordance with Part I.F.6 of the Permit. Part I.F.6 requires those reports to include
the following information:
a) Geologic logs that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs were prepared by a
Professional Geologist licensed by the State of Utah or otherwise approved
beforehand by the Director ;
b) A well completion diagram that details all physical attributes of the well
construction, including:
1) Total depth and diameters of boring;
2) Depth, type, diameter, and physical properties of well casmg and screen,
including well screen slot size;
3) Depth intervals, type and physical properties of annular filterpack and seal
materials used;
4) Design, type, diameter, and construction of protective surface casing; and
5) Survey coordinates prepared by a State of Utah licensed engineer or land
surveyor, including horizontal coordinates and elevation of water level
measuring point, as measured to the nearest 0.01 foot; and
c) Aquifer permeability data, including field data, data analysis, and interpretation of
slug test, aquifer pump test or other hydraulic analysis to determine local aquifer
hydraulic conductivity in each well.
Between April and June 2005, EFRI installed wells MW-23, MW-24, MW-25, MW-27, MW-28,
MW-29, MW-30, and MW-31. On August 23, 2005, EFRI submitted a Perched Monitoring
Well Installation and Testing at the White Mesa Uranium Mill April through June 2005 Report,
prepared by Hydro Geo Chern, Inc., that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover.
Between August 30 and September 2, 2010, EFRI installed wells MW-33, MW-34, and MW-35.
On October 11, 2010, EFRI submitted Installation and Hydraulic Testing of Perched Monitoring
49
Wells MW-33, MW-34, and MW-35 at the White Mesa Uranium Mill Near Blanding Utah,
prepared by Hydro Geo Chern, Inc. that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover. During the week of April 25, 2011, EFRI installed wells MW-36, and
MW-37. On June 28, 2011, EFRI submitted Installation and Hydraulic Testing of Perched
Monitoring Wells MW-36, and MW-37 at the White Mesa Uranium Mill Near Blanding Utah,
prepared by Hydro Geo Chern, Inc. that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover.
b) Existing Wells
The Existing Wells, MW-1, MW-2, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-
18, MW-19, MW-26 and MW-32 as well as wells MW-16, MW-20 and MW-22, which are not
compliance monitoring wells, and piezometers P-1, P-2, P-3, P-4 and P-5, were all constructed
and installed prior to original issuance of the Permit. Some of those wells date back to 1979.
During several site visits and four split groundwater sampling events between May 1999 and the
date of original issuance of the Permit, and a review of available as built information, DRC staff
noted the need for remedial construction, maintenance, or repair at several of these wells,
including:
(i)
(ii)
(iii)
A.
B.
c.
D.
16 of the existing monitoring wells failed to produce clear groundwater in
conformance with the EPA RCRA TEGD, apparently due to incomplete well
development. Consequently, the Permit required that MW-5, MW-11, MW-18,
MW-19, MW-26, TW4-16, and MW-32 be developed to ensure that groundwater
clarity conforms to the EPA RCRA TEGD to the extent reasonably achievable;
The Permit required the Mill to install protective steel surface casings to protect
the exposed PVC well and piezometer casings for piezometers P-1, P-2, P-3, P-4,
and P-5 and wells MW-26 and MW-32; and
Several problems were observed with the construction ofMW-3, including:
A review of the MW-3 well as-built diagram showed that no geologic log was
provided at the time of well installation. Consequently, the Director was not
able to ascertain if the screened interval was adequately located across the base
of the shallow aquifer;
MW-3 was constructed without any filter media or sand pack across the
screened interval;
An excessively long casing sump (a 9 or 10 foot long non-perforated section of
well casing), was constructed at the bottom of the well; and
The well screen appeared to be poorly positioned, based on the low
productivity of the well, (there is no geologic log to verify proper positioning).
50
The Mill developed the wells as required and installed the protective casings required. The
Director concluded that EFRI had fulfilled the requirements and sent EFRI a Closeout Letter on
August 5, 2008.
With respect to the concerns raised about MW-3, the Mill installed MW-3A approximately 10
feet southeast of MW-3, in order to verify the depth to the upper contact of the Brushy Basin
Member of the Morrison Formation (the "UCBM"). After installation, the Director reviewed the
geologic log for MW-3 and the as-built reports for both MW-3 and MW-3A and concluded that
the well screen for MW-3A is 2.5 feet below the UCBM and the well screen for MW-3 is 4.5
feet above the UCBM. Therefore MW-3 is a partially penetrating well; whereas MW-3A is fully
penetrating. The Director concluded that semiannual sampling must continue in both wells until
sufficient data is available and the DRC can make a conclusion regarding the effects of partial
well penetration and screen length. As a result, the GWDP was modified to require that MW-3A
be completed with a permanent surface well completion according to EPA RCRA TEGD. EFRI
completed MW-3A as required, and on August 5, 2008 the DRC sent EFRI a Closeout Letter.
Both MW-3 and MW-3A are currently sampled semiannually.
Subsequent to original Permit issuance, on January 6, 2006, DRC staff performed an inspection
of the compliance groundwater monitoring wells at the Mill. During the inspection, well MW -5
was found to have a broken PVC surface casing. The repair of MW -5 was added to the Permit
compliance schedule to require the Mill to repair the broken PVC casing to meet the
requirements of the Permit.
The Permit required EFRI to submit an As-Built report for the repairs of monitoring well MW-5
on or before May 1, 2008. EFRI submitted the required report, and on August 5, 2008 the DRC
sent EFRI a Closeout Letter.
The groundwater monitoring program at the Mill has historically had numerous wells with
elevated turbidity, turbidity levels which could not stabilize to within 10% Relative Percent
Difference (10% RPD) or both. Identification of equipment problems and improvements to field
sampling practices did not result in improvements to measured turbidities. Ongoing turbidity
issues were the result of monitoring requirements which were most likely ill-suited to the site
geology. It is suspected that many wells at the Mill might not be capable of attaining a turbidity
of 5 NTU due to the natural conditions in the formation hosting the perched monitoring wells
(the Burro Canyon Formation and Dakota Sandstone). Clay interbeds occur in both the Burro
Canyon Formation and Dakota Sandstone, and friable materials occur within the Burro Canyon
Formation. Saturated clays and friable materials will likely continue to be mobilized using
standard purging techniques currently in use for the sampling program at the Mill. Mobilized
kaolinite (a cementing material within the formation) is expected to be an additional continuing
source of turbidity in perched wells. EFRI discussed the turbidity issues with DRC and agreed to
complete a redevelopment program for the selected wells at the Mill in a "good-faith" effort to
reduce the turbidity level. Surging, bailing, and overpumping were determined to be the
preferred well development techniques. The rationale for using surging and bailing followed by
overpumping is consistent with U.S. Environmental Protection Agency ("EPA") guidance and
guidance provided in other technical papers and publications.
51
Select, nonpumping, chloroform, nitrate and groundwater POC, wells were redeveloped during
the period from fall 2010 to spring 2011 by surging and bailing followed by overpumping. The
results of the redevelopment are provided in the Report entitled: Redevelopment of Existing
Perched Monitoring Wells White Mesa Uranium Mill, Near Blanding Utah, prepared by Hydro
Geo Chern, Inc. September 30, 2011 (the "Redevelopment Report"). The Redevelopment Report
provides a qualitative description of turbidity behavior before and after redevelopment and
provides a number of conclusions and recommendations. A copy of the Redevelopment Report
was previously submitted under separate cover. The Redevelopment Report was closed out by
the Director in a letter dated November 15, 2012. The closeout denied EFRI recommendations.
However, due to other modifications to the sampling strategies, turbidity of the wells is no longer
considered an issue.
As described above, the ex1stmg wells have been reviewed by the Director, and repairs,
modifications, retrofits, etc. have been made as required to conform those wells to the
requirements of Pmt I.E.4 of the Permit, to the extent reasonably practicable.
2.9.6.2 Ground Water Sampling
Ground water sampling is performed in accordance with the requirements of Part I.E.5 of the
Permit, which requires that all monitoring shall be conducted in conformance with the following
procedures:
a) Grab samples shall be taken of the groundwater, only after adequate removal or
purging of standing water within the well casing has been performed;
b) All sampling shall be conducted to ensure collection of representative samples, and
reliability and validity of groundwater monitoring data. All groundwater sampling
shall be conducted in accordance with the currently approved Groundwater Monitoring
Quality Assurance Plan;
c) All analyses shall be performed by a laboratory certified by the State of Utah to
perform the tests required;
d) If any monitor well is damaged or is otherwise rendered inadequate for its intended
purpose, EFRI shall notify the Director in writing within five days of the discovery;
and
e) Immediately prior to each monitoring event, EFRI shall calibrate all field monitoring
equipment in accordance with the respective manufacturer's procedures and guidelines.
EFRI shall make and preserve on-site written records of such equipment calibration in
accordance with Part II.G and H of the Permit. Said records shall identify the
manufacturer's and model number of each piece of field equipment used and
calibration.
In accordance with the requirements of Part I.E.1 (a) of the Permit, groundwater sampling at the
Mill is performed in accordance with the White Mesa Uranium Mill Ground Water Monitoring
Quality Assurance Plan (QAP) (the "QAP"), which has been approved by the Director. The
QAP complies with UAC R317-6-6.3(1) and (L) and by reference incorporates the relevant
requirements of the Handbook of Suggested Practices for Design and Installation of Ground-
Water Monitoring Wells (EPN600/4-89/034, March 1991), ASTM Standards on Ground Water
and Vadose Investigations (1996), Practical Guide for Ground Water Sampling EPN60012-
52
851104, (November 1985) and RCRA Ground Water Monitoring Technical Enforcement
Guidance Document (1986), unless otherwise specified or approved by the Director. A copy of
the current version of the QAP, Date: 6-06-12 Revision 7.2, is included as Appendix K.
2.9. 7 Description and Justification of Parameters to be Monitored
The groundwater parameters to be monitored are described in Table 2.9.1.3-1. The process of
selecting the groundwater quality monitoring parameters for the original Permit included
examination of several technical factors. These factors are listed below and discussed in detail in
Section 4 on pages 9-19 of the 2004 Statement of Basis. :
a) The number and types of contaminants that might occur m feedstock materials
processed at the Mill;
b) Mill process reagents as a source of contaminants;
c) Source term abundance in the Mill's tailings cell solutions, based on historic
wastewater quality sampling and analysis that had been done at the Mill's tailings cells;
and
d) A consideration of contaminant mobility in a groundwater environment, based on site
specific .KI information where available and lowest .KI values in the literature where
site specific .KI information is not available.
One additional parameter, tin, was added to the list of groundwater monitoring constituents in
2007. Tin was not originally a required groundwater monitoring parameter in the Permit, and
was omitted from the original Permit due to non-detectable concentrations reported by EFRI in
three tailings leachate samples (2004 Statement of Basis, Table 5). With the addition of the
alternate feed material from Fansteel Inc., tin was estimated to increase from 9 to 248 tons in the
tailings inventory. The Director concluded that, with an estimated .KI of 2.5 to 5, tin is not as
mobile in the groundwater environment as other metals; however, with the acidic conditions in
the tailings wastewater, tin could stay in solution and not partition on aquifer materials. As a
result, tin was added as a monitoring constituent to Table 2 of the Permit.
2.9.8 Quality Assurance and Control Provisions for Monitoring Data
Part I.E.1 (d) of the Permit sets out some special conditions for groundwater monitoring. Under
those conditions, the Mill must ensure that all groundwater monitoring conducted and reported
complies with the following:
a) Depth to groundwater measurements shall always be made to the nearest 0.01 foot;
b) All groundwater quality analyses reported shall have a minimum detection limit or
reporting limit that is less than its respective GWCL concentration defined in Table 2
of the Permit; and
c) All gross alpha analysis reported with an activity equal to or greater than the GWCL
shall have a counting variance that is equal to or less than 20% of the reported activity
concentration. An error term may be greater than 20% of the reported activity
concentration when the sum of the activity concentration and error term is less than or
equal to the GWCL.
53
As mentioned in Section 2.9.6.2 above, Part I.E.1(a) of the Permit requires that all groundwater
sampling shall be conducted in accordance with the currently approved QAP. The detailed
quality assurance and control provisions for monitoring data are set out in the QAP, a copy of
which is attached as Appendix K to this Application.
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of Discharge
Systems (R317 -6-6.3.J)
As discussed in Section 2.7.1 above, the Mill has been designed as a facility that does not
discharge to groundwater or surface water. Tailings and other wastes associated with Mill
operations are designed to be permanently disposed of in the Mill's tailings cells. The Mill's
tailings cells can therefore be considered the Mill's discharge system in that they permanently
contain discharges from the Mill's process circuits and all other Mill tailings and wastes.
The following plans and specifications and as built reports relating to tailings Cells 1, 2, 3, 4A
and 4B are referenced in this Application and were previously submitted on the dates noted
below under separate cover:
a. Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
b. Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by D' Appolonia
Consulting Engineers, Inc.;
c. Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia Consulting
Engineers, Inc.;
d. Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc.;
e. Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation;
f. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by EFRI (then named International
Uranium (USA) Corporation);
g. Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants; and
h. Cell4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah, July
2008 prepared by Geosyntec consultants.
1. Cell4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007, prepared
by Geosyntec Consultants
J. Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-6-6.3.K)
2.11.1 General
The ground water most likely to be affected by a potential discharge from Mill activities is the
perched aquifer.
54
The deep confined aquifer under White Mesa is found in the Entrada and underlying Navajo
Sandstones, is hydraulically isolated from the perched aquifer, and is therefore extremely
unlikely to be affected by any such potential discharges. The top of the Entrada Sandstone at the
site is found at a depth of approximately 1,200 feet below land surface (see the discussion in
Sections 2.5.1.1 and 2.5.1.2 above). This deep aquifer is hydraulically isolated from the shallow
perched aquifer by at least two shale members of the Morrison Formation, including the Brushy
Basin (approximately 295 feet thick) and the Recapture (approximately 120 feet thick) Members.
Other geologic units are also found between the perched and deep confined aquifers that include
many layers of thin shale interbeds that contribute to hydraulic isolation of these two
groundwater systems, including: the Morrison Formation Westwater Canyon (approximately 60
feet thick), and Salt Wash (approximately 105 feet thick) Members, and the Summerville
Formation (approximately 100 feet thick). Artesian groundwater conditions found in the deep
Entrada/Navajo Sandstone aquifer also reinforce this concept of hydraulic isolation from the
shallow perched system. See the discussion on page 2 of the 2004 Statement of Basis.
2.11.2 Background Ground Water Quality in the Perched Aquifer
This Section describes the groundwater quality in the perched aquifer. See Sections 2.5.1.3,
2.5.1.4 and 2.5.1.5 above for a more detailed description of the perched aquifer itself, the depth
to ground water, the saturated thickness, flow direction, porosity, hydraulic conductivity and
flow system characteristics of the perched aquifer.
As mentioned in Section 2.9.1.5 above, a significant amount of historic groundwater quality data
had been collected by EFRI and previous operators of the Mill for many wells at the facility.
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality assurance
issues. The Director also noted several groundwater quality issues that needed to be resolved
prior to a determination of background groundwater quality at the site, such as a number of
constituents that exceeded their respective GWQS and long term trends in uranium in
downgradient wells MW -14, MW -15 and MW -17, and a spatial high of uranium in those three
downgradient wells.
As a result of the foregoing, the Director required that the Existing Well Background Report be
prepared to address and resolve these issues. DUSA prepared the Existing Well Background
Report that evaluated all historic data for the thirteen existing wells for the purposes of
establishing background groundwater quality at the site and developing groundwater compliance
limits GWCLs under the GWDP. Prior to review and acceptance of the conclusions in the
Existing Well Background Report, the GWCLs were set on an interim basis in the GWDP. The
interim limits were established as fractions of the state GWQSs for drinking water, depending on
the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells based primarily on the analysis performed in the Existing Well
background Report. It should be noted, however, that, because the GWCLs have been set at the
mean plus second standard deviation, or the equivalent, un-impacted groundwater would
55
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
As required by the Permit, the Existing Well Background Report addressed all available historic
data, which includes pre-operational and operational data, for the compliance monitoring wells
under the Permit that were in existence at the date of issuance of the Permit. The Regional
Background Report focuses on the pre-operational site data and the available regional data to
develop the best available set of background data that could not have been influenced by Mill
operations. The New Well Background Report, which was required by the Permit, analyzed the
data collected from the new wells, which were installed in 2005, to determine background
concentrations for constituents listed in the Permit for each new well.
The Existing Well Background Report and the New Well Background Report were prepared to
satisfy several objectives. First, in the case of the Existing Well Background Report, to perform
a quality assurance evaluation and data validation of the existing and historical on-site
groundwater quality data in accordance with the requirements of the Permit, and to develop a
database consisting of historical groundwater monitoring data for "existing" wells and
constituents.
Second, in the case of the New Well Background Report, to compile a database consisting of
monitoring results for new wells, which were collected subsequent to issuance of the Permit, in
accordance with the Mill's QAP data quality objectives.
Third, to perform a statistical, temporal and spatial evaluation of the existing well and new well
data bases to determine if there have been any impacts to groundwater from Mill activities.
Since the Mill is an existing facility that has been in operation since 1980, such an analysis of
historic groundwater monitoring data was required in order to verify that the monitoring results
to be used to determine background groundwater quality at the site and GWCLs have not been
impacted by Mill activities.
Finally, since the analysis demonstrated that groundwater has not been impacted by Mill
activities, to develop a GWCL for each constituent in each well.
The Regional Background Report was prepared as a supplement to the Existing Well
Background Report to provide further support to the conclusion that Mill activities have not
impacted groundwater.
In evaluating the historic data for the existing wells, INTERA used the following approach:
• If historic data for a constituent in a well do not demonstrate a statistically significant
upward trend, then the proposed GWCL for that constituent is accepted as representative
of background, regardless of whether or not the proposed GWCL exceeds the GWQS for
that constituent. This is because the monitoring results for the constituent can be
considered to have been consistently representative since commencement of Mill
activities or installation of the well; and
56
• If historic data for a constituent in a monitoring well represent a statistically significant
upward trend or downward trend in the case of pH, then the data is further evaluated to
determine whether the trend is the result of natural causes or Mill activities. If it is
concluded that the trend results from natural causes, then the GWCL proposed in the
Existing Well Background Report will be appropriate.
After applying the foregoing approach, JNTERA concluded that, other than some detected
chloroform and related organic contamination at the Mill site, which is the subject of a separate
investigation and remedial action, and that is the result of pre-Mill activities, and some elevated
nitrate concentrations in certain wells which were considered to be associated with the
chloroform plume, there have been no impacts to groundwater from Mill activities (See Section
2.16.1 below relating to the chloroform contamination and Section 2.16.2 relating to the nitrate
contamination).
In reaching this conclusion, JNTERA noted that, even though there are a number of increasing
trends in various constituents at the site, none of the trends are caused by Mill activities, for the
following reasons:
• There are no noteworthy correlations between chloride and uranium in wells with
increasing trends in uranium, other than in upgradient wells MW-19 and MW-18, which
JNTERA concluded are not related to any potential tailings seepage. JNTERA noted that
it is inconceivable to have an increasing trend in any other parameter caused by seepage
from the Mill tailings without a corresponding increase in chloride;
• There are significant increasing trends upgradient in MW-1, MW-18 or MW-19 in
uranium, sulfate, TDS iron, selenium, thallium, ammonia and fluoride and far
downgradient in MW-3 in uranium and selenium, sulfate, TDS and pH (decreasing
trend). JNTERA concluded that this provides very strong evidence that natural forces at
the site are causing increasing trends in these constituents (decreasing in pH) in other
wells and supports the conclusion that natural forces are also causing increasing trends in
other constituents as well; and
• On a review of the spatial distribution of constituents, it is quite apparent that the
constituents of concern are dispersed across the site and not located in any systematic
manner that would suggest a tailings plume.
JNTERA concluded that, after extensive analysis of the data, and given the conclusion that there
have been no impacts to groundwater from Mill activities, the GWCLs set out in Table 16 of the
Existing Well Background Report are appropriate, and are indicative of background ground
water quality. JNTERA did advise, however, that proposed GWCLs for all the trending
constituents should be re-evaluated upon Permit renewal to determine if they are still appropriate
at the time of renewal. See Table 16 of the Existing Well Background Report for JNTERA's
calculation of background ground water quality as represented by the proposed GWCLs. See
Section 6.0 of the Existing Well Background Report for a discussion of the statistical manner
used to calculate each proposed GWCL.
Upon approval of the Existing Wells Background Report, the Director required that the New
Well Background Report be prepared to address and resolve similar issues in the newer wells.
57
EFRI prepared the New Well Background Report that evaluated all historic data for the nine new
wells for the purposes of establishing background groundwater quality at the site and developing
GWCLs under the GWDP. Prior to review and acceptance of the conclusions in the New Well
Background Report, the GWCLs for the new wells were set on an interim basis in the GWDP.
The interim limits were established as fractions of the state GWQSs for drinking water,
depending on the quality of water in each monitoring well at the site.
In evaluating the new well data, INTERA used the same approach in the New Well Background
Report that was used in the Existing Well Background Repmt for existing well data. In addition,
INTERA compared the groundwater monitoring results for the new wells to the results for the
existing wells analyzed in the Existing Well Background Report and to the pre-operational and
regional results analyzed in the Regional Background Report. This was particularly important
for the new wells because there is no historic data for any constituents in those wells dating back
to commencement of Mill operations. A long-term trend in a constituent may not be evident
from the available data for the new wells. By comparing the mean concentrations of the
constituents in the new wells to the results for the existing wells and regional background data,
INTERA was able to determine if the constituent concentrations in the new wells were consistent
with background at the site.
INTERA concluded that after applying the foregoing approach, there have been no impacts to
groundwater in the new monitoring wells from Mill activities. INTERA concluded that the
groundwater monitoring results for the new wells are consistent with the results for the existing
wells analyzed in the Existing Well Background Report and for the pre-operational and regional
wells, seeps and springs analyzed in the Regional Background Report. INTERA noted that there
were some detections of chloroform and related organic contamination and degradation products
and nitrate and nitrite in the new wells, which are now the subject of two separate investigations
(see Sections 2.16.1 and 2.16.2), but that such contamination was the result of pre-Mill activities.
As a result, given the conclusion that there have been no impacts to groundwater from Mill
activities, INTERA concluded that the calculated GWCLs for new wells set out in Table 10 of
the New Well Background Report are appropriate, and are indicative of background ground
water quality. Again, INTERA noted that GWCLs for trending constituents should be re-
evaluated upon Permit renewal to determine if they are still appropriate at the time of renewal.
Additionally, the Flow Sheet states to "Consider an Alternate Approach" for determination of
GWCLs in trending constituents. In its report, INTERA recommended, as an alternative, that
GWCLs be set at the highest of a) the Flow Sheet approach, b) the highest historical value or c)
the fractional approach; provided that in no event would the GWCL be less than mean plus 20% .
This approach was rejected by the DRC in favor of the mean plus two standard deviation or
equivalent. See Table 10 of the New Well Background Report for INTERA's calculation of
background ground water quality as represented by the proposed GWCLs. See Section 2.2 of the
New Well Background Report for a discussion of the statistical manner used to calculate each
proposed GWCL.
The University of Utah Study confirmed INTERA's conclusions in the Background Reports that
groundwater at the site has not been impacted by Mill operations (see the discussion in Section
1.3 above).
58
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed during the New Well
Background Report. It should be noted, however, that, because the GWCLs were set at the mean
plus two standard deviations, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
Part I.G.2 of the Permit provides that out-of-compliance status exists when the concentration of a
pollutant in two consecutive samples from a compliance monitoring point exceeds a GWCL in
Table 2 of the Permit. Per the requirements of Part I.G.4(c) of the Permit, EFRI is required to
prepare and submit written plans and time schedules, for Director approval, to fully comply with
the requirements of Part I.G.4(c) of the Permit relating to any such out-of-compliance situation,
including, but not limited to:
(i) submittal of a written assessment of the source(s);
(ii) submittal of a written evaluation of the extent and potential dispersion of said
groundwater contamination; and
(iii) submittal of a written evaluation of any and all potential remedial actions to restore and
maintain ground water quality at the facility, for the point of compliance wells and
contaminants in question, to ensure that: 1) shallow groundwater quality at the facility
will be restored and 2) the contaminant concentrations in said point of compliance wells
will be returned to and maintained in compliance with their respective GWCLs.
Seven Plans and Time Schedules and six Source Assessment Reports ("SARs") have been
submitted to address consecutive exceedances other than pH which have been noted in wells
since the establishment of the GWCLs in the January 20, 2010 GWDP. The Plans and Time
Schedules and the SARs are included in Table 2.11.2-1. These Plans and Time Schedules and
SARs were previously submitted under separate cover.
On July 12, 2012, EFRI and the Director entered into a Stipulated Consent Agreement relating to
the implementation of the June 13, 2011 Plan and Time Schedule and the September 7, 2011
Plan and Time Schedules. The Stipulated Consent Agreement required the completion of a SAR
to meet the requirements of the June 13, 2011 Plan and Time Schedule and the September 7,
2011 Plan and Time Schedules.
Subsequent Plan and Time Schedules submitted to the Director have been approved by the
Director in letters to EFRI. The submission dates and the associated DRC approval dates of the
Plans and Time Schedules and the associated SARs are listed on Table 2.11.2-1.
Given the varied background groundwater quality at the site, previously identified rising trends
in some wells and other factors, it cannot be assumed that consecutive exceedances of a
constituent in a monitoring well means that contamination has been introduced to groundwater in
that well. The exceedances may very well be the result of background influences. The approach
59
in these Plans therefore is to first determine if the recent exceedances are the result of
background influences. If they are determined to be the result of background influences, then no
remedial actions are required. If, however, they are determined to not be the result of natural
background influences, then further analyses will be required.
Based on the information available at this time, EFRI believes that the GWCL exceedances
observed are the result of natural influences and reflect the need to adjust some of the GWCLs
for the site.
2.11.3 GWCL Determination for Field pH
During the completion of the 4th Quarter 2010 Quarterly Groundwater Monitoring Report, EFRI
noted eleven perched groundwater monitoring wells with pH measurements below the GWCLs.
These wells are located upgradient, cross-gradient, and downgradient of the Mill and tailings
cells. Investigation into the eleven pH GWCLs in question indicated that the GWCLs for
groundwater pH in all wells established in the January 20, 2010 GWDP were erroneously based
on historic laboratory results instead of field measurements as contemplated by Table 2 of the
GWDP. EFRI notified DRC that the existing GWCLs for groundwater pH were incorrectly based
on laboratory results rather than field measurements and proposed to submit revised descriptive
statistics for field pH to be used as revised pH GWCLs by the end of the second quarter 2011.
EFRI received approval from DRC to proceed with the revision of the pH GWCLs based on field
measurements. The data processing and statistical assessments necessary to revise the GWCLs
based on historic field pH data were completed. The data processing and statistical assessments
completed were based on the DRC-approved methods in the logic flow diagram included as
Figure 17 of the New Well Background Report. Following the statistical evaluation of pH data,
EFRI compared the Mill's groundwater pH data from the 2nd Quarter of 2011, including
accelerated sampling results through June 2011, and noted that all of the June 2011 groundwater
results, and many of the other results from the 2nd Quarter, were already outside the revised
GWCLs to be proposed based on the logic flow diagram.
It was noted that the historical trend of decreasing pH, which was addressed in the Background
Study Reports, appeared to be present in nearly all wells throughout the Mill site area, including
upgradient, downgradient, and cross-gradient wells in the groundwater monitoring program. As
of June 2011, all groundwater monitoring wells demonstrated a downward trend in the field pH
data over time.
EFRI notified DRC that the 2nd Quarter 2011 data exceeded the recalculated GWCLs. EFRI
advised DRC that, as a result of these findings, EFRI did not believe it was appropriate to
continue with its efforts to reset the GWCLs for pH based on field pH data, as originally
planned, but instead it appeared that it would be more appropriate to undertake a study to
determine whether the decreasing trends in pH are due to natural influences and, if so, to
determine a more appropriate way to determine GWCLs.
EFRI and DRC agreed on further investigations to be completed, as well as the steps and
milestone dates to be incorporated into a pH Report. The procedures for investigating the
decreasing site-wide pH trends is documented in the Plan to Investigate pH Exceedances in
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Perched Groundwater Monitoring Wells White Mesa Uranium Mill Blanding, Utah, Prepared by
Hydro Geo Chern, Inc, April 13, 2012 (the "pH Plan and Time Schedule"). The pH Plan and
Time Schedule described the pH investigation, which was incorporated into the July 12, 2012
Stipulated Consent Agreement referred to above. The pH Plan and Time Schedule was
previously submitted under separate cover.
The Stipulated Consent Agreement of July 12, 2012 specified that a pH Report be completed as
well as a separate investigation into the natural phenomenon that was causing the site-wide trend.
As a result, two reports investigating and describing the causes of the pH trend were completed.
These reports are the pH Report, dated November 9, 2012 (INTERA, 2012b) and the
Investigation of Pyrite in the Perched Zone, White Mesa Uranium Mill ("Pyrite Report"), dated
December 7, 2012 (HGC, 2012b).
The pH Report consists of a statistical and geochemical evaluation of the decline in pH in
groundwater wells at the Mill. The primary conclusion from the pH Report was that the
historical trend of decreasing pH, which was addressed in the Background Study Reports,
appears to be present in nearly all wells throughout the Mill site area, including upgradient,
downgradient, and crossgradient wells in the groundwater monitoring program, and there seems
to be no abatement of the trend. The wide-spread nature of the decrease in pH in upgradient,
downgradient, and crossgradient wells suggests that the pH decreases result from a natural
phenomenon unrelated to Mill operations, which is also confirmed by the indicator parameter
analysis conducted as part of the pH Report. As discussed in The Pyrite Report, the most likely
cause of declining pH across the site appears at this time to be the oxidation of pyrite, possibly
due to increasing water levels at the site attributed primarily to recharge of wildlife ponds and/or
the introduction of oxygen into the perched water zone as a result of increased groundwater
sampling frequency. Based on the conclusion that the pH trend was caused by natural
phenomenon, the pH Report recalculated the Groundwater Compliance Limits ("GWCLs") for
all compliance monitoring wells at the site.
The Pyrite Report evaluated and quantified the presence of pyrite throughout the Mill site, and
identified and quantified the mechanism by which it contributes to the sitewide decline in pH.
The results of the investigation support pyrite oxidation as the most likely mechanism to explain
decreases in pH and increases in sulfate concentrations in site wells and indicates that pyrite
must be considered in assessing perched water chemistry in the future. The complex interaction
of the various naturally occurring factors identified at the site, including the presence of pyrite at
varying concentrations, variable oxygen transport, and variable carbonate species concentrations,
is expected to result in relatively large background variations in pH, sulfate (and therefore TDS)
concentrations, as well as variations in background concentrations of pH sensitive analytes such
as metals. The expected impact of these various factors on pH and analyte concentrations, all of
which are unrelated to Mill operations, is generally consistent with site analytical results,
suggesting that pyrite oxidation plays a significant role in perched water chemistry at the site.
The primary conclusion from the activities conducted to date and described above is that the pH
trends are not due to potential tailings leakage or Mill activities, but to a natural phenomenon
unrelated to Mill operations.
61
In an effort to diminish any trends that may have resulted in whole or in part, from increasing
water levels attributed to the Wildlife ponds at the Mill, EFRI discontinued recharging the two
most northern of these ponds, commencing in March 2012.
2.11.4 Quality of Ground Water at the Compliance Monitoring Point
The analytical results from groundwater sampling are reported quarterly in Groundwater
Monitoring Reports, which are filed with the Director pursuant to Part I.F.1 of the Permit.
2.12 Compliance Sampling PJan (R317-6-6.3.L)
The Mill's plan for sampling groundwater compliance monitoring points is discussed in detail in
Section 2.9 .1.3 above, and the plan for sampling the leak detection systems in Cells 4A and 4B is
discussed in Section 2.15.3 below. This section addresses other sampling required under the
Permit. As the Mill is designed not to discharge to groundwater, there are no flow monitoring
requirements in the Permit.
2.12.1 Tai1ings CeH Wastewater Qua]ity Sampling PJan
Part I.E.10 of the Permit requires that, on an annual basis, EFRI collect wastewater quality
samples from each wastewater source at each tailings cell at the facility, including wastewaters
in surface impoundments, and slimes drains. The sampling is conducted in August of each
calendar year in compliance with an approved plan. The Tailings SAP (dated July 30, 2012) was
approved by the Director on August 2, 2012. A copy of the approved Tailings and Slimes Drain
Sampling Program, Revision 2.1, July 30,2012 is attached as Appendix L to this Application.
The purpose of the Tailings SAP is to characterize the source term quality of all tailings cell
wastewaters, including impounded wastewaters or process waters in the tailings cells, and
wastewater or leachates collected by internal slimes drains. The Revision 2.1, Tailings SAP
requires:
• Collection of samples from the pond area of each active cell and the slimes drain of each
cell that has commenced de-watering activities;
• Samples of tailings and slimes drain material will be analyzed at an offsite contract
laboratory and subjected to the analytical parameters included in Table 2 of the Permit
and general inorganics listed in Part I.E.1(d)(2)(ii) of the Permit, as well as semi-volatile
organic compounds;
• A detailed description of all sampling methods and sample preservation techniques to be
employed;
• The procedures utilized to conduct these analyses will be standard analytical methods
utilized for groundwater sampling and as shown in Section 8.2 of the QAP;
• The contracted laboratory will be certified by the State of Utah in accordance with UAC
R317 -6-6.12A; and
• 30-day advance notice of each annual sampling event must be given, to allow the
Director to collect split samples of all tailings cell wastewater sources.
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The tailings and slimes drain sampling events are subject to the currently approved QAP, unless
otherwise specifically modified by the Tailings SAP to meet the specific needs of this type of
sampling. The QAP has been approved by the Director and satisfies the most applicable
requirements of the following references, unless otherwise specified by the Director through his
approval of the Tailings SAP:
• Standard Methods for the Examination of Water and Wastewater, twentieth edition,
1998; Library of Congress catalogue number: ISBN: 0-87553-235-7;
• E.P.A. Methods for Chemical Analysis of Water and Wastes, 1983; Stock Number EPA-
600/4-79-020;
• Techniques of Water Resource Investigations of the U.S. Geological Survey, (1998);
Book 9;
• Monitoring requirements in 40 CFR parts 141 and 142, 2000 ed., Primary Drinking
Water Regulations and 40 CFR parts 264 and 270, 2000 ed.; and
• National Handbook of Recommended Methods for Water-Data Acquisition, GSA-GS
edition; Book 85 AD-2777, U.S. Government Printing Office Stock Number 024-001-
03489-1.
2.12.2 White Mesa Seeps and Springs Sampling Plan
The initial Permit required EFRI to submit a plan for groundwater sampling and analysis of all
seeps and springs found downgradient or cross gradient from the tailings cells for Director
review and approval. The Director approved the plan on March 17, 2009. A copy of the
Sampling Plan for Seeps and Springs in the Vicinity of the White Mesa Uranium Mill, Revision:
1, June 10, 2011, is attached as Appendix C to this Application. As of this writing, Revision 1.0
of this SAP is undergoing review by the Director.
Under the Seeps and Springs SAP, sampling is conducted on an annual basis between May 1 and
July 15 of each year, to the extent sufficient water is available for sampling, at six identified
seeps and springs near the Mill. The sampling locations were selected to correspond with those
seeps and springs sampled for the initial Mill site characterization performed in the 1978 ER,
plus additional sites located by EFRI, the United States Bureau of Land Management and Ute
Mountain Ute Indian Tribe representatives.
Samples are analyzed for all groundwater monitoring parameters found in Table 2 of the Permit.
The laboratory procedures utilized to conduct the analyses of parameters listed in Table 2 are the
same as utilized for groundwater sampling and as shown in Section 8.2 of the QAP. In addition
to these laboratory parameters, the pH, temperature and conductivity of each sample will be
measured and recorded in the field. Laboratories selected by EFRI to perform analyses of seeps
and springs samples are required to be certified by the State of Utah in accordance with UAC
R317-6-6.12.A.
The seeps and springs sampling events are subject to the currently approved QAP, unless
otherwise specifically modified by the Seeps and Springs SAP to meet the specific needs of this
type of sampling. The QAP has been approved by the Director and satisfies the applicable
requirements of the references listed in Section 2.12.1 above, unless otherwise specified by the
Director through his approval of the Seeps and Springs SAP.
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2.12.3 Monitoring of Deep Wells
Due to the fact that the deep confined aquifer at the site is hydraulically isolated from the
shallow perched aquifer (see the discussion in Section 2.11.1 above) monitoring of the deep
aquifer is not required under the Permit.
2.13 Description of the Flooding Potential of the Discharge Site (R317 -6-6.3.M)
2.13.1 Surface Water Characteristics
The Mill site is located on White Mesa, a gently sloping (1% SSW) plateau that is physically
defined by the adjacent drainages which have cut deeply into regional sandstone formations.
There is a small drainage area of approximately 62 acres (25 ha) above the site that could yield
surface runoff to the site. Runoff from the mesa is conveyed by the general surface topography
to either Westwater Creek, Corral Creek, or to the south into an unnamed branch of Cottonwood
Wash. Local porous soil conditions, topography and low average annual rainfall of 13.3 inches
(reported as 11.8 by Dames and Moore in historic reports) cause these streams to be
intermittently active, responding to spring snowmelt and local rainstorms (particularly
thunderstorms). Surface runoff from approximately 624 acres of the Mill drains westward and is
collected by Westwater Creek, and runoff from another 384 acres drains east into Corral Creek.
The remaining 4,500 acres of the southern and southwestern portions of the site drain indirectly
into Cottonwood Wash (1978 ER, p. 2-143). The site and vicinity drainages carry water only on
an intermittent basis. The major drainages in the vicinity of the Mill are depicted in Figure 12
and their drainage areas are tabulated in Table 2.13.1-1. Total runoff from the mesa (total yield
per watershed area) is estimated to be less than 0.5 inch annually (1978 ER, p. 2-143).
There are no perennial surface waters on or in the vicinity of the Mill site. This is due to the
gentle slope of the mesa on which the site is located, the low average annual rainfall of 13.3
inches per year at Blanding, local soil characteristics and the porous nature of local stream
channels. Prior to Mill construction, three small ephemeral catch basins were present to the
northwest and northeast of the Mill site.
Corral Creek is an intermittent tributary to Recapture Creek. The drainage area of that portion of
Corral Creek above and including drainage from the eastern portion of the site is about 5 square
miles. Westwater Creek is also an intermittent tributary of Cottonwood Wash. The Westwater
Creek drainage basin covers nearly 27 square miles at its confluence with Cottonwood Wash 1.5
miles west of the Mill site. Both Recapture Creek and Cottonwood Wash are similarly
intermittently active, although they carry water more often and for longer periods of time due to
their larger watershed areas. They both drain to the south and are tributaries of the San Juan
River. The confluences of Recapture Creek and Cottonwood Wash with the San Juan River are
approximately 18 miles south of the Mill site. The San Juan River, a major tributary for the
upper Colorado River, has a drainage of 23,000 square miles measured at the USGS gauge to the
west of Bluff, Utah (1978 ER, p. 2-130).
Storm runoff in these streams is characterized by a rapid rise in flow rates, followed by rapid
recession primarily due to the small storage capacity of the surface soils in the area. For
64
example, on August 1, 1968, a flow of 20,500 cubic feet per second was recorded in Cottonwood
Wash near Blanding. The average flow for that day, however, was only 4,340 cfs. By August 4,
the flow had returned to 16 cfs (1978 ER, p. 2-135). Monthly streamflow summaries as updated
from Figure 2.4 of the FES are presented in Figure 13 for Cottonwood Wash, Recapture Creek
and Spring Creek. Flow data are not available for the two smaller water courses closest to the
Mill site, Corral Creek and Westwater Creek, because these streams carry water infrequently and
only in response to local heavy rainfall and snowmelt, which occurs primarily in the months of
April, August, and October. Flow typically ceases in Corral Creek and Westwater Creek within
6 to 48 hours after precipitation or snowmelt ends.
2.13.2 Flood Protection Measures
The Mill was designed and constructed to prevent runon or runoff of storm water by a) diverting
runoff from precipitation on the Mill site to the tailings cells; and b) diverting runoff from
surrounding areas away from the Mill site via three drainage ditches that have been constructed
north (upslope) of the Mill facility.
, A detailed description of the flooding potential of the site, including the 6-hour probable
maximum precipitation (which is more conservative than the 100-year flood plain), and
applicable flood protection measures is provided in the UMETCO Minerals Corporation: White
Mesa Mill Drainage Report for Submittal to NRC, January 1990.
In addition to the foregoing designed control features, the facility has developed a Stormwater
Best Management Practices Control Plan which includes a description of the site drainage
features and the best management practices employed to ensure appropriate control and routing
of stormwater. A copy of the Mill's Stormwater Best Management Practices Plan is included as
Appendix G to this Application.
2.14 Contingency Plan (R317-6-6.3.N)
As required by Part I.H.15 of the Permit, the Mill has a Contingency Plan for regaining and
maintaining compliance with the Permit limits and for re-establishing best available technology
as defined in the Permit. A copy of the most cmrent approved version of the Mill's Contingency
Plan is included as Appendix M to this Application.
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting Failure
of the System (R317-6-6.3.0)
Part I.D. of the Permit sets out a number of DMT and BAT standards that must be followed. Part
I.E. of the Permit sets out the Ground Water Compliance and Technology Performance
Monitoring requirements, to ensure that the DMT and BAT standards are met. These provisions
of the Permit, along with the DMT Plan, Cell 4A and Cell 4B BAT Monitoring Operations and
Maintenance Plan and other plans and programs developed pursuant to these Parts, set out the
methods and procedures for inspections of the facility operations and for detecting failure of the
system.
65
In addition to the programs discussed above, the following additional DMT and BAT
performance standards and associated monitoring are required under Parts I.D and I.E. of the
Permit
2.15.1 Existing Tailings Cel1 Operation
Part I.D.2 of the Permit provides that authorized operation and maximum disposal capacity in
each of the existing tailings Cells, 1, 2 and 3 shall not exceed the levels authorized by the Mill
License and that under no circumstances shall the freeboard be less than three feet, as measured
from the top of the FML. Part I.E.7(a) of the Permit requires that the wastewater pool elevations
in Cells 1 and 3 must be monitored weekly to ensure compliance with the maximum wastewater
elevation criteria mandated by Condition 10.3 of the Mill License. However, a letter from the
Director dated January 27, 2011, which approved the use of Cell 4B, and a subsequent letter
dated March 14, 2011, stated that authorization of the use of Cell 4B and approval of the DMT
and Cell 4A Operations and Maintenance ("O&M") Plans effectively eliminated the former
freeboard elevation requirements for tailings Cell 3.
Part I.D.2 further provides that any modifications by EFRI to any approved engineering design
parameter at these existing tailings cells requires prior Director approval, modification of the
Permit and issuance of a construction permit.
2.15.2 Existing Facility DMT Performance Standards
Part I.D.3 of the Permit requires EFRI to operate and maintain certain Mill site facilities and the
existing tailings disposal cells to minimize the potential for wastewater release to groundwater
and the environment, including, but not limited to the following additional DMT measures:
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3
Parts I.D.3 (a) and (d) require that at all times EFRI operate and maintain Cells 1, 2 and 3 to
prevent groundwater quality conditions in any nearby monitoring wells from exceeding the
GWCLs in Table 2 of the Permit. The groundwater compliance monitoring program described
in detail in Section 2.9.1.3, is designed to provide early detection of a system failure in these
tailings cells.
2.15.2.2 Slimes Drain Monitoring
Part I.D.3(b)(l) of the Permit requires that EFRI at all times maintain the average wastewater
head in the slimes drain access pipe to be as low as reasonably achievable (ALARA) in each
tailings disposal cell, in accordance with the approved DMT Plan. Compliance is achieved when
the average annual wastewater recovery elevation in the slimes drain access pipe, determined
pursuant to the currently approved DMT Plan, meets the conditions in Equation 1of Part
I.D.3(b)(3) of the Permit.
Part I.E.7(b) of the Permit requires that EFRI monitor and record quarterly the depth to
wastewater in the slimes drain access pipes as described in the currently approved DMT Plan at
Cell 2, and upon commencement of de-watering activities, at Cell 3, in order to ensure
66
compliance with Part I.D.3(b)(3) of the Permit. At this time, de-watering of Cell 3 has not
commenced.
Quarterly measurements of the wastewater head in Cell 2 are reported in the quarterly DMT
reports submitted to DRC pursuant to the requirements of Part I.F.1, Table 7 of the GWDP. The
historic measurements for 2009 through 2013 are included in Appendix J. Annual compliance
calculations pursuant to Part I.D.3(b)(3) of the GWDP are submitted to DRC on or before March
1 of the following year. The annual compliance calculations submitted to date for Cell 2 are
summarized in Appendix J.
As noted in Appendix J, annual slimes drain compliance was not achieved for 2010, in
accordance with Part I.D.3 of the Permit. As noted in correspondence with DRC, the monthly
monitoring requirements specified in Part I.D.3(b)(2) of the February 2011 revision of the
GWDP seriously interfered with EFRI's ability to comply with Parts I.D.3(b)(i) and I.D.3 (b)(3)
of the GWDP. The monthly testing requirement resulted in the slimes drain pump being off (not
pumping) an average of 6.42 days per month every month which is equivalent to 77 days (11
weeks) per year or 20 percent of the year for performance of the measurements.
The GWDP was amended in July 2011 to change the frequency of the slimes drain testing from
monthly to quarterly. The average annual wastewater recovery elevation in the slimes drain pipe
has been in compliance (that is, less than the previous year's running average) since the
monitoring frequency changed from monthly to quarterly in July 2011.
2.15.2.3 Maximum Tailings Waste Solids Elevation
Part I.D.3(c) of the Permit requires that upon closure of any tailings cell, EFRI must ensure that
the maximum elevation of the tailings waste solids does not exceed the top of the FML liner.
2.15.2.4 Wastewater Elevation in Roberts Pond
Part I.D.3(e) of the Permit requires that Roberts Pond be operated so as to provide a minimum 2-
foot freeboard at all times, and that under no circumstances will the water level in the pond
exceed an elevation of 5,624 feet above mean sea level. Part I.D.3(e) also provides that in the
event the wastewater elevation exceeds this maximum level, EFRI must remove the excess
wastewater and place it into containment in Cell 1 within 72 hours of discovery.
Part I.E.7(c) of the Permit requires that the wastewater level in Roberts Pond must be monitored
and recorded weekly, in accordance with the currently approved DMT Plan, to determine
compliance with the DMT operations standard in Part I.D.3( e) of the Permit;
2.15.2.5 Inspection of Feedstock Storage Area
Part I.D.3(f) of the Permit requires that open-air or bulk storage of all feedstock materials at the
Mill facility awaiting Mill processing must be limited to the eastern portion of the Mill site (the
"ore pad") described by the coordinates set out in that Part of the Permit, and that storage of
feedstock materials at the facility outside of this defined area, must meet the requirements of Part
I.D.11 of the Permit. Part I.D.ll requires EFRI to store and manage feedstock materials outside
the defined ore storage pad in accordance with an approved Feedstock Management Plan. On
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June 20, 2008, EFRI submitted a White Mesa Mill Containerized Alternate Feedstock Material
Storage Procedure for Director review and approval. A copy of that procedure is included as
Appendix N to this Application. The Director is currently reviewing that procedure.
Part I.E.7(d) of the Permit requires that EFRI inspect the feedstock storage areas weekly to:
a) Confirm that the bulk feedstock materials are maintained within approved feedstock
storage defined by Table 4 of the Permit; and
b) Verify that all alternate feedstock materials located outside the feedstock storage area
defined in Table 4 are stored in accordance with the requirements found in Part I.D.11.
Part I.E.7(d) further provides that EFRI must implement the Feedstock Material Storage
Procedure immediately upon Director approval.
The Mill's procedure under the Mill License for inspection of the Mill's ore pad is contained in
Section 3.3 of the DMT Plan, a copy of which is attached as Appendix H to this Application.
2.15.2.6 Monitor and Maintain Inventory of Chemicals
Part I.D.3(g) of the Permit requires , EFRI to provide secondary containment to capture and
contain all volumes of reagent(s) that might be released at any individual storage area. This
requirement applies to all chemical reagents stored at existing storage facilities and held for use
in the milling process. Response to spills, cleanup thereof, and required reporting must comply
with the provisions of an approved Emergency Response Plan as found in the approved
Stormwater Best Management Practices Plan, stipulated by Parts I.D.10 and I.D.3(g) of the
Permit. Part I.D.3(g) further provides that for any new construction of reagent storage facilities,
such secondary containment and control must prevent any contact of the spilled or otherwise
released reagent or product with the ground surface.
Part I.E.9 of the Permit requires that EFRI monitor and maintain a current inventory of all
chemicals used at the facility at rates equal to or greater than 100 kg/yr. This inventory is to be
maintained on-site, and must include:
(i) Identification of chemicals used in the milling process and the on-site laboratory;
and
(ii) Determination of volume and mass of each raw chemical currently held in storage
at the facility.
A copy of the Mill's chemical Inventory is attached as Appendix 0 to this Application. A copy
of the Mill's Stormwater Best Management Practices Plan, Revision 1.5; September 2012 is
attached as Appendix G to this Application.
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2.15.3 BAT Performance Standards for Cell 4A
2.15.3.1 BAT Operations and Maintenance Plan
Part I.D.6 of the GWDP requires EFRI to operate and maintain Cell4A so as to prevent release
of wastewater to groundwater and the environment in accordance with a BAT Operations and
Maintenance Plan. At a minimum such plan must include the following performance standards:
a) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
b) The leak detection system maximum allowable daily leak rate shall not exceed 24,160
gallons/day;
c) After EFRI initiates pumping conditions in the slimes drain layer in Cell 4A, EFRI will
provide continuous declining fluid heads in the slimes drain layer, in a manner
equivalent to the requirements found in Part I.D.3(b) for Cells 2 and 3; and
d) Under no circumstances shall the freeboard be less than 3-feet in Cell 4A, as measured
from the top of the FML.
The BAT Operations and Maintenance Plan required under Part I.D.6 was approved by the
Director on December 21, 2011. A copy of the most current! y-approved BAT Operations and
Maintenance Plan is included as Appendix F to this Application.
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.8 of the Permit provides that, after Director approval of the Tailings Cell 4A BAT
Operations and Maintenance Plan, EFRI must immediately implement all monitoring and
recordkeeping requirements contained in the plan. At a minimum, such BAT monitoring shall
include:
a) Weekly Leak Detection System (LDS) Monitoring-including:
(i) continuous operation of the leak detection system pumping and monitoring
equipment, including, but not limited to, the submersible pump, pump controller,
head monitoring, and flow meter equipment approved by the Director. Failure of
any pumping or monitoring equipment not repaired and made fully operational
within 24-hours of discovery shall constitute failure of BAT and a violation of the
Permit;
(ii) measurement of the fluid head above the lowest point on the secondary FML by
the use of procedures and equipment approved by the Director. Under no
circumstance shall fluid head in the leak detection system sump exceed a 1-foot
level above the lowest point in the lower FML on the cell floor. For purposes of
69
compliance monitoring this 1-foot distance shall equate to 2.28 feet above the
leak detection system transducer;
(iii) measurement of the volume of all fluids pumped from the leak detection system.
Under no circumstances shall the average daily leak detection system flow
volume exceed 24,160 gallons/day; and
(iv) operation and maintenance of wastewater levels to provide a 3-foot Minimum of
vertical freeboard in tailings Cell 4A. Such measurements must be made to the
nearest 0.1 foot.
b) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4A slimes drain system,
monthly recovery head tests and fluid level measurements are to be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of the Permit and any plan approved by the Director.
2.15.4 BAT Performance Standards for Cell 4B
2.15.4.1 BAT Operations and Maintenance Plan
Part I.D.13 requires EFRI to operate and maintain Cell 4B so as to prevent release of wastewater
to groundwater and the environment in accordance with a BAT Operations and Maintenance
Plan, and that at a minimum such plan must include the following performance standards:
e) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
f) The leak detection system maximum allowable daily leak rate shall not exceed 26,145
gallons/day;
g) After EFRI initiates pumping conditions in the slimes drain layer in Cell 4B, EFRI will
provide continuous declining fluid heads in the slimes drain layer, in a manner
equivalent to the requirements found in Part I.D.3(b) for Cells 2, 3 and 4A; and
h) Under no circumstances shall the freeboard be less than 3-feet in Cell4B, as measured
from the top of the FML.
As mentioned above, the BAT Operations and Maintenance Plan was approved by the Director
on December 21, 2011. A copy of the most currently-approved BAT Operations and
Maintenance Plan, is included as Appendix F to this Application.
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.12 of the Permit provides that EFRI must implement all monitoring and recordkeeping
requirements contained in the Tailings Cell 4B BAT Operations and Maintenance Plan. At a
minimum, such BAT monitoring includes:
c) Weekly Leak Detection System (LDS) Monitoring-including:
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(i) continuous operation of the leak detection system pumping and monitoring
equipment, including, but not limited to, the submersible pump, pump controller,
head monitoring, and flow meter equipment approved by the Director. Failure of
any pumping or monitoring equipment not repaired and made fully operational
within 24-hours of discovery shall constitute failure of BAT and a violation of the
Permit;
(ii) measurement of the fluid head above the lowest point on the secondary FML by
the use of procedures and equipment approved by the Director. Under no
circumstance shall fluid head in the leak detection system sump exceed a 1-foot
level above the lowest point in the lower FML on the cell floor. For purposes of
compliance monitoring this 1-foot distance shall equate to 2.25 feet above the
leak detection system transducer;
(iii) measurement of the volume of all fluids pumped from the leak detection system.
Under no circumstances shall the average daily leak detection system flow
volume exceed 26,145 gallons/day; and
(iv) operation and maintenance of wastewater levels to provide a 3-foot Minimum of
vertical freeboard in tailings Cell 4B. Such measurements must be made to the
nearest 0.1 foot.
d) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4B slimes drain system,
monthly recovery head tests and fluid level measurements are to be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of the Permit and any plan approved by the Director.
2.15.5 Stormwater Management and Spill Control Requirements
Part I.D.10 of the Permit requires EFRI to manage all contact and non-contact stormwater and
control contaminant spills at the facility in accordance with an approved stormwater best
management practices plan. Such plan must include the following minimum provisions:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R317-6-6.3(G) and R317-6-6.4(C);
b) Prevent, control and contain spills of stored reagents or other chemicals at the Mill site;
c) Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
d) Report reagent spills or other releases at the Mill site to the Director in accordance with
UAC 19-5-114.
The Mill's Stormwater Best Management Practices Plan dated June 12, 2008, was approved by
the Director on July 1, 2008. A copy of the most recently approved Mill's Stormwater Best
Management Practices Plan Revision dated 1.5 September 2012, is included as Appendix G to
this Application.
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2.15.6 Tailings and Slimes Drain Sampling
Part I.E.1 0 of the Permit requires EFRI to annually collect wastewater quality samples from each
wastewater source at each tailings cell at the facility, including surface impounded wastewaters,
the leak detection systems (if present) and slimes drain wastewaters. All such sampling must be
conducted in August of each calendar year in compliance with the approved Tailings Sampling
Plan. See Section 2.12.1 above for a more detailed description of this program.
The Mill's Tailings and Slimes Drain Sampling Program was approved by the Director. The
most recently approved version is included as Appendix L to this Application.
2.15.7 Additional Monitoring and Inspections Required Under the Mill License
Under the Mill License daily, weekly, and monthly inspection reporting and monitoring are
required in accordance with NRC Regulatory Guide 8.31, Information Relevant to Ensuring that
Occupational Radiation Exposures at Uranium Recovery Facilities will be As Low As is
Reasonable Achievable, Revision 1, May 2002 ("Reg Guide 8.31"), by Section 2.3 of the Mill's
ALARA Program and by the Mill's Environmental Protection Manual ("EPM"). These
requirements are over and above the inspections described above that are required under the
Permit.
Additional daily, weekly, monthly, quarterly, and annual inspection and reporting requirements
are specified in the EFRI DMT Plan and Tailings Management System Procedure (Section 3.1 of
the EPM). The DMT Plan and Tailings Management System are included as Appendix H and
Appendix I to this Application, respectively.
2.15.7.1 Daily Inspections
Three types of daily inspections are performed at the Mill under the Mill License:
a) Radiation Staff Inspections
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the Mill's Radiation Safety Officer ("RSO") or
designated health physics technician should conduct a daily walk-through (visual) inspection of
all work and storage areas of the Mill to ensure proper implementation of good radiation safety
procedures, including good housekeeping that would minimize unnecessary contamination.
These inspections are required by Section 2.3.1 of the Mill's ALARA Program, and are
documented and on file in the Mill's Radiation Protection Office.
b) Operating Foreman Inspections
30 CFR Section 56.18002 of the Mine Safety and Health Administration regulations requires that
a competent person designated by the operator must examine each working place at least once
each shift for conditions which may adversely affect safety or health. These daily inspections are
documented and on file in the Mill's Radiation Protection Office.
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c) Daily Tailings Inspection
Section 3.1 of the Mill's EPM requires that during Mill operation, the Shift Foreman, or other
person with the training specified in paragraph 2.4 of the Tailings Management Procedure,
designated by the RSO, will perform an inspection of the tailings line and tailings area at least
once per shift, paying close attention for potential leaks and to the discharges from the pipelines.
Observations by the Inspector are recorded on the appropriate line on the Mill's Daily Inspection
Data form.
2.15.7.2 Weekly Inspections
Three types of weekly inspections are performed at the Mill under the Mill License:
a) Weekly Inspection of the Mill Forms
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the RSO and the Mill foreman should, and
Section 2.3.2 of the Mill's ALARA Program provides that the RSO and Mill foreman or their
respective designees shall, conduct a weekly inspection of all Mill areas to observe general
radiation control practices and review required changes in procedures and equipment. Particular
attention is to be focused on areas where potential exposures to personnel might exist and in
areas of operation or locations where contamination is evident.
b) Weekly Ore Storage Pad Inspection Forms
Paragraph 3.3 of the DMT Plan and Part I.E.7.(d of the Permit requires that weekly feedstock
storage area inspections be performed by the Radiation Safety Department to confirm that the
bulk feedstock materials are stored and maintained within the defined area of the ore pad and that
all alternate feed materials located outside the defined ore pad area are maintained in accordance
with the requirements of the Permit. The results of these inspections are recorded on the Mill's
Ore Storage/Sample Plant Weekly Inspection Report.
c) Weekly Tailings and DMT Inspection
Section 3.1 of the EPM requires that weekly inspections of the tailings area and DMT
requirements be performed by the radiation safety department.
2.15. 7.3 Monthly Reports
Two types of monthly reports are prepared by Mill staff:
a) Monthly Radiation Safety Reports
The RSO reviews the results of daily and weekly inspections, including a review of all
monitoring and exposure data for the month, and provides to the Mill Manager a monthly report
containing a written summary of the month's significant worker protection activities (Section
2.3.4 of the ALARA Program).
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b) Monthly Tailings Inspection Reports
Section 3.1 of the EPM, requires that a Monthly Inspection Data form be completed for the
monthly tailings inspection. This inspection is typically performed in the fourth week of each
month and is in lieu of the weekly tailings inspection for that week.
Mill staff also prepares a monthly summary of all daily, weekly, monthly and quarterly tailings
inspections.
2.15.7.4 Quarterly Tailings Inspections
Section 3.1 of the EPM requires that the RSO or his designee perform a quarterly tailings
inspection.
2.15.7.5 Annual Evaluations
The following annual evaluations are performed under the Mill License, as set out in Section 3.1
of the EPM.
a) Annual Technical Evaluation
An annual technical evaluation of the tailings management system must be performed by a
registered professional engineer (PE), who has experience and training in the area of
geotechnical aspects of retention structures. The technical evaluation includes an on-site
inspection of the tailings management system and a thorough review of all tailings records for
the past year. The Technical Evaluation also includes a review and summary of the annual
movement monitor survey (see Section (b) below).
All tailings cells and corresponding dikes are inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches are inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations were performed for the receipt of alternate feed
material during the year, the capacity evaluation forms and associated calculation sheets will be
reviewed to ensure that the maximum tailings capacity estimate is accurate. The amount of
tailings added to the system since the last evaluation will also be calculated to determine the
estimated capacity at the time of the evaluation.
As discussed above, tailings inspection records consist of daily, weekly, monthly, and quarterly
tailings inspections. These inspection records are evaluated to determine if any freeboard limits
are being approached and to identify any areas of potential concern. The evaluation also
involves discussion with the Environmental and/or Radiation Technician and the RSO regarding
activities around the tailings area for the past year. During the annual inspection, photographs of
the tailings area are taken. The training of individuals is also reviewed as a part of the Annual
Technical Evaluation.
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The registered engineer obtains copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These
copies are then included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 1st of every year to
the Directing Dam Safety Engineer, State of Utah, Natural Resources.
b) Annual Movement Monitor Survey
A movement monitor survey is conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes
3-S, 4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data
generated from this survey is reviewed and incorporated into the Annual Technical Evaluation
Report of the tailings management system.
c) Annual Leak Detection Fluid Samples
Annually, the leak detection system fluids in Cells 1, 2, 3, 4A and 4B are sampled when present
as described in the Tailings Sampling Plan in Section 2.12.1.
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to Remedy
any Violation of Applicable Ground Water Quality Standards (R317-6-6.3.P)
There are two circumstances where applicable groundwater standards have been exceeded at the
site that are not associated with natural background: chloroform contamination, and nitrate
contamination. As discussed below, none of these circumstances appear to be related to
discharges from milling activities. See Section 2.11.2 for a discussion of the current
investigation into exceedances of GWCLs for certain constituents and decreasing pH trends at
the site, which EFRI believes are associated with natural background.
2.16.1 Chloroform Investigation
In May, 1999, excess chloroform concentrations were discovered in monitoring well MW-4,
which is screened in the shallow perched aquifer along the eastern margin of the Mill site.
Because these concentrations were above the GWQS for chloroform, the Executive Secretary of
the Utah Water Quality Board initiated enforcement action against the Mill on August 23, 1999
through the issuance of a Groundwater Corrective Action Order (UDEQ Docket No. UG0-20-
01), which required completion of: 1) a contaminant investigation report to define and bound the
contaminant plume, and 2) a groundwater corrective action plan to clean it up. Repeated
groundwater sampling by both the Mill and DRC have confirmed the presence of chloroform in
concentrations that exceed the GWQS along the eastern margin of the site in wells that are
upgradient or cross gradient from the tailings cells. Other VOC contaminants and nitrate and
nitrite have also been detected in these samples. After installation of 27 new monitoring wells at
the site, groundwater studies appear to have defined the boundaries of the chloroform plume.
Based on the location of the plume and characterization studies completed to date, the
contamination appears to have resulted from the operation of temporary laboratory facilities that
were located at the site prior to and during construction of the Mill facility, and septic drainfields
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that were used for laboratory and sanitary wastes prior to construction of the Mill's tailings cells.
Interim measures have been instituted in order to contain the contamination and to pump
contaminated groundwater into the Mill's tailings cells. To that end, the Mill has equipped five
of the wells (MW-4, TW4-4, MW-26 (previously named TW4-15), TW4-19 and TW4-20) with
pumps to recover water impacted by chloroform and to dispose of such water in the Mill's
tailings cells.
In the 2004 Statement of Basis, DRC noted on page 3 that, while the contaminant investigation
and groundwater remediation plan are not yet complete, the DRC believes that additional time is
available to resolve these requirements based on the following factors: 1) hydraulic isolation
found between the shallow perched aquifer in which the contamination has been detected and the
deep confined aquifers which are a source of drinking water in the area, 2) the large horizontal
distance and the long groundwater travel times between the existing groundwater contamination
on site and the seeps and springs where the shallow aquifer discharges at the edge of White
Mesa, and 3) lack of human exposure for these shallow aquifer contaminants along this travel
path.
EFRI submitted a Preliminary Corrective Action Plan, White Mesa Mill Near Blanding, Utah,
August 20, 2007, prepared by Hydro Geo Chern, Inc., on August 21, 2007, and a Preliminary
Contamination Investigation Report, White Mesa Mill Near Blanding, Utah, November 20, 2007,
prepared by Hydro Geo Chern, Inc., on December 21, 2007. DRC has requested changes to the
proposed plans. When a Corrective Action Plan is approved by the Director, it will be subject to
public comments.
As part of the active strategy in the first phase of the Corrective Action Plan, EFRI has operated
a chloroform capture system, referred to as the "Long-term Pump Test" continuously since
January 31, 2010. The purpose of the test is to serve as an interim action that will remove a
significant amount of chloroform-contaminated water while gathering additional data on
hydraulic properties in the area of investigation. Chloroform-contaminated water is captured by
pumping six wells located within the identified chloroform plume, and transferred via an above-
ground piping network to Tailings Cell 1 for disposal.
Effectiveness of the first phase of the Corrective Action is evaluated and documented in
quarterly reports to the Director. EFRI estimates that, as of the first quarter of 2014, 699 lbs. of
chloroform have been extracted through the capture system.
2.16.2 Nitrate Investigation
During review of the New Well Background Report and other reports, a Nitrate contaminant
plume was identified by DRC staff in five monitoring wells in the Mill site area, including wells:
MW-30, MW-31, TW4-22, TW4-24, and TW4-25. TW4-25 is located upgradient of the Mill's
tailings cells. Elevated concentrations of chloride also appear to be associated with the nitrate
plume.
On September 30, 2008, the Director issued a request for a voluntary plan and schedule for EFRI
to investigate and remediate this Nitrate contamination. On November 19, 2008 EFRI submitted
a plan and schedule prepared by INTERA, Inc., which identified a number of potential sources
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for the contamination, including several potential historic and offsite sources. On January 27,
2009, the Director and EFRI signed a Stipulated Consent Agreement ("SCA") by which EFRI
agreed to conduct an investigation of the Nitrate contamination, determine the sources of
pollution, and submit a report by January 4, 2010.
EFRI submitted a Contaminant Investigation Report ("CIR") on December 30, 2009. On October
5, 2010 the Director issued a Notice of Additional Required Action ("NARA") letter that notified
EFRI of the Director's determination that the 2009 CIR was incomplete.
On December 20, 2010 EFRI and the Director entered into Revision 0 of a Tolling Agreement,
allowing a tolling period until April 30, 2011 in order to provide time for EFRI to prepare a Plan
and Schedule for Director review addressing additional investigations to resolve open issues
identified in the October 5, 2010 NARA, and to execute a revised SCA.
EFRI submitted a Plan and Schedule on February 14, 2011 and a revised Plan and Schedule on
February 18, 2011. The Director provided comments on the revised Plan and Schedule on
March 21, 2011. In an April 20, 2011 meeting, EFRI and the Director agreed that the Plan and
Schedule to conduct additional nitrate investigations would be composed of four to five phases
of study, including geoprobe drilling and soil sampling/analysis to investigate natural nitrate salt
reservoir sources in the vadose zone beyond the Mill site, potential Mill sources, and other
potential sources; groundwater sampling and analysis of existing monitoring wells for non-
isotopic analytes; deep bedrock core sampling/analysis of possible natural nitrate reservoir and
potential nitrate source locations; stable isotopic sampling/analysis of groundwater in existing
monitoring wells; and stable isotopic sampling/analysis of soil/core samples, if needed.
On April 28, 2011, EFRI and the Director entered into Revision 1 of the Tolling Agreement to
extend the Tolling Period through June 30, 2011 and adopt the agreements made on April 20,
2011. Under the Tolling Agreement Revision 1, EFRI agreed to submit a Revised Phase 1 (A
through C) Work Plan on or before May 6, 2011 and a Revised Phase 2 through 5 Work Plan and
Schedule on or before June 3, 2011.
EFRI submitted a May 6, 2011 Revised Phase 1 Work Plan and Schedule for the Phase 1 A-C
investigation for Director review. EFRI conducted field and laboratory work for the Phase 1 A-C
study in May and June, 2011.
EFRI submitted a Revised Phase 2 through 5 Work Plan and Schedule for Director review on
June 3, 2011. The Director provided comments on this document on June 23, 2011 and advised
EFRI that in order to revise the 2009 SCA to incorporate needed deliverables and timelines, the
Phase 2 through 5 Work Plan would need to be expanded to the same level of detail as was
provided for Phase 1 in Attachment 1 of the Revision 1 Tolling Agreement.
On June 30, 2011, EFRI and the Director entered into Revision 2 of the Tolling Agreement
extending the Tolling Period to August 31, 2011, to facilitate the revision of the Phase 2 through
5 Work Plan to provide the required level of detail to construct a replacement SCA. EFRI
submitted a separate July 1, 2011 detailed Revision 0 of the Work Plan and Quality Assurance
Plan ("QAP") for the Phase 2 investigation. The Director provided comments on this document
on July 7, 2011. EFRI provided a July 12, 2011 Revision 1.0 to the Phase 2 QAP and Work Plan,
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which DRC conditionally approved in a letter dated July 18, 2011. On August 1 and 2, 2011
EFRI submitted by email preliminary laboratory results for the Phase 1 A-C study to the Director.
On August 4, 2011, EFRI provided a Revision 1.0 to the Phase 2 - 5 Work Plan for Director
review. The Director provided comments on the Phase 2-5 Work Plan, Revision 1.0 and the
August 1, 2011 preliminary laboratory results on August 11, 2011. EFRI submitted Revision 2.0
of the Phase 2-5 Work Plan for Director review on August 11, 2011.
On August 25, 2011, the Director determined that based on review of the Revision 2.0 Phase 2-5
Work Plan, a finalized Plan and Schedule that meets the satisfaction of the Director, and which
would allow the preparation of a replacement SCA, was not possible at that time; and that the
development of a replacement SCA for continued contaminant investigation activities was not
supported.
At a meeting on August 29, 2011, EFRI and DRC agreed that:
1. After more than two years of investigation it has been determined that there are site
conditions that make it difficult to determine the source(s) of the contamination at the
White Mesa site;
2. As a result, resources will be better spent in developing a CAP in accordance with UAC
R317-6-6.15(D), rather than continuing with further investigations as to the source(s) of
the contamination.
In discussions during October 2011, EFRI and the Director acknowledged that it has not been
possible to date to determine the source(s), cause(s), attribution, magnitudes of contribution, and
proportion(s) of the local nitrate and chloride in groundwater, and thereby cannot eliminate Mill
activities as a potential cause, either in full or in part, of the contamination. As a result, EFRI and
the Director agreed that resources will be better spent in developing a Corrective Action Plan in
accordance with UAC R317 -6-6.15(D), rather than continuing with further investigations.
On October 3, 2011 EFRI and the Director entered into a revised Stipulated Consent Agreement
which required EFRI to submit a Corrective Action Plan for Director review that included plans
to:
Phase I -determine the physical extent of soil contamination observed at the Ammonium
Sulfate Crystal Tanks, and provide a control measure consisting of either removal of the
areal extent of contamination down to bedrock, or a Plan and Schedule for covering the
areal extent of contamination with at least 6 inches of concrete, followed by removal
action during or before site closure.
Phase II -implement near term active remediation of the nitrate contamination by
pumping contaminated water into the Mill's tailings cells for disposal. This phase is to
include development, implementation, operation, and monitoring of a pumping well
network to contain and hydraulically control the nitrate plume; monitoring of chloride
concentrations; and any required increases to the Mill's surety for activities in this Phase.
Phase III -develop, if necessary, a comprehensive long-term solution for the nitrate
contamination at the Mill Site. This Phase is to be determined after public participation
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and Director approval, and may include continuation of Phase I and II activities alone or
in combination with any of the following: monitored natural attenuation, additional
remediation and monitoring, determination of additional hydrogeologic characterization,
contaminant travel times, points of exposure to public or wildlife, risk analysis,
cost/benefit analysis, and possible development and petition of the Board for alternate
corrective action concentration limits.
EFRI submitted a Draft Corrective Action Plan on November 30, 2011. The Director provided
comments on the Draft Corrective Action Plan on January 19, 2012. EFRI provided Revision
1.0 of the Corrective Action Plan on February 27, 2012, and received comments from the
Director on March 19, 2012. Pursuant to the revised SCA, EFRI provided Revision 2.0 to the
Director on 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.
Based on the schedule included in the CAP and as delineated and approved by the SCO, the
activities associated with the implementation of the CAP began in January 2013. The reporting
requirements specified in the CAP and SCO are included in the quarterly nitrate reports.
2.17 Other Information Required by the Director (R317-6-6.3.Q)
As discussed below, a chemical inventory report and a Hydrogeologic investigation report for the
southwest portion of the Mill site have been completed at the request of the Director. No other
information has been specifically required by the Director to be included in this Application at
this time. EFRI will provide additional information as requested by the Director.
2.17.1 Chemica/Inventory Report
Part I.H.1 of the Permit requires that EFRI complete a historical review and conduct an inventory
of all chemical compounds or reagents stored, used, or currently in use at the facility. including
the types of chemicals and the total volumes present, and historically used, as data is available.
EFRI submitted a chemical inventory report on June 7, 2005, and submitted additional related
information on November 17, 2006.
Part I.H.1 requires that at the time of Permit renewal, the Permittee shall submit an updated
inventory report. Part I.E.9 requires that the inventory address chemicals used in the milling
process and the on-site laboratory. The updated inventory report is provided in Appendix 0 of
this Application.
2.17.2 Southwest Hydrogeologic Investigation
Part I.H.6 of the Permit required that EFRI perform a detailed Southwest Hydrogeologic
Investigation to define, demonstrate and characterize: 1) the hydraulic connection and local
groundwater flow directions between the area near Tailings Cell 4B, and the western margin of
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White Mesa, and 2) the full physical extent of the unsaturated area between former well MW -16,
MW-33 and the western margin of White Mesa.
During 2011, EFRI installed 18 piezometers to define the geologic and physical extent of the
apparent unsaturated structural high between Tailings Cell 4B and the western margin of White
Mesa and the location and direction of groundwater flow paths between Tailings Cell 4B and
Westwater and Cottonwood Seeps and Ruin Spring. Consistent with Part I.H.6.c) of the Permit,
EFRI submitted an investigation report, the Hydrogeology of the Perched Groundwater Zone in
the Area Southwest of the Tailings Cells, White Mesa Uranium Mill Site (the "Southwest
Hydrogeology Report"), prepared by Hydro Geo Chern, on January 12, 2012. The Director
provided comments in a conference call during May 2012, and in a letter dated May 30, 2012.
EFRI submitted a revised version of the Report on August 3, 2012 and agreed to repeat slug
testing of piezometer DR-08. DRC's September 20, 2012 review Summary and RFI, specifically
requested that EFRI:
• repeat slug testing of piezometer DR-08,
• recalculate hydraulic properties, and
• recalculate travel times if necessary based on new data.
The Second Revision to the Report, addressing the data and re-calculations resulting from
retesting of piezometer DR-08, was submitted on November 7, 2012.
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-6.3.R)
This Application has been performed under the direction, and bears the seal, of Harold R.
Roberts, Executive Vice President and Chief Operating Officer EFRI. Mr. Roberts is a
Registered Professional Engineer in the State of Utah, No. 165838.
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent Ground
Water Contamination During the Closure and Post Closure Phases of Operation (R17 -6-6.3.8)
2.19.1 Regulatory Requirements for Uranium Mills
2.19.1.1 Long Term Custodian
One unique feature of the regulatory scheme for uranium mill tailings is that Section 83 of the
Atomic Energy Act of 1954, as amended by the Uranium Mill Tailings Radiation Control Act of
1978 ("UMTRCA") (the Atomic Energy Act of 1954 as so amended is referred to herein as the
"AEA")4 requires that, prior to license termination, title to uranium mill tailings (lle.(2)
byproduct material) must be transferred to the United States Department of Energy ("DOE") or
the State in which the activity occurred, if the State so elects, for custody and long term care. 10
CFR 40.28 provides a general license to DOE or the State for that purpose.
2.19.1.2 Responsibility For And Manner Of Clean Up
UMTRCA amended the AEA to require that all Title ll facilities (i.e., active mills) comply with
4 See 42 U.S.C. 2113.
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the decontamination, decommissioning, and reclamation standards prescribed by the
Commission5 and to require that such facilities post reclamation bonds or surety6.
Responsibility for reclamation of Title II facilities rests with the licensee. 10 CFR Part 40
Appendix A Criterion 6A requires the adoption of a Director-approved reclamation plan for the
site, Criterion 9 requires that financial surety must be established to fund the cost of reclamation
in accordance with such plan, and Criterion 10 requires that each licensee include in its financial
surety an amount equivalent to $250,000 (1978 dollars) to cover the costs of long-term
surveillance by the long-term government custodian (DOE). Criteria 6, 9 and 10 have been
incorporated by reference into the Utah rules by UAC R313-24-4.
2.19.1.3 Surface
The reclamation plan adopted by the Mill at the outset, as required by 10 CFR Part 40, Appendix
A, Criterion 9, addresses the decontamination and decommissioning of the Mill and Mill site and
reclamation of tailings and other waste disposal areas.
As is the case for most uranium mills, the Mill's reclamation plan requires that, upon closure, all
mill buildings, unsalvageable equipment, contaminated soils (impacted by Mill operations within
the Mill site itself as well as surrounding areas that may be impacted by windblown radioactive
dusts from milling operations) etc. be deposited in the tailings cells and the tailings cells capped
in place.
Appendix A, Criterion 6(6) sets the standard for determining when all impacted areas, other than
the tailings impoundments have been adequately cleaned up. Criterion 6(6) provides that
byproduct material containing concentrations of radionuclides other than radium in soil, and
surface activity on remaining structures, must not result in a total effective dose equivalent
(TEDE) exceeding the dose from cleanup of radium contaminated soil to the benchmark standard
of 5pCi/g concentration of radium in the upper 15 em (6 in) of surface soils and 15 pCi/g
concentration of radium in the subsurface soils, and must be at levels which are ALARA. If
more than one residual radionuclide is present, the sum of the ratios for each radionuclide present
will not exceed "1" (unity). Further details on the NRC's approach to evaluating reclamation
plans and release criteria for uranium mill sites, including the manner of modeling the release
standard set out in Criterion 6(6), are contained in NUREG-1620, Rev 1, Standard Review Plan
for the Review of a Reclamation Plan for Mill Tailings Sites Under Title II of the Uranium Mill
Tailings Radiation Control Act of 1978, Final Report, June 2003 ("NUREG-1620").
2.19.1.4 Groundwater
Each uranium mill is required to have a groundwater monitoring program. In the case of the
Mill, the Permit implements the applicable requirements of U AC R317 -6. If there is
groundwater contamination after cessation of operations, the requirements of UAC R317-6.15
must be satisfied.
5 See 42 U.S.C. 2113.
6 See 42 U.S.C. 2201.
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2.19.1.5 License Termination
Section 83.7 of the ABA 7 provides that material and land transferred to the long term custodian
must be transferred without cost to the long-term custodian other than administrative and legal
costs incurred in carrying out such transfer.
In order to cover the costs of long-term surveillance, Criterion 10 requires that a minimum
charge of $250,000 (1978 dollars) must be paid by each mill operator to the general treasury of
the United States or to an appropriate State agency prior to the termination of a uranium mill
license.
In most cases if there is a groundwater contamination problem, the problem must be remediated
prior to license termination, or an alternate corrective action concentration limit under R317 -6-
6.15.0 must be achieved that is protective of public health and the environment. In some
circumstances DOE may agree to take some additional actions after it takes title to the site, such
as additional monitoring, if not onerous and provided adequate funding is provided.
Upon the Director and the NRC being satisfied that all regulatory requirements have been met
and the site is reclaimed in a manner that satisfies all applicable standards, the Mill's license will
be terminated upon transfer of the tailings to DOE. 10 CFR 40.28 provides a general license in
favor of the long-term custodian for custody of and long-term care of the tailings impoundments
and any surrounding lands transferred to it. 8 The surrounding areas not transferred to DOE
would generally be free-released.
2.19.2 Current Reclamation Plan
The Mill's Reclamation Plan, Revision 3.2B, was approved by DRC under the Mill License on
January 26, 2011. The Reclamation Plan sets out the requirements to be met by EFRI for the
final reclamation and closure of the Mill facility, including the tailings cells and all impacted
surrounding areas, in accordance with the requirements of 10 CFR Part 40, Appendix A (which
have since been incorporated by reference into UAC R313-24). A copy of the Mill's
Reclamation Plan, Revision 4.0 was previously submitted to the Director in November 2009 and
is on file at the DRC.
EFRI submitted Revision 5.0 of the Reclamation Plan in September 2011. DRC provided one
round of interrogatories for this document in March 2012. EFRI provided responses to these
interrogatories in May and August 2012. DRC provided review comments on EFRI's May and
August 2012 responses in February 2013.
On April 30, 2013, a meeting was held in Denver, Colorado to discuss specific issues identified
in DRC's February 2013 review comments, including, but not limited to, DRC's request for site-
specific tailings data and a probabilistic seismic hazard analysis (PSHA) for the Mill site.
Representatives of DRC, DRC's consultant (URS Professional Solutions, LLC), EFRI, and
7 See 42 U.S.C. 2113.
8 In circumstances where the facility has a groundwater contamination plume, additional lands may be acquired by
the licensee in order to bound the plume. In these circumstances these additional lands would be transferred along
with the capped tailings impoundments, to DOE.
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EFRI's technical consultant (MWH Americas, Inc.) attended the meeting. During the meeting,
EFRI proposed a tailings investigation to address the request for site-specific tailings data. A
work plan for this investigation was provided to DRC on June 24, 2013, and DRC provided
approval of the work plan verbally to EFRI on September 12, 2013. The tailings investigation
was completed in October 2013, and subsequent laboratory testing of collected samples was
completed in April 2014. A Tailings Data Analysis Report summarizing the results of the
investigation is currently being prepared for submittal to DRC in June 2014. A PSHA for the
Mill site is being prepared for submittal to DRC in June 2014 as well. Submission of responses
to DRC's February 2013 review comments on Revision 5.0 of the Reclamation Plan are planned
to be completed in 2014 after DRC's review of the Tailings Data Analysis Report and PSHA for
the Mill site. The results provided in the Tailings Data Analysis Report and PSHA for the Mill
site will be used to update technical analyses to address DRC's February 2013 review comments
on Revision 5.0 of the Reclamation Plan. The responses will also incorporate decisions made at
the April30, 2013 meeting on key issues related to Revision 5.0 of the Reclamation Plan.
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan
The Mill License is currently in timely renewal. As part of the Mill License Renewal, DRC is
re-examining the Mill's Reclamation Plan for content and adequacy. At the time of original
issuance of the Permit, the Director had not completed his review of the Mill's Reclamation
Plan. As a result, new requirements were added to the Permit to ensure that the final reclamation
design approved by the Director on his re-examination of the Reclamation Plan will provide
adequate performance criteria to protect local groundwater quality.
To this end, three requirements were included in Part I.D.8 of the Permit to ensure that the cover
system for each tailings cell will be designed and constructed to:
a) Minimize the infiltration of water into the radon barrier and underlying tailings waste;
b) Prevent the accumulation of leachates within the tailings that might create a bathtub
effect and thereby spill over the maximum elevation of the FML inside any disposal
cell; thereby causing a release of contaminants to the environment; and
c) Protect groundwater quality at the compliance monitoring wells by ensuring that
contaminant concentrations there do not exceed their respective GWQS or GWCL
defined in Part I.C.l and Table 2 of the Permit.
To provide consistency with the performance criteria stipulated by the Director at other lle.(2)
disposal operations, a 200-year minimum performance period was required for all three of these
criteria.
In addition, Part I.D.9 was included in the Permit, which provides that upon commencement of
decommissioning, EFRI will reclaim the Mill site and all related facilities, stabilize the tailings
cells, and construct a cover system over the tailings cells in compliance with all engineering
design and specifications of the approved reclamation plan. Part I.D.7 also provides that the
Director reserves the right to require modifications to the Mill's Reclamation Plan for purposes
of compliance with the Utah Ground Water Quality Protection Regulations, including but not
limited to containment and control of contaminants, or discharges, or potential discharges to
waters of the State.
83
Finally, Part I.D.9 was added to the Permit to provide the Director an opportunity to ensure that:
a) The post-closure performance requirements for the tailings cell cover system in Part
I.D.8 is fully and adequately integrated into the Mill's Reclamation Plan. Part I.H.2
was also added to the Permit to require EFRI to complete an infiltration and
contaminant transport model of the final tailings cell cover system to demonstrate the
long-term ability of the cover to protect nearby groundwater quality. As a part of this
cover system performance modeling required by Part I.H.2, the Director will determine
if changes to the cover system are needed to ensure compliance with the Part I.D.8
performance criteria;
b) All other facility demolition and decommissioning activities outlined in the
Reclamation Plan will be done in a manner adequate to protect local groundwater
quality. Issues or concerns to be considered and resolved include:
(i) Identification, isolation, and authorized disposal of any un-used chemical reagents
held in storage at the Mill site at the time of closure;
(ii) Demolition, excavation, removal, and authorized disposal of all contaminated
man-made structures, including, but not limited to: buildings, pipes, power lines,
tanks, access roads, drain fields, leach fields, fly-ash disposal ponds, feedstock
storage areas, Mill site wastewater storage ponds, solid waste disposal landfills,
and all related appurtenances; and
(iii) Excavation, removal, and authorized disposal of all contaminated soils found
anywhere outside of the tailings cells at the facility.
Through this process, the Director will be able to ensure that DMT has been adequately
established for both the final tailings cell cover system and reclamation of the facility.
EFRI submitted an Infiltration and Contaminant Transport Modeling Report, White Mesa Mill
Site, Blanding, Utah, November 2007, prepared by MWH Americas, Inc., in November, 2007.
EFRI submitted a revised Infiltration and Contaminant Transport Modeling Report, White Mesa
Mill Site, Blanding, Utah, March 2010 ("revised ICTM Report") in response to DRC comments.
The March 2010 report is currently being reviewed in conjunction with the Reclamation Plan,
Revision 5.0. DRC provided interrogatories for the revised ICTM Report in March 2012. EFRI
provided responses to these interrogatories in May and September 2012. DRC provided review
comments on EFRI's May and September 2012 responses in February 2013.
On April 30, 2013, a meeting was held in Denver, Colorado to discuss specific issues identified
in DRC's February 2013 review comments for Revision 5.0 of the Reclamation Plan and the
revised ICTM Report. As noted in Section 2.19.2, included in the discussions at this meeting
was DRC's request for site-specific tailings data. EFRI proposed a tailings investigation to
address DRC's concerns. The tailings investigation was completed in October 2013 and
subsequent laboratory testing of samples collected was completed in April 2014. A Tailings
Data Analysis Report summarizing the results of the investigation is currently being prepared for
submittal to DRC in June 2014. Submission of responses to DRC's February 2013 review
comments on the revised ICTM Report are planned to be completed in 2014 after DRC's review
of the Tailings Data Analysis Report. The results provided in the Tailings Data Analysis Report
84
will be used to update technical analyses to address DRC's February 2013 review comments on
the revised ICTM report. The responses will also incorporate decisions made at the April 30,
2013 meeting on key issues related to the revised ICTM Report.
2.19.4 Post-Operational Monitoring
Monitoring will continue under the Permit after cessation of operations, during reclamation and
after reclamation has been completed until such time as the Mill License and Permit are
terminated and the reclaimed tailings impoundments are transferred to the Department of Energy
for perpetual care and maintenance.
3.0 CONCLUSIONS
This Application describes the key monitoring and DMT performance standard requirements and
other protections contained in the Permit.
EFRI believes that with this Application, the accompanying Background Reports and other
documentation, the Director has been provided sufficient information to determine that:
a) EFRI has demonstrated that the applicable class TDS limits, ground water quality
standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) EFRI utilizes treatment and discharge minimization technology at the Mill
commensurate with plant process design capability and similar or equivalent to that
utilized by facilities that produce similar products or services with similar production
process technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
85
4.0 SIGNATURE AND CERTIFICATIONS
This Application is dated June 5, 2014 and is being submitted by Energy Fuels Resources (USA)
Inc.
Energy Fuels Resources (USA) Inc.
By: tZ?fl£
Frank J. Filas
Vice President, Permitting and Environmental Affairs
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the~ · Hit e and imprisonment for knowing violations.
c;:/7
Vice President, Permitting and Environmental Affairs
CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that the foregoing Application has been prepared under my direction, that I have
reviewed this Application, that I am familiar with the Mill facilities, and attest that this
Application has been prepared in accordance with good engineering practices.
'B'.arold R. Roberts
86
5.0 REFERENCES
American Society for Testing and Materials. 1996. Standards on Ground Water and Vadose
Investigations.
Dames & Moore. January 30, 1978. Environmental Report, White Mesa Uranium Project San
Juan County, Utah.
D' Appolonia Consulting Engineers, Inc. June 1979. Engineers Report: Tailings Management
System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. May 1981. Engineer's Report: Second Phase Design -
Cell 3 Tailings Management System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. February 1982. Construction Report: Initial Phase -
Tailings Management System, White Mesa Uranium Project Blanding, Utah.
Division of Radiation Control, Utah. December 1, 2004. Statement of Basis For a Uranium
Milling Facility at White Mesa, South of Blanding, Utah, Owned and Operated by
International Uranium (USA) Corporation.
EFRI. August 2000. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -
Tailings Management System. Prepared by EFRI (formerly International Uranium (USA)
Corporation).
Energy Fuels Nuclear, Inc. March 1983. Construction Report: Second Phase Tailings
Management System, White Mesa Uranium Project.
Energy Fuels Nuclear, Inc. January 14, 2011. Revised Phase 2 QAP and Work Plan, Revision
2.0.
Energy Fuels Nuclear, Inc. July 12, 2011. Reclamatin Plan for the White Mesa Mill, Blanding,
Utah. Source material License No.SUA-1358 Docket No. 40-8681 Revision.
Environmental Protection Agency. March, 1991. Handbook of Suggested Practices for Design
and Installation of Ground-Water Monitoring Wells (EP A/600/4-89/034 ).
Environmental Protection Agency. November, 1985. Practical Guide for Ground Water
Sampling (EPA/600/2-851104).
GeoSyntec Consultants. January 2006. Cell 4A Lining System Design Report For The White
Mesa Mill Blanding, Utah.
Geosyntec Consultants. July 2008. Cell 4A Construction Quality Assurance Report, White
Mesa Mill Blanding, Utah.
Geosyntec Consultants. November 2010. Construction Quality Assurance Report.
Geosyntec Consultants. December 8, 2012, Cell 4B Design Report, White Mesa Mill, Blanding
Utah
87
Hydro Geo Chern, Inc. 2001. Update to report: Investigation of Elevated chloroform
concentrations in Perched Groundwater at the White Mesa Uranium Mill Near Blanding,
Utah.
Hydro Geo Chern, Inc. August 29, 2002. Letter Report.
Hydro Geo Chern, Inc. August 20, 2007. Preliminary Corrective Action Plan, White Mesa Mill
Near Blanding, Utah.
Hydro Geo Chern, Inc. April 13, 2012. (2012a). Plan and Time Scheduler for Assessment of pH
Uner Groundwater Discharge Permit UGW370004.
Hydro Geo Chern, Inc. May 7, 2012. (2012b). Nitrate Corrective Plan.
Hydro Geo Chern, Inc. December 7, 2012. (2012c). Investigation of Pyrite in the Perched Zone,
White Mesa Uranium Mill, Blanding, Utah.
Hydro Geo Chern, Inc. June 6, 2014 Hydrogeology of the White Mesa Uranium Mill Site Near
Blanding, Utah.
HydroSOL VB, Inc. 2000. AQTESOL VB for Windows. Users Guide.
INTERA, Inc. October 2007. (2007a). Revised Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. November 16, 2007. (2007b). Revised Addendum: --Evaluation of Available Pre-
Operational and Regional Background Data, Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. April 30, 2008. Revised Addendum: --Background Groundwater Quality Report:
New Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County,
Utah.
INTERA, Inc. December 30, 2009 Nitrate Contamination Investigation Report White Mesa
Uranium Mill Site Blanding, Utah.
INTERA, Inc. June 1, 2010 Background Groundwater Quality Report for Wells MW-20 and
MW-22 for Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah.
INTERA, Inc. May 11, 2011. Revised Phase 1 (A through C) Work Plan and Schedule for Phase
1 A - C Investigation.
INTERA, Inc. June 3, 2011. Revised Phase 2 through 5 Work Plan and Schedule.
88
INTERA, Inc. October 10, 2012. Source Assessment Report, White Mesa Uranium Mill,
Blanding Utah.INTERA, Inc. November 9, 2012. pH Report White Mesa Uranium Mill,
Blanding Utah.
INTERA, Inc. May 7, 2013. Source Assessment Report for TDS in MW-29, White Mesa
Uranium Mill, Blanding Utah.
INTERA, Inc. August 30, 2013.Source Assessment Report for Selenium in MW-31, White Mesa
Uranium Mill, Blanding Utah.
INTERA, Inc. December 17, 2013. Source Assessment Report for Tetrahydrofuran in MW-01,
White Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. January 13, 2014. Source Assessment Report for Gross Alpha in MW-32, White
Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. March 19, 2014. Source Assessment Report for Sulfate in MW-01 and TDS in
MW -03A, White Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. May 1, 2014. Background Groundwater Quality Report for Wells MW-35, MW-
36 and MW-37 for Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
Kirby, 2008. Geologic and Hydrologic Characterization of the Dakota-Burro Canyon Aquifer
Near Blanding, San Juan County, Utah. Utah Geological Survey Special Study 123.
Knight-Piesold LLC. November 23, 1998. Evaluation of Potential for Tailings Cell Discharge
-White Mesa Mill.
MWH Americas. March, 2010. Revised Infiltration and Contamination Transport Modeling
Report, White Mesa Mill Site, Blanding Utah, Denison Mines (USA) Corp.
Nuclear Regulatory Commission. May 1979. Final Environmental Statement related to operation
of White Mesa Uranium Project Energy Fuels Nuclear, Inc., Docket No. 40-8681.
Resource Conservation Recovery Act. 1986. Ground Water Monitoring Technical Enforcement
Guidance Document.
Revised Tolling Agreement, Revision 3, between DUSA and the Director, Revision 2. August
21, 2011.
Stipulated Consent Agreement Docket No. UGW12-03 between Denison Mines (USA) Corp.
and the Director of the Division of Radiation Control. July 12, 2012.
T. Grant Hurst and D. Kip Solomon, Department of Geophysics, University of Utah. May 2008.
Summary of work completed, data results, interpretations and recommendations for the
89
July 2007 Sampling Event at the Denison Mines, USA, White Mesa Uranium Mill Near
Blanding Utah.
United States Geological Survey. 1998. Techniques of Water Resource Investigation of the US
Geological Survey, Book 9.
TITAN Environmental Corporation. July 1994. Hydrogeological Evaluation of White Mesa
Uranium Mill.
Umetco Minerals Corporation. April 10, 1989. Cell 4 Design, White Mesa Project Blanding,
Utah.
Umetco Minerals Corporation. January 1990. White Mesa Mill Drainage Report for Submittal
to NRC.
Umetco Minerals Corporation and Peel Environmental Services. 1993. Groundwater Study,
White Mesa Facilities, Blanding, Utah.
Utah, State of. January 20,2010. Ground Water Discharge Permit No. UGW370004
Utah, State of. June 21, 2010. Ground Water Discharge Permit No. UGW370004
Utah, State of. February 15, 2011. Ground Water Discharge Permit No. UGW370004
Utah, State of. June 13, 2011. Ground Water Discharge Permit UGW370004 Plan and Time
Shceduler Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the First,
Second, Third and Fourth Quarters of 2010 and First Quarter 2011.
Utah, State of. September 7, 2011. Ground Water Discharge Permit UGW370004 Plan and Time
Shceduler Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the First,
Second, Third and Fourth Quarters of 2010 and First Quarter 2011.
Utah, State of. July 14, 2011. Ground Water Discharge Permit No. UGW370004
Utah, State of. August 24, 2012. Ground Water Discharge Permit No. UGW370004
Utah, State of. Radioactive Materials License No. UT 1900479 (the "Mill License").
Utah, State of. December 13, 2012. Groundwater Discharge Permit UGW370004 Plan and Time
Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the Third
Quarter of 2012.
Utah, State of. March 15, 2013. Groundwater Discharge Permit UGW370004 Plan and Time
Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the Third
Quarter of 2012.
90
Utah, State of. August 28, 2013. Groundwater Discharge Permit UGW370004 Plan and Time
Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the Third
Quarter of 2012.
Utah, State of. September 20, 2013. Groundwater Discharge Permit UGW370004 Plan and Time
Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the Third
Quarter of 2012.
Utah, State of. December 5, 2013. Groundwater Discharge Permit UGW370004 Plan and Time
Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for Constituents in the Third
Quarter of 2012.
91
Table No.
1.2-1 ............. .
1.2-2 ............. .
2.4-1 .............. .
2.5.2.1-1 ......... .
2.5.3-1 ........... .
2.5.3-2 .......... ..
2.5.3-3 ........... .
2.5.3-4 .......... ..
2.5.3-5 ........... .
2.9.1.3-1. ....... ..
2.11.2-1 ......... ..
2.13.1-1 ........... .
INDEX OF TABLES
Description
Chloroform Monitoring Wells (Depth and Purpose)
Nitrate Monitoring Wells (Depth and Purpose)
Groundwater Monitoring Wells (Depth and Purpose)
Water Quality of Groundwater in the Mill Vicinity
Results of Quarterly Sampling Ruin Spring (2003-2004)
Results of Annual Sampling Ruin Spring (2009-2013)
Results of Annual Sampling Cottonwood Seep (2009-2013)
Results of Annual Sampling Westwater Seep (2009-2013)
Results of Annual Sampling Entrance Spring (2009-2013)
Groundwater Monitoring Constituents Listed in Table 2 of the
Permit
Plan & Time Schedule and Source Assessment Report Status
Drainage Areas of Mill Vicinity and Region
Table 1.2-1
Chloroform Monitoring Wells (Depth and Purpose)
,eiJ Location Tgtal Depth I Purpose
=='=" ~
TW4-1 111.04 Chloroform Monitoring Well
TW4-2 121.125 Chloroform Monitoring Well
TW4-3 141.00 Chloroform Monitoring Well
TW4-4 114.50 Chloroform Pumping Well
TW4-5 121.75 Chloroform Monitoring Well
TW4-6 98.55 Chloroform Monitoring Well
TW4-7 119.80 Chloroform Monitoring Well
TW4-8 126.00 Chloroform Monitoring Well
TW4-9 121.33 Chloroform Monitoring Well
TW4-10 111.00 Chloroform Monitoring Well
TW4-11 100.00 Chloroform Monitoring Well
TW4-12 101.50 Chloroform Monitoring Well
TW4-13 102.50 Chloroform Monitoring Well
TW4-14 93.00 Chloroform Monitoring Well
MW-26 121.33 Chloroform Pumping Well/Groundwater
Monitoring Well
TW4-16 142.00 Chloroform Monitoring Well
MW-32 130.60 Chloroform Pumping Well/Groundwater
Monitoring Well
TW4-18 137.50 Chloroform Monitoring Well
TW4-19 121.33 Chloroform Pumping Well
TW4-20 106.00 Chloroform Pumping Well
TW4-21 120.92 Chloroform Monitoring Well
TW4-22 113.50 Chloroform Monitoring Well/Nitrate
Pumping Well
Well Location Total Depth Purpos I
TW4-23 113.50 Chloroform Monitoring Well
TW4-24 113.50 Chloroform Monitoring Well/Nitrate
Pumping Well
TW4-25 134.80 Chloroform Monitoring Well/Nitrate
Pumping Well
TW4-26 86.00 Chloroform Monitoring Well
TW4-27 96.00 Chloroform Monitoring Well
TW4-28 105.00 Chloroform Monitoring Well
TW4-29 91.00 Chloroform Monitoring Well
TW4-30 90.00 Chloroform Monitoring Well
TW4-31 104.00 Chloroform Monitoring Well
TW4-32 113.00 Chloroform Monitoring Well
TW4-33 84.70 Chloroform Monitoring Well
TW4-34 94.00 Chloroform Monitoring Well
TW4-35 Installation in Chloroform Monitoring Well Progress
TW4-36 Installation in Chloroform Monitoring Well Progress
Table 1.2-2
Nitrate Monitoring Wells (Depth and Purpose)
W:ell Locatio,n To,talD pth Purpose
~ ,.._
TWN-1 112.50 Nitrate Monitoring Well
TWN-2 95.00 Nitrate Pumping Well
TWN-3 110.00 Nitrate Monitoring Well
TWN-4 136.00 Nitrate Monitoring Well
TWN-5 155.00 Abandoned
TWN-6 135.00 Water Level Monitoring Well
TWN-7 120.00 Nitrate Monitoring Well
TWN-8 160.00 Abandoned
TWN-9 102.50 Abandoned
TWN-10 107.50 Abandoned
TWN-11 147.50 Abandoned
TWN-12 115.00 Abandoned
TWN-13 120.00 Abandoned
TWN-14 135.00 Water Level Monitoring Well
TWN-15 155.00 Abandoned
TWN-16 100.00 Water Level Monitoring Well
TWN-17 100.00 Abandoned
TWN-18 100.00 Nitrate Monitoring Well
TWN-19 110.00 Water Level Monitoring Well
Table 2.4-1
Permit Monitoring Wells (Depth and Purpose)
WeD Location Total Depth Ptu:po e
MW-1 115.00 Semi-Annual Groundwater Compliance
MW-2 125.00 Semi-Annual Groundwater Compliance
MW-3 96.00 Semi-Annual Groundwater Compliance
MW-3A 95.00 Semi-Annual Groundwater Compliance
MW-4 122.00 No Longer Included In Groundwater
Program
MW-5 138.50 Semi-Annual Groundwater Compliance
MW-11 135.00 Quarterly Groundwater Compliance
MW-12 129.00 Semi-Annual Groundwater Compliance
MW-14 127.00 Quarterly Groundwater Compliance
MW-15 134.00 Semi-Annual Groundwater Compliance
MW-17 110.00 Semi-Annual Groundwater Compliance
MW-18 148.50 Semi-Annual Groundwater Compliance
MW-19 149.00 Semi-Annual Groundwater Compliance
MW-20 114.50 Semi-Annual Groundwater Monitoring
MW-22 140.00 Semi-Annual Groundwater Monitoring
MW-23 129.00 Semi-Annual Groundwater Compliance
MW-24 119.90 Semi-Annual Groundwater Compliance
MW-25 115.10 Quarterly Groundwater Compliance
MW-26 121.33 Quarterly Groundwater Compliance
MW-27 91.00 Semi-Annual Groundwater Compliance
MW-28 106.00 Semi-Annual Groundwater Compliance
MW-29 125.00 Semi-Annual Groundwater Compliance
I
MW-30 107.00 Quarterly Groundwater Compliance
MW-31 129.00 Quarterly Groundwater Compliance
MW-32 133.70 Semi-Annual Groundwater Compliance
MW-33 103.50 Dry, Not sampled
MW-34 109.00 Water Level Monitoring only
MW-351 123.60 Quarterly Groundwater for Background
MW-361 119.90 Quarterly Groundwater for Background
MW-3i 120.20 Quarterly Groundwater for Background
Notes:
1 -The Background Report for MW-35, MW-36, and MW-37 was submitted on May 1, 2014. These wells will
continued to be sampled quarterly until such a time that the Background Report is approved.
Table 2.5.2.1-1
Water Quality of Entrana!Navajo Aquifer in the Mill Vicinity
FES, Test Well Well#2 Well #5 Parameter (G2R) 6/01/991 6/08/991
(1/27177-3/231781)
Field Specific Conductivity 310 to 400 (umhos/cm)
Field pH 6.9 to 7.6
Temperature (0C) 11 to 22
Estimated Flow m/hr (gpm) 109(20)
pH 7.9to8.16
Uet~ruition., mg/Uter
TDS (@ 180°C) 216to1110
Redox Potential 211 to 220
Alkalinity (as CaCOS3) 180 to 224
Hardness, total (as CaC03) 177 to 208
Bicarbonate 226 214
Carbonate (as CO,) 0.0 <1.0 <1.0
Aluminum 0.003 0.058
Aluminum, dissolved <0.1
Ammonia (as N) 0.0 to 0.16 <0.05 <0.05
Antimony <0.001 <0.001
Arsenic, total .007 to 0.014 0.018 <0.001
Barium, total 0.0 to 0.15 0.119 0.005
Beryllium <0.001 <0.001
Boron, total <0.1 to 0.11
Cadmium, total <0.005 to 0.0 <0.001 O.ot 8
Calcium 50.6 39.8
Calcium, dissolved 51 to 11 2
Chloride 0.0 to 50 <1.0 2.3
Sodium 7.3 9.8
Sodium, dissolved 5.3 to 23
Silver <0.001 <0.001
Silver, dissolved <0.002 to 0.0
Sulfate 28.8 23.6
Sulfate, dissolved (as S04) 17 to 83
Vanadium 0.003 0.003
Vanadium, dissolved <.002 to 0.16
Manganese 0.011 0.032
Manganese, dissolved 0.03 to 0.020
Chromium, total 0.02 to 0.0 0.005 0.005
Copper, total 0.005 to 0.0 0.002 0.086
Fluoride 0.18 0.1 8
Fluoride_, dissolved 0.1 to 0.22
Iron, total 0.35 to 2.1 0.43 0.20
Iron~ dissolved 0.30 to 2.3
Lead, total 0.02 -0.0 <0.001 0.018
Magnesium 20.4 21.3
Magnesium, dissolved 15 to 21
1 Zero values (0.0) are below detection limits.
~ FES, Test Well Well #2 Well #5 Parameter (G2R) 6/01/991 6/08/991 I'
(1/27n7-3123nS1)
Molybdenum, dissolved 0.004 to 0.010
Nickel <0.001 0.004
Nitrate +Nitrate as N <0.10 <0.10
Nitrate (as N) <.05 to 0.12
Phosphorus, total (asP) <0.01 to 0.03
Potassium 3.1 3.3
Potassium, dissolved 2.4 to 3.2
Selenium <0.001 <0.001
Selenium, dissolved <.005 to 0.0
Silica, dissolved (as Si02) 5.8 to 12
Strontium, total 0.5 to 0.67
Thallium <0.001 <0.001
Uranium, total (as U) <.002 to 0.16 0.0007 0.0042
Uranium, dissolved (as U) <.002 to 0.031
Zinc 0.010 0.126
Zinc, dissolved 0.007 to 0.39
Total Or£anic Carbon 1.1 to 16
Chemical Oxygen Demand <1 to 66
Oil and Grease 1
Total Suspended Solids 6 to 1940 <1.0 10.4
Turbidity 5.56 19.1
Determination ~p_Cilliter) -
Gross Alpha <1.0
Gross Alpha + precision 1.6+ 1.3 to 10.2+2.6
Gross Beta <2.0
Gross Beta + precision 8+8 to 73+19
Radium 226 + precision 0.3+0.2
Radium 228 <1.0
Ra-226 +precision 0.1 +.3 to 0.6+0.4
Th-230 + precision 0.1+0.4 to 0.7+2.7
Pb-210 +precision 0.0+4.0 to 1.0+2.0
Po-210 +_Qrecision 0.0+0.3 to 0.0+0.8
Source: Adapted from FES Table 2.25 with additional Mill sampling data
Parameter
Major Ions (ml!fl}
Alkalinity
Carbon Dioxide
Carbonate
Bicarbonate
Hydroxide
Calcium
Chloride
·Fluoride
Magnesium
Nitrogen, Ammonia As N
Nitrogen, Nitrate+Nitrite as N
Phosphorous
Potassium
Sodium
Sulfate
111 Physical Properties
Conductivity (umbos/em)
pH
TDS (mg/L)
TSS (mg!L)
Turbidity (NTU)
Metals-Dissolved (mg/L)
Aluminum
Antimony
Arsenic
Barium
Ber:yllium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Uranium
Vanadium
Zinc
Radionuclides (pCi/L)
Gross Alpha Minus Rn & U
Lead 210
Radium 226
Thorium 230
Thorium 232
Thorium 228
Table 2.5.3-1
Results of Quarterly Sampling
Ruin Spring (2003-2004)
Ruin Spring
Ql-03 Q2-03 Q3-03 Q4-3
--196 198
--ND ND
--ND ND
--239 241
-ND ND
153 156 149 158
28.1 21.5 27.4 28.0 --ND 0.5
34.8 34.2 31.7 34.2
ND ND ND ND
1.6 1.5 1.4 1.4
0.10 ND -ND
2.6 3.3 3.3 3.9
110 105 103 113
503 501 495 506
. . 1440 1410 . -7.91 7.98 . . 1040 1000 . . 13.5 ND
-. 0.16 0.13
ND ND 0.40 ND
ND ND ND ND
0.001 ND ND 0.001
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND 0.082 ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
0.013 0.012 0.012 0.012
ND ND ND ND
ND ND ND ND
0.009 0.011 0.010 0.010
ND ND ND ND
0.014 ND ND ND
. --.
42 ND ND ND
0.3 ND 0.3 ND
0.3 0.2 0.5 ND
--ND ND
-. ND ND
.
Ql-04 Q2-04 Q3-04 Q4-04
193 191 195 183
ND ND 12 ND
ND ND ND ND
235 232 238 223
ND ND ND ND
158 162 176 186
29.3 28.5 26 25
0.5 0.6 0.6 0.6
35.8 35.1 37.1 38.6
ND 0.06 ND 0.06
1.73 1.85 1.34 1.7
ND ND ND ND
3.4 3.6 4.0 3.7
104 110 113 116
539 468 544 613
I
1390 1440 1320 1570
- --
1050 1110 1050 1070
ND ND ND ND
ND 0.12 --
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
0.012 0.012 0.012 0.012
ND ND ND ND
ND ND ND ND
0.011 0.011 0.009 0.010
ND ND ND ND
ND ND ND ND
ND ND 1.4 ND
ND ND ND ND
ND ND 1.3 ND
ND ND 0.4 ND
ND ND ND -
ND ND --
Constituent 2009
Carbonate <1
Bicarbonate 233
Calcium 151
Chloride 28
Fluoride 0.5
Magnesium 32.3
Nitrogen-
Ammonia 0.09
Nitrogen-
Nitrate 1.4
Potassium 3.3
Sodium 104
Sulfate 528
TOS 1010
Arsenic <5
Beryllium < 0.5
Cadmium <0.5
Chromium <25
Cobalt <10
Copper <10
Iron <30
Lead <1.0
Manganese <10
Mercury <0.5
Molybdenum 17
Nickel <20
Selenium 12.2
Silver <10
Thallium <0.5
Tin <100
Uranium 9.11
Vanadium <15
Zinc <10
um ;prmg -
Table 2.5.3-2
Results of Annual Sampling
R . S . (2009 2013)
RuinSor"nl!
2011-2011-
2010 May July 2012
Mu..ior Ioru lnl2/i)
<1 <1 1 <1
254 241 239 237
136 145 148 147
23 25 44 28
0.53 0.45 0.5 0.52
29.7 30.6 31.1 31.9
<0.05 NO <0.05 <0.05
1.7 1.7 1.6 1.6
3.07 3.2 3.3 3.5
93.4 110 111 115
447 486 484 464
903 942 905 1000
Metals (ui!I'J.)r·
<5 <5 <5 <5
< 0.5 < 0.5 <0.5 <0.5
<0.5 <0.5 <0.5 <0.5
<25 <25 <25 <25
<10 <10 <10 <10
<10 <10 <10 <10
<30 <30 <30 <30
<1.0 <1.0 <1.0 <1.0
<10 <10 <10 <10
<0.5 <0.5 <0.5 <0.5
17 16 17 16
<20 <20 <20 <20
10 11.8 10.2 10.8
<10 <10 <10 <10
<0.5 <0.5 <0.5 <0.5
<100 <100 <100 <100
8.47 9.35 8.63 8.68
<15 <15 <15 <15
<10 <10 <10 <10
Range of
Average
I Historic
Values for
Monitoring Ave 2003-
2013 WeDs 1 * 20042
<1
208 -~
149 --
26.3 NO-213 27
0.538 NO-1.3 0.6
32.1 --
<0.05 ,:_, -=~
1.56 --
3.46 -,;;
118 --
553 NO-3455 521
952 1019-5548 1053
<5 =" -
<0.5 ---
<0.5 NO-4.78 O.Dl
<25 ---·
<10 ---
<10 -· --
<30 NO -7942 25
<1.0 -
<10 ND-34,550 5
<0.5 --, -~
16.1 --
<20 NO-61 ~ 0.05
10.2 NO-106.5 12.1
<10 ---
<0.5 --
<100 -
9.12 NO-59.8 10
<15 --
<10 -
Radilllu~ics (pClll)
Gross Alpha <0.2 <0.2 <-0.3 <-0.05 <-0.09 <1.0 NP ~3g 0.28
VQ(!;S '{u :IX~)
Acetone <20 <20 <20 <20 <20 <20 ~ --
Benzene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ----
Carbon
tetrachloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --·
Chloroform <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --·-
Chloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ----
MEK <20 <20 <20 <20 <20 <20 ---
Methylene
Chloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -e -
Naphthalene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Tetrah ydrofuran <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 .. -
I
Toluene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ---
Xylenes <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
From Figure 3, Table 10 and Appendix B of the Revzsed Addendum, Background Groundwater Quality Report.
New Wells for Denison Mines (USA) Corp's White Mesa Mill Site, San Juan County, Utah, April30, 2008,
prepared by INTERA, Inc. and Table 16 and Appendix D of the Revised Background Groundwater Quality
Report: Existing Wells for Denison Mines (USA) Corp.'s White Mesa Uranium Mill Site, San Juan County,
Utah, October 2007, prepared by INTERA, Inc.
2 From Figure 9 of the Revised Addendum, Evaluation of Available Pre-Operational and Regional Background
Data, Background Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp.'s White Mesa
Mill Site, San Juan Couinty, Utah, November 16, 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-1, MW-2,
MW-3,MW-3A,MW-4,MW-5,MW-11,MW-12,MW-14,MW-15,MW-l7,MW-18,MW-19,MW-20,MW-
22, MW-23, MW-24, MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 andMW-32i
Table 2.5.3-3
Results of Annual Sampling
0 on woo eep -c tt d s (2009 2013)
Cottonwood See)
Range of
] ~
Average
Historic
Values for
2011-2011-Monitoring Ave 1977-
Constituent 2009 2010 May .Tulv 2012 2013 Wells1* 1982 I
'l\1a·or Ions (mgll)
Carbonate <1 <1 <1 6 <1 <1 -·-
Bicarbonate 316 340 330 316 326 280 ,. -
Calcium 90.3 92.2 95.4 94.2 101 87.9 I --
Chloride 124 112 113 134 149 118 ND-213 31
Fluotide 0.4 0.38 0.34 0.38 0.38 0.417 ND-1.3 0.8
Ma2,ncsium 25 24.8 25.2 25.2 27.7 23.6 -"" -
Nitrogen-<0.05 <0.05 <0.05 <0.05 Ammonia <0.05 <0.05 -~ -'"-
Nitrogen-Nitrate 0.1 <0.1 0.1 <0.1 <0.1 <0.1 --
Potassium 5.7 5.77 6 5.9 6.2 5.53 ·---
Sodium 205 214 229 227 247 217 ---
Sulfate 383 389 394 389 256 403 ND-3455 230
TDS 1010 900 1030 978 1040 996 1019-5548 811
Mcta.ls'(ug/1)
Arsenic <5 <5 <5 <5 <5 <5 ---
Beryllium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 --
Cadmium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ND-4.78
Chromium <25 <25 <25 <25 <25 <25 -~ -
Cobalt <10 <10 <10 <10 <10 <10 --
Copper <10 <10 <10 <10 <10 <10 """
Iron <30 <30 53 <30 <30 <30 ND -7942 150
Lead <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
<10 <10 <10 <10 ND -
Manganese <10 <10 34,550 580
Mercury <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 --
Molybdenum <10 <10 <10 <10 <10 <10 ....
Nickel <20 <20 <20 <20 <20 <20 ND-61 -
Selenium <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 ND-106.5 ·-
Silver <10 <10 <10 <10 <10 <10 -.
Thallium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 ~ --
Tin <100 <100 <100 <100 <100 <100 --
Uranium 8.42 8.24 7.87 8.68 8.17 8.95 ND-59.8 -
Vanadium <15 <15 <15 <15 <15 <15 -
Zinc <10 <10 <10 <10 <10 <10 -
RsdioJo.Ribs,(liCill)
Gross Alpha <0.2 <0.2 <0.1 <-0.1 <-0.2 <1.0 ~D-36 7.2
V.OCS (IIWL)
Acetone <20 <20 <20 <20 <20 <20 ---
Benzene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --~
Carbon
tetrachloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -·~
Chloroform <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Chloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --..
MEK <20 <20 <20 <20 <20 <20 . ..,. ~'-
Methylene
Chloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ~ -
Naphthalene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ---
Tetrahydrofuran <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ---
Toluene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ---
Xylenes <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ---
I From Figure 3, Table 10 and Appendtx B of the Revzsed Addendum, Background Groundwater Quality Report.
New Wells for Denison Mines (USA) Corp's White Mesa Mill Site, San Juan County, Utah, April30, 2008,
prepared by INTERA, Inc. and Table 16 and Appendix D of the Revised Background Groundwater Quality
Report: Existing Wells for Denison Mines (USA) Corp.'s White Mesa Uranium Mill Site, San Juan County, Utah,
October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April30, 2008 (MW-1, MW-2,
MW-3,MW-3A,MW-4,MW-5,MW-11,MW-12,MW-14,MW-15,MW-17,MW-18,MW-19,MW-20,MW-
22, MW-23, MW-24, MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)
Constituent 2009
Carbonate <1
Bicarbonate 465
Calcium 191
Chloride 41
Fluoride 0.7
Magnesium 45.9
Nitrogen-Ammonia <0.05
Nitrogen-Nitrate 0.8
Potassium 1.19
Sodium 196
Sulfate 646
pH (s.u.) 8.01
TDS 1370
Arsenic <5
Beryllium <0.5
Cadmium <0.5
Chromium <25
Cobalt <10
Copper <10
Iron 89
Lead <1.0
Manganese 37
Mercury <0.5
Molybdenum 29
Nickel <20
Selenium <5.0
Silver <10
Thallium <0.5
Tin <100
Uranium 15.1
Vanadium <15
Zinc <10
Table 2.5.3-4
Results of Annual Sampling
Westwater Seep (2009-2013)
~· Westw111er-Seep
k
2011-2011-
2010 May Jul}'
Mtl'or Ions (mi1J
<1 <1
450 371
179 247
40 21
0.6 0.54
44.7 34.7 Not
0.5 0.06 Sampled
-Dry
<0.1 <0.1
6.57 3.9
160 112
607 354
7.38 7.2
1270 853
Metals (uw'l)
<5 12.3
<0.5 0.91
<0.5 0.9
<25 <25
<10 <10
<10 16
56 4540
<1.0 41.4
87 268
Not
<0.5 <0.5 Sampled
29 <10 -Dry
<20 29
<5.0 <5.0
<10 <10
<0.5 <0.5
<100 <100
46.6 6.64
<15 34
<10 28
Range of
Average Historic
Values for
Monitoring
2012 2013 Wells1 *
--
--
--
NO-213
NO-1.3
Not Not --
Sampled Sampled-
-Dry Dry -
-·
-
-
NO-3455
6.7-8.9
1019-5548
----
NO-4.78
-
·~ -
-
NO -7942
-
Not Not NO-34.550
Sampled Sampled----Dry Dry
-'"
NO-61
NO-106.5
-
--
-
ND-59.8
-
-
IJ
Rn.diQJb!!i('S.foClfl).
Not Not Not
0.5 Sampled Sampled Sampled-
Gross Alpha < -0.1 <0.3 -Dry -Dry Dry ND -36,
V0€.5'(~)
Acetone <20 <20 ND -
Benzene <1.0 <1.0 ND --
Carbon tetrachloride <1.0 <1.0 ND ..
Chloroform <1.0 <1.0 ND -
Chloromethane <1.0 <1.0 ND Not Not Not -
MEK <20 <20 ND Sampled Sampled Sampled--
Meth_yJene Chloride <1.0 <1.0 ND -Dry -Dry Dry --
Naphthalene <1.0 <1.0 ND --
Tetrah ydrofuran <1.0 <1.0 ND -
Toluene <1.0 <1.0 ND ..
Xylenes <1.0 <1.0 ND
1 From Figure 3, Table 10 and Appendix B of the Revised Addendum, Background Groundwater Quality Report: New Wells for
Denison Mines (USA) Corp's White Mesa Mill Site, San Juan County, Utah, Apri130, 2008, prepared by INTERA, Inc. and Table
16 and Appendix D of the Revised Background Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp.'s
White Mesa Uranium Mill Site, San Juan County, Utah, October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on Apri130, 2008 (MW-1, MW-2, MW-3, MW-3A,
MW-4,MW-5, MW-11, MW-12,MW-14,MW-15,MW-17,MW-18,MW-19, MW-20, MW-22, MW-23,MW-24,MW-25,
MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)
II
Constituent 2009
Carbonate <I
Bicarbonate 292
Calcium 90.8
Chloride 60
Fluoride 0.7
Magnesium 26.6
Nitrogen-Ammonia 0.28
Nitrogen-Nitrate 1.4
Potassium 2.4
Sodium 61.4
Sulfate 178
TDS 605
Arsenic <5
Beryllium <0.5
Cadmium <0.5
Chromium <25
Cobalt <10
Copper <10
Iron <30
Lead <1.0
Manganese 54
Mercury <0.5
Molybdenum <10
Nickel <20
Selenium 12.1
Silver <10
Thallium <0.5
Tin <100
Uranium 15.2
Vanadium <15
Zinc <10
Gross Alpha 0.9
Table 2.5.3-5
n ranee spnng -3
Results of Annual Sampling
E t S . (2009 201 )
Entrance Sorio2
2011-2011-
2010 Mav Jul.y
Maior Ions (J112/))
<I <I 7
332 270 299
96.5 88.8 96.6
63 49 64
0.73 0.58 0.58
28.9 26.4 28.4
<0.05 <0.05 0.32
I 1.4 0.5
2.74 2.6 2.9
62.7 62.5 68.6
179 166 171
661 571 582
Metals (uWJ)
<5 <5 <5
<0.5 <0.5 <0.5
<0.5 <0.5 <0.5
<25 <25 <25
<10 <10 <10
<10 <10 <10
<30 37 55
<1.0 <1.0 <1.0
11 47 84
<0.5 <0.5 <0.5
<10 <10 <10
<20 <20 <20
9.2 13.1 5.5
<10 <10 <10
<0.5 <0.5 <0.5
<100 <100 <100
17.8 18.8 15.3
<15 <15 <15
<10 <10 <10
Radiololtics (pCi/1)
<0.5 1.5 1.6
Range of Average
Historic VaJues
2012 2013
for Monitoring
Wells1*
<I <I --
298 292 --
105 121 _,
78 139 ND-213
0.64 0.71 ND -1.3
32.7 43
<0.05 <0.05 --
2.8 2.06 --
2 3.83
77.4 127 ""'
171 394 ND-3455
660 828 1019-5548
-
<5 <5 --
<0.5 <0.5 -
<0.5 <0.5 ND-4.78
<25 <25
-<10 <10
<10 <10 ~
34 162 ND -7942
<1.0 <1.0 -
<10 259 ND-34.550
<0.5 <0.5 -·
<10 <10 ~
<20 <20 ND-61
13.2 11.2 ND -106.5
<10 <10 -
<0.5 <0.5
<100 <100 -
21.1 38.8 ND-59.8
<15 <15
<10 <10 -
0.5 2.3 ND-36
VOCSCuiUL)
Acetone <20 <20 <20 <20 <20 <20 --
Benzene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -·
Carbon tetrachloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Chloroform <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Chloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ·-
MEK <20 <20 <20 <20 <20 <20 --
Methylene Chloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Naphthalene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -~
Tetrah ydrofuran <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1-
Toluene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Xylenes <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ~
I From Figure 3, Table 10 and Appendix B of the Revtsed Addendum, Background Groundwater Qualtty Report.
New Wells for Denison Mines (USA) Corp's White Mesa Mill Site, San Juan County, Utah, April30, 2008,
prepared by INTERA, Inc. and Table 16 and Appendix D of the Revised Background Groundwater Quality
Report: Existing Wells for Denison Mines (USA) Corp.'s White Mesa Uranium Mill Site, San Juan County, Utah,
October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April30, 2008 (MW-1, MW-2,
MW-3,MW-3A,MW-4,MW-5,MW-ll,MW-12,MW-14,MW-15,MW-17,MW-18,MVV-19,MVV-20,MW-22,
MW-23, MW-24, MW-25, MW-26, MW-27, MW-28, MW-29. MW-30, MW-31 and MW-32)
Table 2.9.1.3-1
Groundwater Monitoring Constituents Listed in Table 2 of the Permit
Nutrients:
Ammonia (as N)
Nitrate & Nitrite (as N)
Heavy Metals:
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Uranium
Vanadium
Zinc
Radiologies:
Gross Alpha
Volatile Organic Compounds:
Acetone
Benzene
2-Butanone (MEK)
Carbon Tetrachloride
Chloroform
Chloromethane
Dichloromethane
Naphthalene
Tetrahydrofuran
Toluene
Xylenes (total)
Others:
Field pH (S.U.)
Fluoride
Chloride
Sulfate
TDS
Table 2.11.2-1
Plan & Time Schedule and Source Assessment Report Status
Plan and Time
Schedule (P&TS) Monitoring DRCP&TS
Date Periods Covered ApprovaJ Date SARDate SAR ApprovaJ Date Constituents
Q1, Q2, Q3, Q4 I
of2010, Q1 of
I 6/13/2011 2011 7112/2012 10110/2012 4/25/2013 Multiple
917/2011 Q22011 7112/2012 10110/2012 4/25/2013 MuJtiple I
pH report -11/9112
I 4113/2012 Multiple 7/12/2012 Pyrite Report-1217112 4/25/2013 pH-multiple wells
12/13/2012 Q3 2012 2/4/2013 5/8/2013 7/23/2013 TDS -MW-29
3115/2013 Q4 2012 5/30/2013 8/30/2013 9117/2013 Se-MW-31 I
8/28/2013 Q1 2013 9117/2013 12117/2013 117/2014 THF-MW-01
9/20/2013 Q2 2013 10/16/2013 1113/2014 3110/2014 Gross Alpha-MW-32
S04-MW-01, TDS -MW-
12/5/2013 Q3 2013 12118/2013 Submitted 3119114 03A
Table 2.13.1-1
Drainage Areas of Mill Vicinity and Region
I Basin Descrlption Dtairn\,ge Are-a
SQ.~S km:z ~~
Corral Creek at confluence with Recapture Creek 5.8 15.0
Westwater Creek at confluence with Cottonwood Wash 26.6 68.8
Cottonwood Wash at USGS Gauge west of project site :::::205 <531
Cottonwood Wash at confluence with San Juan River
:::::332 <860
Recapture Creek at USGS gauge 3.8 9.8
Recapture Creek at confluence with San Juan River
:::::200 <518
San Juan River at USGS gauge downstream at Bluff, Utah :::::23,000 <60,000
Source: Adapted from 1978 ER, Table 2.6-3
Figure No.
1 ....................... .
2 ....................... .
3 ....................... .
4 ....................... .
5 ....................... .
6 ....................... .
? ...................... ..
8 ....................... .
9 ....................... .
10 ....................... .
11 ....................... .
INDEX OF FIGURES
Description
White Mesa Mill Location Map
White Mesa Mill Land Map
Generalized Stratigraphy of White Mesa Mill
Approximate Elevation of Top of Brushy
Basin
Kriged 1st Quarter, 2014 Water Levels
Showing Inferred Perched Water Flow Paths
Southwest of Tailings Cells
Seeps and Springs on USGS Topographic
Base White Mesa
1st Quarter, 2014 Depths to Perched Water,
White Mesa Site
1st Quarter, 2014 Perched Water Saturated
Thickness White Mesa Site
Groundwater (Well and Spring) Sampling
Stations in the White Mesa Vicinity
White Mesa Mill Site Plan Showing
Locations of Perched Wells and Piezometers
Mill Site Layout
12 ... ... .. .. .. ... .. .. ..... Drainage Map of the Vicinity of the White
Mesa Mill
13. . . . . . . . . . . . . . . . . . . . . .... Streamflow Summary Blanding, UT Vicinity
WYOMING
UTAH
Legend
* Public Land Ownership
White Mesa Mill Private
• Town
• Village
-Highway
--Road
-·---··Stream
--Intermittent Stream
Tribal Land
Bureau of Land Management
Forest Service
State Trust Land
1:300,000
3 1.5 0
MILES
REVISIONS
N Date: By
3 ~
County: San Juan State: Utah
Locat1on Portions of T37S R22E S2~
Authoc areither
FIGURE 1
WHITE MESA MILL
LOCATION MAP
Date: 5/20/2014 Drafted By: areither
W.IUSA\Utah\Mill\MappiO!li\G'MJis.:harg~PamutAW\LandOwner.;lti~fltlop,m)((l' /6/212014 10:26:23 AM by IT!hefilll!l\on
24
C .-25
~_;J4_ntl t~~t seh.ool Sect•on
----............ 1
'-.....
\
\
'
I
/I
\ "
' '
\ '
\12
\
\
\
\13
\ ' """ .,.,.,----·~·
Surface Land Ownership
CJ Private
·~ Mill Site Claim
~ Utah State Lease
18
19
Bureau of Land Management
\.,.. ....
31
COTTONWOOD
I
( .
' \
?:-
19
/
' ,,
I
\
0 Bureau of Land Management \.~
I
\,_
)
I
I
J !
I
I
'1
20
' \
\ •,
I ---r 8 I
B~reau of Land Management
17
20_..-----,.. ..
·-( -, I ... , __ ~?
\34 \. 1 !;
10
' CJ)C (l.l>lif '::T::r o ~ ~r;;
2 ~·6. :i~ g ·~
'
CJ Blanding Municipal Boundary J -
CJ Utah Land Trust School Section I ! ' ...., ~·, ~ ._ i.; \1 ·I ~ -' I · I
.~.lii:PJ,I'i~,~lll~_20·13 ?/ttoni31 <?.e,09~~e:l11~ Societl,~cubed CJ Ute Mountain Ute 30
Legend
U JjProperty Boundary c::JTownship and Range
0 Structures CJ Section
Ov Seep or Spring ----Canyon Rim
Well c._·· Pond • Active -----Drainage
-$-Abandoned
29
Coordinate System: NAD 1983
StatePiane Utah South FIPS 4303 Feet
N
1 IN = 3,000 FT t
3,000 1,500 0 3,000
SCALE IN FEET
r I
... /~ ;/ J' / i . t£' .-ev ENERGYFUELS
REVISIONS I Project: WHITE MESA MILL
Data: By: I County: San Juan illtata: Utah
Location: PortiOns oiT37S R22E
FIGURE 2
WHITE MESA MILL LAND MAP
Author: mhenington Data: 6/2/2014 Drafted By: mhenington
'I..() ~ ~J 1
.
Le t 0
CD z
.
0
"" ' " '· '• ', ' ' ' -, ', ' ' '
' "" ' "'-\_ "" "'-, " " '· '-, ' "-.
EOLIAN SAND
COVERED BY UNCONSOLIDATED ALLUVIUM,
COLLUVIUM AND TALUS
SAND AND SILT, REDDISH BROWN VERY
FINE-GRAINED
~-= MANCOS SHALE:::---~-= = SHALE, LIGHT GRAY, SOFT
DAKOTA SANDSTONE
SANDSTONE, QUARTZ, LIGHT YELLOW BROWN,
POORLY SORTED, IRON CONCREATIONS, WELL
INDURATED
Q) , , ---" , ' BURRO CANYON FORMATION
SANDSTONE, QUARTZ, LIGHT GRAY TO LIGHT
BROWN, CROSS-BEDDED, CONGLOMERATIC,
POORLY SORTED INTERBEDDED WITH GRAY-GREEN
SHALE z
.
0 0 n z
(/)
(/) w z ~ 0
0 CD
I I-
w I-<( .
0 ~ ..q-
N X z 0 a: a.. a.. <( 0 L1) n z
.
0
0
.
0
0
N z
.
L1)
CXJ
-
', "\_ '· -, "·"' ',""' ',"' ', '
- - --· --
r
I ' I :
Taken from Stratigraphic SecUon near Water Well # 3
BRUSHY BASIN MEMBER
--------
WESTWATER CANYON MEMBER
-----------
RECAPTURE MEMBER
SALT WASH MEMBER
SUMMERVILLE FORMATION
------------
ENTRADA SANDSTONE
------------
NAVAJO SANDSTONE
-·----
z 0
i= <(
~ a: 0 u. z 0 C/) a: a:
0 ~
SHALE, GRAY, Gfli\Y-GREEN.I\ND f'Uf"Wl.E. Sll.lY
Ill! PART WITH SOI,1£ SANO$T0NE LENSES
SANDSTONE, ARKOSIC, YELLOW TO GREENISH GRAY,
FINE TO COARSE GRAINED, INTERBEDDED WITH
GREENISH-GRAY TO REDDISH-BROWN SHALE
SHALE, REDDISH-GRAY SILTY TO SANDY
INTERBEDDED WITH SANDSTONE, ARKOSIC,
REDDISH-GRAY, TO YELLOW-BROWN, FINE-TO
MEDIUM-GRAINED
SANDSTONE, QUARTZ, YELLOWISH-TO
REDDISH BROWN, FINE-TO COARSE-GRAINED
INTERBEDDED WITH REDDISH-GRAY SHALE
SANDSTONE, RED-BROWN, THIN-BEDDED, WITH RIPPLE
MARKS, ARGILLACEOUS WITH SHALE INTERBEDS
SANDSTONE, QUARTZ WHITE TO GRAYISH
BROWN, MASSIVE, CROSS-BEDDED, FINE-TO
MEDIUM-GRAINED
SANDSTONE, QUARTZ, LIGHT YELLOWISH-BROWN TO
LIGHT-GRAY AND WHITE, MASSIVE, CROSS-BEDDED,
FRIABLE, FINE-TO MEDIUM-GRAINED
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
~ -~ -DR-25
kriged top of Brushy Basin
elevation contour and label
approximate axis of Brushy Basin
paleoridge
approximate axis of Brushy Basin
paleovalley
X s386 abandoned boring showing
elevation in feet amsl
MW-5
·5·191
TW4-12
0 5521
TWN-7
Q 5545
perched monitoring well showing
elevation in feet amsl
temporary perched monitoring well
showing elevation in feet amsl
temporary perched nitrate monitoring
well showing elevation in feet amsl
PIEZ-1 perched piezometer showing
_, 5551 elevation in feet amsl
TW4-32 temporary perched monitoring well
~5499 installed September, 2013 showing
elevation in feet amsl
RUIN SPRING 6 531)0 seep or spring showing
elevation in teet amsl
HYDRO
GEO
CHEM,INC.
APPROVED
APPROXIMATE ELEVATION OF
TOP OF BRUSHY BASIN
WHITE MESA SITE
DilTS REFERENCE H :!718000!71802/
201 4_GWDP _rehewal_app/Ubbel1 4rv.sr!
FIGURE
4
.,.-...
__....,.,rfo
0
inferred perched water path line
potential perched flow pathline
(assuming hypothetical connection
to Cottonwood Seep)
kriged perched water level contour
and label
kriged nitrate> 10 mg/L within area
addressed by nitrate CAP
kriged chloroform > 1 0 ug/L
estimated area having saturated
thickness less than 5 feet
® estimated dry area
MW-5 e perched monil<!lring well
TW4-12 0 ternporary perched monitoring well
TWN-7 <> temporary perched nitrate monitoring well NOTE: MW:4, MW-26. TW4-•h TW4-19. and TW4~20 are chloroform
PIEZ-1
~ perched piezometer
TW4-32 temporary perched monitoring well ~ installed September, 2013
RUIN SPRING b seep or spring
HYDRO
GEO
CHEM,INC.
KRIGED 1st QUARTER, 2014 WATER LEVELS
SHOWING INFERRED PERCHED WATER FLOW PATHS
SOUTHWEST OF TAILINGS CELLS
APPROVED DATE REFERENCE H:/718000/71802/
2014_GWDP _renewal_app/Uwl0314path.srf
FIGURE
5
:2 "-m U) c..;
9
a 0 N ,_.:
li;
.0 E "' a. Q) (/)
>. "' '0 lt
~ E (!)
N a a a co
':::: (/) a
17
0.5 -·--0.5 --
i I
•.-"' ~ ! I '-
:\ ~t "-~
! \.,... .~. ·' \ f'
. ~/ .,.J 'Wo '::·~ ...
\ 1f" + ---· ... _____. \_ ·-{,)--1-_.,
Mile
\~ \~
/
SEEPS AND SPRINGS
ON USGS TOPOGRAPHIC BASE
WHITE MESA g • WESTWATER Seep or Spring __. EM INC rpproved
§ L ____ ~54~68~----~E:I:ev:a:ti:o:n~(f:ee:t~):ab:o=v=e~m:e:a~n~s=ea~le~ve=I--------------~N~O~R~T!H~~~~~~~C~li~~~,~~~~·~S~J~S~~~~L_~~~v~-~--~v~ .. ~-~~--~-~-~--~---_.----~ ':::: "'
Figure ·s
( ..... _,
®
MW·5
.106
TW4-12
0 43
TWN-7
Q s6
PIEZ-1
~63
TW4·32
~49
estimated area having saturated
thickness less than 5 feet
estimated dry area
perched monitoring well showing
depth to water in feet
temporary perched monitoring well
showing depth to water in feet
temporary perched nitrate monitoring
well showing depth to water in feet
perched piezometer showing
depth to water in feet
temporary perched monitoring well
installed September, 2013 showing
depth to water in feet
RUIN SPRING o seep or spring
NOTE: MW-4, MW-26, TW~. TW4-19, and TW4-20 are chloroform
HYDRO
GEO
CHEM,INC. APPROVED DATE
-llb~De1f
alf:lnf.J ood
~,5
~ ·~
1st QUARTER, 2014 DEPTHS
TO PERCHED WATER
WHITE MESA SITE
REFERENCE H :/718000/71802/
2014_ GWDP _renewal_ app/Udtw0314.srf
FIGURE
7
-
®
MW-5
.12
TW4--12
0 29
TWN-7 ~18
PIEZ-1
Q 4Q
TW4-32
~64
estimated area having saturated
thickness less than 5 feet
estimated dry area
perched monitoring well showing
saturated thickness in feet
temporary perched monitoring well
showing saturated thickness in feet
temporary perched nitrate monitoring
well showing saturated thickness in feet
perched piezometer showing
saturated thickness in feet
temporary perched monitoring well
installed September, 2013 showing
saturated thickness in feet
RUIN SPRING b seep or spring
HYDRO
GEO
CHEM,INC.
p.PPROVED
:~bong_onc9 lWN<n
tw~l'
1st QUARTER, 2014 PERCHED ZONE
SATURATED THICKNESSES
WHITE MESA SITE
DATE REFERENCE H:m 8ooom 802/
2014_ GWDP _renewal_app/Usat0314.srf
we.lls
FIGURE 8
.. ..
.. 4t
• ..
' .;
..,__
.... • " '·"-~!
... I
, .. -~ \"'··r;
r;,'•" , . .. J, ....
~ ... ( ...... ~
.. !:. ~··-,) \ -\.~~ ,...J l # ,~ I .~-· 'L. ~ ./'1'' ·-'4t .. .. .. l
: ;/ ,I I
! oj i -: ..
, ~~ \ '\ ~\ •. I
0 JO·
I ./ ..
!
G1R \ A :
N
.,, __...-;,)~ E n ~ .. -
s
~ 500' 0 1500' 3000'
~~ I I
SCALE: 1" = 3,000'
-:•~ '~ I .• ., ~ ;· , .... : I .• - -I ~ 1\ I I' i :·~··~··1 ··~··1 ····· ~ I ,., , = -~ ••
•• . '-· I ' ».•• ~. ,. .... ~ . ~ ~ .· ~. i I )
'I ~~ r
I
I f . '
' l
'· . . . ) I \ \ i j .-_::11!.1'?•
<.... .. -r ~ ~
":r
,,,
, ..
... .. I ____.I I--~ A ~ I ~
\
,~._.~...,.. -l·r ···
. C".;_/'' ~ I
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... ./\ ' . . .. . # • ' : ,, . ~. .. ' ... r-~ .G4.
> .. .. , .. •
\ I ;
I ~ r
• • . .. • ..t ~ -4 .,. .. . .. . ' • • . -• I . ..
G2R ---· ' I • : • ....
5
• • • • • • I
• I • • • • •
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... 'I.e \ ... -:.,..\
"' \. • I _.
••• ~
~~· ...
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~ "1 :
~;
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~
-
~
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.. ..
I
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........ ~ \,. ~ # ~.....,...,.. ) ... . ~ ., s . .... ... ,_..,_ o ' ~ ~ ~\ )~ -
•• ~I t~· ~ ... i -
"*,.r}'J.-.\....... ' , '\..,:· ' '· ·. \ ..
(
\ ,,
I)\ ... >\ ~ I • .. l , •• l •••• , •• ··~·· • I Ruin Spring •
It G3RA •
• • 1 ~(·.,., ' ; ': ',, ,.. ..
' Q; --..··'1 .· ~ I Q j ~~~ ..... ~~ •,.; ) '-\ ... • •
' .. \
\ .. .. #~ \ ' .. ..;
# .,.. .. ~
• (_)
L ... ""\.
'·· .... ~~-·~~ ; I I • : '11 •• , •• 1 ....
:It-• • ._ ! \:._";) > -, I\
I
... •. ' • (. .. , ,'I.')
4o • \ I # "-. \ ~ ~ ii I \ ·-....)
I • ' ,, ' ' I! -.
... ' ; . I ..... ~ "" -.
l ,_,.,w \ I '\.. \ \ I 1 •
,J># ~ --...,,~
\~
_)
.....
I 1 .:
\ ... ........_._ _ _) (
I! ... I ···---. ~ ( 1 .. ...,.wt.t't 1.(,;0
·.) .. ' ~ ./ , ..
.· ... !.(,; ( , ~ ~ .. ....... _. ·. .. ~ ,, .....
) •• 1 ~ ·~--
....
• • • • i •
I -~ , ¥ I
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• I • • . ..
•• •
~~·/t···· ' .. rn ~' . ~ ... I • ..
\ ~
~-
' "'' ... ~--... ..... ....,. .. ~~-• ,,
1"14. .. .. .... -A!
l
UTE
' . ~ \~, ~> .. ~~
•
_A. G4R GROUNDWATER (WELL OR SPRING)
SAMPLING LOCATION
-•1• •1• •1• PROPERTY BOUNDARY
RESERVATION BOUNDARY
5+ WATER SUPPLY WELL
-··-··-CANYON RIM
TW4-35
¢
TW4-19 EB
MW-5 • TW4-12
0
TWN-7
~
PIEZ-1
~
TW4-32
~
ptoposed lemporary parohe.d
msni1oring well
perched chloroform or
nitrate pumping well
perched monitoring well
temporary perched monitoring well
temporary perched nitrate monitoring well
perched piezometer
temporary perched monitoring well
installed September, 2013
RUIN SPRING b seep or spring
HYDRO
GEO
CHEM,INC.
APPROVED
~f-"d 1Wtl,n
~.
<Q . ~. M¥1;18 -~,
WHITE MESA MILL SITE PLAN
SHOWING LOCATIONS OF PERCHED
WELLS AND PIEZOMETERS
DATE REFERENCE H:/718000/71802/
2014_ GWDP _renewal_app/Uwelloc14.srf
FIGURE
10
oo oo ~~:~-~' AMMs;>NIA
SALT Q
sx
BUILDING
Q KEROSENE
0 ~ 0 -
oo
0 •
SODIUM
CHLORATE
SAMPLE PLANT
I I
D
TOPS<?IL
:-\] j
)
·7 ,•) v ·· ..
-----·
.-·
..
100 50
N
s
100 200
SCALE IN FEET
Resources (USA) Inc, Energy Fuels Blvd Suite 600
225 Umon d CO 80228 Lakewoo •
• 1 USGS GAUGE NO. 09376900
• 2 USGS GAUGE NO. 09378630
• 3 USGS GAUGE NO. 09378700
81ACK
1:\~!>.l• V1Tf
'6ci6' J
I
\
I
400
I-350 UJ UJ u.. uJ 300 -0:: (.,) <(
AVERAGE ANNUAL FLOW=950 AF-(1966-2001)
DRAINAGE AREA=3,77 SQ. MI.
AVERAGE ANNUAL YIELD=252.1 AF/SQ. MI.
-
.---YIELD-AF/SQ, Ml
MIN. AVG,
1600
t:u 1400
UJ u.. ~ 1200
(.,)
MAX $ 250 ~-~1000
0 _, u..
~ 200 .
I I-150 z 0 :::;;
UJ 100 (.!) ~ 50 -UJ ~
t:u 400
UJ u.. uJ 0::
350
300
2.7 252
(1990)
-
,-
. JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
MONTH
RECAPTURE CREEK NEAR BLANDING
USGS GAUGE 09378630
AVERAGE ANNUAL FLOW=7757 AF-(1966-1971)
DRAINAGE AREA=4,95 SQ. MI.
AVERAGE ANNUAL YIELD=153 AF/SQ. MI.
881
(1983)
~
$ 0 YIELD-AF/SQ. Ml _,
u..
~ I t-z 0 :::;;
250
200
150
UJ ~ 100 I
MIN. AVG.
46.9 153
(1971)
UJ 50 ~ ~ 0 JAN FEB 0MAR APR MAY JUN :::SEP~DECJ
MONTH
SPRING CREEK ABOVE DIVERSIONS,
USGS GAUGE 09376900
0 _, u..
>-_,
I I-z 0 :::;;
UJ (.!) ~
UJ ~
MAX.
262
(1966)
800
600
400
200
-
AVERAGE ANNUAL FLOW=6547 AF-(1965-1986)
DRAINAGE AREA=205 SQ. MI.
AVERAGE ANNUAL YIELD=32 AF/SQ. MI.
-
YIELD-AF/SQ. Ml
MIN. AVG. MAX.
4.9
(1976)
32 88
(1983) I
-
-Lr lit
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV d
MONTH
COTTONWOOD WASH NEAR BLANDING
USGS GAUGE 09378700
NOTES
1. FOR THE LOCATION OF WATER COURSES
SUMMARIZED, SEE FIGURE 3.7-1
2. SOURCE OF DATA, WATER RESOURCES DATA RECORDS.
COMPILED AND PUBLISHED BY USGS.
REVISIONS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
Date By I c.;oun!y: San Juan 1 ::;tate: utah
5-1 4 DLS Location:
::;cate: N/A
Figure 13
Streamflow Summary
Blanding UT Vicinity
j Date: Aug, 2009 j DraltedBy: D.Siedd
Streamflow Summary dwg Figure 13
I
Appendix
A .................... .
B .................... .
c .................... .
D .................... .
E .................... .
F .................... .
G .................... .
H .................... .
!. ..................... .
J ..................... ..
K ..................... .
L ..................... ..
M ...................... ..
N ..................... ..
INDEX OF APPENDICES
Description
Radioactive Materials License Amendment No.
4: March 31,2007
White Mesa Mill Site Maps with Well
Locations
Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill,
Revision: 1, June 10, 2011.
Results of Soil Analysis at Mill Site
Tables: Chemical and Radiological
Characteristics of Tailings Solutions, Leak
Detection Systems and Slimes Drains
Cell 4A and 4B BAT Monitoring, Operations
and Maintenance Plan 07 Ill Revision: Denison
2.3
Stormwater Best Management Practices Plan,
Revision 1.5: September 2012
White Mesa Mill Discharge Minimization
Technology (DMT) Monitoring Plan, 7/2012,
Revision: Denison-12.1
White Mesa Mill Tailings Management System,
7/2012, Revision: Denison 12.1
Cell 2 Slimes Drain Calculations and Figure
2009-2013
White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP)
Date 6/6/2012 Revision 7.2
Tailings and Slimes Drain Sampling Program,
Revision 2.1, July 30,2012
Contingency Plan, 12111 Revision: DUSA-4
White Mesa Mill Containerized Alternate
Feedstock Material Storage Procedure, PBL-
19, Revision: 1.0, December 18, 2012
0 .... .. ... . . . .... .. . . . .. . White Mesa Mill Chemical Inventory
Appendix A
Radioactive Materials License Amendment No.4: March 31,2007
~.15.1937 t:33JM 1'().340 P.4
TECHNICAL EVALUA TlON REPORT
REQUEST TO RECEIVE AND PROCESS AL ~NATE FEED MATERIAL
DOCKET NO. 40-8681
LICENSEE: International Uranium (USA) Corporation
FACILilY; \Nhite Mesa Uranium Mill
PROJECT MANAGER= James Park
SUMMARY AND CONCLUSIONS:
LICENSE NO. SUA-1358
The U.S. NuClear Regulatory Commission staff has reviewed Energy Fuels Nuclear, Inc.'s
(EFN's) request dated Apnl s, ·i 997, to receive and process uranium-bearing material currently
contained at Cabot Performance Materials' (CPM's) facility near Boyertown, Pennsylvania.
The material would be processed at the White Mesa mill, of which EFN is the former owner.
The current 0\lllner of the mill and NRC licensee, International Uranium (USA) Corporation
(IUC), previously has agreed to abide by all commitments and representation made _by EFN.
Based en its review of the Apnl 3, 1997, submittal and additional information provided by letters
dated May 6, May 19, June 20, and August 6, 1997, the NRC staff considers the amendment
request acceptable.
DESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:
By its submittal dated April3, 1997, EFN requested that NRC Source Material Ucense
SUA-1358 be amended to allow receipt and processing of alternate feed material (i.e., material
other than natural uranium ore) at its White Mesa uranium miU located near Blanding, Utah.
This uranium-bearing material, weighing approximately 16,000 dry tone, is held curTently by
CPM at its facility near Boyertown, Pennsylvania. The material is a moist solid (up to
40 percent moisture content) which contains uranium at an average concentration of
0.3 percent by weiahft and P,...onomically attractive cancentrations of tantalum and niobium.
CPM is authorized to po688SS this material under NRC Source Material Ucense SMB-920.
The material will be shipped by train and exclusive-use trucks from CPM's facility to the White
Mesa mill in intermodal containers. After being loaded and sealed at CPM's facility, the
containers will be transported by truck to a nea1rby intermOdal rail terminal. The containers will
be loaded on flatbed railcars and transported crcss-country to the final ran destination (either
Grand Junction, Colorado or Green River, Utah), where they will be transferred to tnJcks fer the
final leg of the journey to the White Mesa mill. Each container has a capacity of 25 cubic yards,
and it is expected that approximately 15 containers will be loaded and transported each day.
At the mill site, the uranium-bearing material will be emptied from the intermodal containers into
the ore receiving hopper. From there, the materiaJ will be processed through the semi-
autogenous grtnd (SAG) mill, where water will be added to aeate a slurry, which is then
1
fl,X;.15.1997 t:34A1 t<l. 34e P.S
pumped to .a pulp storage tank and from there into the leach cln:uil 1n tha 1each circuit. the
slurry will be treated to separate the uranium frotn the tantalum and niobium, and IUC wm ublize
the uranium and vanadium solvent extraction circuitB, respectively. to recover these metals.
IUC plans to add two filter presses and some additional piping to its mill circuit to aid in the
processing of this material.
Watsr spray systems will be utilized to reduce the potential for dust dispersion and airtome
contamination in emptying the intennodal containers. Other than the slight circuit cnanges
mentiOned previously, IUC anticipates that processing the uranium-bearing material will not
differ from processing natural uranium/vanadium ores.
IUC will provide per&onal protective equipment (coveralls, gloves, and full-face respirators (to
be used if needed)) to individuals engaged in processing the material. The efficiency of
airborne contamination control measures during the material handling operations will be
assessed in the immediate vicinity of these operations. Alrbome particulate samples and
breathing zone samples will be cclledad during initial material processing activities and
analyzed for gross alpha. Sampling results will be used to establish health and safety
guidelines to be implemented throughout the processing operations.
Additional environmental air samples wiD be collected at nearby locations to the material
prccessjng activities and analyzed to ensure that the established contamination control
measures arw adequate and effective.
Trucks used to transport the material to the mill site wiD be radiometricaUy scanned upon arrival
to ensure that leakage has not occurred and that radiation levels are_ within appropriate limits.
TruckS will again be scanned prior to theiT release from the site restricted area. In addition, the
intermodal containers used to transport the material will be properly closed, cleaned (if
necessary), surveyed, and documented before leaving the site.
TECHNICAL EVALUATION:
The NRC staff has review8d JUC'a raquest In accordance With 1 o CFR Part 40, Appendix A.
requirements and NRC staff guidance ~mal Position and Guidance on the Use of Uranium Mill
Feed Material Other Than Nmural Ores" (60 FR 49296; September 22, 1995). This guidance
(referred to hereinafter aa the alternate feed guidance) requires that the staff make the following
determinations in its revtewa of Hcensee requests to pnx:es\!1 material other than natural
uranium ores.
1. Whether the feed material meets the definition of "ore;"'
2. 'lllhether the feed matetial contain& hazardous waste: and
3. Whether the ore is being p~ primarily fur its source-material content.
2
AUG.15.1997 1:34PM t-«J. 34e p. 6
Deteanination of whether the feed material js "ore"
For the tailings and wastes from the proposed processing to qualify as 11 e.(2) byproduct
material, the feed material must qualify as "ore." In the alternate feed guidance, ore is defined
as
" ... a naturat or native matter that may be 1'11ined and treated for the extraction of
any of its constituents or any other matter from which source material is
extracted in a licensed uranium or thorium mill ...
lhe proposed alternate feed material contains uranium at an average concentration of 0.3
percent by weight therefore, it meets the definition of "source materia~" as defined at 1 o CFR
40.4. IUC i& proposing to extract this uranium. Therefore, the material meets the definition of
ore, because it Is a "matter from which source material Is extracted In a licensed uranium or
thorium mill."
Determination of whether the feed material contains tevatdOJJS.waste
Under the aHemate feed guidance, proposed feed material which contains a listed hazardous
waste wm not be apprawd by the NRC staff for processing at a licensed min. F~ materials
which exhibit only a characteristic of hazartlous waste (I.e., lgnitablllty, corroalvity, reactivity, or
toxicity) would not be regulated as hazardous waste and could therefore be approved by the
staff for recycling and sxtradian of source matenal. However, this does not apply to residues
from water treatment. Therefore, NRC staff acceptance of such raidues as feed material
would depend on their not containing any hazardous or Characteristic hazardous waste.
The NRC staff has reviewed the following sources of information in detennining whether the
uranium-bearing material i& or contains hazardous waste: (1) the average c:ompoaition data for
the material, as submitted by IUC on June 20, 1997, (2) 1he results of additional testing, as
provided by letter dated May e. 1997 I (3) NRC files for the Boyertown fadlity, which address, in
part. the proceu used to produce the material and the methods used to store the material, and
(4) supplementary information concerning the State of Pennsylvania Department of
Environmental Protection's hazardous waste regulations. In additionw as an attachment to
a Jetter dated August 6, 1997, IUC provided an atradavit from CPM In which CPM affirmed that
the material is not and does nat contain hazardous waata.
Based on its revieW, the NRC atatr finds that the uranium-bearing material ia not hazardous
wasta and does not contain hazardous waste. The NRC staff has determined alBa that the
uranium-bearing material is not • residue from water ~nent. This material is the result of
the initial processing of raw ares containing tantalum and nlabtum.
Therefore, the NRC staff considers the uranium-bearing material acceptable for recycling and
extraction of source materiaL
3
~.15.1997 1=35PM 1'(). 348 P. 7 -
OeterminifAgn of whether tt1e feed material js being proce§Sed prjmantv fcc its soyrce:material
content ·
To show that potential alternate~ material is being processed primarily for itB source-
material content, a licensee must either (1) demonstrate that the material would be approved
for disposal in the tailings impoundment under the 11Rnal Revised Guidance on Disposal of Nan-
Atomic Energy Ad of 1954, Section 11e.(2) Byproduct ~aterial in Tailings Impoundments;" or
(2) certify, under oath or affirmation, that the material i& being processed primanly for the
recovery of uranium and for no other primary purpose. Any such certification must be
supported by an appropriate justification and accompanying doaJmentation.
The licensee has provided a signed affirmation that the uranium-bearing material is being
processed primarily for the recovery of uranium and for no other primary purpese. IUC states
that the uranium content of the material, in conjunction with the reduced uranium processing
costs associated with the recovery of the tantalum and niobium, makes processing the CPM
material economically attractive to IUC. The NRC staff has discussed with IUC the business
arrangements regarding the material and finds that IUC is paying CPM for the acquisition of the
material.
The NRC staff has reviewed the anaJytical data provided by IUC and infannation contained in
the NRC's flies fbr the CPM facility, and finds that the uraniUm concentration in the material is
comparable With th• in natural uranium ores which are and were normally processed by
uranium mills in the U.S.. These natural ores contained uranium at concentrations of 0.3
percent and below. Therefore, the NRC staff conside1'1!1 IUC'a justification to be acceptable.
Conclusjons concerning alternate feed material designation
Based on the information provided by the licensee, the NRC staff finds that the CPM's uranium-
bearing matenal is altema1e feed material because: (1) It meets the deftnltion of •are," (2) tt
does not contain hazardous waste, and (3) it Is being processed primarily for its source-material
content
Other cgnsjc;leratigns
The NRC staff has alsa concluded that the proce&slng af this material wtl not mutt In (1) a
significant change or Increase In the types or amounts of effluents that may be released offsite;
(2) a significant Increase In Individual or cumulative occupational radiation exposure; (3) a
significant construction impact; or (4) a significant increase In the potential for or consequences
from radiological accidents. Thill canctuslon fa based on the following fnfonnation:
a. Yelowcake produced from the processing of this matartal will nat causa the currantJy-
approved yeOowcake pnxtuction limit of 4380 tons per year to be exceeded. In addition,
and aa a resutt. radiological doses to members of the public in the Vicinity of the mill will
not be elevated above levels previously assessed and approved.
4
. .
~.15.1997 1:35PM 1'().34e P.8
b. The-physicaf changes to the miU cira.Jit that JUC wil implement to process this material
are not significant. No c:onstruction impacts beyond those previously assessed will be
involVed with these changes.
c. Tailings produced by the processing af this material wiU be disposed of on-site in an
existing lined tailings impoundment (Cell 3). The addition of these tailings (a maximum
of 16,000 tonsj to Cell3 w111 increase the tctP1 amount of tailings in the cell by one
percent, to a total at approximately 69 percent of cell capacity; therefore, no new
impoundments are necessary. The design of the existing impoundments previously has
been approved by the NRC, and IUC iS required by its NRC license to conduct regular
monitcring of the Impoundment liners and of the groundwater around the impounclments
to detect leakage if it should occur.
d. The uranium-bearing material contains metals and other parameters which already are
present In the mill taiHngs dispoaed of in the Cell 3 impoundment. Analysie of samples
from the uranium-bearing material and from Cell 3 show that the only.pc.. i::ll.netens
present in significantly higher concentrations in the uranium-bearing material are fluorine
and carbon. Howaver, these concentrc •i ....... should not hava an advenla impact on the
overall Cell 3 tamngs composition, because the amount af tail~gs (a maximum of 16,000
tons) produced by processing the material is not significant in comparison to the total
amount of tailings currently in the cell (approximately 1.4 mDIIon tons). Additional~. as
stated previously, IUC is requi~ ta conduct regular monitoring of the impoundment
leak detection systems and of the groundwater in the vicinity of the Impoundments to
detect leakage if it should ccc:ur.
e. For the following reasons, it is not expected that transportation impacts associated with
the movement of the material by train and truck fram Pennsylvania to the White Mesa
mill will be significant:
• The material will be shipped as '"low specific a~ material in exclusMHJ&e
containcl"'i (I.e., no other materials will be In the cont.inel"'i with the uranium-
bearing material). The containeR will be appropriately labeled. placarded, and
manifested, and shipment& will be tracked by tha shipping company from CPM's
facility until they reach the Write M8S11 mnl.
• On average during 1998, 370 trucks per day traveled the stJ etch of State Road
191 between Monticello, UT and Blanding, UT (penaonal communication wfth the
State d Utah Department of Transportation). An additional15 trudcs per day
travelng this roule to the mill represents an incre8sed tratriG load of only four
percent. Shipnenta are expected to take place over the course of a limited time
period (three to siX months).
• The containers and trucks involved in transporting the material to the mm site will
be surveyed and decontaminated, as necessary, prior to leaving CPM's factllty
for Whita Meaa and again prior to leaving the mnl site for the retum trip .
5
AUG.15.1997 1:36PM 1'(),34a P.9
f. Mll~proyees Involved in handling the material wil be prtwided Wfth personal protective
equipment. including respirat~ry protadlon. AJrbome particulate and breathing zone
sampling resurts wt11 be used to establish health and safety guideHnes to be
implemented throughout 1he processing operations.
RECOMMENDED LICENSE CHANGE:
Pursuant to Trtte 10 of the Code of Federal Regulations, Part 40, Source Material Ucense
SUA-1358 will be amended by the addition of License Condition No. 10.9 as fallow&:
10.9 The licensee ia authorized to receive and process source material from Cabot
Perfonnance Materials' facility near Boyertown, Pennsylvania, in accordance with the
amendment request dated April 3, 1997, aa amended by submittals dated May 19, and
August 6, 1997.
ENVIRONMENTAL ;;.A?ACT EVALUATION:
Because IUC's receipt and processing of the .,:ner;al wm not result in (1) a significant change
or inaeas~ in the types or amounts of efftuer.ts that may be raleased otfBite; (2) a significant
increase in indiVidual or cumulative occupational radiation exposure; (3) a significant
construdion impact; or (4) a significant inCJ8ase In the potential for or conuquences from
radiological accidents, an environmental review was not performed since actions meeting theSe
criteria are categorically exduded under 10 CFR 51.22(c)(11).
6
lliiiitli'WWW1iililWWlliWWWtp
U.S. NUCLEAR REGULATORY COIOIISSION
MATERIALS UCENSE
............... ,. ~"AGE 1 ~ · 8 ~P.t..ees
Putsuaot to tbe Atomic: EDeqy AA:t of J9S4, u amended, the Et1ergy Rcorpniuti01l Act of 1974 (Public Law 93-438), aucS Title 10, Code of
Federal Regulatioa.s, Chapter I. Puts 30, J I, 32, 33. 34. 35. 36. 39, 40. and 70. ud in teliance on statemrnu IJid repRXDwions hetetofore made
by tbe licellsee.. a license iJ hen!by issued aulborizin~ the licensee to receive, acquim. possess. uui transfer byptoduc:t. source, and special nuclear
materi31 designated below; to ase mc:h material far !he ~(1) md at tbe place(s) de.sipated below; to deli vet or uaDJfer 1ucb material to
penOWI authorized to rec:eive it in acconfana: with uae n:gulatio111 of the applicable Put(s). This license shall be deemed to contain the conditious
specified in Section 183 of tbc Atomic EDergy Act of 1954, u amended, and is 1ubject to all ;~ppliuble rul~. regulatiODI, and orders of the
Nuclear RegulatOJ1' Commission now or hereafter in effect an4 tO my conditiom specified below.
--------------------------------r-------------------------------~
2.
International Uranium (USA) Corporation
[Applicable Amendments: 2.]
6425 S. HighWay 191
P.O. Boxaoi
Blanding, utah 84511
3. License Number
6. Byproduct, Source, .mdlor
Special Ntl(;l~ Ma&cri~
7. Chemical audlor P11y ~....1 .
Form
. 8. Muirm•m Amount tiW l.itJ':nsec
May Poaaeu at AtJ.y One ThDc
UDderlbis License
Natural Uranium Any
SECTION 9: Admlnlstratlva Conditions ..
9.1 The authorized place of use shall be the liCensee's V'Jh1ta Mesa ~ium mil6ng facrlity,
located in San Juan County, Utah. ·
9.2 All written noticeS and reports to the NRC raquirad under this liCense, with the exception of
incident and event notiftcations under 10 CFR 20'..2202 and 10 CFR -40.60 requiring
telephone notJftcation, shall be addressed to the 01ief, Uranium Recovery Branch, Division of
Waste Management. Ofllce of Nudear Material Safety and Safeguards.
Incident and event notifications that require telephone notification shall be made to the NRC
Operations Canter at [phone].
9.3 The licensee shall conduct operations in accordance with statements, representations, and
conditiOnS contained in the ficense renewal application submitted by letter dated August 23,
1991, as revised by submittals dated J~nuary 13, and April7, 1992, November 2.2, 1994,
July zr. 1995, Oecen'mer 13, and December 31, 1998, and January 30, 1997, whiCh are
hereby Incorporated by reference, and for the standby Trust Agreement. dated April 29,
1997, except where superseded by license conditions bakJw.
\Nhenever the ward "wilr is used in the above rafar~~nced documents, it shall denote a
requirement [Applicable Amendments: 2]
9.4 A The licensee may, without prior NRC approval, and subject to the c;onditions speQf'Jed
in Part B of this condition:
(1) Make changes in the facility or process, as presented in the application.
AUG.15.1997 1:37PM P.11
~·a. 'A' A a· 'A~~.~~ .. ~ 7A" ... ~'a· ·a· ·a· ·a a
-MATERIALS LICENSE
SUPPLEMENTARY SHEET
August 15, 1997
(2) Make changes in the procedures presented in the application.
(3) Conduct tests or experiments net presented in the a~pplicaticn.
B. The r.censee shall file an application for an amendment to the license, unless the
following conditions are satisfied.
(1) 'The change, tet. or experiment does not conflict Mth any requirement
specifically stated in thiS license, or impair the licensee's ability to meet au
applicable NRC regulations. r:;:n --:-
(2) There i& r.o degtad~?;in ~ ~\r;~ or environmental comr,litments in
the llcenSfRppU~on. or provided tJY tht:t .aj,proved reclamation plan • • ~. ,'l ....,.4 .. v •. <..' ··~ ., .. ~
(3) The ~riga, test, or_ experiment Is consistent ~lte condusions of actions an~ and selected in the i:A dated FebNary 1~~
·~ . . .. .-... .
c. The n~·s 'd~enrinations concerning Part B pf-tfl~r'fdition, shall be made by a
"Safety and Envt~trtal Review Panel (S~~: ·:The S~lthall co~lat of a
mlnlrnum of three incfMduals. One .member'af,~~ERP shal~Mv& expertise In
management and ~ ~ponSib(e-for~al and fina),cial eppi'OVQJ ch~nges;
one member shall h~ve ~rti~ in operat!o.~~ar con~rt and shall have
respq()Sibility tor lfnP.Ien'lenting -atrj ~'!ill; ~ilnges; and, oq,, member shall be the
COlJlOrate radlatan ~·-~ \CR~) ~.~lent. with~ ~ponslbifrty ot
assurtng chan~.ccnfalm to. rlldfi11191) 1saf8tY . .ahd ~~'tequlrements.
Additl011al rnernl:iers may be incfud8d 11'1 .thti SE~ ~:approp~. to address technical
asp·adts.'such ~ ~ ~~~d~~~r ~. sw. water hydrology, spacffl~,.alih sdf[!t1~ an6o~A« ' :n~1:~9anes, T~~~ry members or
pecmane!)t members, othef than 1he three a~speQfief.t.1ndJviduals. may be consuhaiits: :.: ·:r1 • ·~~ ·) I ' ' •• )J" '~· ·:-• • ~~"-.. ,• •• t \ I •., ~"~
D. The ftcansee~"J maintain ~ids of any chang~~a pursuant to th:J condition
until rrcense tem'linat{pn. These records s~~ i!'clUV.,~n safety and environf1'8ntal
evaluations, made tJYltle SERP, ~ ~·basis for detemining changes are in
compliance with the requlniftMtnlj.(Bfitjt~ td'ln Part B of this condition. The licensee
shall furnish. ln an .tMual111port to NRC, a description of such changes. tests, or
expetirrieilts, lnduding a summary of the safety and environmental evaluation of each.
In addition, the licensee shaU annually submit ta the NRC changed pages to the
Operations Plan and Reclamation Plan of the approved license application to reflect
changes ~ under this condition.
The licensee's SERP shall function in accordance with the standard operating procedures
submitted by letter dated June 10, 1997.
[Applicable Amendments: 3)
NRC FOAM 314A
(7 .... 1
9.5
9.6
•••••••••••••••• ¥
1997
The licensee shall maintain an NRc-approved financial surety arrangement. consistent wtth
10 CFR 40, Appendix A. Crtteria 9 and 1 a, adequate 1o caver the estimated costs, if
accomplished by a thirU party, for decommissioning and dec:ontan'tination of the mill and mm
site, for reclamation of any tailings or waste disposal areas, ground-water restoration as
warranted and for the long-term surveillance fee. Within three months of NRC approval of a
revised reclamation/dec:ommissioning plan, the ncensee shall submit, fOr NRC reView' and
approval, a proposed revision to the financial surety arrangement if estimated costs in the
ne'Niy approved plan exceed the amount covered in the existing financial surety. The revised
surety shall then be in effect within 3 months Of 'Mitten NRC approwl.
Annual updates to the ~mo~~~O. CFR 40, Appendix A, crnena 9 and 10,
shall be submitted to tne NRC:.&Meast' 3 moritRS.;n·tD~e anniversary data which is
designated as June ~ {Jr ;actf yesr. If the NRC has nOt'll&ep,coved a proposed revisicn to the
surety coverage 3Q:&ffS·pnorto the expiration date of the tixi~ surety arrangement. the
licensee shaJI extena;1he existing sunrty ai'T3ngament for 1 yif~,AJong with each proposed
revision or annui:"iipdate, the Jfcensee shall submit supporting~dc;:umentation showing a
breakdown o~tt)e costs-and the basis for the ccst estfmat~th':ir$Jstments for inflation, ma~n~enanct ·or..a mfnrtn~~ percent contlngencv.f~.:~ ih.:!t'glnee~ng plans,
activities petlbrmed an~ .any. other conditions affec::jing· mated costs for site closure. The
basis forth& cost estimate" i$ !he 'NRC app~tM~d,r8ci~nl~i!lsioning plan or NRC
approved l'e'tisions to th&_J'I~.,:-Tlle previously P.~ldance e~ •Reccmmefldad
Outtlne for 'Stta Spedftc ~on 3Qd $abt~~ ~ ~..ouUJnes the minii'T1Um
considerations used ·ay.fhe ~C ~r:t·~e revtewof,~~~ure:estimaf!,%. Reclamati~eco~•ianlng 'plaiJ5 ~cj. ~~·p~es should foll~this outfine.
•,I ' ' • I I ! f I • • I • f ! •
The eurrentfV'approvecfsLIJBty i~nti: Performanett:B!)nd 18-2~1; issued by National
Union Fira lrmkr:anca ~ny .in faVOr .of tha N~S ~~;tft8 associ~ Standby Trust
Agreement, ~ Aprfl29, .,997·, ~a11 .be ecintlh~&inaintained:lfl an amount not less
than $11,278,1.34 for the purpl):Se of COh'lp~ ~·~ CFR 40t~ndlx A. Criteria 9 and
10, until a repl~nt is authorized by 111a NRC: 1 • • ,. '*·· • · . . . . ' ,.,. ·•
' !.. ·~:1 [Applicable Amandr,1811~: 2, 3] l·~
... ' I \ 11 .~ '" ,.._,
Standard operating proceddtti shall t1,e·e~~~~ followed far an operationai process
activities involving radiaactivw matariaiS-ihat fll1! handled, processed, or stonld. SOPs for
operational adivities shaD enumerate pertinent radlation 811fety practices to be followed.
AdditionallY, written procedures shall be established fOr non-operational activities to Include
in--plant and environmental monitoring, bioassay analyses, and Instrument calibrations. An
up-to-date c:Dpy of each written pnx:edure shall be kept in the mill ~ to which it applies.
An written pnxedura for both operatlonal and non-openltianal activities shall be reviewed
and approved in writiog by the radiation safety offtcer (RSO} before implementation and
whenever a cflange in procedure is proposed to ensure that proper radiation protection
principles are being applied. In addition, the RSO shall perform.a documented review of all
existing operating proceduru at least annually.
9. 7 Before engaging in any activity not previously assessed by the NRC, the licensee shall
administer a cultural resoun:e inventory. All disturbances associated with the proposed
development 'Will be completed In compliance with the National Historic Preservation Act (as
..
AUG.15.1997 1:38PM
U.S. NUCL~R REGULATOOY C01MSSa0N 1
-~MATElUALS LICENSE
SUPPLEMENTARY SHEET
amended} and its implementing regulations (36 CFR 800), and the An::haeological Resources
Protection Act (as amended) and its implementing regulations (43 CFR 7).
In order to ensure that no unapproved disturbance of c:::ultural resources occurs, any work
resulting in the discovery Of previously unknown cultural artifacts shan cease. llle artifacts
shan be Inventoried and evaluated in accordance with 36 CFR Part 800, and no disturbance
shall occur until the licensaa has received authorb;ation from the NRC to proceed.
The licensee shaH ~oid by project design, where feasible, the archeological sites designated
"conttfbuting" in the report submitted by letter dated July 28, 1988. When it is not feasible to
avoid a site designated "contrjb~nsOtn tf\l)~d~tf)e licensee .shall institute a data recovety
program fOr that site based qb-tt)&~ ~ ~.,~ by letter from C. E. Baker of
Energy Fuels Nuclear.*"'M.~Metvin T. Smith, Utah ~rt~c Preservation Officer (SH~). dated ~~:~.~;~i981. 't1,;: .• ,
The licensee s~~er through archeological excavation ai~.:SSntnbuting" sites listed in
the report whid))'are-1o~ed in or within 100 feet of borrow ~ile areas,
construction ~. o~!! ~eter of.the reclaimed ~l.lng~ Jmp~dmenl Data recovery
fieldwork at ~ch site ~:1hese criteria shaU beco~ltted prior to the start of any
pn:~ject related disturbance Within 100 feet of the sfte,. J.Jat.analysis a~.report preparation
need not be complete. · '. \ :~··.:; · -~ ., . ·
t ,. • .. t : "; I •"•.' • • ~
Additionali'yf tJ,e licen~ Shaf\:~~uct·~·te:mng··~.b required to.~able the Commission
to detennlne. if those.~ites Cleitgr:'Bte9 .fS ... U!J_!:i~~~" in ,the repo~~1ld located within
100 feet otf)resent o~il,1.own ~11!t·~·~f88S are: of ~ch s~lftcance to warrant
their redes~tion o ·~r:itributlhg.." In·~~,,~~ such t~ shall ~'eompleted befOre any aspec:tofth~ .. w~ertakinQ . .'~~·~~·~· ~1 1 .!~· ··:: .. ,.A~ · ~~·
0 t. f •I I .. I \.o • o • t • ~ 0 ·~-· '"I\ ? ... ArcheologfcaJ~tractoii Shiill-be a~'veei.iR ~i,Ji~ the Cq•fi~lan. The Commission
wtll approve an tlr,aheologfcal c:On~orWba ~~ minlmu~~dards for a principal
investigator set foJ1tl in 38 CFR Part.f58.; Atianfndix c,··and ~quaURcations are found
acceptable by the oi-:1~. ~~ .. ~
9.8 The licensee is hereby ~o posseSSr~uct material In 1he fonn of uranium
Wlilste taDings and other urantum,&J~ _.. gaoerated by the licensee's mflllng
operations authorized by this license. Mill tailings shaU not be transferred fram the site
without specific prior approval of 1he NRC in the fon'n of a license amendment. The licensee
shall rnai 1tain a permanent record of all transfers made under the provisions of thi.s condition.
9.9 The licensee is hereby exempted from the requirements of Section 20.1902 (e) of 10 CFR
Part 20 for areas wiihin the mill, prov;dec:t that all entrances to the nill are conspicuously
posted in accordance with Section 20.1902 (e) and.-. the 'M)rds, •Any area within this rmll
may contain radioactNe material. •
9.10 Release of equipment or packages from the restricted area shall be In accordance with
"Guidelines for Oeccntamlnation of Facttitfes and equipment Prtor to Release far Unrestricted
Use or Tetmination of Ucenses for Byproduct. Souree, or Special Nuctear Material," dated
May 1987, or suitable alternative proceduru. appi"DVed by the NRC prier to any such release.
~.15.1997 1:39PM
NRC FORM 374A
(7-861
u..S. NUCLEAR REGULATORY COfAISSION
-MATERIALS LICENSE
SUPPLEMENTARY SHEET
SECTION 10: Operational Controls, Limits, and Restrictions
10.1
10.2
10.3
10.4
10.5
10.6
10.7
10.8
The mill production rate shall not exceed ~0 tons of yenowcake per year.
All flquid effluents from mill precess buildings, with the exception of sanitary wastes, shall be
retwned to the mill drcuit or discharged to the tailings impoundment.
Freeboard rrmits for Cells 1-1, 3, and 4A, and tonnage limits for Cell3. shan be as stated in
Section 3.0 to Appendix E of the approved ncense application.
Disposal of material and equip~,~n(~.._.,e mill site shall be conducted as
described in the licensee~ subMiftals~ ~ 12, 1994 and May 23, 1 ~. with the
following addition: ."'"... ·~ ,.,. ·•• · ·~ .:i · .. , r•, .. "'-' '''t' :, ... : ·~yf ;}
A. The maximyin..ltfl thickness for matP.Iials placad over't:aftri:igs shall be less than 4-feet
thick. Su~uent ltfts .shall be less than 2-feet thick. Eiicti lift shall be compacted by
trackins;¢ ~~-equipment. such as a cat ~~ at le~ ~ prior to placement of
subsaquant littS:.r. .. _ . · · ·' ·" , ·
' • I!. " .~::~ • o·"' I ~.J .... ~
• .... -' • " \ ,.• I ' • / o
In accordai,'K:e with the Dcansee'& submittal dated~;20i 1993, the11q!tnsee Is hereby
authorized tQ:dlspose of 1JYpr:Uquc:t ~~ gen~ .U·Ucensed irt'SitU leac:O facilities,
b . ..,.,. to hi.-_ foflowi • ~ ' I l'• • ""' su ~-U'ftJ ng c:on~:u.avn&: • · ,· .:·~ :· .. ~>
a • • "'. I • '• • • ' J, • f • ' r..,
-0 (/ 0 1 , 00 I I 0 0 .l ... •; '.,• ,. \Q.''•
A. Disposal of wast& is limbd'lb 5QQO eub~~:~m .-single ~~rca.
•• • • • J) •' • .. ·.. .. ;., ., .... i 'IIi . .. '., -•' . .. .. ;: .
B. All ~n~~9Uipme~.~~l ~'Cit~~. ~. or ~oned to minimize
void spat:e5. Bilt't'!t•.~ntainingc ~ tder thm:.~Oit or sludjJ)S shaU be emptied into
the ~al area)nd-ihe ~at'tet,;~: ~~ contain.~·son or sludges shall be
verified \Q.be t\JII prior to disposid. ~~Is f'Otdotnpletetyt~t-:wtl be filled with tailings ,.. .... -11 ) 1 • ,I,~J, ) ' ._tP•, "" :M.II • • .... 'I\ '!\.. "-" .... '
t f , I',: 'J '•J ... ·~· ... , l"l\~ :·
c. All waste shaii.de:Ouried in ceo No.3 unless prior~ approval iS obtained fre1n the
NRC for attarrtatii bu~ location~. , \, ~ ~~ ,( ..:. . 'l-"~ 14 ::b_..__. o<J.~ D. All disposal aCtiVitieS shaD -tMi d~ti:ijh8~. ·, ne documentation shall include
desctiptians of 1t\e waste and the disposal tacatlo~. as w.=ll as an actiOns required by
this condltfon. An annual SU1TWT1aTy of the amounts of waste disposed of frtlm off-s-ite
generators shall be sant to the NRC.
The ncansee is authorized to racaive and process soun:e materialS from the Allied Signal
Corporation's Metropolis, Illinois, facility in accordance with the amendment request dated
June 15, 1993.
The licensee is authorized to receive and process source material from Allied Signal, Inc. of
MetJ:opolis, Illinois, in accordance With the amendment requ~st dated September 20, 1996,
and amended by letters dated OCtober 30, and November 11, 1998.
The licensee is authorized to 1'11C8ive and process source materia,, in accordance with the
amendment request dated March 5, 1997. [Applicable Amendments: 1]
.fL'G. 15 1997 1: 39='M ., •••••••••••••••.•••• ~:J:-~it •••• ,
~ NIJCI..EAR REGULATORY COflftiiSSIOfll P!11oGe ,:; r;:,. R !IAQ!S ~~~~-~~N~~~~--~~~~~--~~~--
M.ATElUALS UCENSE
-. SUPPi.EIIENTARY SHEET
~1 I A _4 <:lii:Q 4,.,..,.
Auoust 15. 1997
1 0. 9 The licensee is authorized to receive and proce~~ source material from cabot Perfonnance
Materials' facility near Boyerto\Nn, Pennsylvania, in accordance with the amendment request
dated April3, 1997, as l!lrnended by submittals dated May 19, and August 6, 1997.
[Applicable Amendments; 4]
SECTION 11: Monitoring, Recording, and Bookkeeping Requirements
11.1
11.2
11.3
The results of sampling, analyses, surveys and monitoring, the reautts of calibration of
equipment, reportS on audlts .. ~~.f~=tings and training courses required by
this license and any su~~ews; lnv . ~ ns~;and corrective actions, srall be
documented. Unle$6 Qthemise specified In the NR~~Ialions all such documentation
shall be maintaine~, ~.r'-r'period of at least five (5) years.~-: .~ ..
~ :-.,~-.,:" ~
.. ct ••••
The licensee s~.:finplement the effluent and environmental mO.RitOring program specified in
Section S.S of tbe re"ewj!l application as revised with the followinr/P,odiffcations or additions: .. . . . . . • I , ,t I <# • • '" I .., ,. .
A. stack' sainpllng shall i~du.de a detarmlnation..af'.ftow i'Bte. . ..... 1
. • • • • • I ~·' • • W\
o I I I ,I "· ,. ~
B. St.~rface water sampkt$ sttan af&~ 0e analyzed terfiiannualfy fO't,Ultal and dissolved U.
nat, Ra-226, and Th-23'01 with the except]~ Qt.y,ewestwater~ek. which shall be
sampled annually for Water sedlrnetrf:5' and~~ as above .. ~sediment sample
shatt not be taken in place df a walE!f: s.a"TP~uhtess. a water s~ple was not available.
' '~ f• h , ~ , ... ' '• • r . •. • •.
c. GroUJ1dwater ~A1P.~ng shall.h!! ~n~~·fn a~~~ requirements In
Ucense Condition 1.1.3. . · 1 • •• :·· • '"""" • ~ I o • .. I I o I I : • o o. • • ~!; :' ~.-...
' I "''-•t• ');1":1 D. The licensee shalt' utilize lowe'r: Ur'nlas of det~tfln acco~ with Section 5 of
Regul.tcry, Guide 4.14 (Revision 1)1 for an~ of efllu~nd environmental
samples.. · , · ' .''-..., () . ~ ·, . . . ~ .. ;
E. The inspection~·~ertarmed semiannually of tQ.~ ~ ~riflce assembly commtttad to in
the submittal dated M~ ~,.1~ .. ~~ ~~mented. The critfcal Offfice
assembly shall be calibrat.ct:at 1.-st eWiy 2 years against a posHive displacement
Roots matw to obtain the reqUired calibration curve.
The licensee shall implement a groundwater detection monitoring program to ensure
compliance to 10 CFR Part 40, Appendix A. The detection monitoring program shall be in
accordance \Wh the report entitled, "Points of Compliance, VVhite Mesa Uranium Mill,"
submitted by letter dated October 5, 1994, as modified by the following:
A. The leak detection system for all ponds wfl1 be checked weekly. If liquid is present, it
shall be analyzed for chloride, sulfate, selenium. and pH. The samples will be
statlstically analyzed 1o determine if significant linear trends exist, and the results will
be submittad to NRC tar re"~~iew.
---------------------~--------._~--~~
11.4
11.5
11.6
1'«).34e P.16
vwwawwwwwwwww~ww ''*"***********·*' u.S. NUClEAR REGULATOIIIY COWIISSOflt ~ 7 OF A ~
~u~c~-~-.~~-~~--------~------~-----
MATERIALS UCENSE
-,SUPPLEMI!!NTARY SHEET
~IJA-1::1..~ A-... ""'' ·-
An oea .. ·-·-
August 15, 1997
B. If a significant linear trend is indicated, the licensee will submit a proposed con-ective
action for review and approval to NRC The corrective action shall indude a discussion
on delineation of the areal extent and concentration of hazardous constituents.
C. The licensee shan sample monitoring wells VVMMN-5, -11, -12, -14, -15, and -17, on a
quarterly basis. Samples shall be analyzed for chloridet potassium, nickel, and
uranium, and the results of such sampling shall be included with the environmental
monitoring reports submitted in accordance with 1 o CFR 40.65.
During extended periods of mill standby, !!.ight-hour annual sampling for U-nat, Ra-226, Th-
230 and Pb-210 may be eHmin~·ifro~A81Birbo$'1e sampling show levels below 10 percent
of the appropriate 10 CFR PBrt. ~~imits. · ·~ ~! 'L ~: 1,1
1i._-> '. :;:~'!· • ••· .... • ~·:. AJ
During periods of~.~. sampling frf""'"~"!cies for area a'iw;bo.cpe uranium sampling YJithi'1
the mill may be ~ to quarter1y, provided measured levels remain below 10 percent of
the deriVed air ~l:entration (OAC). If these levels exceed 10 ~n:ent of the OAC, the
sampling frequency should follow the recommendations in R•~laiQry Guide 8.30.
' . ) . .. ·. ) .
calibration of i~lant 8ir a'~ radiation monitoring eqtif~inftm ·~hall ti6'performed as spedfied
in the license renewal ap~icaiicn, unde_rSer=tfon 3;0 .~~ "Radlatfon•l?,rctectlon Procedures
Manual," with-the exception thm i~lant~lir S8f11'PI~Uipment sha)l \)8 calibrated at least
quarterty and air sampling eqUipment c;hecks shllllll tle'...Oo.Cumented. \:,.
1 _: 1 I 1 \. • . . , . I . C, . '•.
The licensea-shall perfonn an an~ual ALA~.~~t;~ttia radtatJon S{i~ prog~m in
accordance-With R~latory Guide 8~31.' ·: r ·: 1 • · · • , .....
~ ,•J •
' o I I . · .. •'~o ,. ..... ..
SECTION 12: Reporting ReqUirementS ~~ i .~· ; .• ' ... :'): '.t')
12.1
• • , t _,.-
The licensee stl311-~bmit to N~C fQr.ravfew,.~ Jtin~.~o, 199J(~atafled reclamation plan
for the authorized t~Uings disposal area whi~ Includes the ~l'lt:IWina: •. • .• .:>#
A A post-operati~~ inteom stabiriZ3tion plan which ~ils methods to prevent wind and
water erosion and recnQ'tge ~.~~ill~"* 41,.'-~ ~->·~ I
B. A plan to detennine the best methodology to dewater and/or c;onsolidate the tailings
cells prior to placement of the final reclamation cowr.
C. Plan and aoss-sectional views af a final111clamation cover which details the location
and elevation of tailings. The plan shaU indude details an cover thickness, physical
characteristics of cover materials, proposed testing of cover materials (specifications
and quality assu111nce), the estimated volumes of cover materiaJs and their avanability
and location.
D. Detailed plans for placement of rock or vegetative cover on the final redaimed tamngs
pile and mill site areL
E. A proposed implementation schedule for items A through D above which defines the
sequence of events and expected time ranges.
-.._.._ ~---··---------------.------.--.._-
12.2
MATERIALS LICENSE
-SUPPLEMENTARY SHEET
August 15, 1997
F. An analysis to show that the proposed type and thickness of soil cover is adequate to
provide attenuation of radon and is adequate to assure Jong..term stability, as well as
an analysis and proposal on methodology and tfrne required to restore ground water in
confonnance to regulatory requin!ments.
G. The licensee shall indude a detailed cost analysis of each phase of the reclamation
plan to indude contractor costs, prcjected costs of Inflation based upon the schedule
proposed in item e. a proposed contingency cost. and the costs of long-term
maintenance and monitoring.
..
.. ·'
..
'-• ... -:' ,·
.... ~
., ·.
i=t,X; • 15. 1997 1 : 3:J=IM 1'().343 P.4
TECHNICAL EVALUATION REPORT
REQUESTTO RECEIVE AND PROCESS ALTERNATE FEED MATERIAL
DOCKET NO. 40-8681
LICENSEE: International Uranium (USA) Corporation
FACILilY: \Nhite Mesa Uranium Mill
PROJECT MANAGER: James Park
SUMMARY AND CONCLUSIONS:
LICENSE NO. SUA-1358
The U.S. Nuclear Regulatory Commission staff has reviewed Energy Fuels Nuclear, Inc.'s
(EFN's) request dated Apnl s, "i997, tc receive and process uranium-bearing material currently
contained at Cabot Perfonnance Materials' (CPM's) fadlity near Boyertown, Pennsylvania.
The material would be processed at the White Mesa mill, of which EFN is the former owner.
The current CMner of the mill and NRC licensee, International Uranium (USA) Corporation
(IUC), previously has agreed to abide by all commitments and representation made _by EFN.
Based en its review of the Apnl 3, 1997, submittal and additional information provided by letters
dated May 6, May 19, June 20, and August 6, 1997, the NRC staff considers the amendment
request acceptable.
DESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:
By its submittal dated April 3, 1997, EFN requested that NRC Source Material Ucense
SUA-1358 be amended to allow receipt and proce5Sing of alternate feed material (i.e., material
ether than natural ur11nium ore) at its White Mesa uranium mill located near Blanding, Utah.
This uranlum-~ring material, weighing approximately 16,000 dry tons, is held currently by
CPM at its facility near Boyertown, Pennsylvania. The material i& a moist solid (up to
40 pen::ent moisture content) which contains uranium at an· average concet tb ation of
0.3 percent by welght1 and P".Onomically attractive concentrations of tantalum and niobium.
CPM Is authorized to possess this material under NRC Source Material Ucense SMB-920.
The material will be shipped by train and exdusive-use trucks frorr, CPM's facility to the White
Mesa mill in intermodal containens. After being loaded and sealed at CPM's facility, the
containers will be transported by truck to a nearby intermodal rail terminal. The containers Will
be loaded on flatbed railcars and transported cross--ccuntry to the final ran destination (either
Grand Junction, Colorado or Green River, Utah), where they will be transferred to trucks for the
final leg of the joumey to the White Mesa mill. Each container ha& a capacity of 25 cubic yards,
and it is expected that approximately 15 containers will be loaded and transported each day.
At the mill site, the uranium-bearing material win be emptied from the intermodal containers into
the are receiving hopper. From there. the material will be processed through the semi-
autogenous grind (SAG) mill, where water will be added to aeate a sluny, which is then
1
AUG.15.1997 1:34PM I'(). 34el p. 5
pumped to-41 pulp storage tank and from there into the leach circuit. ln the leach circuit, the
slurry Will be treated to separate the uranium from the tantalum and niobium, and IUC wm ublize
the uranium and vanadium solvent extraction circuits, respectively, tD recover these metals.
lUC plans to add two filter presses and same additional piping to its mill circuit to aid in the
processing of this material.
Wat6 spray systems will be utilized to reduce the potential fer dust dispersion and airborne
contamination in emptying the intennodal ex~ntainers. Other than the slight circuit changes
mentiOned previously, IUC anticipates that processing the uranium-bearing material will not
differ from precessing natural uranium/vanadium ores.
IUC will provide personal protective equipment (coveraHs, gloves, and full-face respirators (to
be used if needed)) to individuals engaged in processing the material. The efficiency of
airborne contamination central measures durtng the material handling operations will be
assessed in the immediate vicinity cf these operations. Airborne particulate samples and
breathing zane samples will be collected during initial material processing activities and
analyzed for gross alpha. Sampling results will be used to establish health and safety
guidelines to be implemented throughout the processing operations.
Additional environmental air samples will be collected at nearby locations to the material
processing activities and analyzed to ensure that the established contamination control
measures are adequate and effective.
Trucks used to transport the material tc the mill site wiD be radiometricaUy scanned upon arriVal
to ensw. that leakage has not occurMCI and that radiation rev. are_ within appropriate limits.
TruckS will again be scanned prior to their release from the site restrict$d area. In addition, the
intermodal ex~ntalners used to transport the material will be proper1y closed, cleaned (if
necessary), surveyed, and documented before leaving the site.
TECHNICAL EVALUATION:
The NRC staff has reviawad IUC's request in accordance With 10 CFR Part 40, Appendix A.
requirements and NRC staff guidance '"Fmal Position and Guidance on the Use of Uranium Mill
Feed Material Other Than l\!9tural Ores" (60 FR 49296; September 22, 1995). This gutdance
(referred to hereinafter as the alternate feed guidance) raqulres that the staff make the following
determinations in its reviews of Hcensee requests to procet58 material ather than natui'CII
uranium ores.
1. Whether tfw feed material meets the definition of "ore;"
2. 'Mlether the feed material contains hazardous waste: and
3. Whether tne ere is being p~ primarily for it& source-material content.
2
~.15.1997 1=34PM t-().340 P.6
Determination af whether the feed material js "om"
Fer the tailings and wastes from the propased processing to qualify as 11 e. (2) byproduct
material, the feed material must qualify as "ore." fn the alternate feed guidance, ore is defined
as
" ... a naturat or native matter that may be rt"ined and treated for the extraction of
any of its constituents or any other matter from which source material is
extracted in a licensed uranium or thorium mill."
The proposed alternate feed material contains uranium at an average concentration of 0.3
percent by weight therefore, it meets the detimticn Of "source materia~" as defined at 1 o CFR
40.4. IUC I& proposing to extract this uranium. Therefore, the material meets the definition of
ore, because it Is a "matter from which source material Is extracted In a licensed uranium or
thorium mill. •
Determination of whether tbe feed material contajns tmzardous WJ18te
Under the alternate feed guidance, proposed feed material which contains a listed hazardous
waste will not be approved by the NRC staff for processing at a licensed min. Feed materials
which exhibit only a characteristic of hazardous waste (I.e., lgnltabillty, COJTCSivtty, reactivity, or
toxicity) would not be regulated as hazardous waste and could therefore be approved by the
staff for recycling and extradian of source matenal. However, this does not apply to residues
from water treatment. Therefore, NRC staff acceptance of such residue& as feed material
would depend on their not containing any hazardous or CharacteliStic hazardous waste.
The NRC staff has reviewed the following sources of information in detennining whether the
uranium-bearing material is ar contains hazardous waste: (1) the average Q)ITlpo&ition data for
the material, as submitted by IUC an June 20, 1997, (2) the results of additional testing, u
provided by letter dated May 6, 1997, (3) NRC files for the Boyertown facility, which address, in
part, the prac:eu used to produce the material and the me1hods used to store the material, and
(4) supplementary information concerning the State of Pennsylvania Department of
Environmental Protection's hazardous waste regulations. In addition, as an attachment to
a letter dated Augu&t 6, 1997, IUC provfded an anadaYit from CPM In which CPM affinned that
the material is not and does nat contain hazardous waste.
Based on tts revieW, tne NRC statr finds tttat the uranium-bearing material is nat hazardous
wasta and does not coma;, hazardoUB wast.. The NRC staff has determined alaa that the
uranium-beanng material is nut a rwidue from water treatment. This material is the result of
the initial pi"'QQSSfng of raw ares containing tantahJm and niobium.
Therefore, the NRC 8taff considers the uranium-bearing material acceptable for recycling and
extraction of source materiaL
3
AUG.15.1997 1:35PM 1'().340 P.7 -
Oeterroinaqpo of whether the feed material :is being proceged cdmarily foe jts soycce;naterial
content ~
Ta show that potential alternate fee<1 material is being processed primarily for its source-
material content, a licensee must either (1) demonstrate that the material would be approved
far disposal in the tailings impoundment under the "Final Revised Guidance on Disposal Of Non·
Atomic Energy Ad of 1954, Section 11e.(2) Byproduct ~aterial in Tailings Impoundments;'" or
(2) certify, under oath or amnnauon, that the material is being procesaed primanly for the
recovery of uranium and for no other primary purpose. Any such certification must be
supported by an appropriate justification and accompanying doa.~mentation.
The licensee has provided a signed affirmation that the uranium-bearing material is being
precessed primarily for tf1e recovery of uraniUITI and for no other primary purpose. IUC states
that the uranium content of the matern.l, In conjunction with the reduced uranium processing
costs associated with 1he recovery of the tantalum and niobium, makes processing the CPM
material economically attractive to IUC. The NRC starr has discussed with IUC the business
arrangements regarding the material and finds that IUC is paying CPM for the acquisition of the
material.
The NRC staff has reviewed the analytiCal data provided by IUC and infarmation contained in
the NRC's files for the CPM facility, and finda that the uraniUm concentration in the material iS
comparable With thilt In nab.Jral uraniLim ores Whid1 are and were normally processed by
uranium mills In the U.S.. 1l1e$e natural ores contained uranium at concentrations of 0.3
percent and betaw. Therefore, the NRC staff considers IUC's justiftcation to be acceptable.
Conclusjons concerning alternate feed matedal designation
Based on the information provided by the licerwee, the NRC staff ftnda that tha CPM's uranium-
bearing material is alternate feed material because: (1) It meets the deftnttlon af "ore, .. (2) ft
does net contain hazardous waste, and (3) it is being procassed primarily for Its source-material
content
Other cgnsjclenltions
The NRC staff has aiBD concluded that the processing af this material wll not mutt In ('1) ~
significant change or Ina-ease In the types or amounts of eftluent:a that may be released offsite;
(2) a significant increase In Individual or cumulative occupational radiation exposure; (3) a
significant construction impact or (~) a significant ine~ruse In the potential for or consequences
from radiological accidents. This conctusion ia based on the following infonnlltion:
a. YeUowcake produced from the processing of thls materfal will not cauae the currently-
approved yeRowcake production limit of 4380 tons per year ta be exceeded. In addition,
and aa a result. radiological doses to members of the public In 1he Yidnity of the mill will
net be elevated above levels previously assessed and approved.
4
!=tJ;. 15. 1997 1: 3SPM l'fJ.34e P.B
b. lhe-physicaf changes to the miU circuit that IUC will implement to process this material
are not significant No construction impacts beyond those previously assessed will be
involVed with these changes.
c. Tailings produced by the processing af this material wiD be disposed of an-site In an
existing lined tailings impoundment (Cell 3). The adcfltion of these tailings (a malcimum
of 16,000 tons) to Cell 3 will increase the totP• amount Of tailings in the cell by one
percent, to a total of approximately 69 percent of cell capacity; therefore, no new
impoundments are necessary. The design of the existing inpoundments previOusly has
been approved by the NRC, and IUC iS required by its NRC license to condud regular
manitaring of the impoundment liners and of the groundwater around the impoundments
to detect leakage If it should occur.
d. The uranium-bearing material contains metals and other parameters which already are
present in the mill tamngs dispoeed of in the Cell 3 impoundment. Analysis of samples
from the uranium-bearing material and from Cell3 show that the only.~~:~~,netars
present in significantly higher concentrations in the uranium-bearing material are fluorine
and carbon. Howaver, these conce11b ~ •: ....... should not have an advenle impact on the
overall Cell3 tailings campositian, because the amount aftaR!!1gs (a maximum of 16,000
tons) produced by processing the material is not significant in comparison to the total
amount of tailings currently In the cell (approximately 1.4 mHiion tons). Additional~. as
stated previously, IUC is required tD conduct regular monitoring of the impoundment
leak detection systems and of the groundwater in the viCinity of the impoundments to
detect leakage if It should occur.
e. For the following reasons, it is not expected that transportation impact& associated with
the movement of the material by train and truck frum Pennsytvania to the White Mesa
mill will be significant
• The material will be shipped as "low specific activity" material in exciU&ive-u&e
containers (I.e., no other materials will be in the containers with the uranium-
bearing material). The containers will be appropriately labeled, placarded, and
manifested, and shipments will be tracked by the shipping company from CPM's
facility until they reach the VVhite Mesa mill.
• On average during 1998, 370 trucks per day traveled the sb etch of State Road
191 between Monticello. UT ana Blanding., UT (personal communication with the
State d Utah Department of Transportation). An additional16 trucks per day
travelng this lOUie to the mHI represents an incre8sed trafliG load of only four
percent Shiprnentl!l are expected to take place over the catne of a limited time
period (three to SiX months).
• The containers and trucks inYoiYed in transporting the material to the mnl site wm
be surveyed and decontaminated, as necessary, prior to leaving CPM's facility
for 'Mlita Meea and again prior to leaving the mnl site for the retum bip.
5
AUG.15.1997 1:36PM 1'().340 P.9
f. Mill-employees involved In handling the material wil be provided with personal protective
equipment. including respiratory protection. AJrbome partictJiate and breathing zone
sampling result& wm be used to estabfJSh health and safety guidelines to be
implemented throughout the processing operations.
RECOMMENDED LICENSE CHANGE:
Pursuant to Title 1 0 of the Code of Federal Regulations, Part 40, Source Material Ucense
SUA-1358 will be amended by the addition of License Condition No. 10.9 as fallow&:
10.9 The licensee is authorized to receive and process source material from Cabot
Perfonnance Materials' facility near Boyertown, Pennsylvania. in accordance with the
amendment request dated April 3, 1997, as amended by submittals dated May 19, and
August 6, 1997.
ENVIRONMENTAL ;;wi?ACT EVALUATION:
Because IUC's receipt and processing of the 'Tl!Jtefial will not result in (1) a significant change
or lncreass In the types or amounts of effluents that may be relealled offillte; (2) a significant
increase In indiVidual or cumulative occupational radiation exposure; (3) a significar)\
construction imp•ct; or (4) a significant inCf8aae in the potential for or consequences from
radiological accidents, an environmental review was not performed since actions meeting these
criteria are categorically exduded under 10 CFR 51.22(c)(11 ).
6
Appendix B
White Mesa Mill Site Maps with Well Locations
1 z ~ .~
i ~ ! ~ 'a i '~ ~ ~ :0.
,.
'
TWN-15 ~
; /
MW-03 ~
I
1W4-32
1W4-13
·TW,:4.-P'2
MW-04 t
1W4'-08 I
1W4-36 I 1W4-01
MW-32
1W4-64
1W4-14
34
I
YWY5
Bureau of Land Ma
Copyright:© 2013 National Geographic Socjety~bcub
Legend
U U Property Boundary
D Structure
o-r Seep or Spring
Well
-$-Abandoned Monitoring Well **
-$-Active Monitoring Well **
Potable Water Well
D Township and Range
O section
----Canyon Rim
Surface Land Ownership
C]Private
~ Mill Site Claim
~ Utah State Lease
D Bureau of Land Management
D Blanding Municipal Boundary
D Utah Land Trust School Section
D Ute Mountain Ute
Pond
----Drainage
** Monitoring well depths are listed in
Tables 1.2-1, 1.2-2, and 2.4-1
Coordinate System: NAD 1983 StatePiane Utah South FIPS
4303 Feet N
2,000
1 IN= 1,500 FT
1,000 0 ! 2,000
Date: By: County: San Juan State: Utah
Location: PORTIONS OF T37S R22E
APPENDIX 8-1
WHITE MESA MILL (NORTH)
! t ~ ~ ~--------------------------------------------------------------------------------------------------------------------------------------_l __ _l_j~A~u~~o~~m~h~e~nin~g~ron~:2D~~~e!6/~V~20~14~==~D~~oo~By~m~h!en:in!~~on~
-o X E ~ ~ d .. ::;; a. ~ (I) c ;.
0 1:! ~ Q_
5 §
(I) "-Q) ~
&\ ~ S! g> ·a. a. .. :.;; :::; --' ~ ~ 5 ~
r
COTTONWOOQ
I •
MW-03 ~
-'1 " .f IN-5 ~lNG'
'10
Copyright:© 2013 National Geographic Society, i-cubed
Legend
II II Property Boundary
0 Structure
Ov-Seep or Spring
Well
-$-Abandoned Monitoring Well**
-$-Active Monitoring Well**
Potable Water Well
C) Township and Range
L__=-_] Section
------Canyon Rim
Surface Land Ownership
C) Private
~ Mill Site Claim
~ Utah State Lease
D Bureau of Land Management
D Blanding Municipal Boundary
D Utah Land Trust School Section
D Ute Mountain Ute
Pond
Drainage
** Monitoring well depths are listed in
Tables 1.2-1, 1.2-2, and 2.4-1
Coordinate System: NAD 1983 StatePiane Utah South FIPS
~3~~ N
1 IN = 1 '500 FT I
1,000 0~=~~~~2~,000
SCALE IN FEET
2,000
WHITE MESA MILL
Dme: By: County: San Juan State: Utah
Location: PORTIONS OF T37S R22E
APPENDIX B-2
WHITE MESA MILL (SOUTH)
;2 ~ ~---------------------------------------------------------------------------------------------------------------------------------------L--_.~~A~ut~ho~r.m~h~en-in~gt~on--~D~m~e~6/~~2~0-14----~Drn~ftoo~-~By~m~h~en~in~gt~on~
Appendix C
Sampling Plan for Seeps and Springs in the Vicinity of the White Mesa Uranium Mill,
Revision: 1, June 10, 2011.
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
SEEPS AND SPRINGS
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Denison Mines (USA) Corp.
Suite 950, 1050 17th Street
Denver CO 80265
June 10, 2011
Table of Contents
1.0 Introduction and Objectives .................................................................................................................... 3
2.0 Seeps and Springs Sampling locations .................................................................................................... 3
2.1 Timing of Sample Collection ................................................................................................................ 3
3.0 Field and Sampling Procedures ............................................................................................................... 4
3.1 Field Data ............................................................................................................................................. 5
3.2 Decontamination ................................................................................................................................. 5
3.3 Field QC ............................................................................................................................................... 5
3.4 Sample Handling .................................................................................................................................. 6
4.0 QA and Data Evaluation .......................................................................................................................... 6
5.0 laboratory Analysis ................................................................................................................................. 6
5.1 Analytical Quality Control. ............................................................................................................. 6
5.2 Evaluation of Analytical Data-.............................................................................................................. 7
6.0 Reporting ........................................................................................................................................... 7
1.0 Introduction and Objectives
This Sampling and Analysis Plan ("SAP") describes the procedures for sampling seeps and springs in the
vicinity of the Denison Mines (USA) Corp. ("Denison") White Mesa Uranium Mill ("the Mill") in
Blanding, Utah as required by the State of Utah Groundwater Discharge Permit ("GWDP") No.
UGW370004.
The objective of the seeps and springs sampling program is to collect annual surface water samples from
the locations identified below as required by the GWDP. This SAP specifies the sample collection
requirements, procedures, analytical methodologies and associated quality control ("QC") checks, sample
handling protocols and reporting requirements for the annual seeps and springs sampling program.
2.0 Seeps and Springs Sampling Locations
The annual seeps and springs sampling locations correspond with those seeps and springs sampled for the
initial site characterization performed for the Environmental Assessment as shown on Plate 2.6-10 of the
Environmental Report (Dames & Moore, 1978), and additional sites located by Denison, the BLM and
Ute Mountain Tribal representatives. The locations included in the annual seeps and springs sampling
event are:
• Cottonwood Seep
• Westwater Seep
• Ruin Spring
• Corral Canyon Seep
• Entrance Spring
• Corral Springs
The Permit Section I.F.7 (g) requires that survey data for the seeps and springs be submitted prior to the
collection of samples. UDEQ previously clarified the requirement to submit survey data only prior to the
first sampling and not on an annual basis. The survey data submitted with the first annual seeps and
springs report in 2009 was incorrect. In response to the incorrect data, DUSA completed another survey
of the seeps and springs in December 2009. Those survey data are included in Table 1 of this SAP and
the locations are shown on Figure 1 included in Tab A. The surveyed coordinates and elevations of the
seeps and springs were within 1 foot of the highest point of the saturated seepage face on the day of the
survey
2.1 Timing of Sample Collection
Seeps and spring sampling will be conducted on an annual basis and will be scheduled between May 1
and July 15 of each year. This sampling period is aimed at maximizing the opportunity for flow but
excludes the potential for surface water influence occasioned by late summer "monsoon" conditions. For
each annual sampling period, the locations noted above will be visited a minimum of three times in order
to attempt collection of a sample. Should a visit reveal a change in conditions at any of these dry
locations which may yield water sampling opportunities, Denison will proceed with limited hand tool
excavation of the sampling location. The hand-dug excavation will be left open for a maximum of 48
hours and allowed to fill with water. If water collects in the excavation, it will be sampled. If the
location is excavated with hand tools, it will be filled after sampling has been completed, with the soil that
was removed from it per the Bureau of Land Management (BLM) request included in Tab C. Should
three annual visits at seeps and springs locations reveal only dry conditions, and a continued absence of
physical development opportunities, a sample will not be collected and such conditions (and the inability
to sample) will be recorded on the field data sheet and reported along with the results of collected samples
for that annual sampling event.
Denison will provide at least 15 days notice of sampling in order to allow the Executive Secretary to
collect split water quality samples of the seeps and springs.
3.0 Field Sampling Procedures
The field sampling and data collection program will obtain samples to be analyzed for the groundwater
compliance parameters listed in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using the methods specified in the currently approved Denison Quality Assurance
Plan for Groundwater sampling ("QAP"). Minimum detection limits or reporting limits for seeps and
springs analyses will be less than or equal to the Groundwater Quality Standards defined in Table 2 of the
GWDP. The minimum detection limits for total dissolved solids ("TDS"), sulfate, and chloride will be 10
mg/L, 1 mg/L, and 1 mg/L respectively.
Field activities include collecting samples, recording of field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling procedures employed at each location will be dependent on the site location and access.
Several sampling methodologies may be employed during one annual event based on access limitations
and flow rates of the seeps and springs that are sampled. Potential sampling methodologies are briefly
described below.
Direct Collection
Direct collection of the samples involves collecting the sample directly into the sample container from the
surface water feature or from spring out-flow. In instances where direct collection is employed the
parameters which require filtration will be collected by one of two methods. In the first method the
peristaltic pump will be used to draw the sample from the out-flow and pump it through a 0.45 micron
filter directly into the appropriate sample container. The second method is used in situations with limited
access for the generator required to run the peristaltic pump. When the generator cannot be used, a large,
unused sample jug will be used to collect the sample. The peristaltic pump will then be used to transfer
the sample from the large sample jug to the sample bottles through a 0.45 micron filter. This filtration
and pumping will be completed at a location where there is access for the generator.
Peristaltic Pump
Sample collection with a peristaltic pump involves collecting the sample from the source or out-flow
using the peristaltic pump. The peristaltic pump is used to deliver the sample from the source or out-flow
to the sample bottles. Filtered parameters are pumped through a 0.45 micron filter prior to delivery to the
sample bottle.
Sample Ladle
Sample collection using a ladle involves dipping or filling a ladle made from an inert material into the
surface water source or out-flow and filling the ladle. The sample is transferred from the ladle to the
sample bottles. This process is repeated until the sample bottles are filled. Filtered parameters are
collected into a large, unused sample jug. The peristaltic pump is then used to transfer the sample from
the large sample jug to the sample bottles through a 0.45 micron filter.
3.1 Field Data
In addition to the analytical parameters noted above, field data will be recorded at the time of sample
collection. Field parameters required by the GWDP include pH, specific conductance and temperature.
Additional field parameters such as oxidation reduction potential (REDOX) and turbidity may be
measured as available sample volume allows. Field data will be recorded on the Field Data Record
included in Tab B of this SAP.
As previously noted, the dates of the site visits, the availability of surface water for sampling, and the
possibility for development will be recorded on the field data sheets for inclusion in the annual report.
3.2 Decontamination
Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable
sampling equipment is used to collect samples. Decontamination procedures will be as described in the
approved QAP. Rinsate blanks will be collected daily after decontamination of sampling equipment. If
disposable or dedicated sampling equipment is used to collect samples then rinsate blanks will not be
collected.
3.3 Field QC
The field QC samples generated during the annual seeps and springs sampling event will include sample
duplicates, trip blanks, and rinsate blank samples as appropriate.
Sample Duplicates
Sample duplicates will be collected at a frequency of one duplicate per 20 field samples. Sample
duplicates will be collected by filling the sample container for a certain analytical parameter for the
duplicate immediately following the collection of the parent sample for that parameter.
Trip Blanks
Trip blank samples will be included in every shipment of samples that has field samples to be analyzed
for Volatile Organic Compounds ("VOCs"). Trip blank samples are VOC sample containers filled by the
analytical laboratory with laboratory grade deionized water and shipped to the site. Trip blank samples
are taken into the field with the sample containers, never opened, and kept with the field samples from
collection through shipment to the analytical laboratory for analysis. Trip blanks are analyzed to
determine if the sample concentration of VOCs have been effected by the "trip" from collection through
shipment.
Rinsate Blank Samples
Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated,
reusable sampling equipment is used to collect samples. If the sampling equipment has a disposable
component that comes in contact with the samples and the component is changed prior to sampling at
each location then a rinsate blank sample will not be collected. For example, if a peristaltic pump is used
to collect and filter seeps and springs samples and the tubing used in the peristaltic is changed at each
location and never reused for more than one sample, no rinsate blank sample would be required.
3.4 Sample Handling
Seeps and springs sampling events will be subject to the applicable sample handling requirements noted
in the approved White Mesa Mill Groundwater Quality Assurance Plan ("QAP"), Revision 6, dated
March 22, 2010.
4.0 QA and Data Evaluation
The Permit requires that the annual seeps and springs sampling program be conducted in compliance with
the requirements specified in the Mill's approved QAP, the approved SAP and the Permit itself. To meet
this requirement, the data validation for the seeps and springs sampling program will utilize the
requirements outlined in the QAP, the Permit and the approved SAP as applicable. The Mill QA
Manager will perform a QA/QC review to confirm compliance of the monitoring program with
requirements of the Permit, QAP and SAP. As required in the QAP, data QA includes preparation and
analysis of field QC samples, review of field procedures, an analyte completeness review, and quality
control review of laboratory data methods and data.
The QAP and the Permit identify the data validation steps and data quality control checks required for the
seeps and springs monitoring program. Consistent with these requirements, the Mill QA Manager will
performed the following evaluations: a field data QA/QC evaluation, a receipt temperature check, a
holding time check, an analytical method check, a reporting limit check, a trip blank check, a QA/QC
evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each laboratory's
reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
Samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP
using the analytical methods and specified reporting limits contained in the approved QAP. Laboratories
used for the seeps and springs sampling program will be Utah certified as required by the GWDP Part
l.E.6 (c). Laboratory data will be validated as described in the approved QAP and as described in Section
4.0 above. Analytical QC is described below.
5.1 Analytical Quality Control
Analytical QC samples and protocols are described in the approved QAP. Laboratory QC procedures will
meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for
by the State of Utah.
The analytical QC samples included at least the following: a method blank, a laboratory control spike
("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where
applicable. It should be noted that:
• Laboratory fortified blanks are equivalent to LCSs.
• Laboratory reagent blanks are equivalent to method blanks.
• Post digestion spikes are equivalent to MSs.
• Post digestion spike duplicates are equivalent to MSDs.
• For method E900.1, used to determine gross alpha, a sample duplicate was used instead of a
MSD.
All qualifiers, and the corresponding explanations reported in the QA/QC Summary Reports for any of
the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager.
The effect on data usability will be discussed in the evaluation section of the annual report.
5.2 Evaluation of Analytical Data
An evaluation of the analytical data will be completed in the annual report. A discussion of the results
will be included which will summarize the data relative to any detections reported in the samples with
comparisons as appropriate to the Mill groundwater quality data.
6.0 Reporting
DUSA will collect seeps and springs samples annually as required by the GWDP Part l.F.7. Each report
will: 1) document the sampling event by means of providing the field sheets recorded at the time of
sampling; 2) transmit copies of all field measurements and laboratory results; 3) provide a water table
contour map that includes water table elevation of all groundwater monitoring wells at the facility and the
elevations of the phreatic surfaces observed at each of the seeps and springs sampled; and 4) provide an
evaluation and interpretation of the groundwater quality data collected. Specific reporting requirements
for the seeps and springs sampling program will include but are not limited to:
• The annual seeps and springs monitoring report will be included with the 3'd quarter Routine
Groundwater Monitoring Report due on December 1, of each year.
• The seeps and springs water table contour map will include all water level data measurements
from all monitoring wells at the site from the 3'ct quarter groundwater monitoring event for each
year.
• The seeps and springs water table contour map shall be at the map scale such that all seeps and
springs listed in this Plan and monitor wells at the site may be seen on one map.
Table 1
s L eeps an dS . S I~ f iprmgs urvey n orma 100
December 2009 Survey
Location Latitude (N) Longitude (W) Elevation
FROG POND 37°33'03.5358" 109°29'04.9552" 5589.56
CORRAL CANYON 37°33'07.1392" 109°29'12.3907" 5623.97
ENTRANCE SPRING 37°32'01 .6487" 109°29'33.7005" 5559.71
CORRAL SPRINGS 37°29'37.9192" 109°29'35.8201" 5383.35
RUIN SPRING 37°30'06.0448" 109°31'23.4300" 5380.03
COTTONWOOD 37°31'21.7002" 109°32'14.7923" 5234.33
WESTWATER 37°31'58.5020" 1 09°31'25. 7345" 5468.23
Verification Survey July 2010
RUIN SPRING 37°30'06.0456" 109°31'23.4181" 5380.01
COTTONWOOD 37°31'21.6987" 109°32'14.7927" 5234.27
WESTWATER 37°31'58.5013" 109°31'25.7357" 5468.32
Attachment A
I''
I
Field Data Record-Seeps and Springs Sampling
Seep or Spring Location: ----------------------
Date For Initial Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Second Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Third Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Sampling Personnel:
Weather Conditions at Time of Sampling: ________________ _
Estimated Seep or Spring Flow Rate: ------------------
Field Parameter Measurements:
-pH
-Temperature (°C) --------------~
-Conductivity !!MHOC/cm ------------
-Turbidity (NTU) (if measured). __________ _
-Redox Potential Eh (m V) (if measured) ______ _
Analytical Parameters/Sample Collection Method:
Par~ter Sample Taken Fifter~ = S.ampling, Method
Direc~ ,JYe-ri tattle Lad~
11, l-ump
VOCs o Yes oNo o Yes oNo 0 0 0
THF o Yes oNo o Yes oNo 0 0 0
Nutrients o Yes oNo o Yes oNo 0 D 0
Other Non o Yes oNo o Yes oNo 0 0 0
Radiologies
Gross Alpha o Yes oNo o Yes oNo 0 D D
QC Samples Associated with this Location:
o Rinsate Blank
o Duplicate
Duplicate Sample Name: ___________ _
(t)ther
Cd critie in no~s,sectio~"l
0
0
0
0
0
Notes: ______________________________ _
Appendix D
Results of Soil Analysis at Mill Site
{
\..._
--·-·-~ Results Of Soil Analyses At Mill Site
a ';:!
-e~ l Jlf I'! ~-~~ •iJ~ .!! t-a '"il,-. !'"' .... '!l ...... ~! i1 fll,Q .J. :a--~ ~t ,:..; .§ ~ r=.~ ~ a ~£ !!•0 >O"'"""' .... o.l'-' .... ...... Ea .... Fo <~ f..:! ......... J1-~ ~ ..... Q.o ..
,t ~
Bllillding 4 0-4 SiL 7.6 36.0 7.4 7.9 0.3 .15 1.2 1.1 .63 15 (Bnd)
Ustollic 4-12 SiCL 8.7 49.0 7.6 8.0 0.3 0.14 0.8 0.2 0.53 3 Hep!llrgid
Pinc·silty, 18-40 SiCL 8.0 43.7 8.0 8.5 2.0 0.30 0.7 0,6 0.42 3 mixeil
9 0-5 SiL 8.9 38.7 7.6 8.1 0.3 0.17 0.9 1.8 0.53 10
5-12 SIL 9.3 45.6 8.0 8.4 0.3 0.18 0.9 1.4 0.47 2
18-40 SiL 8.0 38.7 8.5 9.0 3.8 0.18 1.2 11.5 0.37 2
40-50 SiCL 9.0 38,9 8.8 9.2 1.6 0.18 1.0 12.5 0.26 1
Source: Adapted from 1978 ER Table 2.10-2.2
SiCL = $ilty clay loam: SiL = slit loam
. ~ ... -~,.,_ • ._..___ •••-• <o l o -•. , a ' ( •• .• -
~---~
]a c:.lg ti~ ~~ i Q.o
198 12.8
170 16.6
165 14.9
182 13.1
138 10.9
123 11.9 ..
161 15.9
·~~
o=•: :\~.':1"'~, •. \Ll' • \v • • \o\'oo'fll·•
Appendix E
Tables: Chemical and Radiological Characteristics of Tailings Solutions, Leak Detection
Systems and Slimes Drains
Celli
Ch emtca I d R d' I I Ch an a 10 og1ca t . f arac ens tcs
~-~
Constituent 1987 2003 2007 2008 2009 2010 2011 2012 2013 2013 (Avg) (Avg) _ _(resample} ,
Major Ions Crtagll_l
Carbonate <5 <1 ND ND <1 <1 <1 <1 <1 NS
Bicarbonate <5 NA ND ND <1 <1 <1 <1 <1 NS
Calcium 630 307 483.8 604 635 711 577 426 768 NS
Chloride 8000 6728 37340 9830 20700 7440 33800 78000 9900 NS
Fluoride <100 3005 31.72 0.3 0.4 28.4 69.2 62.9 4130 NS
Magnesium 7900 5988 21220 6550 16200 5410 14300 16000 4470 NS
Nitrogcn-Ammonla 7800 3353 10628 5250 15200 8120 12900 9750 3900 NS
Nitrogen-Nitrate <100 41.8 269.4 64.9 142 58 212 556 128 NS
Potassium NA 647 5698 1880 4140 1840 4510 9750 6580 NS
Sodium 10000 8638 62600 13200 39000 16700 29500 41700 15900 NS
Sulfate 190000 63667 287600 118000 232000 107000 182000 158000 100000 NS
pH (s.u.) 0.70 1.88 0.80 1.53 1.15 2.73 2.23 1.9 2.74 NS
TDS 120000 94700 357400 131000 140000 130000 216000 342000 149000 NS
Conductivily:(umhos/cm) NA NA NA NA 365000 110000 112000 136000 94200 NS
Metals '(ugfl} = -Arsenic 440000 121267 849000 271000 436000 74400 299000 25500 9800 NS
Beryllium 780 475 2262 500 410 338 1270 3180 415 NS
Cadmium 6600 3990 29320 8790 9120 2940 13700 30700 2380 NS
Chromium 13000 6365 29940 6760 18700 5620 22700 12100 8350 NS
Cobalt 120000 NA 88240 23500 97500 16200 56000 53100 25500 NS
Ca1mer 740000 196667 881000 360000 168000 125000 483000 885000 544000 NS
Iron 3400000 2820000 13480000 3280000 2390000 3400000 8940000 840000 1420000 NS
Lead <20000 3393 27420 11200 10600 9240 23600 17000 2810 NS
Manganese 140000 162500 990200 206000 723000 173000 735000 1560000 188000 NS
Mercury NA NA ND ND 7.61 7.2 61.4 117 6.16 NS
Molji_bdenum 240000 50550 415600 106000 142000 35300 235000 434000 16800 NS
Nickel 370000 36950 40860 32000 156000 27500 43700 15000 39100 NS
Selenium <20000 1862 15420 13000 14800 5220 11600 8090 2690 NS
Silver <5000 NA 1559.2 449 558 155 1110 4310 329 NS
Thallium 45000 NA 407.8 165 387 193 560 13 63.3 NS
Tin <5000 NA 6512 1240 2290 263 1500 <100 <100 NS
Uranium 105000 134517 788600 416000 578000 159000 838000 1450000 140000 NS
Vanadium 280000 348000 2208200 1200000 773000 752000 2500000 1940000 98200 NS
Zinc 1300000 NA 642940 476000 229000 171000 398000 811000 228000 NS
.Ra'ili.oiQgic~.(pCUl)_ ' --
Gross Alpha NA 1693331 29380 21900 16500 11300 3610 12600 32700 NS
VO~(uWL)
Acetone 35 NA 66.5 110 710 260 80 310 41.1 NS
Benzene <5 NA ND ND <1 <1 <1 <I <I NS
Carbon tetrachloride <5 NA ND ND <1 <1 <1 <I <1 NS
Chloroform 8 NA ' 6.7 6.6 16 4.9 13 19 7.62 NS
Chloromethane NA NA ND 9.4 11 4.4 3.6 4.0 5 NS
MEK NA NA ND ND 120 65 <1 200 <20 NS
Mclllylene Chloride 11 NA ND ND 2.0 <1 <1 2 <1 NS
Naphthalene <10000 NA <10 ND 1.1 5.4 2 3 <1 NS
Tctrahydrofuran NA NA ISO <20 <100 <10 <500 2.9 <1 NS
Toluene <5 NA ND ND <1 <1 <1 <1 <1 NS
Xylene.~ <5 NA ND ND <1 <1 <1 <1 <1 NS
SVO~(ilalLl. -= 1.2.4-Trichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
1,2-Dichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
1,3-Dichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
1.4-Dichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
1-Methylnaphthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10
2.4,5-Trichlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
2,4,'6-Trichlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
2.4-Dichlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
2,4-Dinwthylphenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
2,4-Dinitrophenol NA NA NA NA <250 <20 <20 <20 <21.6 <20
2.4'-Dinirrotol.uer1e NA NA NA NA <50 <10 <10 <10 <10.8 <10
Celli
Ch em1ca an a 10 og1c I d.R d. I al Ch t arac enshcs
· opl!tllu _n I 1987 2003 2007 2008 2009 2010 2()11 2012 ,, 2013 2013 (Avg) (Avg) 1, .• lregampl e.r__
Mn,lor lu.ns (nWl) F"
2.6-Dinitrotoluene NA NA NA NA <50 <10 <10 <10 <10.8 <10
2-Chloron~hthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10
2-Chforopheno'J NA NA NA NA <50 <10 <10 <10 <10.8 <10
2d\1cthylnaphthaleoe. NA NA NA NA <50 <10 <10 <10 <10.8 <10
2-M!!lhy!pheno1 NA NA NA NA <50 <10 <10 <10 <10.8 <10
2-Niwmbenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
3&4-Methylphenol NA NA NA NA <22 <10 <10 <10 <10.8 <10
3.3'-Dichlorobenzidine NA NA NA NA <100 <10 <10 <10 <10.8 <10
4,6-Dinitro-2-methylphenol NA NA NA NA <250 <10 <10 <10 <10.8 <10
4-BromophcnylphcnyJ ether NA NA NA NA <50 <10 <10 <10 <10.8 <10
4-Chloto-3·1Ilclhylpl'tenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
4-Chloropllenyl phenyl ether NA NA NA NA <50 <10 <10 <10 <10.8 <10
4-Nitrophenol NA NA NA NA <250 <10 <10 <10 <10.8 <10
Ac¢naphthene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Acenaphtltylcm: NA NA NA NA <50 <10 <10 <10 <10.8 <10
Anthracene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Azobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Bonz(a)anihracene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Benzidine NA NA NA NA <100 <10 <10 <10 <10.8 <10
Benzo(~)pyrene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Benzo(b)fluorant.hene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Henzo(g.h,i)_pervlene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Benzo(k)fl.uornnthene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Bi~(2-chloroethoxy)methane NA NA NA NA <50 <10 <10 <10 <10.8 <10
TIUi{2-chlomcLhyl), ether NA NA NA NA <50 <10 <10 <10 <10.8 <10
Bis(2-chJoroisopropyl) ether NA NA NA NA <50 <10 <10 <10 <10.8 <10
BisC2-etbylhcxyl) pluhalate NA NA NA NA <50 27 <10 <10 <10.8 <10
But:Yt benzyl phllialate NA NA NA NA <50 <10 <10 <10 <10.8 <10
Chrysenc NA NA NA NA <50 <10 <10 <10 <10.8 <10
Dibenz(a.h)anlhraccne NA NA NA NA <50 <10 <10 <10 <10.8 <10
Die.UI yl J]hthilJate NA NA NA NA 170 <10 <10 <10 <10.8 <10
Dimetl1yl pbthalnte NA NA NA NA <50 <10 <10 <10 <10.8 <10
DI-n-butyl phthala1e NA NA NA NA <50 <10 <10 <10 <10.8 <10
Di-o-octyl phthalate NA NA NA NA <50 <10 <10 <10 <10.8 <10
Fluoranthene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Fluorene NA NA NA NA <50 <10 <10 <10 <10.8 <10
lfexachlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
lfexachlorobutadiene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Hex~chlorocvclopentudiene NA NA NA NA <50 <10 <10 <10 <10.8 <10
lfexachloroethane NA NA NA NA <50 <10 <10 <10 <10.8 <10
I ntlenQ(l,2,3-cd)pyrene NA NA NA NA <50 <10 <10 <10 <10.8 <10
lso~h()rone NA NA NA NA <50 <10 <10 <10 <10.8 <10
Naphthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Nitrobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10
N-NitrosodimatbyJami ne NA NA NA NA <50 <10 <10 <10 <10.8 <10
N-Ni!rosodi-n-propylamine NA NA NA NA <50 <10 <10 <10 <10.8 <10
N.:Niti'osodfph~nylamine NA NA NA NA <50 <10 <10 <10 <10.8 <10
Pentachlorophenol NA NA NA NA <250 <10 <10 <10 <10.8 <10
Phenanthrene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Phenol NA NA NA NA <50 <10 <10 <10 <10.8 <10
Pyrene NA NA NA NA <50 <10 <10 <10 <10.8 <10
Pyridine NA NA NA NA <50 <10 <10 <10 <10.8 <10
r Historic values reported for Gross Alpha from 1987 and 2003 are total gross alpha reported in pCi!L. All other gross alpha data are reported as Gross Alpha
minus Rn & U.
Ch ennca
' ~ Miffor'lons (mg/l)
Carbonate
Bicarbonate
Calcium
Chloride
Fluoride
Magnesium
Nitrogen-Ammonia
Nitrogen-Nitrate
Potassium
Sodium
Sulfate
pH (s.u.)
TDS
Conductivity (umhos/cm)
M~t1ils (U.W)}
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Uranium
Vanadium
Zinc
Radiologies (pCi/1)
Gross Alpha
VOCS(uJV'L)
Acetone
Benzene
Carbon tetrachloride
Chloroform
Chi oromethane
MEK
MetJ1y!ene. Chloride
Naphthalene
Tetrahydrofuran
Toluene
XvJenes
SVOCS (ugfL)
1 ,2,4-Trichlorobenzene
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 A-Dichlorobenzene
1-Methylnaphthalene
2.4.5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
an a 10 ogaca aractensbcs
Cell 2 Slimes Drain
d R d' I I Ch
2007 2008 I 2009 201,'0
ND ND <1 <1
ND ND <1 <1
572 528 508 496
3700 3860 2750 3510
3.3 ND <0.1 2.4
4100 4030 3750 3790
4020 3620 3240 3820
30.9 20.3 38 126
636 560 689 620
4050 4600 4410 4770
60600 74000 72200 63700
3.18 3.24 3.11 3.39
84300 74600 84100 79900
NA NA 88700 60200
-
26900 19300 14200 23500
298 245 271 267
5500 5840 5510 6370
2750 2450 2230 2510
46500 43800 38700 48200
106000 154000 170000 148000
2770000 3310000 3230000 2720000
566 528 403 586
117000 130000 160000 144000
ND ND <0.5 <4
4080 3190 2240 4630
123000 122000 108000 126000
422 647 726 844
ND ND <10 <10
361 703 368 470
ND ND <100 <100
23000 29200 29900 30600
409000 463000 536000 469000
767000 750000 582000 652000
1290 1570 1580 1000
550 410 570 460
ND ND <1 <1
ND ND <1 <1
20 17 16 15
1.8 ND 2.2 2.3
65 ND 100 83
ND ND <1 <1
14 7.5 16 17
15 NA <100 <10
1.7 ND 2.6 2.6
1.5 ND <1 2.2
NA NA <11 <10
NA NA <11 <10
NA NA <11 <10
NA NA <11 <10
NA NA <U <10
NA NA <11 <10
NA NA <11 <10
NA NA <11 <10
NA NA <51 <20
NA NA <11 <10
NA NA <11 <10
2011 20f2 2013
<1 <1 <l
<1 <1 <1
474 462 465
3110 3730 3270
2.1 1.32 161
3640 3760 3320
2940 3540 1880
38 27 47.2
636 611 622
4590 4380 3980
64200 58300 83700
3.18 3.0 3.02
80200 83800 92200
51400 52900 51100
=
17800 19400 21000
231 251 262
5580 5290 5780
2380 2350 2290
42500 48700 44900
132000 138000 137000
2960000 2850000 2810000
501 619 515
123000 141000 122000
11.1 1.9 <0.5
3510 3610 3650
111000 125000 108000
714 711 678
<10 <10 <10
371 338 278
<100 <100 <100
27100 33400 22800
454000 475000 452000
574000 639000 631000
1230 1370 2270
(2400)*
= ~
690 600 384
<1 <1 <1
<1 <1 <1
20 16 21.4
2 3 2.04
130 100 95.5
<1 <1 <1
13 12 16.8
<10 3.2 3.98
3 2 3.23
<1 2 5.97
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<20 <10 <LO
<10 <20 <20
<10 <10 <10
Cell 2 Slimes Drain
Ch em1ca an d R di I I Ch a Ologlca t . f arac ens Ics
1\fu.ior lons-(nu((l) 2007 2008 2009 2010 2011 2012 2013
i 2,6-Dinitrotoluene NA NA <11 <10 <10 <10 <10
2-Chloronaphthalene NA NA <11 <10 <10 <10 <10
2-Chlorophenol NA NA <11 <10 <10 <10 <10
2-Methylnaphthalene NA NA <11 <10 <10 <10 <10
2-Methylphenol NA NA <11 <10 <10 <10 <10
2-Nitrophenol NA NA <11 <10 <10 <10 <10
3&4-Methylphenol NA NA <21 <10 <10 <10 <10
I 3,3 '-Dichlorobenzidine NA NA <51 <10 <10 <10 <10
4,6-Dinitro-2-methylphenol NA NA <11 <10 <10 <10 <10
4-Bromop_henyl phenyl ether NA NA <11 <10 <10 <10 <10
4-Chloro-3-methyl phenol NA NA <11 <10 <10 <10 <10
4-Chlorophenyl phenyl ether NA NA <51 <10 <10 <10 <10
4-Nitrophenol NA NA <11 <10 <10 <10 <10
Acenaphthene NA NA <11 <10 <10 <10 <10
Acenaphthylene NA NA <11 <10 <10 <10 <10
Anthracene NA NA <11 <10 <10 <10 <10
Azobenzene NA NA <11 <10 <10 <10 <10
Benz(a)anthracene NA NA <21 <10 <10 <10 <10
Benzidine NA NA <11 <10 <10 <10 <10
Benzo(a)pyrcne NA NA <11 <10 <10 <10 <10
Benzo(b )fluoranthene NA NA <11 <10 <10 <10 <10
Benzo(g,h,i)pery1ene NA NA <11 <10 <10 <10 <10
Benzo(k)fluoranthene NA NA <11 <10 <10 <10 <10
Bis(2-chloroethoxy)methane NA NA <11 <10 <10 <10 <10
Bis(2-ch1oroethyl) ether NA NA <11 <10 <10 <10 <10
Bis(2-chloroisopropyl) ether NA NA <11 <10 <10 <10 <10
Bis(2-ethylhexvl) phthalate NA NA <11 <10 <10 <10 <10
Butyl benzyl phthalate NA NA <11 <10 <10 <10 <10
Chrysene NA NA <11 <10 <10 <10 <10
Dibenz( a,h )anthracene NA NA <11 <10 <10 <10 <10
Diethy1 phthalate NA NA <11 <10 <10 <10 <10
Dimetqyl Qhthalate NA NA <11 <10 <10 <10 <10
Di-n-butyl phthalate NA NA <11 <10 <10 <10 <10
Di-n-octyl phthalate NA NA <11 <10 <10 <10 <10
F!uoranthene NA NA <11 <10 <10 <10 <10
Fluorene NA NA <11 <10 <10 <10 <10
Hexachlorobenzene NA NA <11 <10 <10 <10 <10
Hexachlorobutadiene NA NA <11 <10 <10 <10 <10
Hexachlorocyclopentadiene NA NA <11 <10 <10 <10 <10
Hexachloroethane NA NA <11 <10 <10 <10 <10
lndeno(l ,2,3-cd)pyrene NA NA <11 <10 <10 <10 <10
Isophorone NA NA <11 <10 <10 <10 <10
Naphthalene NA NA <11 <10 <10 <10 <10
Nitrobenzene NA NA <11 <10 <10 <10 <10
N-Nitrosodimethylamine NA NA <11 <10 <10 <10 <10
N-Nitrosodi-n-propylamine NA NA <11 <10 <10 <10 <10
N-Nitrosodiphenylamine NA NA <51 <10 <10 <10 <10
Pentachlorophenol NA NA <11 <10 <10 <10 <10
Phenanthrene NA NA <11 <10 <10 <10 <10
Phenol NA NA <11 10.7 <10 <10 <10
Pvrene NA NA <11 <10 <10 <10 <10
Pyridine NA NA <11 <10 <10 <10 <10 .. *Sample was reanalyzed due to comparab1hty w1th the duphcate sample. The reanalysis data are m (parenthesis).
Cell2 LDS
Ch enuca an a 10 OgtCa d R d. I I Ch t . t' arac ens 1cs
Gon's'tituent 2009 ".20111.""' 2011 2012 2013
.MO:ior Ions (niWI)
Carbonate <1 <1 Not Sampled Not Sampled Not Sampled
Bicarbonate 168 324
Calcium 711 615
Chloride 1750 1360
Fluoride 0.4 0.4
Magnesium 596 454
Nitto"en-Ammonia 32.6 0.7
Nitrog_en-Nltratc 2.8 2.2
Potassium 22 13.0
Sodium 412 318
Sulfate 2700 1780
_IJ_H (s.u.) 6.60 7.36
TDS 6750 5310
Conductivity (wnhos/cm) 11000 6500
Metals "(l!Wll ~
...
Arsenic <5 <5 Not Sampled Not Sampled Not Sampled
Beryllium <0.50 <0.50
Cadmium 33.4 1.10
Chromium <25 <25
Cobalt 314 <10
Copper 59 12
Iron 208 37
Lead <1.0 <1.0 I Man~nes~ 1810 395
Mercury <0.50 0.52
Molybdenum 21 13
Nickel 948 <20
Selenium 7.9 9.4
Silver <10 <10
Thallium 0.92 <0.50
Tin <100 <100
Uranium 83.8 79.6
Vanadium 22 <15
Zinc 4220 78
Radiol~iics· (pCiliJ '-
Gross AIDba 13.5 7.3 Not Sampled Not Samjlled Not Samp).L'<i
vecs (uli[L<I) =
~
Acetone <20 <20 Not Sampled Not Sampled Not Sampled
Benzene <1 <1
Carbon tetrachloride <1 <1
Chloroform <1 <1
Chloromethane <1 <1
MEK <20 <20
Methylene Chloride <1 <1
Naphtllalene <1 <1
Tctrallydrofuran <100 6.13
Toluene <1 <1
Xylenes <1 <1
no_rS.lul!l[;)~
l .2,4-Trichlorobenzene NA <10 Not Sampled Not Sampled Not Sampled
1 ,2-0ichlorobenzene NA <10
1,3-Dichlorobenzene NA <10
1.4-Dichlorobenzene NA <10
1-Methylnaphthalene NA <10
2.4,5-Trichlorophcnol NA <10
2,4,6-lrichlo,·ophcnol NA <10
2,4-Dichlorophcnol NA <10
2.4-Dimcthylpheno! NA <10
2,4-Dinitrophenol NA <20
Cell2 LDS
Ch I d R d' I I Ch ermca an a JO O_gJca t . f arac ens Ics
Constlillent 2009 -20TO 2011 2012 2013 =,
MaJor lons.{mill)
2.4-Dinitrotoluene NA <10 Not Sampled Not Sampled Not Sampled
2,,6-Dinitrotoluone NA <10
2-ChloronDphlhl\lene NA <LO
2-Chlo·rophenol NA <10
2-Melhvlnaphthalene NA <10
2-'Metllvlphenol NA <10
2-Nitrophenol NA <10
3&4-Met hylphcuol NA <10
3.3 '-Dichlorobenzidine NA <10
4,6-Dinitrn-2-methy1phenol NA <10
4-BromophenyJ phenvJ ether NA <10
4-Chloro-J -ntethylphenol NA <10
4-Chlorophenyl phenyl ether NA <10
4-NIII'Ophcno] NA <10
Accnaphthene NA <10
Acenrtphtbylene NA <10
Anthracene NA <10
Azobenzene NA <10
llcnz(a)antfh'lleene NA <10
Benzidine NA <10
Benzo(n)pyrcne NA <10
Benzo(bjfluorantbene NA <10
B'enzo(g.h.i)perylt:ne NA <10
Benzo(k)fluoranthcne NA <10
Bis(2·chlol'()cthoxy)ml:ll1lane NA <10
__Bis(2-chloroelhyl)_ ether NA <10
Bis(2-cbloro1sopropy.l) ether NA <10
'Bis(2-ethylhexyl) phthalate NA <10
.Butyl benzyl phthalate NA <10
Chr¥scnc NA <10
DlbCJ1Z(n)l)Q.J1lbl'llt'ene NA <10
Oietbyl phUUllate NA <10
Dimetbyl phlhilll!lc NA <10
DJ-n-butyl pblba.late NA <10
Di-n-octyl vhthalme NA <10
Fluoranthene NA <10
Fluorene NA <10
Hexachlorobenzene NA <10
Hexachlorobutadiene NA <10
Hex-achlorocvclopcn!adiene NA <10
Hexachloroethane NA <10
1nduno(1 ,2',3--'cd)pyrone NA <10
lsophmone NA <10
Nap.hthn!cnc NA <10
Nitrobenzene NA <10
N-Nitrosodimethylamine NA <10
N-NlLrosodi-n-pn)pylamiue NA <10
N-Nirrosodiphcnylaminc NA <10
Pentachlorophenol NA <10
Phenanthrene NA <10
Phenol NA <10
Pyrenc NA <10
Pyridine NA <10
Cell3
Ch em1ca an a 10 OgiC8 I d U d' I l Ch t . f arac ens 1cs
1,.... =
Constituent 1987 2003 2007 2008 2009 2010 2011 2012 2013 2013
I (Avg) (Avg) {feiamvle} 1 -.
I 'Maior Ions (.ruWJ)_ ~
Carbonate NA <1 ND ND <1 <1 <1 <1 <1 NS
Bicarbonate <5 NA ND ND <1 <1 <1 <1 <1 NS
Calcium 300 418 887 478 628 560 200 591 586 NS
Chloride NA 2460 15965 15400 17200 3470 40400 8880 38400 NS
Fluoride <100 667 42.8 1.4 0.6 54.8 64.1 2300 12400 NS
Mtumesium 5400 3386 15767 13100 17100 2500 22100 5680 15400 NS
Ni~rogen-Arnmon.ia 13900 1302 13867 9010 21600 2650 6470 6840 100 NS
Nllrogen-Nitrate <100 20 102 44 142 26 261 64 277 NS
Potassium NA 254 6657 4760 3820 782 2590 1190 2110 NS
Sodium 5900 3198 25583 22900 28600 5620 47900 6660 34400 NS
Sulfate 180000 33400 173667 167000 214000 40400 197000 80000 440000 NS
pH (s.u.) 0.82 2.28 1.60 1.79 1.4 2.18 1.27 2.4 1.05 NS
TDS 189000 51633 228500 193000 243000 56200 296000 120000 410000 NS
Conductivity ~umhos/crn) NA NA NA NA 304000 59800 86400 80300 84300 NS
~I.JI)s_(u~:r ~
Arsenic 163000 32867 256500 489000 ND 52900 263000 4340 66000 NS
BervUium 540 430 913 840 905 206 1570 678 2570 NS
Cadmium 2600 1958 9260 15400 ND 1960 12200 3460 24000 NS
Chromium 12000 3742 14883 12800 ND 3360 22800 10900 30600 NS
Cobalt 48000 NA 82783 57000 ND 13000 76000 76100 99700 NS
Copper 360000 87333 505000 345000 ND 89000 768000 379000 954000 NS
Iron 2100000 1278333 4874500 4400000 5970000 1460000 1.02E+7 3400000 9700000 NS
Lead <20000 2507 9647 16900 ND 17200 16700 1860 14400 NS
Manganese 82000 144000 496833 313000 ND 101000 587000 3110000 2470000 NS
Mcr:cm·y ND NA ND 16 ND <4 30.9 9.6 21.6 NS
Molyb@:num 52000 12250 122167 209000 14 21300 96200 790 56100 NS
Nickel 170000 20917 131833 241000 ND 23800 75800 150000 122000 NS
Selenium <2000 910 5856 10200 ND 3080 6900 2460 7060 NS
Silver <2500 NA 305 1010 ND 101 792 1850 3380 NS
Thallium 4700 NA 446 1200 ND 190 518 1080 694 NS
Tin NA NA 1090 _1070 ND 155 325 <100 <100 NS
Uranium 118000 67833 332333 636000 3690 180000 458000 835000 1200000 NS
Vanadium 210000 158333 935000 1130000 ND 692000 2370000 836000 3220000 NS
Zinc 590000 NA 748833 515000 ND 134000 726000 652000 1430000 NS
Rallio!Qgics {pQitn I
Gross Alphu NA 101583 16533 21700 17000 4030 11100 1530 81900 NS
VOCS '(uJilL1
Acetone 28 NA 80 100 67 37 330 64 302 159
Benzene <5 NA ND ND <1 <1 <1 <1 <5 <1
Carbon tetrachloride <5 NA ND ND <1 <1 <1 <1 <5 <1
Chloroform 6 NA ND 11 4.2 2.6 31 2 56.3 21
Chloromethane NA NA ND ND 1.4 1.8 3.5 1 <5 2.58
MEK NA NA ND ND <1 <1 67 <20 <100 24.5
Mcthyh;ne Chloride 10 NA ND ND <1 <1 7.4 <1 6.95 <1
Naphthalene <10000 NA ND <10 <1 2.1 1.2 <1 <5 <1
Tct•·ahydrofuran NA NA 150 <20 <100 <10 <10 <1 <5 <1
Toluene <5 NA ND ND <1 <1 <1 <1 <5 <1
Xylcnes <5 NA ND ND <1 <1 <I <1 <5 <1
SVOC'SauWL-) "" 1,2,4-TticWnmbcnzenc NA NA NA NA <11 <10 <10 <10 <10.5 <10
1.2-Djchlorobcnzeoe NA NA NA NA <11 <10 <10 <10 <10.5 <10
1,3· Dichlorobenzene NA NA NA NA <11 <10 <10 <10 <10.5 <10
1.4-Di ch'lorobenzene NA NA NA NA <11 <10 <10 <10 <10.5 <10
1-Melhylnag_hthalen~ NA NA NA NA <11 <10 <10 <10 <10.5 <10
2,4,5-Trichlorophonol NA NA NA NA <11 <10 <10 <10 <10.5 <10
2,4,6-Trichloropncnol NA NA NA NA <11 <10 <10 <10 <10.5 <10
2,4-Di.c_hlOJ'OPhenot NA NA NA NA <11 <10 <10 <10 <10.5 <10
2,4-Di metbjllphcnol NA NA NA NA <11 <10 <10 <10 <10.5 <10
2.4-Di.nitrophenol NA NA NA NA <53 <20 <20 <20 <21.1 <20
2A-DinitrotolucnE:_ NA NA NA NA <11 <10 <10 <10 <10.5 <10
Cell3
Ch em1ca an 3' o ogica d R di I I Ch aracterisbcs
~-
Constituent 1987 2003 2007 2008 2009 2010 1011 2012 2013 2013 I• (Avg) (Avg) (resample)
l\1djor Ions C'mgl)) I
2,6-Dinitrotoluene NA NA NA NA <11 <10 <10 <10 <10.5 <10
2-Chloronap_bthalcnc NA NA NA NA <11 <10 <10 <10 <10.5 <10
2-Cblorophenol NA NA NA NA <11 <10 <10 <10 <10.5 <10
2-MethylnaphLbalenc NA NA NA NA <11 <10 <10 <10 <10.5 <10
2-Mclllylphenol NA NA NA NA <11 <10 <10 <10 <10.5 <10
2-Nitrophcnol NA NA NA NA <11 <10 <10 <10 <10.5 <10
3&4-Methylphenol NA NA NA NA <11 <10 <10 <10 <10.5 <10
3.3 '-Dich1orobenzidine NA NA NA NA <21 <10 <10 <10 <10.5 <10
4,6· Dinitro-2-rncr.hyl~nol NA NA NA NA <53 <10 <10 <10 <10.5 <10
4-Brom,Qph~nyl phenyl ether NA NA NA NA <11 <10 <10 <10 <10.5 <10
4-Chloro-3-mc:thyl phenol NA NA NA NA <II <10 <10 <10 <10.5 <10
4-Chlorophenyl phenyl ether NA NA NA NA <11 <10 <10 <10 <10.5 <10
4-Nitropbenol NA NA NA NA <53 <10 <10 <10 <10.5 <10
Acenaphtbene NA NA NA NA <11 <10 <10 <10 <10.5 <10
AccnaphLhyleoe NA NA NA NA <11 <10 <10 <10 <10.5 <10
Anthracene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Azobenzene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Benz(a)unthracene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Benzidine NA NA NA NA <21 <10 <10 <10 <10.5 <10
BenzoCa)pyr:ene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Bonzo(b)fluordn\hell_(.:_ NA NA NA NA <11 <10 <10 <10 <10.5 <10
Benzo(g,h,i)perylene NA NA NA NA <11 <10 <10 <10 <10.5 <10
.Bcnzo(k)fluor-anr.bcnc NA NA NA NA <11 <10 <10 <10 <10.5 <10
B W-2-oh l.oroelhoxy)metlmnc NA NA NA NA <11 <10 <10 <10 <10.5 <10
Bis(2-chloroer.hyl) ether NA NA NA NA <11 <10 <10 <10 <10.5 <10
Bfs(2-chl oroisopf'opyl) ether NA NA NA NA <11 <10 <10 <10 <10.5 <10
Bls{2-ethylhexyl) phU1alat~: NA NA NA NA <11 10.6 <10 <10 <10.5 <10
Butyl b~anzyl phthaHtte NA NA NA NA <11 <10 <10 <10 <10.5 <10
Cfuvscne NA NA NA NA <1 1 <10 <10 <10 <10.5 <10
Dlbenz(a,h)anthracene NA NA NA NA <11 <10 <10 <10 <10.5 <10
DieH1yl _phLhalate NA NA NA NA <11 <10 <10 <10 <10.5 <10
Dimethyl ph~halate NA NA NA NA <1 1 <10 <10 <10 <10.5 <10
Di-n-butyl phthalate NA NA NA NA <11 <10 <10 <10 <10.5 <10
Di-n.octyl phtbalatc NA NA NA NA <11 <10 <10 <10 <10.5 <10
Fluoranthene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Fluorene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Hexachlorobenzene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Hexachlorobutadiene NA NA NA NA <11 <10 <10 <10 <10.5 <10
J·lc.x.acltloroc_ycl bpenlndiene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Hexachloroethane NA NA NA NA <11 <10 <10 <10 <10.5 <10
lndeno( 1.2 3-cd)pyrenc NA NA NA NA <11 <10 <10 <10 <10.5 <10
l:;ophorone NA NA NA NA <11 <10 <10 <10 <LO.S <10
Naphdlah.me NA NA NA NA <11 <10 <10 <10 <10.5 <10
Nitrobenzene NA NA NA NA <11 <10 <10 <10 <10.5 <10
~-Nitrosodimcli1_ylamine NA NA NA NA <11 <10 <10 <10 <10.5 <10
N-Nitrosodi-n-propylamine NA NA NA NA <11 <10 <10 <10 <10.5 <10
N-Nitrosodlphenylamine NA NA NA NA <11 <10 <10 <10 <10.5 <10
Pentachlorophenol NA NA NA NA <53 <10 <10 <10 <10.5 <10
Phenanthrene NA NA NA NA <11 <10 <10 <10 <10.5 <10
Phenol NA NA NA NA <11 <10 <10 <10 <10.5 <10
Pyrena NA NA NA NA <11 <10 <10 <10 <10.5 <10
Pyridine NA NA NA NA <11 <10 <10 <10 <10.5 <10
1 Historic values reported for Gross Alpha from 1987 and 2003 are total gross alpha reported in pCi/L. All other gross alpha data are reported as Gross Alpha
minus Rn & U.
Ce114A
ermca an a 0 OgJCa Ch I d R di I J Ch aractenstics
ConslitueoJ. """ 11 ZO® 2010 2JfU 2012 2013
Mujl)r Ions (JQSllll
Carbonate <1 <1 <1 <1 <1
Bicarbonate <1 <1 <1 <I <1
Calcium 627 598 558 591 668
Chloride 4650 7350 5870 4980 4530
Fluoride 0.3 21.6 30.6 43 1130
Magnesium 3250 4940 4720 2230 3660
Njtrogen-Arnmonia 3140 5230 4930 1540 1340
Nitrogen-Nitrate 28 52 44 27 38.2
Potassium 980 1440 1450 558 773
Sodium 5980 11300 11400 7130 6860
Sulfate 67600 87100 267000 64900 83300
pH (s.u.) 1.40 1.99 1.73 1.2 1.47
TDS 81400 107000 108000 76000 90000
Conductivity (umhos!cm) 131000 101000 82100 78100 66300
-= MetalS 'fiiilll
Arsenic 626000 109000 86600 60500 73700
Beryllium 296 215 323 167 247
Cadmium 1920 3670 2190 844 1450
Chromium 3220 7500 5900 5990 5220
Cobalt 9440 26500 22500 22900 22900
Copper 99200 168000 181000 433000 540000
...Iron 2360000 2920000 3390000 3190000 2620000
Lead 5360 11800 11000 5270 11500
Mtmgnne.'ic 178000 209000 131000 112000 143000
Mercury 1.19 <4 15.2 2.4 0.786
Molybdenum 24300 43800 24200 58200 25500
Nickel 17100 40900 43500 41300 43300
Selenium 4620 5810 4460 1310 2080
Silver 78 193 216 J27 144
Thallium 162 350 410 250 256
Tin 257 378 319 169 118
Uranium 118000 217000 153000 91000 112000
Vanadium 918000 1090000 730000 237000 461000
Zinc 142000 224000 286000 200000 183000
R"~'•louics (pCUJ):
Gross Alph(l 8910 3400 8290 16300 15800
VOCSWgzLJ =
Acetone 60 55 100 25 28.4
Benzene <l <1 <1 <1 <1
Carbon tetrachloride <1 <1 <1 <1 <1
Chloroform 4.0 8.5 10 <1 <1
Chloromethane 3.4 5.5 7.9 <1 <1
MEK <1 <1 <1 <1 <20
Methylune Chloride <1 <1 <1 <20 <1
Naphthalene 1.8 <1 <1 <1 <l
Tctrnhydrofurnn <100 <10 <10 1.36 <1
Toluene <1 <1 <1 <1 <1
Xylenes <1 <1 <1 <1 <1
~ svocs ffiltfll,'
1_.2,4-Trichlorobenzene <11 <10 <10 <10 <10
L2-DicbJ:orobenzenc <11 <10 <10 <10 <10
I ,3-Dichlorobenzene <11 <10 <10 <10 <10
1,.4-Dichlorobenzene <11 <10 <10 <10 <10
1-Methyln.aphtl1ahme <11 <10 <10 <10 <10
2.4.S:rrichlorop11enol <11 <10 <10 <10 <10
2,4;6~Triohlorophcnol <11 <10 <10 <10 <10
2,4-Dichlorophcnol <11 <10 <10 <10 <10
2,4-Dimethylphcnol <11 <10 <10 <10 <10
2.4-Dinitrophenol <53 <20 <20 <20 <20
2,4-Dinitrotoluene <11 <10 <10 <10 <10
2.6-Dihitrololuene <11 <10 <10 <10 <10
2-.Chfotonaphthallolne <11 <10 <10 <10 <10
Ce114A
Ch I em1ca an d R d" 1 l Ch a ·1o 02Jca aractenstlcs
-Consl.iluent 2009 ;z()!h' 201J 2012 2013
Mil or 1ons (nWll
2-Cbloropl)cnol <11 <10 <10 <10 <10
2-Methylnaphth&lerJe <11 <10 <10 <10 <10
2-Methylphenol <11 <10 <10 <10 <10
2-Nitroohenol <11 <10 <10 <10 <10
3&4-MeihyJphenol <11 <10 <10 <10 <10
3,3 '-Dichlorobenzidine <21 <10 <10 <10 <10
4,6-Dinitm-2-methvlphennl <53 <10 <10 <10 <10
4-.Bromoohenyl pherwl ether <11 <10 <10 <10 <10
4-Chlom-3-methylphenol <11 <10 <10 <10 <10
4-C::hloropher\yl phenyl ether <11 <10 <10 <10 <10
4-Nitropllcnol <53 <10 <10 <10 <10
Accnapi'IIJ1ene. <11 <10 <10 <10 <10
Acenaphthylene <11 <10 <10 <10 <10
Anthracene <11 <10 <10 <10 <10
Azobenzene <11 <10 <10 <10 <10
Uen~(n)ilhthra·cenc <11 <10 <10 <10 <10
Benzidine <21 <10 <10 <10 <10
Benzo(o)pyrcne <11 <10 <10 <10 <10
Bem•.o(b)Ouoranthene <11 <10 <10 <10 <10
Beri7-9(~.h.i)perylene <11 <10 <10 <10 <10
Bene-o(l\)fluot'8 nthene <11 <10 <10 <10 <10
Bis(2-chlnruethoxy)methanc <11 <10 <10 <10 <10
Bis(2-.chlomclhyl) ether <11 <10 <10 <10 <10
Bis(2-chloroisopropyl) ether <11 <10 <10 <10 <10
Bis(2-~thylhexyl) phthalate <11 19.6 <10 <10 <10
Butyl benzvl phthalate <11 <10 <10 <10 <10
Chryscne <11 <10 <10 <10 <10
Dibcnz(a,h)anthracene <11 <10 <10 <10 <10
Diethyl ph.thlllate <11 <10 <10 <10 <10
Dimethyl ohtholnte <11 <10 <10 <10 <10
DI-n-butyl phthalate <11 <10 <10 <10 <10
Di-n.-octyl phthalate <11 <LO <10 <10 <10
Fluoranthene <11 <10 <10 <10 <10
Fluorene <11 <10 <10 <10 <10
Hexach1orobenzene <11 <10 <10 <10 <10
Hexachlorobutadiene <11 <10 <10 <10 <10
Hexacllloro<:Yclooe.nt;,~dicne <11 <10 <10 <10 <10
Hexachloroethane <11 <10 <10 <10 <10
l11(!e.no(l ,2.3-cd)pyrcnc <11 <10 <10 <10 <10
lsophorOJlC <11 <10 <10 <10 <10
_NaplHhalene <11 <10 <10 <10 <10
Nitrobenzene <11 <10 <10 <10 <10
N-Nitr.osQdimelhy1amine <11 <10 <10 <10 <10
N-Nitrosodi-n-propylaminc <11 <10 <10 <10 <10
N-Nitrosodip!wnylaminc. <11 <10 <10 <10 <10
Pentnchl.oraphenol <53 <10 <10 <10 <10
Phenanthrene <11 <10 <10 <10 <10
Phenol <11 <10 <10 <10 <10
Pyreoe <11 <10 <10 <10 <10
Pyridine <11 <10 <10 <10 <10
Cell4A LDS
ermca an a 10 OgJCa Ch I d R d. I I Ch aractenstlcs
~onstHuent = 2009 20lf) 2.0ll 2QJZ ~R
_t'\lla_jor Ions ~ ~ --'="'
Carbonate <1 <1 <1 <1 <1
Bicarbonate <1 <1 <1 <1 <1
Calcium 558 474 470 453 429
Chloride 7570 4670 6040 2710 1910
Fluoride 0.7 39.4 46 27 1970
Magnesium 6390 3240 5100 2070 1710
Nilrogen-Arnmonia 4480 2290 3480 1320 1010
Nifrogen-Nitrate 69 183 94 15 28.9
Potassium 1960 934 1500 503 305
Sodium 12600 6700 11000 3500 2930
Sulfate 92400 41700 77400 39600 31400
pH (s.u.} 1.98 2.53 2.32 2.1 2.32
TDS 117000 56900 93800 55400 49700
Conductivity (umhqs/crn) 150000 49000 66600 39600 31300
lfufuls;(u~TJ'
Arsenic 133000 54000 74700 44100 35700
Beryllium 536 295 367 180 188
Cadmium 4010 2650 3160 921 1170
Chromium 9140 3890 5940 3930 2630
Cobalt 37300 15200 21700 22300 44300
Copper 222000 116000 150000 481000 754000
Iron 3940000 1420000 2530000 2460000 1370000
Lead 5270 3400 4520 2300 165
Manganese 389000 157000 207000 95200 86300
Mcrcurr 2.66 6.2 14.7 0.7 <0.5
Motylrdcoum 49200 23900 29300 10200 1200
Nickel 43900 23900 29600 35000 54600
Selenium 5250 2820 3780 1260 1020
Silver 204 62 127 44 24.8
Thallium 252 194 290 332 171
Tin 504 180 119 <100 <100
Uranium 284000 145000 168000 90200 75000
Vanadium 1150000 518000 770000 240000 157000
Zinc 298000 152000 204000 181000 163000
~ Radlofoglcs·(pC)/1) .
Gross AJph.a 7020 3230 7440 4730 6930
vocs (US!liJJ .
Acetone 240 130 120 55 57
Benzene <1 <1 <1 <1 <1
Carbon tetrachloride <1 <1 <1 <1 <1
Chloroform 23 52 26 42 110
Chloromethane 7.9 13 3.8 6 9.93
MEK 78 50 82 36 <20
MetHylene Chloride <1 <1 <1 <1 <1
Naphtha~ne <1 1.5 <1 1 2.35
Tetrah ydrofu ran 140 158 102 117 39.1
Toluene <1 <1 <1 <1 <1
]<y1C:nes <I <1 <1 <1 <1
-S_VOCS lug/£1 ~
1,2,4~ Trichlorobenzene <11 <10 <10 <10 <10
1.2-Dichlorobenzene <11 <10 <10 <10 <10
1,3-Dichlorobenzene <11 <10 <10 <10 <10
1 ,4-Dichlorobcnzene <11 <10 <10 <10 <10
1-Melhylnapot,halcne <11 <10 <10 <10 <10
2,4,5-Trichlorophenol <11 <10 <10 <10 <10
2,4,6-Trichlorophcnol <ll <10 <10 <10 <10
2.4-Dichlorophenol <11 <10 <10 <10 <10
'2,4-Dimethvlphcnol <11 <10 <10 <10 <10
Cell4A LDS
Ch I em1ca an d Raili I . al Ch 0 OgiC t . f arac ens 1cs
cUmilittient. 2009 2010 2011 2012 2013 I
Ma.ior Ions CtJ:fU/ll
2.4-Dinllrophenol <64 <20 <20 <20 <20
2,4-Dioiu·otolucne <11 <10 <10 <10 <10
2.6-Dinitrmnlucne <11 <10 <10 <10 <10
2-Chloronaplrtha.lcne <11 <10 <10 <10 <10
2 -Chlorophenol <11 <10 <10 <10 <10
2-Methylnaph!halene <11 <10 <10 <10 <10
2-Methyl phenol <11 <10 <10 <10 <10
2-Nltrophenol <11 <10 <10 <10 <10
3&4-Methylphcnol <11 <10 <10 <10 <10
3.3 '-Dichlorobenzidine <22 <10 <10 <10 <10
4.6-Dinitro-2-methylpbenol <54 <10 <10 <10 <10
4-Brom,ephenyl phenyl ether <11 <10 <10 <10 <10
4-Chloro-3-methylphenol <11 <10 <10 <10 <10
4-Cblorophcnyl phenyl ether <11 <10 <10 <10 <10
4-Nitrophenol <54 <10 <10 <10 <10
AcenaphtheM <11 <10 <10 <10 <10
Accnuphlhylene <11 <10 <10 <10 <10
Anthracene <11 <10 <10 <10 <10
Azobenzene <11 <10 <10 <10 <10
Bcnz(a)unthraccne <11 <10 <10 <10 <10
Benzidine <22 <10 <10 <10 <10
Benzo(a)pyrene <11 <10 <10 <10 <10
Henzo(b)fluoranthtlne <11 <10 <10 <10 <10
Benz.o(g,h,i)~C!rylene <11 <10 <10 <10 <10
Benzo(k)fluoranthene <11 <10 <10 <10 <10
.Bis(2-ch1oroethoxy)methane <11 <10 <10 <10 <10
Bis(2-chlorcJt:thyJ) ether <11 <10 <10 <10 <10
Bis(2-chloroisopropyl) ether <11 <10 <10 <10 <10
Bis(2-t:rhylhexyl) phlhalate <11 54.9 54-9 16.6 <10
"Butyl bonzyl phthalate <11 <10 <10 <10 <10
Chrvscnc <11 <10 <10 <10 <10
Dibenz{a,h)aJJthracene <11 <10 <10 <10 <10
Dielhyl phtbalat~: <11 <10 <10 <10 <10
Dimethyl phthalate <11 <10 <10 <10 <10
Di-n-butyl phthalate <11 <10 <10 <10 <10
Di-n-ocryJ phthalare <11 <10 <10 <10 <10
Fluoranthene <11 <10 <10 <10 <10
Fluorene <11 <10 <10 <10 <10
Hexachlorobenzene <11 <10 <10 <10 <10
Hexachlorobutadiene <11 <10 <10 <10 <10
Hexach1orocyclopentadiene <11 <10 <10 <10 <10
Hexachloroethane <11 <10 <10 <10 <10
lndeno(l,2,3-cd)pyrene <11 <10 <10 <10 <10
'Jsophol'one <11 <10 <10 <10 <10
Nllphthalcne <11 <LO <10 <10 <10
Nitrobenzene <11 <10 <10 <10 <10
N-Ni~rosodimethylnminc <11 <10 <10 <10 <10
N-Nitrosodi-n-propylamine <11 <10 <10 <10 <10
N-Nitrosodiphenylamine <11 <10 <10 <10 <10
Penlc'lch'lorophenol <54 <10 <10 <10 <10
Phenanthrene <11 <10 <10 <10 <10
Phenol 33 23.5 <10 <10 <10
Fyrene· <11 <10 <10 <10 <10
P_yricline <11 <10 <10 <10 <10
Cell4B
em1ca an a JO_Oil IC3 Ch I d R d. I I Ch aractenshcs
Co)l!Hitut:nt 2011 2012' 2013
M ~iorJons 'fnut/1)
Carbonate <1 <1 <1
Bicarbonate <1 <1 <1
Calcium 570 580 662
Chloride 8290 8170 4570
Fluoride 26.7 23.3 1050
Magnesium 3910 4500 3560
Nitrogen-Ammonia 5220 5580 2060
Niu:ot!en-Nitrate 39 42 51.4
Potassium 1370 1650 1110
Sodium 9050 11700 3150
Sulfate 134000 119000 98100
I'JH (s.u.) 1.87 1.5 1.65
TDS 98000 128000 108000
Conductivity (umhos/cm) 76900 86900 72800
~ Me HilS (uK/J) =
Arsenic 67400 80000 65400
_B <!fY IIi UJil 311 356 334
Cadmium 1990 2540 1990
Chromium 6860 8280 6390
Cobalt 17800 29300 21300
Copper 193000 340000 340000
Iron 2960000 3580000 2830000
Lead 9960 11600 9820
Man!!anese 128000 148000 154000
Mercury 13.7 2.6 1.49
Molybdenum 21400 27600 26100
Nickel 33900 50500 35100
Selenium 4670 4470 3900
Silver 137 169 137
Thallium 237 368 243
Tin 196 215 163
Uranium 133000 171000 110000
Vanadium 660000 783000 163000
Zinc 191000 270000 184000
Radiololrlcs (pCi/1)
Gross Alpha 8590 13600 14600
VOCS(uwiT
Aceto.ne 130 94 43.5
Benzene <1 <1 <1
Carbon tetrachloride <1 <1 <1
Chloroform 9.4 4 8.06
Chloromethane 8.5 8 7.12
MEK <1 <1 <20
Methylene Chloride <1 <1 <1
Naphthalene <1 <1 <1
Tetmhvdrofumn <10 11.1 <1
Toluene <1 <1 <1
Xylcncs <1 <1 <1
SVOCS"[ui!ZQ
1,2,4-Trichlorobenzene <10 <10 <10
1.2-Dic.:hlorobcnzcne <10 <10 <10
1.3.·Dichlorobenzene <10 <10 <10
1,4rDichlorobenzene <10 <10 <10
1-Methylnaphthalcne. <10 <10 <10
2 ,4,.5-11·ic:llloropHcn<)l <10 <10 <10
2,4,6-Tricb.lotophenol <10 <10 <10
2,4-Dichlorophe.nol <10 <10 <10
2,4-Dimethylphenol <10 <10 <10
2,4-Dinitrophcn<:ll <20 <20 <20
2.4-Dinitrotoluene <10 <10 <10
Cell4B
.,., ~ Chemical and Radiolooieal Characteristics
C(mstituenL 2{)11 2012 ·r~ 20.f3'
lVl-1\iot Ions (mg!l)
2.6-Dinitrotoluene <10 <10 <10
2-ChiOl'OllO()bthale:ne <10 <10 <10
2-Chlorophenol <10 <10 <10
2-Me-lhylnophtbalenc <10 <10 <10
2-Me.thYlphenol <10 <10 <10
2-Nitrophenol <10 <10 <10
3&4-Methylphcnol <10 <10 <10
3,3 '-Dich1orobenzidine <10 <10 <10
4,6-Dinitro-2-methylphenol <10 <10 <10
4-Bromophenyl phenyl ether <10 <10 <10
4-Chloro-3-methylpht!nol <10 <10 <10
4-C hlQrophenyl piJenyl ether <10 <10 <10
4-Nitrophenol <10 <10 <10
Acenaphthene <10 <10 <10
Acenaphthylene <10 <10 <10
Anthracene <LO <10 <10
Azobenzene <10 <10 <10
Benz( a)anthracene <10 <10 <10
Benzidine <10 <10 <10
Bcnzo(o)pyrcne <10 <10 <10
Benzo(b).Uuoranthenc <10 <10 <10
Benzo(g,h ,i )perylene <10 <10 <10
Bcnzo(k)Jluornnthene <10 <10 <10
Bis(2-chloroethoxy)methane <10 <10 <10
Bis(2-chloroethyl) ether <10 <10 <10
Bis(2-chloroisopropyl) ether <10 <10 <10
'Bis(2-ethylhexyl) phthalate 410 19 <10
Bu9'j benzyl ]J_hthalate <10 <10 <10
Chrysene <10 <10 <10
Uibcnz(a,b)antht'3.cenc <10 <10 <10
Diethyl phthalate <10 <10 <10
Dimethyl phthalate <10 <10 <10
Di-n-butyl phthalate <10 <10 <10
Ui-n-odyl Rhtbalo_te <10 <10 <10
Fluoranthene <10 <10 <10
Fluorene <10 <10 <10
Hexachlorobenzene <10 <10 <10
Hexachlorobutadiene <10 <10 <10
Hexachlorocyclopentadiene <10 <10 <10
Hexachloroethane <10 <10 <10
l'ndenoC 1,2_,J.cd}pyn:mc <10 <10 <10
_Isophorone <10 <10 <10
Naphthalene <10 <10 <10
Nitrobenzene <10 <10 <10
N-Nitrosodimeth_}'lamine <10 <10 <10
N-Nitrosodi -n-propy !amine <10 <10 <10
N-Nitrosodiphcnylamine <10 <10 <10
PentachlOrophenol <10 <10 <10
Phenanthrene <10 <10 <10
Phenol <10 <10 <10
Pyrone <10 <10 <10
Pyridine <10 <10 <10
Ce114B LDS
Ch I ermca an a ao og 1ca d R d. 1 I Ch t . f arac er1s 1cs
Constituent 2011 2012 2013
Major Ions (mg/l) II'
Carbonate <1 <1 Not Sampled-
Bicarbonate <1 <1 dry
Caldum 486 456
Chloride 3630 6850
Fluoride 28.4 22
Magnesium 3230 3360
Nitrogen-Ammonia 4260 4090
Nitrogen-Nitrate 30 31
Potassium 1130 1060
Sodium 8240 8080
Sulfate 59900 99100
pH (s.u.) 2.23 2.4
TDS 85800 90200
Conductivity (umhos/cm_) 63000 62400
MetaJs (og/1)
Arsenic 54200 41200 Not Sampled-
Beryllium 274 271 dry
Cadmium 1670 1740
Chromium 6250 5930
Cobalt 15600 19000
Copper 176000 181000
Iron 2450000 2120000
Lead 6060 4420
Manganese 118000 162000
Mercury 12.3 3_
Molybdenum 16700 15000
Nickel 30700 33700
Selenium 3710 2880
Silver Ill 117
Thallium 179 175
Tin 332 <100
Uranium 111000 132000
Vanadium 518000 428000
Zinc 172000 182000
Radiologies (pCi/1) =
Gross Alpha 6000 7500 Not Sampled-
dry
VOCS (oWl)
Acetone 390 370 Not Sampled -
Benzene <1 <1 dry
Carbon tetrachloride <1 <1
Chloroform 20 19
Chloromethane 11 11
MEK 240 180
Methylene Chloride <1 <1
Naphthalene <1 <1
Tetrahydrofuran 198 3_22
Toluene <1 <1
Xylenes <1 <1
SVOCS (oWl)
1 ,2.4-Trichlorobenzene <10 <10 Not Sampled -
1 ,2-Dichlorobenzene <10 <10 dry
l ,3-Dichlorobenzene <10 <10
1.4-Dichlorobenzene <10 <10
1-Methylnaphthalene <10 <10
2.4.5-Trichloropheno1 <10 <10
2,4,6-Trichlorophenol <10 <10
2,4-Dichlorophenol <10 <10
2,4-Dimethy_lphenol <10 <10
2.4-Dinitrophenol <20 <20
2,4-Dinitrotoluene <10 <10
2,6-Dinitrotoluene <10 <10
Ceii4B LDS
Chennca and Radiologtcal Characteristics
.21)12
2-Chloronaphthalene <1 0 <10
2-Chlero_t:rheool <10 <10
2-Methyln<lphthaJcne <1 o <1 o
'~--------~2~-~M~c~t~hy~l~p·lh~e~n~o~l----------+-----~<~10~----+-----~<~10~--~
2-Nilrophenol <1 o <1 o
3&4-Methylphenol <10 <10
3.3'-Dichlorobenzidine <10 <10
4,6-Dinitro-2-methylphenol <10 <10
4-BI'omophcnyl phenyl ether <I 0 <I 0
4-Chloro-3-mcthylph~nol <I 0 <1 0
4-Chloropltenyl phenyl ether <1 0 <I 0
4-NitrOIJbenol <10 <10
Acenaphthenc <1 0 <1 0
Acenaphrhylene <10 <10
Anthracene <10 <10
Azobenzene <10 <10
Bcn~(a}anthmcene <10 <10
Benzidine <10 <10
Ben~o(a)pyrene <10 <10
Br.}rrlo('o)fluoramflcne <10 <10
.Benzo(g.h.i)perylene <10 <10
Be117..0(k)fluoramhene <10 <10
Bis(2-chloroethoxy)methane <10 <10
Bis(2-chloroerhyl) ether <10 <10
Uis(2-<:hioroillopropyl) ether <10 <10
Bi.s(2-ethylhexyl) phthalate 191 191
But vi berrLyl P.IHhalatc <10 <10
Chrvsooe <10 <10
Dibenz(a.h)anthracene <10 <10
Dicthyl phthalate <10 <10
Di niethyj _p_hthalatc <10 <10
Di-n-butyl phthal.ate <10 <10
Di-n-octyl ph!hala!c <10 <10
F1uoranthene <10 <10
Fluorene <10 <10
Hexachlorobenzene <10 <10
Hexachlorobutadiene <10 <10
.Hex<l..chlorocyclopentadiunc <10 <10
Hexachloroethane <10 <10
l.ndeno(l.2.3-cd)pyrene <10 <10
lsophorone <10 <10
Naphthalene <10 <10
Nitrobenzene <10 <10
N-Nitrosodimethylarnine <10 <10
N-Nitmsodi-n-Qropylaminc <10 <10
N-Ni.Lro$odiphenylamine <10 <10
Pcntltclilorcmhenol <10 <10
Phenanthrene <10 <10
Phenol <10 <10
Pyrenc <10 <10
Pyridine <10 <10
2013
Not Sampled -
dry
-a1 mgs 1980 2003 IUC/NRC T T as ewa er Wt t s I "'.t amp1es·
Constituent ' ~ ~Minimum Maximum -~
pH (Std units) 0.7 2.33
Nutrients (mg/L) ~
Ammonia (N) 3.0 13900
Nitrite (N) <100 <100
Nitrate (N) 24 24
Nitrate+Nitrite (N) 17.0 49.2
Phosphorus -total 88.1 620
TKN (N) 4900 5300
Inor~anics (mWJ.,)
Bicarbonate (HC03) <5 <5
Bromide <500 <500
Carbonate (C03) <1 <5
Chloride 2110 8000
Cyanide-total 0.022 0.022
Fluoride 0.02 4400
Phosphate <500 <500
Silica 110 400
Sulfate 29800 190000
Sulfide <5 <5
TDS 43100 189000
TOC 76.0 81
TSS 31.0 115
I Metals (m2/J) -
Aluminum 330 2530
Antimony <20 <20
Arsenic 0.3 440
Barium 1.021 0.1
Beryllium 0.347 0.78
Boron 3.5 11.3
Cadmium 1.64 6.6
Calcium 90.0 630
Chromium 1.0 13
Cobalt 14.0 120
Copper 72.2 740
Iron 1080 3400
Gallium <30 <30
Lead 0.21 6.0
Lithium <10 <20
Magnesium 1800 7900
Manganese 74.0 222
Mercury 0.0008 17.6
Molybdenum 0.44 240
Nickel 7.2 370
Potassium 219.0 828
Selenium 0.18 2.4
Silver 0.005 0.14
Sodium 1400 10000
Strontium 3.6 14
Thallium 0.7 45
Tin <5 <5
Titanium 6.5 33.3
Uranium 5.0 154
Vanadium 136 510
Zinc 50 1300
Zirconium 2.3 38.5
Radiolo~cs (pCi/L) -----
Gross Alpha 14000 189000
Gross Beta 74 116000
Lead-210 680 20700
Thori urn-230 3650 76640
Thorium-232 49 121
Polonium-21 0 1410 1410
Radiurn-226 40 1690
Radiurn-228 1.9 1.9
1980 2003 IUC/NRC T T -aa mg,s Wt t s as ewa er ampJes·
Constituent -..=. Minimum Maximum
Total Radium 42 1700
Selected VOCs (ug/L)
Acetone 28 514
Benzene <5 <5
2-butanone (MEK) 11 15.13
Carbon Disulfide 16 16
Carbon Tetrachloride <5 <5
Chloroform 6 16.84
1,1-Dichloroethane <5 <5
1,2-Dichloroethane <5 <5
Dichloromethane 10 11
Tetrahydofuran NIA N/A
Toluene <5 6.25
Vinyl Chloride <10 <10
Xylene (total) <5 <5
Selected Semivolatiles (oWl)
Uun~o(a)p~imme <10 <10
Bis(2-crhylhexyl)phtha latc 1 1
Chrysene <10 <10
Diethyl phthalate <10 18.1
Dimethylphthalate 2.7 2.7
Di-n-buty1phthalate 1.08 1.08
Fluoranthene <10 <10
2-Methylnaphthalene <10 <10
Naphthalene 2.44 2.44
Phenol <10 38.4
*Reproduced from the Utah Division of Radiation Control Groundwater Quality Discharge Permit, Statement of Basis for a
Uranium Mining Facility at White Mesa, South of Blanding, Utah, dated December 1, 2004.
1The data in the Utah Division of Radiation Control Groundwater Quality Discharge Permit, Statement of Basis are based on historical
data collected from Cell 1, Cell2, and Cell 3. The date of collection reflects which cells were operational at the time of sampling.
The location of the samples and date of collection is referenced in the Statement of Basis,
Appendix F
Cell4A and 4B BAT Monitoring, Operations and Maintenance Plan 07111
Revision: Denison 2.3
07/2011 Revision Denison 2.3
Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan.
TABLE OF CONTENTS
1.0 Introduction .............................................................................................................. 2
2.0 Cell Design ............................................................................................................... 2
2.1 Cell 4A Design ................................................................................................. 2
2.2 Cell 4B Design .................................................................................................. 5
3.0 Cell Operation .......................................................................................................... 8
3.1 Solution Discharge to Cell4A .......................................................................... 8
3.2 Solution Discharge to Ce114B .......................................................................... 8
3.3 Initial Solids Discharge into Cell 4A ................................................................ 9
3.4 Initial Solids Discharge into Cell4B ................................................................ 9
3.5 Equipment Access to Ce114A and Ce114B ..................................................... 10
3.6 Reclaim Water System at Cel14A .................................................................. 10
3.7 Reclaim Water System at Ce114B .................................................................. 10
3.8 Interim Solids Discharge to Cell 4A ............................................................... 11
3.9 Interim Solids Discharge to Ce114B ............................................................... 11
3.10 Liner Maintenance and QA/QC for Cell 4A ............................................... 11
3.11 Liner Maintenance and QA/QC for Ce114B ............................................... 11
4.0 BAT Performance Standards for Tailings Cell4A and 4B .................................... 11
5.0 Routine Maintenance and Monitoring ................................................................... 13
5.1 Solution Elevation .......................................................................................... 13
5.2 Leak Detection System ................................................................................... 13
5.3 Slimes Drain System ...................................................................................... 15
6.0 Tailings Emergencies ............................................................................................. 16
7.0 Solution Freeboard Calculations ............................................................................ 16
8.0 List of Attachments ................................................................................................ 18
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1.0 Introduction
Constmction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25, 2007. The construction
authorization provided that Cell 4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the
Groundwater Discharge Pennit No. UGW370004 ("GWDP") and fulfill the
requirements of Parts I.D.6, I.E.8, and I.F.9 of the GWDP.
Construction ofCell4B was authorized by DRC on June 21 ,2010. The constmction
authorization provided that Cell4B shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the GWDP and
fulfill the requirements of Parts I.D.12, I.E.12, and I.F.9 of the GWDP
2.0 Cell Design
2.1 Cell4A Design
Tailings Cell 4A consists of the following major elements:
a) Dikes -consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to 1 V . The west dike has an interior slope of 2H to
1 V . Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation -including sub grade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90%. Floor of
Cell 4A has an average slope of 1% that grades from the northeast to the
southwest comers.
c) Tailings Capacity-the floor and inside slopes of Cell4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML)-consisting of impermeable 60
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mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
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2) Leak Detection System-includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In tum, the gravel filter layer will be enclosed in an envelope of
geotexti1e fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML-consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner-consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System -including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric . The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. The non-woven geotextile
material is overlain at the surface by a woven geotextile fabric, which is
ballasted laterally by sandbags on each side of the backbone of the berm.
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In tum, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as
the "backbone" to the slimes drain system and runs from the far northeast
comer downhill to the far southwest corner of Cell 4A where it joins the
slimes drain access pipe.
3) Slimes Drain Access Pipe-consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and nonwoven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted by sandbags.A reducer
connects the horizontal 18-inch pipe with the 4-inch SDC pipe. At some
future time, a pump will be set in this 18-inch pipe and used to remove
tailings wastewaters for purposes of de-watering the tailings cell.
f) Dike Splash Pads - A minimum of eight (8) 20-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads consist of an extra layer of 60 mil
HDPE membrane that is placed down the inside slope of Cell 4A, from the top
of the dike and down the inside slope. The pads extend to a point 5-feet
beyond the toe of the slope to protect the liner bottom during initial startup of
the Cell. The exact location of the splash pads is detailed on the As-Built
Plans and Specifications.
g) Rub Protection Sheets -In addition to the splash pads described in f) above,
rub sheets are installed beneath all piping entering or exiting Cell 4A that is
not located directly on the splash pads.
h) Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. A second
spillway has been constructed in the southwest corner of Cell 4A to allow
emergency runoff from Cell 4A into Cell 4B. All stormwater runoff and
tailings wastewaters not retained in Cells 3 and 4A, will be managed and
contained in Cell 4B, including the Probable Maximum Precipitation and
flood event.
2.2 Cell4B Design
Tailings Cell 4B consists of the following major elements:
a) Dike -consisting of a newly-constructed dike on the south side of the cell
with a 15-foot wide road at the top (minimum) to support an access road.
The grading plan for the Cell 4B excavation includes interior slopes of 2H
to 1 V. The exterior slope of the southern dike will have the typical slopes
of 3H to 1 V. Limited portions of the Cell 4B interior sideslopes in the
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northwest corner and southeast comer of the cell (where the slimes drain
and leak detection sump will be located) will also have a slope of 3H to
1 V. The base width of the southern dike varies from approximately 100
feet at the western end to approximately 190 feet at the eastern end of the
dike, with no exterior embankment present on any other side of the cell.
b) Foundation -including sub grade soils over bedrock materials. Foundation
preparation included 6-inch over excavation of rock and placement and
compaction of imported soils to a maximum dry density of 90% at a
moisture content between +3% and -3% of optimum moisture content, as
determined by ASTM D-1557. The floor of Cell 4B has an average slope
of 1% that grades from the northwest comer to the southeast corner.
c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass
about 45 acres and the cell will have a water surface area of 40 acres and a
maximum capacity of about 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of 60 mil high
density polyethylene (HDPE) membrane that extends across both the
entire cell floor and the inside side-slopes, and is anchored in a trench at
the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4B floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4B, and
drains to a leak detection sump in the southeast corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML -consisting of a 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends
across the entire Cell 4B floor, up the inside side-slopes and is also
anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner-consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4B, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight.
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e) Slimes Drain Collection System -including a two-part system of strip
drains and perforated collection pipes both installed immediately above
the primary FML, as follows:
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4B that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southeasterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System-includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in tum overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
by a layer of non-woven geotextile to serve as an additional filter material.
The non-woven geotextile material is overlain at the surface by a woven
geotextile fabric, which is ballasted by sandbags. This perforated
collection pipe serves as the "backbone" to the slimes drain system and
runs from the far northwest corner downhill to the far southeast corner of
Cell 4B where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe-consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4B at the southeast comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and non-woven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted laterally by sandbags on each
side of the backbone of the berm. A reducer connects the horizontal 18-
inch pipe with the 4-inch SDC pipe. At some future time, a pump will be
set in this 18-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
f) Cell 4B North and East Dike Splash Pads -Nine 20-foot-wide splash pads
will be constructed on the north and east dikes to protect the primary FML
from abrasion and scouring by tailings slurry. These pads will consist of
an extra layer of textured, 60 mil HDPE membrane that will be installed in
the anchor trench and placed down the inside slope of Cell 4B, from the
top of the dike, under the inlet pipe, and down the inside slope to a point at
least 5 feet onto the Cell 4B floor beyond the toe of the slope.
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g) Rub Protection Sheets -In addition to the splash pads described in f)
above, rub sheets are installed beneath all piping entering or exiting Cell
4B that is not located directly on the splash pads.
h) Emergency Spillway - a concrete lined spillway constructed near the
southern corner of the east dike to allow emergency runoff from Cell 4A
into Cell 4B. This spillway will be limited to a 6-inch reinforced concrete
slab, with a welded-wire fabric installed within its midsection, set atop a
cushion geotextile placed directly over the primary FML in a 4-foot deep
trapezoidal channel. A 100 foot wide, 60 mil HDPE geomembrane splash
pad will be installed beneath the emergency spillway. No other spillway
or overflow structure will be constructed at Cell 4B. All stormwater
runoff and tailings wastewaters not retained in Cells 2, 3 and 4A, will be
managed and contained in Cell 4B, including the Probable Maximum
Precipitation and flood event.
3.0 Cell Operation
3.1 Solution Discharge to Cell4A
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3, or transferred from Cell 2
tailings dewatering operations. The solution will be pumped to Ce114A through
appropriately sized pipelines. The initial solution discharge will be in the
southwest corner of the Cell. The solution will be discharged in the bottom of
the Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and Cell4A, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.
3.2 Solution Discharge to Cell4B
Cell 4B will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3 or Cell 4A, or transferred
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from Cell 2 dewatering operations. The solution will be pumped to Cell 4B
through appropriate sized pipelines pipelines. The initial solution discharge will
be in the southeast comer of the Cell. The discharge pipe will be routed down the
Splash Pad provided in the southeast comer of the Cell at the spillway to protect
the primary FML. The solution will be discharged in the bottom of the Cell, away
from any sand bags or other installation on the top of the FML. Building the
solution pool from the low end of the Cell will allow the solution pool to
gradually rise around the slimes drain strips, eliminating any damage to the strip
drains or the sand bag cover due to solution flowing past the drainage strips. The
solution will eventually be discharged along the dike between Cell 3 and Cell 4B,
utilizing the Splash Pads described above. The subsequent discharge of process
solutions will be near the floor of the pond, through a discharge header designed
to discharge through multiple points, thereby reducing the potential to damage the
Splash Pads or the Slimes Drain system. At no time, subsequent to initial filling ,
will the solution be discharged into less than 2 feet of solution. As the cell begins
to fill with solution the discharge point will be pulled back up the Splash Pad and
allowed to continue discharging at or near the solution level.
3.3 Initial Solids Discharge into Cell 4A
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through appropriately sized
pipelines. The pipelines will be routed along the dike between Cell 3 and Cell
4A, with discharge valves and drop pipes extending down the Splash Pads to the
solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1 A. Figure
2A illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surlace. This is illustrated in Section A-A on Figure 2A. Because of the
depth of Cell 4A, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
3.4 Initial Solids Discharge into Cell 4B
Once Cell 4B is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through appropriately sized
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pipelines. The pipelines will be routed along the dike between Cell 3 and Cell
4B, with discharge valves and drop pipes extending down the Splash Pads to the
solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure lB. Figure
2B illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2B. Because of the
depth of Cell 4B, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
3.5 Equipment Access to Cell4A and Cell 4B
Access will be restricted to the interior portion of the cells due to the potential to
damage the flexible membrane liners. Only low pressure rubber tired all terrain
vehicles or foot traffic will be allowed on the flexible membrane liners. Personnel
are also cautioned on the potential damage to the flexible membrane liners
through the use and handling of hand tools and maintenance materials.
3.6 Reclaim Water System at Cell4A
A pump barge and solution recovery system is operating in the southwest corner
of the cell to pump solution from the cell for water balance purposes or for re-use
in the Mill process. Figure 3A illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
3. 7 Reclaim Water System at Cell 4 B
A pump barge and solution recovery system will be installed in the southeast
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3B illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
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the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
3.8 Interim Solids Discharge to Cell4A
Figure 4A illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4A. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
3.9 Interim Solids Discharge to Cell4B
Figure 4B illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4B. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
3.10 Liner Maintenance and QA/QC for Cell4A
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised Construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
3.11 Liner Maintenance and QA/QC for Cell4B
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Construction Quality Assurance Plan
for the Construction of the Cell 4B Lining System, October 2009, by
Geosyntec Consultants.
4.0 BAT Performance Standards for Tailings Cell 4A and 4B
DUSA will operate and maintain Tailings Cell 4A and 4B so as to prevent release of
wastewater to groundwater and the environment in accordance with this BAT Monitoring
Operations and Maintenance Plan, pursuant to Part I.H.8 of the GWDP. These
performance standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment-the
leak detection system pumping and monitoring equipment in each cell
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includes a submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system in each
cell at no more than 1 foot above the lowest level of the secondary flexible
membrane, not including the sump. A second leak detection pump with
pressure transducer, flow meter, and manufacturer recommended spare
parts for the pump controller and water level data collector is maintained
in the Mill warehouse to ensure that the pump and controller can be
replaced and operational within 24 hours of detection of a failure of the
pumping system. The root cause of the equipment failure will be
documented in a report to Mill management with recommendations for
prevention of a re-occurrence.
2) Maximum Allowable Head-the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane in each cell
by the use of procedures and equipment specified in the White Mesa
Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan, 10/10 Revision: Denison~10.2,
or the currently approved DMT Plan. Under no circumstance shall fluid
head in the leak detection system sump exceed a 1-foot level above the
lowest point in the lower flexible membrane liner, not including the
sump.
3) Maximum Allowable Daily LDS Flow Rates-the Permittee shall
measure the volume of all fluids pumped from each LDS on a weekly
basis, and use that information 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 Cell
4B. The maximum daily LDS flow volume will be compared against the
measured cell solution levels detailed on the attached Table 1A or 1B for
Cells 4A or 4B, respectively, to determine the maximum daily allowable
LDS flow volume for varying head conditions in the cell.
4) 3-foot Minimum Vertical Freeboard Criteria-the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4A and Cell4B. Said measurements
shall be made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring-immediately after the
Permittee initiates pumping conditions in the Tailings Cell4A or Cell
4B slimes drain system, quarterly recovery head tests and fluid level
measurements will be made in accordance with a plan approved by the
DRC Executive Secretary. The slimes drain system pumping and
monitoring equipment, includes a submersible pump, pump controller,
water level indicator (head monitoring), and flow meter with volume
totalizer.
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5.0 Routine Maintenance and Monitoring
01121/2010 Revision
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Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager and RSO.
5.1 Solution Elevation
Measurements of solution elevation in Cell 4A and Cell 4B are to be taken by
survey on a weekly basis, and measurements of the beach area in Cell4A and Cell
4B with the highest elevation are to be taken by survey on a monthly basis, by the
use of the procedures and equipment specified in the latest approved edition of the
DMTPlan.
5.2 Leak Detection System
The Leak Detection System in Cell 4A and Cell 4B is monitored on a
continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The water levels are measured
every hour and the information is stored for later retrieval. The water
levels are mea~ured 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.
The water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill's environmental monitoring data base,
and into the files for weekly inspection reports of the tailings cell leak
detection systems. Within 24 hours after collection of the weekly water
level data, the information will be evaluated to ensure that: 1) the water
level in the Cell 4A and Cell 4B leak detection sumps did not exceed the
allowable level (5556.14 feet amsl in the Cell 4A LDS sump and 5558.5
feet amsl in the Cell4B sump), and 2) the average daily flow rate from the
LDS did not exceed the maximum daily allowable flow rate at any time
during the reporting period. For Cell 4A and Cell 4B, under no
circumstance shall fluid head in the leak detection system sump exceed a
1-foot level above the lowest point in the lower flexible membrane liner,
not including the sump. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and Cell 4B leak detection system, the
total volume of all fluids pumped from the LDS of each cell 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 for each cell.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day from Cell 4A or 26,145 gallons/day from Cell 4B. The
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maximum daily LDS flow volume will be compared against the measured
cell solution levels detailed on the attached Tables 1A and lB, to
determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4A and Cell 4B. Any abnormal or out of
compliance water levels must be immediately reported to Mill
management. The data collector on each cell is also equipped with an
visual strobe light that flashes on the control panel if the water level in the
leak detection sump exceeds the allowable level (5556.14 feet ams1 in the
Cell 4A LDS sump and 5558.5 feet amsl in the Cell 4B sump). The
current water level is displayed at all times on each data collector and
available for recording on the daily inspection form. Each leak detection
system is also equipped with a leak detection pump, EPS Model # 25505-
3 stainless steel, or equal. Each pump is capable of pumping in excess of
25 gallons per minute at a total dynamic head of 50 feet. Each pump has a
1.5 inch diameter discharge, and operates on 460 volt 3 phase power.
Each pump is equipped with a pressure sensing transducer to start the
pump once the level of solution in the leak detection sump is
approximately 2.25 feet (elevation 5555.89 in the Cell 4A LDS sump and
5557.69 feet amsl in the Cell 4B sump) above the lowest level of the leak
detection sump (9 inches [0.75 feet] above the lowest point on the lower
flexible membrane liner for Cell 4A and 2 114 inches [0.19 feet] for Cell
4B), to ensure the allowable 1.0 foot (5556.14 feet amsl in the Cell 4A
LDS sump and 5558.5 feet amsl in the Cell 4B sump) above the lowest
point on the lower flexible membrane liner is not exceeded). The attached
Figures 6A and 6B (Cell 4A and 4B, respectively), Leak Detection Sump
Operating Elevations, illustrates the relationship between the sump
elevation, the lowest point on the lower flexible membrane liner and the
pump-on solution elevation for the leak detection pump. The pump also
has manual start and stop controls. The pump will operate until the
solution is drawn down to the lowest level possible, expected to be
approximately 4 inches above the lowest level of the sump (approximate
elevation 5554.0 and 5555.77 ft amsl for Cells 4A and 4B, respectively).
The pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
are recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
perforated section of the PVC collection pipe. The distance from the top
flange face, at the collection pipe invert, to the centerline of the 22.5
degree elbow is 133.4 feet in Cell 4A and 135.6 feet in Cell 4B, and the
vertical height is approximately 45 feet in Cell4A and approximately 42.5
feet in Cell4B. The pump is installed at least 2 feet beyond the centerline
of the elbow. The bottom of the pump will be installed in the leak
detection sump at least 135.4 feet in Cell 4A and 137.6 feet in Cell4B or
more from the top of the flange invert. A pressure transducer installed
within the pump continuously measures the solution head and is
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Cell4A BAT Monitoring, Operations and Maintenance Plan 0 l/21/20 10 Revision
Denison 2.2
programmed to start and stop the pump within the ranges specified above.
The attached Figure 5, illustrates the general configuration of the pump
installation.
A spare leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller on either cell can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.
5.3 Slimes Drain System
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe of each cell and a near
as possible to the bottom of the slimes drain sump. The bottom of the
slimes drain sump in Cell 4A and Cell 4B are 38 and 35.9 feet below a
water level measuring point, respectively, at the centerline of the slimes
drain access pipe, near the ground surface level. Each pump discharge
will be equipped with a 2 inch flow meter, E/H Model #33, or equal, that
reads the pump discharge in gallons per minute, and records total gallons
pumped. The flow rate and total gallons will be recorded by the Inspector
on the weekly inspection form.
(ii) The slimes drain pumps will be on adjustable probes that allow the pumps
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A and Cell 4B slimes drain pumps will be checked weekly to
observe that they are operating and that the level probes are set properly,
which is noted on the Weekly Tailings Inspection Form. If at any time
either pump is observed to be not working properly, it will be repaired or
replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A and Cell 4B slimes drain access riser
pipes shall be monitored and recorded weekly to determine maximum and
minimum fluid head before and after a pumping cycle, respectively. All
head measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) After initiation of pumping conditions in Tailings Cell 4A or 4B, n a
quarterly basis, each 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 a Quarterly Data fonn, by
measuring the depth to water below the water level measuring point on the
slimes drain access pipe;
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Cell4A BAT Monitoring, Operations and Maintenance Plan 01121/2010 Revision
Denison 2.2
The slimes drain pumps for each cell will not be operated until Mill management
has determined that no additional process solutions will be discharged to that cell,
and the cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
6.0 Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
7.0 Solution Freeboard Calculations
The maximum tailings cell pond wastewater levels in Cell 1, Cell 2, Cell 3, Cell4A, and
Cell4B are regulated by condition 10.3 of the White Mesa Mill 11e.(2) Materials
License. However, freeboard limits are no longer applicable to Cell 2, Cell 3, and Cell
4A, as discussed below.
Condition 10.3 states that "Freeboard limits, stormwater and wastewater management for
the tailings cells shall be determined as follows:
A. The freeboard limit for Cell 1 shall be set annually in accordance
with the procedures set out in Section 3.0 to Appendix E of the
previously approved NRC license application, including the
January 10, 1990 Drainage Report. Discharge of any surface water
or wastewater from Cell 1 is expressly prohibited.
B. The freeboard limit for Cell4B shall be recalculated annually in
accordance with the procedures established by the Executive
Secretary. Said calculations for freeboard limits shall be submitted
as part of the Annual Technical Evaluation Report (ATER), as
described in Condition 12.3 below [of the license and not included
herein]. Based on approved revisions to the DMT Plan dated
January 2011, the freeboard limit is no longer applicable to Cells 2,
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Cell 4A BAT Monitoring, Operations and Maintenance Plan
3 and4A.
01/2112010 Revision
Denison 2.2
C. The discharge of any surface water, stormwater, or wastewater
from Cells 3, 4A, and 4B shall only be through an Executive
Secretary authorized spillway structure. [Applicable NRC
Amendment:16] [Applicable UDRC Amendment: 3] [Applicable
UDRC Amendment:4]"
The freeboard limits set out in Section 6.3 of the DMT Plan are intended to capture the
Local6-hour Probable Maximum Precipitation (PMP) event, which was determined in
the January 10, 1990 Drainage Report for the White Mesa site to be 10 inches.
Based on the PMP storm event, the freeboard requirement for Cell 1 is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Celli freeboard
limit is not affected by operations or conditions in Cells 2, 3, 4A, or 4B.
Cells 2 and 3 have no freeboard limit because those Cells are full or near full of tailings
solids. Cell 4A has no freeboard limit because it is assumed that all precipitation falling
on Cell4A will overflow to Cell4B. All precipitation falling on Cell2, 3, and 4A and
the adjacent drainage areas must be contained in Cell 4B. The flood volume from the
PMP event over the Cell2, 3, and Cell4A pond areas, plus the adjacent drainage areas,
which must be contained in Ce114B, is 159.4 acre-feet of water.
The flood volume from the PMP event over the Cell4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). For the
purposes of establishing the freeboard in Cell4B, it is assumed Cell4A has no freeboard
limit and all of the flood volume from the PMP event will be contained in Cell 4B. The
flood volume from the PMP event over the Cell 4B area is 38.1 acre-feet of water ( 40
acres, plus the adjacent drainage area of 5.7 acres, times the PMP of 10 inches). This
would result in a total flood volume of 197.5 acre-feet, including the 123.4 acre-feet of
solution from Cells 2 and 3 and 36 acre-feet of solution from Cells 2, 3, and 4A that must
be contained in Cell4B. The procedure for calculating the freeboard limit for Ce114B is
set out in the DMT Plan.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for Cells 1, 4A, and 4B but
based on License condition 10.3 and the procedure set out in the DMT Plan, the
freeboard limits for Cells 1, 4A, and 4B will be at least three feet.
Figure 7, Hydraulic Profile Schematic, shows the relationship between the Cells, and the
relative elevations of the solution pools and the spillway elevations.
The required freeboard for Cell4B will be recalculated annually.
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Cel14A BAT Monitoring, Operations and Maintenance Plan
8.0 List of Attachments
0112112010 Revision
Denison 2.2
1) Figures 1A and lB, Initial Filling Plan, Geosyntec Consultants
2) Figure 2A and 2B, Initial Filling Plan, Details and Sections, Geosyntec
Consultants
3) Figure 3A and 3B, Initial Filling Plan, Solution and Slurry Pipeline Routes,
Geosyntec Consultants
4) Figure 4A and 4B, Interim Filling Plan, Geosyntec Consultants
5) Figure 5, Leak Detection System Sumps for Cell 4A and 4B, Geosyntec
Consultants
6) Figure 6A and 6B, Leak Detection Sump Operating Elevations, Geosyntec
Consultants
7) Figure 7, Hydraulic Profile Schematic
8) Cell 4A and Cell 4B Freeboard Calculations
9) Table 1A, Calculated Action leakage Rates for Various Head Conditions,
Cell 4A, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
1 0) Table 1 B, Calculated Action leakage Rates for Various Head Conditions,
Cel14B, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
11) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan.
• The most recent, approved version of the DMT Plan is included as
Attachment G to this Application.
N:\Ce114B1July 2011 Bat O&M Plan Revision 2.3Vu1y 2011 BAT 0 and M Revision for pennit\Cell 4A and 4B 0 M
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Page 18
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Geosynt~ Consultants Table 1A
Ca!CY.lated Action t.ea.kage Rates for Various Head Conditions
cell 4A, White Mesa M1JI
Blandtng, Utah
Head Above Uner C.kullted Adlan l.•kap Rate
System (feet) (plfans/•Cte/ot)
s 222.04 -· - --
1-10 31.4.0 -15 384.58 --1-----20 444.08 -----2S 496.5 --30 543.88 --------35 587.5
---~ --37 ()04.0
Geos~ntec Consultants Table 18
Calculated Actlo.n Leakage .Rates for Varlous Head Conditions
CeU 48, White Mesa Mill
Blanding, Utah
Head Above Uner System C.Jculated Actfon lealc111e Rate
(feet) (pllanJ/Icte/dayJ
5 211.4 ----·-10 317.0 -15 369.9
20 422.7
25 475.6 ~-------30 528.4
~-------35 570.0 -------= 37 581.2
Appendix G
Stomzwater Best Management Practices Plan,
Revision 1.5: September 2012
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O.Box809
Blanding, Utah
September 2012
Prepared by:
Energy Fuels Resources (USA) Inc.
1050 17th Street, Suite 950
Denver, CO 80265
TABLE OF CONTENTS
Best Management Practices Plan
Revision 1.5: September 2012
1.0 INTRODUCTION/PURPOSE ................................................................................................................................ 2
2.0 SCOPE ................................................................................................................................................................... 3
3.0 RESPONSIBILIT¥ ................................................................................................................................................ 4
4.0 BEST MANAGEMENT PRACTICES .................................................................................................................. S
4.1 General Management Practices Applicable to All Areas ......................................................................... S
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: .............................................. 5
4.1.2 Keep Potential Pollutants from Contact with Precipitation .............................................................. 5
4.1.3 Keep Paved Areas from Becoming Pollutant Sources ...................................................................... 5
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area .................................................................................................................. 5
4.1.5 Recycle Fluids Whenever Possible: .................................................................................................. 5
4.2 Management Practices for Process and Laboratory Areas ....................................................................... 6
4.2.1 Clean Up Spills Properly .................................................................................................................. 6
4.2.2 Protect Materials Stored Outdoors .................................................................................................... 6
4.2.3 Management ..................................................................................................................................... 6
4.2.4 Materials Management ..................................................................................................................... 6
4.3 Management Practices for Maintenance Activities .................................................................................. 7
4.3.1 Keep a Clean Dry Shop .................................................................................................................... 7
4.3.2 Manage Vehicle Fluids ..................................................................................................................... 7
4.3.3 Use Controls During Paint Removal ................................................................................................ 7
4.3.4 Use Controls During Paint Application and Cleanup ....................................................................... 7
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment ............................................ 8
4.4.1 Wash Down Vehicles and Equipment in Proper Areas .................................................................... 8
4.4.2 Manage Stockpiles to Prevent Windbome Contamination ............................................................... 8
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources .................................................... 8
Figures
Figure 1: White Mesa Mill Site Layout ...................................................................................................................... 17
Figure2: White Mesa Mill Site Drainage Basins ........................................................................................................ 18
Figure 3: Energy Fuels Resources (USA) Inc.-White Mesa Mill Management Organization Chart ........................ 20
Figure 4: Energy Fuels Resources (USA) Inc. -Corporate Management Organizational Chart ............................... 22
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP ........................ 10
TABLE 2.0: REAGENT YARD LIST ....................................................................................................................... ll
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST 1 .......................................................................... 12
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1 ........................................................ 13
TABLE 5.0: EAGENT YARD/BULK CHEMICALS LIST 1 ................................................................................... 14
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST 1 ...................................................................... 15
Page 1
1.0 INTRODUCTION/PURPOSE
Best Management Practices Plan
Revision 1.5: September 2012
Energy Fuels Resources (USA) Inc. ("EFR") operates the White Mesa Uranium Mill ("the Mill)
in Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect
to water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to EFRon March 8,
2005. As a part of compliance with the Permit, EFR is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Executive Secretary of the Division of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
management practices to minimize or prevent spills of chemicals or hazardous materials, which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to storm water or surface water drainage
routes. Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements these practices in a good faith effort to minimize all sources of
pollution at the site.
Page 2
2.0 SCOPE
Best Management Practices Plan
Revision 1.5: September 2012
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC license
conditions. All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments. A site map of the Mill is provided in Figure I. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
wash down to the process sewers, and ultimately the tailings system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of storm water, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
EFR White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP"), and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs").
Page 3
3.0 RESPONSIDILITY
Best Management Practices Plan
Revision 1.5: September 2012
All Mill personnel are responsible for implementation of the practices in this BMPP. EFR White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The Mill Management Organization is presented in Figure 3. The EFR Corporate Management
Organization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table 1.
Page4
Best Management Practices Plan
Revision 1.5: September 2012
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
by product Materials License #UT1900479. Areas requiring maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be reported to site management and maintenance departments for necessary action to
repair damage or perform reconstruction in order for the control feature to perform as
intended. Status of maintenance or repairs will be documented during follow up
inspections and additional action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
PageS
Best Management Practices Plan
Revision 1.5: September 2012
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D.l O.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE") near the areas where they may be needed for spill response.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 6
Best Management Practices Plan
Revision 1.5: September 2012
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids .
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings area
Page 7
Best Management Practices Plan
Revision 1.5: September 2012
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and tile truck wash station).
• At the truck wash station, make sure the water collection and recycling system is working before
turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Wind borne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep surfaces moist but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
TABLES
Page 9
Personnel
Dan Hillsten
Wade Hancock
Scot Christensen
David E. Turk
Garrin Palmer
Personnel
Stephen P. Antony,
Harold R. Roberts
David C. Frydenlund
Jo Ann Tischler
TABLE 1
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Staff
Title Work Phone
Mill Manager 435-678-4105
Maintenance 435-678-4166
Superintendent
Mill Superintendent 435-678-2221
Manager, Environment, 435-678-4113
Health and Safety
Mill Environmental
Compliance
Coordinator 435-678-4115
Corporate Management Staff
Title Work Phone
President and Chief 303-974-2142
Operating Officer
Executive Vice 303-389-4160
President and Chief
Operating Officer
Sr. Vice President 303-389-4130
Regulatory Affairs and
General Counsel
Director; Compliance 303-389-4132
Home Phone/
Other Contact Number
Cell: 435-979-3041
435-678-2753
Cell: 435-979-0410
435-678-2015
435-678-7802
Cell: 435-459-9786
CeU: 435-459-9463
Home Phone/
OtJter Contact
Number
Cell: 303-378-8254
Cell: 303-902-2870
303-221-0098
Cell: 303-808-6648
Cell: 303-501-9226
Page 10
REAGEN'T ..
-
AMMONIUM
SULFATE(BULK)
AMMONIUM
SULFATE(BAGS)
ANHYDROUS AMMONIA
TRIDECYLALCOHOL
DIESEL FUEL
GRINDING BALLS
KEROSENE
POL OX
PROPANE
SALT (BAGS)
SALT (BULK)
SODA ASH (BAGS)
SODA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
TABLE 2
REAGENT YARD LIST
QIJANTI:rY NUMBER: eJF'
(~BS)-· ~sr®~GE
TANKS · ---~· ' .
54,000 2
26,000 -
107,920 2
45,430 ---
2
1
72,000 ---
1,344 1
2
10,360 ---
1
39,280 --
0 1
1
39,280 ---
84,100 1
1
101,128 1
1
1
0 1
4,801,440 1
1
1
1-.~ARACIT't -,_ ~'G~[(f>NS} .. . .
'
24,366
31,409
250
6,000
10,315
10,095
25,589
13,763
18,864
16,921
8,530
16,921
22,561
29,940
19,905
1,394,439
3,000
5,000
Page 11
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST 1
Chemical In Lab R~ Quantitv in Stock
Aluminum nitrate 2270 kg 1.8 kg
Ammonium bifluoride 45.4 kg 2.27 kg
Ammonium chloride 2270 kg 2.27 kg
Ammonium oxalate 2270 kg 6.8 kg
Ammonium thiocyanate 2270 kg 7.8 kg
Antimony potassium tatrate 45.4 kg 0.454
' n-8utyl acetate 2270 kg 4L
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.81 kg
Ferrous ammonium sulfate 454 kg 0.57
Potassium chromate 4.54 kg 0.114kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2270kg 1.4
Zinc acetate 454 kg 0.91 kg
Chemical. in Volatiles and RQ" Quantit)f in Stock
Flammables Lockers
fA.BCl
Chloroform 4.54 kg 8L
Formaldehyde 45.4 kg <1 L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ" Quantity in Stock
Chloroform 4.54 kg 55 gal
Hydrochloric acid 2,270 kg 58 gal
Nitrate acid 454 kg 5L
Phosphoric Acid 2,270 kg 10 L
Sulfuric acid 454 kg 25 L
Hydrofluoric acid 45.4 kg 1 L
Ammonium hydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above
regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act."
Page 12
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
CHEMICAL B.Q: " ·QUA.TYIN --. I _, sto . _ "<3'~
' .. .c'tJ Ml?aLitfD, -
Acetic Acid .. GlaciaJ 1.000 lbs 4gal
Ammonium Hydroxide 1,000 lbs 5L
Calcium Hypochlorite 10 lbs 2 kg (4.4 lbs)
Chlorine 10 lbs Olbs
Ferrous Sulfate Heptahydrate 1 000 lbs 5 kg (111bs)
Hydrochloric 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanganate 0.1 N 32 gal 5 kg (111bs}
Sodium Hypochlorite 5.5% 1001bs 2 kg (11 lbs) of 5.5%
solution
Silver Nitrate 1 lb Olbs
Trichloroethylene 1001b 2L
1. This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Materials in this list are stored in a locked storage
compound near the bulk storage tank area. The Mill also stores small
quantities of other materials that are not hazardous substances per
the above regulation.
2. Reportable Quantities are those identified in40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 13
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
REAGENT RQ' QUANTITY IN REAGENT
YARD
Sulfuric Acid 1,000 lbs 9,000,000 lbs
Hyperfloc 1 02 None 1,500 lbs
Ammonia -East Tank 1001bs Olbs
Ammonia-West Tank 1001bs 105,000 lbs
Kerosene 100 gal 500 gal
Salt (Bags) None 20,000 lbs
Soda Ash Dense (Bag) None 50,000 lbs
Polyox None 490 lbs
Tributyl phosphate None 9,450 lbs
Diesel 100 gal Approx. 3300 gal
Gasoline 100 gal Approx. 6000 gal
Alamine 336 drums None 8,250 gal
Salt( Bulk Solids) None 50,000 lbs
Salt(Bulk Solutions) None 9,000 gal
Caustic Soda I 1,000 lbs 16,000 lbs
Ammonium Sulfate None 150,000 lbs
Sodium Chlorate None 350,000 lbs
Alamine 310 Bulk None 0 lbs
lsodecanol None 2,420 gal
Vanadium Pentoxide3 10001bs 30,000 lbs
Yellowcake3 None <1 00,000 lbs
Ammonia Meta Vanadate 10001bs Olbs
Floc 655 21,000 lbs
Floc 712 1,250 lbs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building and/or Mill Yard
Page 14
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT BQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1 ,540 gallons
Transmission Oils 100 gal 110 gallons
Water Soluble Oils 100 gal 110 gallons
Xylene (mixed isomers) 100 gal 0 gallons
Toluene 1000 gal 0 gallons
Varsol Solvent 100 gal 0 gallons
(2% trimethyl benzene in petroleum
distillates)
1. This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 15
FIGURES
Page 16
Figure 1
White Mesa Mill
Mill Site Layout
Page 17
Figure 2
White Mesa Mill
Mill Site Drainage Basins
Page 18
I
I
00000
o o~o
D o 0oo
ALTERNATE
FEED
CIRCUIT •
DRY REAGENT
STORAGE
c:::l
REAGENT YARD ~
SUBSTATION
sx
BUILDING
•
..
OQwATER
TANK
Cl:1
GRIZZLY
0 OLD
DECONTAMINATION f:::::::JPAD
0 0 PROCESS WATER
0 0 •
VPL STORAGE 11 o· o·
•
oO
0 1
SODIUM
CHLORATE
D
0
SHOP
..
ORE PAD
SAMPLE PLANT
I
D
TOPSOIL
(,
'\J I t
r
a:
t ~ z :::> 0 lXI
iZ a: <C
0 ~ w 1-~ e: en w a:
f
I
-..::::::::=,
X
)(
100 50 100
SCALE IN FEET
Energy Fuels Resources . (USA) Inc.
. •.
rojocl. White Mesa Mill
SanJuan l!l! UT
MILL SITE
bAY OUT
FIGURE 1
~
CELL4B
DRAINAGE BASIN •p
44.67 AC.
PMF CONTAINED
WITHIN BASIN
1000 0 1000 ~
DRAINAGE BASI
42.14AC. 1
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
l "'
Energy Fuels Resources (USA) Inc.
05/1 eJOe f!M
06111/08 BM
1219108 DLS
ln/08 11M
'"'"~< 11 r.u I "'1dnor HRR
White Mesa Mill
;uue: Ul
MILL SITE
DRAINAGE BASINS
FIGURE 2
Qlle 200!5 l)(o.m<lo Oy
Figure 3
White Mesa Mill
Mill Management Organization Chart
Page 19
Sr. VP Regulatory
Affairs & General
•;.
~
1•~'\o
Figure3
Energy Fuels Resources (USA) Inc.
White Mesa Mill Management
Organizational Structure
""l",i-
President & CEO
Executive VP and Chief
Operating Officer
Mill Manager
'tl
-----------------------,---t-·-~-~-----·----~----,--•----------------r--~----------------
Mill
Radiation Safety
Officer
11 ~'
1
I
Mill
.. :
Mill Operations
Personnel ~ I ~
I
Figure 4
Wbite Mesa Mill
Energy Fuels Resources (USA) Inc.
Organizational Structure
Page 22
Figure 4
Energy Fuels Resources (USA) Inc.
Organizational Structure
~~
President & CEO
Sr. VP Regulatory
Affairs & General
Counsel
Director, Compliance
Executive VP and Chief
Operating Officer
;(, '" II ·~!El'~&::iJ'i4~t£)i)@t(;-•N· .. ~:. ...... ~,
Mill Manager Manager,
Environmental, Health,
and Safety
Appendix H
White Mesa Mill Discharge Minimization Technology (DMT) Monitoring Plan, 7/2012,
Revision: Denison-12.1
WHITE MESA MILL DISCHARGE MINIMIZATION
TECHNOLOGY (DMT) MONITORING PLAN
Revision 12.1
July 2012
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
White Mesa Mill-Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denisonl2.1
Page 2 of26
WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. INTRODUCTION .................................................................................................................. 3
1.1. Background ...................................................................................................................... 3
2. DAILY TAILINGS INSPECTIONS ...................................................................................... 4
2.1. Daily Inspection ............................................................................................................... 4
3. WEEKLY TAILINGS AND DMT INSPECTION ................................................................ 5
3 .1. Weekly Tailings Inspections ............................................................................................ 5
Northing .................................................................................................................................. 9
Easting ..................................................................................................................................... 9
3.2. Weekly Inspection of Solution Levels in Roberts Pond ................................................ 12
3.3. Weekly Feedstock Storage Area Inspections ................................................................. 12
4. ANNUAL EVALUATIONS ................................................................................................. 12
4.1. Freeboard Limits ............................................................................................................. 13
4.1.1. RobertsPond ........................................................................................................... 13
4.2. Annual Leak Detection Fluid Samples ........................................................................... 13
4.3. Annual Inspection of the Decontamination Pads ........................................................... 13
4.4. Annual Inspection of the Ammonium Sulfate Pad ......................................................... 14
5. OTHER INSPECTIONS ....................................................................................................... 14
6. REPORTING REQUIREMENTS ......................................................................................... 14
6.1. DMT Reports .................................................................................................................. 14
Attachment A
Attachment B
Attachment C
ATTACHMENTS
Forms
Feedstock Storage Area
Tables
N:\DMT Plan\DMT Plan 06.2012 Revision 12. I \DMT Plan July 2012 Rev 12.1 clean.doc
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
1. INTRODUCTION
7/12 Revision: Denisonl2.1
Page 3 of26
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. UT19004 79 (the "RML ") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the 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 develop the initial DMT Plan in
response to GWDP requirements. In developing the initial DMT Plan, Denison 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 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
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
N:\DMT Plan\DMT Plan 06.2012 Revision 12.1\DMT Plan July 2012 Rev 12.1 clean.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denisonl2.1
Page 4 of26
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 G WDP 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 LOS 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-1 to this DMT Plan regardless of the origin ofthe requirement.
The triggers for further action and the associated actions when evaluating Cells
1, 2, and 3, leak detection systems are discussed in the Tailings Management
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System procedure, Section 2.1 q).
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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) (Cell4A 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 Cell4B 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 Pennitmust
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKLY 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
Cell4A and Cell4B) 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-1 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 1-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 Cell4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table lA and lB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cel14A 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 re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface ofCell2. 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.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
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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 ofthe
Cell2 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 Cell2, 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 ofthe 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 Cell2 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 Cell2 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 Cell2;
( vii)If at any time the most recent average annual head in the Cell2 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 Cell3, Cell4A, and 4B are currently active, no pumping from the Cell3,
Cell4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell3, Cell4A, or Cell4B, a similar procedure will be developed for
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ensuring that average head elevations in the Cell3, Cell4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B
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 Celli and Roberts Pond, the
Reference Point is a wooden stake with a metal disk on it located on the southeast
comer 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 Cell4A and 4B. The elevation at the top
of this piece ofrebar (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 Celll/Roberts Pond Reference Point on the top ofthe 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, Cell4A, Cell4B, or
Roberts Pond, or the area of the beach in Cell4B 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
typically 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. Cell4A
The Assistant will walk down the slope in the northeast comer of Cell 4A and
place the Survey Rod at the liquid level.
II. Cell4B
The Assistant will walk down the slope in the southeast comer of Cell4B and
place the Survey Rod at the liquid level.
III. 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:
Northing Easting
Roberts Pond 323,041 2,579,697
Celli 322,196 2,579,277
Cell4A 320,300 2,579,360
Cell4B 320,690 2,576,200
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B.
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;
(i) The Assistant will hold the Survey Rod vertically with one end ofthe 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;
(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
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
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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 0.1 0 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 (RSO).
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 118 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
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 Roberts 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.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
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4.1. Freeboard Limits
4.1.1. Roberts Pond
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The freeboard limit for Roberts Pond is a liquid maximum elevation of5,624.0 feet above mean sea
level, as specified in the GWDP.
4.2. Annual Leak Detection Fluid Samples
Pursuant to Part I.E.10(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
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.
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4.4. Annual Inspection of the Ammonium Sulfate Pad
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During the second quarter of each year, the Ammonium Sulfate Pad will be inspected to ensure the
integrity of the 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 within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Annual Decontamination
Pad/Ammonium Sulfate Pad Inspection form. The in..c;pection frnd ings any repairs req uired an l
repairs completed shall be summarized in the 2nd Quarter DJVIT Monitoring Report due eptembcr l
of each calendar year. The first inspection of the Ammonium Sulfate Pad will be conducted during
the second quarter in the year following installation/completion of the pad.
5. 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.
6. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
6.1. DMT Reports
Quarterly reports ofDMT 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 l.F.2 of the
GWDP relating to the inspections described in Section 3.1 (a) (Leak Detection
Systems Monitoring), Section 3.1 (b) (Slimes Drain Water Level Monitoring), 3.1
(c) (Tailings Wastewater Pool Elevation Monitoring), 3.l(d) (Tailings
Wastewater Pool and Beach Area Elevation Monitoring), 3.2 (Weekly Inspection
of Solution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area
Inspections);
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;
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c) With respect to the annual inspection of the New Decontarrlination Pad described
in Section 6.5(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 6.5(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; and
e) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell2 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.
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White Mesa Mill-Discharge Minimization Technology Monitoring Plan
ATTACHMENT A
FORMS
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Attachment A-1
DAILY INSPECTION DATA
Any Item not "OK" must be documented. A check mark= OK, X= Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell2 Cell3
Inspector: _______ _
Date;, ________ _
Accompanied by· .. ____ _
Time: ________ _
Cei14A Cei14B
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. Gal. Gal. Gal. Gal.
pumped pumped .pumped pumped pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-1)
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ATTACHMENT A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: Inspectors: -------------
1. Pond and Beach elevations Cell 1: (a) Pond Solution Elevation
(msl, ft)
(b) FML Bottom Elevation 5597. __ _
(c) Depth of Water above FML ((a)-(b)) _____ _
Cell4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b)) _____ _
Cell 4B: (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)) _____ _
2. Leak Detection Systems
Observation:
New Decon Pad, New Decon Pad, New Decon Pad
Porta11 Portal2 Portal3
Is LOS (Portal) __ wet __ dry __ wet __ dry __ wet __ dry
wet or dry?
If wet, Record Ft to Ftto Ftto
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
* Does Level exceed 12 mches above the lowest pomt on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell4A and 5558.50 for Cell4B)? no __ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete): --------------------
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ATTACHMENT A-3
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ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through ____ Date oflnspection: _______ _
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: ___ _
comments: __________________________________ _
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no: __ _
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: ------------------------------------------
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White Mesa Mill-Discharge Minimization Technology Monitoring Plan
Other comments:
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White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-4
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ANNUAL DECONTAMINATION/AMMONIUM SULFATE PAD INSPECTION
Date oflnspection: _______ _
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:
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White Mesa Mill-Discharge Minimization Technology Monitoring Plan
Ammonium Sulfate Pad:
7/12 Revision: Denison 12.1
Page 22 of26
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:
Note: For the annual inspection of the Existing, New Decontamination Pads and the Ammonium
Sulfate Pad, 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
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White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENTB
FEEDSTOCK STORAGE AREA
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White Mesa Mill-Discharge Minimization Technology Monitoring Plan
N
l
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White Mesa Mill-Discharge Minimization Technology Monitoring Plan
ATTACHMENT C
TABLES
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White Mesa Mill -Discharge Minimization Technology Monitoring Plan 7112 Revision: Denisonl2.1
Page 26 of26
Table 1A
Calculated Action leakage Rates
for Various head Conditions
Cell4A White mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons I acre I day)
Table lB
Calculated Action leakage Rates
for Various head Conditions
Cell4B 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 I acre I 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
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Appendix I
White Mesa Mill Tailings Management System, 7/2012,
Revision: Denison 12.1
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
Revision 2.1
July 2012
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
7/I2 Revision: Denison 2.1
Page 2 of37
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
TABLE OF CONTENTS
1. INTRODUCTION .................................................................................................................. 3
1.1. Background ...................................................................................................................... 3
2. DAILY TAILINGS INSPECTIONS ...................................................................................... 4
2.1. Daily Comprehensive Tailings Inspection ....................................................................... 4
2.2. Daily Operations Inspection ............................................................................................. 7
2.3. Daily Operations Patrol .................................................................................................... 7
2.4. Training ............................................................................................................................ 7
2.5. Tailings Emergencies ......................................................................................................... 7
3. WEEKLY TAILINGS AND DMT INSPECTION ................................................................ 8
3.1. Weekly Tailings Inspections ............................................................................................ 8
4. MONTHLY TAILINGS INSPECTION ............................................................................... 11
5. QUARTERLY TAILINGS INSPECTION ........................................................................... 12
6. ANNUAL EVALUATIONS ................................................................................................. 13
6.1. Annual Technical Evaluation ......................................................................................... 13
6.2. Movement Monitors ........................................................................................................ 14
6.3. Freeboard Limits ............................................................... -............................................. L4
6.3.1. Ce111 ....................................................................................................................... 15
6.3.2. Ce112 ....................................................................................................................... 15
6.3.3. Cell 3 .................................................................................................. , .................... 15
6.3.4. Cel14A .................................................................................................................... 15
6.3.5. Cel14B .................................................................................................................... 15
7. OTHER INSPECT! ONS ........................................................................................................ 18
8. REPORTING REQUIREMENTS ........................................................................................ 18
8.1. Monthly Tailings Reports .............................................................................................. 18
Appendix A
Appendix B
Appendix C
Appendix D
APPENDICES
Forms
Tailings Inspector Training
Certification Form
Example Freeboard Calculations for Cell 4B
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White Mesa Mill -Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
1. INTRODUCTION
7/12 Revision: Denison 2.1
Page 3 of37
This Tailings Management System procedure for the White Mesa Mill (the "Mill") provides
procedures for monitoring the tailings cell systems as required under State of Utah Radioactive
Materials License No. UT1900479 (the "RML"). The procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
Mill's Groundwater Discharge Permit ("GWDP") Number 370004, are presented in the DMT
Monitoring Plan ("DMT Plan"), which is a separate Plan.
This Tailings Management System procedure and the DMT Plan 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 Tailings Management System is published and maintained in the Mill's Environmental
Protection Manual while the DMT Plan is issued as a stand-alone document.
1.1. Background
This 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 develop the initial DMT Plan in
response to GWDP requirements. In developing the initial DMT Plan, Denison 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 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. The 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 DMT Plan that flow from the RML and
not from the GWDP have been separated from the DMT Plan and have been returned to their
original status as this 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
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 4 of37
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 I, 2, and 3 Leak Detection Systems ("LDSs") have
been included in this DMT Plan. The inclusion of this RML requirement is to address the DRC
request for uniformity in monitoring and reporting requirements for Cells I, 2, and 3 and to address
anticipated GWDP modifications regarding the LDS monitoring in Cells I, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.I. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the evaporation cell (Celli) and the
four tailings cells (Cells 2, 3, 4A, and 4B) will be inspected. Observations will be made of the
current condition of each cell, noting any corrective action that needs to be taken.
The Radiation Safety Officer (RSO) or his designee is responsible for performing the daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform the daily tailings inspection.
Observations made as required by this Tailings Management System by the inspector will be
recorded on the Daily Inspection Data form (a copy of which is included in Appendix A to this
Tailings Management System procedure). The daily leak detection check for Cells I, 2, and 3 will be
recorded on the Daily Inspection Data form included as Attachment A-I of the DMT Plan. The
Daily Inspection Data form included with this Tailings Management System procedure contains an
inspection checklist, which includes a tailings cells map, and spaces to record observations,
especially those of immediate concern and those requiring corrective action. 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. Additional inspection
items are required under the DMT Plan, which requires that the daily inspection form requirements
in Attachment A to the DMT Plan also be completed.
Areas to be inspected include the following: Celli, 2, 3, 4A and 4B, the liners of Cells I, 2, and 3,
Dikes 4A-S, 4A-E, and 4B-S, wind movement of tailings, effectiveness of dust minimization
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 5 of37
methods, spray evaporation, Cell2 spillway, Cell3 spillway, Cell4A spillway, Cell3, Cell4A and
4B liquid pools and associated liquid return equipment, and the Cell 1, 2, and 3 leak detection
systems.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from
CCD to the active tailings cell; SX raffinate lines that can discharge into Cell 1,
Cell4A or Cell4B; the pond return line from the tailings area to the Mill; and,
lines transporting pond solutions from one cell to another.
b) Celli.
c) Cell2.
d) Cell 3.
e) Cell4A.
f) Cell4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S.
h) The Cell2 spillway, Cell3 spillway, Cell4A spillway, Cell3, Cell4A and Cell
4B liquid pools and associated liquid return equipment.
i) Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
j) Spray evaporation pumps and lines.
k) Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 6 of37
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
I) Observation of flow and operational status of the dust control/spray evaporation
system(s).
m) Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
4A, and 4B.
n) Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
o) An estimate of flow for active tailings slurry and SX line(s).
p) An estimate of flow in the solution return line(s).
q) Daily measurements in the leak detection system sumps of the tailings Cells 1, 2,
and 3 will be made when warranted by changes in the solution level of the
respective leak detection system. Measurement of fluids in the Cells 4A and 4B
leak detection system and recording of the daily measurements of the Cells 1, 2,
and 3 leak detection systems sumps are discussed in the DMT Plan.
The trigger for further action when evaluating the measurements in the Cells 1, 2,
and 3 leak detection systems is a gain of more than 12 inches in 24 hours. If
observations of trigger levels of fluids are made, the Mill Manager should be
notified immediately and the leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter and
totalizer is recording on Cells 1, 2, and 3, a notation of the date and the time will
be recorded on the Daily Inspection Data form. This data will be used in
accordance with License Condition 11.3 .B through 11.3 .E of the Mill's
Radioactive Materials License, to determine whether or not the flow rate into the
leak detection system is in excess of the License Conditions.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed following notification to the Executive
Secretary.
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
these items cannot be performed.
2.2. Daily Operations Inspection
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Page 7 of37
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection ofthe tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the RSO and/or Mill
management in the event that during their inspection they discover that an abnormal condition or
tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
Inspectors will notify the RSO and/or Mill management immediately if, during their inspection, they
discover that an abnormal condition exists or an event has occurred that could cause a tailings
emergency. Until relieved by the Environmental or Technician or RSO, inspectors will have the
. authority to direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the RSO, one of whom will notify Corporate Management. If
dam failure occurs, notify your supervisor and the Mill Manager immediately. The Mill Manager
will then notify Corporate Management, MSHA (303-231-5465), and the State of Utah, Division of
Dam Safety (801-538-7200).
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
7/12 Revision: Denison 2.1
Page 8 of37
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system 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 Cell 1, 2, and Cell 3 the leak detection system is
measured by use of a dual-probe system that senses the presence of solutions in
the LDS system (comparable to the systems in Cells 4A and 4B) and indicates
the presence of solution with a warning light. The water levels are measured to
the nearest 0.10 inch. The water level data in Cells 1, 2, and 3 is recorded on the
Daily Tailings Inspection Form included as Attachment A-1 of the DMT Plan.
If sufficient fluid is present in the leak detection system of Cells 1, 2, and 3, the
fluid shall be pumped from the LDS, to the extent reasonably possible, and the
volume of fluid recovered will be recorded. 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 flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed
time since fluid was last pumped or increases in the LDS fluid levels were
recorded, whichever is the more recent. This calculation shall be documented as
part of the weekly inspection.
For Cells 1 and 3, upon the initial pumping of fluid from an LDS, a fluid sample
shall be collected and analyzed in accordance with paragraph 11.3 C. of the
RML. The LDS requirements for Cells 4A and 4B are discussed in the DMT
Plan.
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 re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface ofCell2. As a result of the re-grading of
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page 9 of37
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.
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
Cell2 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 3 8.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell2 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)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. The extension ofthe Cell 2 slimes drain access pipe
did not require any changes to the measurement procedure. The surveyed measuring
point on the extended pipe is used as required. The elevation of the measuring point
is 5618.73 fmsl. The head measurements are calculated in the same manner, using
the same procedures as those used prior to the extension of the Cell 2 slimes drain
access pipe; however, the total depth to the bottom of the pipe is now 37.97 feet as
noted on the corrected form in Attachment A.
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 results will be recorded as depth-in-pipe measurements on the Weekly Tailings
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page 10 of37
Inspection Form. The quarterly recovery test specified in the GWDP is discussed in
the DMT Plan.
It is important to note that the extension of the Cell 2 slimes access pipe has not
changed the method of calculation of the pre-and post-pump head calculations, only
the constant (Cell 2 slimes drain access pipe height) used in the calculation has
changed. The head is calculated by subtracting the depth to liquid from 37.97 feet
rather than from the previous measurement of 38 feet. The weekly Tailings
Inspection form included in Attachment A has been changed to reflect the extension
height;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii) Because Cell3, Cell4A, and 4B are currently active, no pumping from the Cell3,
Cell4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell3, Cell4A, or Cell4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell3, Cell4A, and 4B slimes drains
are kept as low as reasonably achievable, and that the Cell3, Cell4A, and Cell4B
slimes drains are inspected and the results reported in accordance with the
requirements of the permit.
c) Wind Movement ofTailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
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. Weekly and annual inspection requirements for the
New Decontamination Pad are discussed in the DMT Plan.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill's maintenance shop and the ore feeding grizzly.
A. The Existing Decontamination Pad will be inspected on a weekly basis.
Any soil and debris will be removed from the Existing Decontamination
Pad immediately prior to inspection of the concrete wash pad for
cracking Observations will be made of the current condition of the
Existing Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad. Any abnormalities relating to the pad and
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 11 of37
any damage or cracks on 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.
e) Summary
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 Inspection form is provided in Appendix A of this
Tailings Management System procedure. A similar form containing DMT inspection requirements
is provided as Attachment A ofthe DMT Plan.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the RSO or his designee from the Radiation
Safety Department and recorded on the Monthly Inspection Data form, an example of which is
contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days since the
last monthly tailings inspection and can be conducted concurrently with the quarterly tailings
inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be visually inspected at key
locations to determine pipe wear. The critical points of the pipe include bends, slope
changes, valves, and junctions, which are critical to dike stability. These locations to
be monitored will be determined by the Radiation Safety Officer or his designee
from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be
checked for stability and signs of distress.
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
d) Overspray Dust Minimization
7112 Revision: Denison 2.1
Page 12 of37
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the RSO or his designee from the Radiation Safety
Department, having the training specified in Section 2.4 above, once per calendar quarter. A
quarterly inspection should be performed no sooner than 45 days since the previous quarterly
inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3 .I
c) Construction Review
7/12 Revision: Denison 2.1
Page 13 of37
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.
d) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page 14 of37
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
RSO regarding activities around the tailings area for the past year. During the annual inspection,
photographs of the tailings area will be taken. The training of individuals will be reviewed as a part
ofthe Annual Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Executive Secretary and to the Assistant State Engineer, Utah Division of Water Rights at the
address specified below.
Assistant State Engineer
Utah Division of Water Rights
1594 West North Temple, Suite 220
P.O. Box 146300
Salt Lake City, Utah 84114-6300
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 4A-
E, 4A-S, and 4B-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage
areas, was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up
factor of 0.90 feet.
The flood volume from the PMP event over the Cell2 and Cell3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123 .4 acre-feet of water.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 15 of37
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of0.77 feet.
The flood volume from the PMP event over the Cell 4B area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), times the PMP of 10
inches, with a wave run up factor of 0. 77 feet.
The total pool surface area in Cell 1 is 52.9 acres, in Cell4A is 40 acres, and in Cell4B is 40
acres. The top ofthe flexible membrane liner ("FML") for Cell1 is 5,618.2 FMSL, for Cell4A
is 5,598.5 FMSL and for Cell4B is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. Cell 1
The freeboard limit for Cell1 will be set at 5,615.4 FMSL. This will allow Cell1 to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 1 03 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of0.90 feet equals 2.85 feet. The
freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive
Materials License condition 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2
The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell2 will be attributed to Cell4A (and/or any future tailings cells).
6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell3 is close to being filled with solids, and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future
tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell4A is inapplicable since all ofthe PMP flood volume associated with
Cell4A will be attributed to Cell4B. A spillway has been added to Cell4A to allow overflow into
Cell4B.
6.3.5. Cell4B
The freeboard limit for Cell4B will be set assuming that the total PMP volume for Cells 2, 3, 4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell4B is as follows:
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
(a) When the Pool Surface Area is 40 Acres
7/12 Revision: Denison 2.1
Page 16 of37
When the pool surface area in Cell4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell4B will be 5,594.6FMSL, which is 5. 7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Cell 4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres
Wave run up factor
Total required freeboard
38.1 acre-feet
159.4 acre-feet
197.5 acre-feet
4.9 feet
0.77 feet
5.7 feet
(all values in the above calculation have been rounded to the nearest one-tenth of afoot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation ofthe beach area in Cell4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevation of the beach area in Cell 4B first exceeds 5,594 FMSL, then the
freeboard limit for the remainder of the ensuing year (period t=O) (until the next November 1) will
be calculated when that elevation is first exceeded (the "Initial Calculation Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
4B prior to the Initial Calculation Date ("To") will be determined;
ii) The expected number of dry tons to be deposited into Cell4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("L:lo*"), will be determined;
iii) L:l0* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4B will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directly proportional to the reduction in the available space in Cell4B
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 17 of37
for solids. That is, the reduced pool surface area for period t=O ("RP Ao"), after the
reduction, will be calculated to be:
(1-(~0 * x 1.5) I (2,094,000-To)) x 40 acres= RPAo
vii) The required freeboard for Cell 4B for the remainder of the period t=O can be
calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the
quotient of 197.5 acre feet divided by the RPA0. The freeboard limit for Cell4B for
the remainder of period t=O would then be the elevation ofthe FML for Cell4B of
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculation is set out in Appendix F.
(d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5,594 FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARP At-I)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-1).
The RP At-I used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARP At-I is merely the RP A that would have
been used for period t-1 had the actual tonnages for year t-1 been known at the outset
of period t-1 and had the RP A been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARP At-I can be calculated using the following formula:
(1 -~t-1 I (2,094,000-Tt-I)) x ARP At-2 = ARP At-!
Where:
• ~t-I is the actual number of dry tons of tailings solids deposited in Cell4B
during period t-1;
• T1_1 is the actual number of dry tons of tailings solids historically deposited in
Cell4B prior to the beginning of period t-1; and
• ARP At-2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARP At-2 is 40 acres;
ii) Once the ARP At-I for the previous period (period t -1) has been calculated, the RP A
for the subject period (period t) can be calculated as follows:
(1-(~t* x 1.5) I (2,094,000-Tt)) x ARPAt-1 = RPAt
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Where:
7112 Revision: Denison 2.1
Page 18 of37
• ~~* is the expected number of dry tons of tailings to be deposited into Cell4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• T1 is the actual number of dry tons of tailings solids historically deposited in
Cell4B prior to the beginning of period t; and
• ARP A1_1 is the Adjusted Reduced Pool Area for period t-1, which is the pool
urface area for the previous period (period .-1) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for peri d t can be cal culated in feet to be the wave run up
factor for Cell 4B of 0.77 feet plns the qu tient f J 97.5 acre feet di ided by the
RP A1• The freeboard limit for Cell 4B for period t would then be th elev~tion of the
FML for Cell4B of5594.0 FMSL less tbis required freeboard amount rounded to the
nearest one-tenth of a foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting freeboard limit will persist until the next Annual Calculation
Date for period t+ 1.
An example of this calculation is set out in Appendix D.
(e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New Tailings Cell
When a spillway is added between Cell4B and a new tailings cell then, if an approved freeboard
limit calculation method for the new cell is set to cover the entire PMP event for Cells 2, 3, 4A, 4B
and the new tailings cell, the freeboard limit for Cell4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3, 4, 5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily inspection forms included as Appendix A to this Tailings Management
System procedure, the inspection forms included as Attachment A of the DMT Plan and the
Operating Foreman 's Daily Inspection form the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the RSO, the report shall be submitted to the RSO for
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .I
7/12 Revision: Denison 2.1
Page 19 of37
review. The Mill Manager will review the report as well before the report is filed in the Mill Central
File. The report will contain a summary of observations of concern noted on the daily and weekly
tailings inspections. Corrective measures taken during the month will be documented along with the
observations where appropriate. All daily and weekly tailings inspection forms will be attached to
the report. A monthly inspection form will also be attached. Quarterly inspection forms will
accompany the report when applicable. The report will be signed and dated by the preparer in
addition to the Radiation Safety Officer and the Mill Manager.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A
FORMS
7/12 Revision: Denison 2.1
Page 20 of37
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page 21 of37
APPENDIX A-1
DAILY INSPECTION DATA
Inspector: _______ _
Date; ----------Accompanied by:. ___ _
Time: ---------
Any Item not "OK" must be documented. A check mark= OK, X= Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM I
Tnsp_ecrion Items Conditions ofPotential Concern Celli Cell2 Cell3
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks. Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Location or Orientation
II. OPERATIONAL SYSTEMS and INTERIOR of CELLS
Inspection Items Conditions ofPotential Concern Celli Cell2 Cell3
N s E w
Interior Cell Walls
Liner Observable Liner Damage
Water Level Greater Than Operating Level, Large
Change Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner -
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Cell4A Cell4B
Celi4A Cell4B
N S E w NS E w
--
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
III. DIKES AND EMBANKMENTS
InsQection Items Conditions of Potential
Concern
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas,
Areas of Seepage Outbreak
Crest Cracks, Subsidence, Severe
Erosion
IV. FLOWRATES
Slurrv Line(s)
GPM
Dike 1-1
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
J
7/12 Revision: Denison 2.1
Page 22 of37
Dike 1-Dike 2 Dike3
1A
No No No
visible visible visible
exterior exterior exterior
slope or slope or slope or
dike to dike to dike to
inspect inspect inspect
No No No
visible visible visible
exterior exterior exterior
slope or slope or slope or
dike to dike to dike to
inspect inspect inspect
Dike
4A-S
Pond Return S-X Tails
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Obsetved Entire Discharge Line
VI. DUST CONTROL
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
Yes ------Yes ------
Cell2 Cell3
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Dike Dike
4A-E 48-S
~-
Sorav Svstem
------'No
No _____ __::
Cell4A Cell4B
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7112 Revision: Denison 2.1
Page 23 of37
I General Meteorological conditions: I I I I I
Vll. DAILY LEAK DETECTION CHECK
Daily Leak Detection Checks are recorded on the Daily Inspection Data form included
as Attachment A-1 of the DMT Plan
VITI OBSERVATIONS OF POTENTIAL CONCERN
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Action Required
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page24 of37
~~ :!. ::.: --·
f i --~----. ~' ' ~-~
a (~ / r ~ I " ,---.,~ . . ~ !' '~ . . F I , r i ·-·~:-, ~ ~ ~ I ~ I ·---,~ ~~ • ·' n n .. . 0 ' 0 =-!a m · rn 1 · , ill o·
r-. I ITI '§ = ,_ lj F t"' ::a -. --/ ~ I "' :z g -8 ""' o -.. -·-,, _o , 1
0
If o ill-. g _, ' . . -0
""' ITI · } c.> , 1T1 r.' 1 _.. -" r-. . b · r-~ -r-t; ;;,, r-' I i5 .if ~ t!5
. I " "" . ~ I I ' [ ~ ~ ·---.
4:(-t-o-..
f (
I ~
F
I "--, /L ---= -~ m -
iTI
.,.,....._.._., -------2!
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White Mesa Mill -Standard Operating Procedures 12/12 Revision: Denison 2.2
Page 25 of37 Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A-2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: _______ _ fuspectors: -------------
1. Slimes Drain Liquid Levels Cell 2 Pump functioning properly ___ _
------~Depth to Liquid pre-pump
_______ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37.97' -Depth to Liquid Pre-
pump= __ _
Post-pump head is 37.97' -Depth to Liquid Post-
pump= __ _
2. Existing Decontamination Pad (concrete) ___________________ _
3. Tailings Area fuspection (Note dispersal of blowing tailings):
4. Control Methods Implemented:.~---------------------
5. Remarks: ________________________________ _
6. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3 .I
7/12 Revision : Denison 2.1
Page 26 of37
APPENDIX A-3
MONTmY INSPECTION DATA
Inspector: __________________________ __
Date: -------------------------------
1. Slurry Pipeline:
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of
Flow
Diversion Berm:
Stability Issues
Signs ofDistress
Comments:
Diversion Ditch 1
---~yes __ no
---~yes __ no
---~yes __ no
____yes __ no
---~yes __ n
0
---~yes __ n
0
Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
____yes _____ no ____yes __ no
____yes __ no ____yes __ no
____yes __ no ____yes __ no
____yes __ no ____yes __ no
------------------------------------------------------------------------
3. Summary of Activities Around Sedimentation Pond: -------------------
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: __ _____, es __ ~no
7112 Revision: Denison 2.1
Page 27 of37
Overspray carried more than 50 feet from the cell: __yes no
If "yes", was system immediately shut off? __yes __ no
Comments: ------------------------------------------------------------------
5. Remarks: ______________________________________________________________ __
6. Settlement Monitors
Cell2 Wl: Cel12W3-S: Cell3-1N: ----------Cell2 W2: Cel12El-N: ____ _ Cell3-1C: ____ _
Cell2 W3: Cel12El-1S: _____ _ Cell3-1S: ____ _
Cell2 W4: Cell2El-2S: ____ _ Cell3-2N: ____ _
Cell 2W7-C: _______ _ Cell2 East: Cell2W5-N: --------Cell2 W7N: -----------Cell2 W7S: -----------Cel12 W6N: ____ _
Cell 2 W6C: ______ _ Cell 2 W6S: ____ _ Cell 2 W4N: ____ _
Cell 4A-Toe: ____ _ Cell2 W4S: ____ _ Cell 2 WSC: ____ _
Cell 3-2C: ____ _ Cell3-2S: Cel12 WSS:
Cel13-3S: _____ _ Cell 3-3C; _____ _ Cell3-3N: ------Cell3-4N: -------Cell3-6N: ------Cell3-7S: ____ _
Cell 3-7C: _____ _ Cell3-7N: _____ _ Cell3-8S: ____ _
Cell 3-SC: _____ _ Cell 3-SN: ____ _
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections:-----------------------
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White Mesa Mill -Standard Operating Procedures
Book II : Environmental Protection Manual, Section 3 .I
7/12 Revision: Denison 2. I
Page 28 of37
APPENDIX A-4
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector: __________________________ __
Date: __________________________ __
1. Embankment Inspection:
2. Operations/Maintenance Review: ------------------------------
3. Construction Activities: ------------------------------------------
4. Estimated Areas:
Cell3 Cell4A Cell4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated 2ercent of cover area
Comments: ------------------
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXB
TAILINGS INSPECTOR TRAINING
7/12 Revision: Denison 2.1
Page 29 of37
This document provides the training necessary for qualifying management-designated individuals
for conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections.
Tailings inspection forms will be included in the monthly tailings inspection reports, which
summarize the conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring
no action) or that conditions of potential concern exist (requiring action). A "check" mark indicates
no action required. If conditions of potential concern exist the inspector should mark an "X" in the
area the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division ofDam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A of this Tailings Management System
procedure. A similar form containing DMT inspection requirements is provided as Attachment A of
the DMT Plan. The inspection form contained in this Tailings Management System procedure is
summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page 30 of37
are to be monitored for leaks, and loose connections. The pipeline supports are to be
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks,
severe erosion or cavities are also items that require investigation and notation on daily
forms. Exposed liner or absence of cover from erosion are potential items of concern for
ponds and covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 4B solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It
is important to cover exposed liner immediately as exposure to sunlight will cause
degradation of the PVC liner. Small areas of exposed liner should be covered by hand.
Large sections of exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these
conditions have been noted to the Radiation Safety Officer, a work order will be written by
the Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
3. Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 4A-S, 4A-E, and 4B-S, , should be inspected
closely for mice holes and more importantly for prairie dog holes, as the prairie dogs are
likely to burrow in deep, possibly to the liner. If any of these conditions exist, the inspection
report should be marked accordingly.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Flow Rates:
7112 Revision: Denison 2.1
Page 31 of37
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2, 3, 4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by Environmental, Health and Safety personnel as close to 8:00
a.m. as possible. All snow or ice should be melted before a reading is taken.
7. Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8. Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
N:\Tailings Management System Procedure\ Tailings Management System-June 2012\Tailings Management System Rev 2.1 June 2012 clean. doc
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
7/12 Revision: Denison 2.1
Page 32 of37
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit on Cell4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell4A and 4B dike) is 15 mph. These limits should not
be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation ofWildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
11. Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .I
7/12 Revision: Denison 2.1
Page 33 of37
Form, Appendix C. This form should be signed and dated only after a thorough review ofthe
tailings information previously presented. The form will then be signed by the RSO and
filed.
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXC
CERTIFICATION FORM
Date: --------------------------
Name: -------------------------
7/12 Revision: Denison 2.1
Page 34 of37
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System Supervisor
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White Mesa Mill -Standard Operating Procedures
Book ll: Environmental Protection Manual, Section 3. I
7112 Revision: Denison 2.1
Page 35 of37
Assumptions and Factors:
APPENDIXD
Example of Freeboard Calculations
For Ceii4B
o Total PMP volume to be stored in Cell4B-159.4 acre feet
o Wave runup factor for Cell4B-0.77 feet
o Total capacity ofCell4B-2,094,000 dry tons
o Elevation ofFML ofCe114B-5,600.35 FMSL
o Maximum pool surface area of Cell 4B-40 acres
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL -1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL-March 1, 2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Tailings Actual Tailings Solids
Tailings Solids Solids Disposition into Disposition into Cell 4B
Disposition into Cell 4B at the determined at end of
Cell4B beginning of the the period (dry tons)*
Determined at period, multiplied by
the beginning of 150% Safety Factor
the period (dry (dry tons)
tons)*
March 1, 2012 to 150,000 225,000 225,000
November L 2012
November 1, 2012 to 300,000 450,000 275,000
November t 2013
November 1, 2013 to 200,000 300,000 250,000
November 1, 2014
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only.
Based on these assumptions and factors, the freeboard limits for Cell4B would be calculated
as follows:
1. Prior to March 1, 2012
Prior to March 1, 2012, the maximum elevation of the beach area in Cel14B is less than or
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2. March L 2012 to November 1. 2012
The pool surface area would be reduced to the following amount
7/12 Revision: Denison 2.1
Page 36 of37
(1 -225,000 I (2,094,000-1 ,000,000)) x 40 acres= 31.77 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave run up factor for Cell4B of0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell4B would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1. 2012 'lo November 1. 2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor)
equaled actual tonnages for the period. Since the actual tonnage of225,000 dry tons was the
same as the modeled tonnage of225,000 dry tons, the recalculated pool surface area is the
same as the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1 -450,000 I (2,094,000-1,000,000 -225,000)) x 31.77 acres= 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided
by 15.32 acres equals 12.89 feet. When the wave run up factor for Cell4B of0.77 feet is
added to this, the total freeboard required is 13.66 feet. This means that the freeboard limit
for Cell4B would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus
13.66 feet, rounded to the nearest one-tenth of a foot). This calculation would be performed
at November 1, 2012, and this freeboard limit would persist until November 1, 2013.
4. November 1, 2013 to November 1, 2014
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor)
equaled actual tonnages for the period. Since modeled tonnages exceeded actual tonnages,
the pool area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(1 -275,000 I (2,094,000-1,000,000-225,000) x 31.77 acres= 21.72 acres.
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White Mesa Mill -Standard Operating Procedures
Book ll: Environmental Protection Manual, Section 3 .l
7112 Revision: Denison 2.1
Page 37 of37
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1, 2013.
Then, calculate the modeled pool surface area to be used for the period:
(1-300,000 I (2,094,000 -1,000,000-225,000-275,000)) x 21.72 acres= 10.75 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided
by 10.75 acres equals 18.37 feet. When the wave run up factor for Cell4B of0.77 feet is
added to this, the total freeboard required is 19.14 feet. This means that the freeboard limit
for Cell4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus
18.4 feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2013, and this freeboard limit would persist until November 1, 2014.
N :\Tailings Management System Procedure\Tailings Management System-June 2012\Tailings Management System Rev 2.1 June 2012 clean.doc
Appendix J
Cell2 Slimes Drain Calculations and Figure 2009-2013
n tD --N
(,/) --· 3 1 Vl
tD ro .....
"' ;;:;·
Vl c N ..,
QJ -· ::::J
I
N 0 0 U) .. .--
N :;-
0 ro QJ ..... ~ 0 VI ro .. ..... ;;:;·
N Vl N
0
~
~ ..
N 0
~ N ..
20
N 0
~ w
N .j:>.
0 0
N N 0 0
Feet Below Top of Standpipe
N 0
0 0
1-' 00
0 0
1-' 0"1
0 0
1-' .j:>.
0 0 I I I •n ;J 11/30/2009
3/30/2009
5/30/2009
7/30/2009
9/30/2009
11/30/2009
1/31/2010
-3/31/2010
-5/31/2010
7/31/2010
9/30/2010
11/30/2010
1/31/2011
3/31/2011
5/31/2011
7/31/2011
9/30/2011
-11/30/2011
-1/31/2012
3/31/2012
5/31/2012
7/31/2012
9/30/2012
11/30/2012
-1/31/2013
-3/31/2013
5/31/2013
-7/31/2013
9/30/2013
Table J-1
Cell2 Slimes Drain Recovery Head and SDRE Values from 2009-
2013
2013 Test Closing Elevation of Reported SDRE Values Measurement Point Date (fmsl)** Level (feet) (Reported as fmsl)
3/25/2013 5618.73 21.85 5596.88
6/24/2013 5618.73 22.16 5596.57
9/23/2013 5618.73 22.25 5596.48
11119/2013 5618.73 22.35 5596.38
IE2ol3* 67158.93
N2o13* 12
2012 Test Closing Elevation of Reported SDRE Values Measurement Point Date (fmsl) Level (feet) (Reported as fmsl)
3112/2012 5618.73 20.90 5597.83
5/29/2012 5618.73 21.10 5597.63
9/27/2012 5618.73 21.84 5596.89
12117/2012 5618.73 21.84 5596.89
IE2012* 67167 .72
N2o12* 12
2011 Test Closing Elevation of Reported SDRE Values Measurement Point Date (fmsl) Level (feet) (Reported as fmsl)
112112011 5611.76 13.15 5598.61
2/28/2011 5611.76 10.42 5601.34
3118/2011 5611.76 11.31 5600.45
4/25/2011 5611.76 11.57 5600.19
5/20/2011 5611.76 13.17 5598.59
6/23/2011 5611.76 12.18 5599.58
7/19/2011*** 5611.76 12.59 5599.17
12119/2011 *** 5611.76 12.86 5598.90
IE2o11 * 67192.97
N2ou* 12
Table J-1
Cell 2 Slimes Drain Recovery Head and SDRE Values from 2009-
2013
2010 Test Closing Elevation of Reported SDRE Values Measurement Point Date (fmsl) Level (feet) (Reported as fmsl)
1115/2010 5611.76 13.96 5597.80
2/2112010 5611.76 12.50 5599.26
3/15/2010 5611.76 11.04 5600.72
4112/2010 5611.76 10.40 5601.36
5/19/2010 5611.76 10.43 5601.33
6/30/2010 5611.76 10.13 5601.63
8/2/2010 5611.76 10.74 5601.02
911/2010 5611.76 10.65 5601.11
9/24/2010 5611.76 11.50 5600.26
10/25/2010 5611.76 12.35 5599.41
11/23/2010 5611.76 10.81 5600.95
12/22/2010 5611.76 11.58 5600.18
IE20io* 67205.03
N2o10* 12
2009 Test Closing Elevation of Reported SDRE Values Measurement Point Date (fmsl) Level (feet) (Reported as fmsl)
1130/2009 5614.83 11.25 5603.58
2/27/2009 5614.83 9.35 5605.48
3/28/2009 5614.83 8.84 5605.99
4/27/2009 5614.83 11.98 5602.85
5/20/2009 5614.83 10.28 5604.55
6/22/2009 5614.83 13.00 5601.83
7/30/2009 5614.83 13.00 5601.83
8/31/2009 5614.83 11.04 5603.79
9/28/2009 5614.83 11.46 5603.37
10/30/2009 5614.83 13.35 5601.48
11/23/2009 5614.83 12.49 5602.34
12/14/2009 5614.83 13.12 5601.71
IE2oo9* 67238.80
N2oo9 12
*Per the requirement of the GWDP Part I.D.3 when monthly and quarterly measurements are
combined in the GWDP required equation, the quarterly values shall be multiplied by a
coefficient of three (3).
** The standpipe elevation was extended and surveyed in 2011. This change in elevation has
no effect on the resulting slimes drain elevation values listed in and used in the calculations.
***Per the Permit Part I.D.3.(b).2 effective July 11, 2011, the frequency of the Cell2 slimes
drain recovery tests was changed from monthly to quarterly.
Table J-2
' Cell 2 Slimes Drain ~
-.. Annual SDRE C0'ilipliance Data
Date Submitted
Compliance for Compared to in the DMT
Calendar year* SDRE Value (fmsl) Calendar Year* SDRE Value (fmsl) Difference (ft.) Report**
2013 5597.77 2012 5599.05 1.28 1/29/2014
2012 5599.05 2011 5600.00 0.95 2/28/2013
2011 5600.00 2010 5600.25 0.25 2/27/2012
2010 5603.32 2009 5603.23 -0.09 2/25/2011
2009 5603.33 2008 5603.63 0.30 2/26/2010
Annual slimes drain compliance was not achieved in accordance with Part 1.0.3 ofthe Permit in 2010. However, it was determined
that noncompliance was due to the frequent downtime of the slimes drain pump in order to meet monthly sampling requirements. As
such the frequency of the slimes drain recovery tests was changed from monthly to quarterly in accordnace with Part 1.0.3.(b).2 ofthe
Permit effective July 11, 2011. Annual compliance has been achieved each year since the monitoring frequency was changed.
* -Annual slimes drain compliance is determined by calculating the 3 year average as required by Part 1.0.3 of the Permit, dated
August 24, 2012.
**-The details of the annual slimes drain compliance calculations and the supporting data can be found the in 4th Quarter OMT
reports which were submitted to UOEQ on the dates provided in the table above.
Appendix K
White Mesa Uranium Mill Ground Water Monitoring Quality Assurance Plan (QAP)
Date 6/6/2012 Revision 7.2
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP)
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN (QAP)
State of Utah
Groundwater Discharge permit No. UGW370004
Denison Mines (USA) Corp.
P.O. Box 809
Blanding, UT 84511
Page I of61
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
TABLE OF CONTENTS
Date: 06-06-12 Revision 7.2
Page 2 of61
1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2.2 Overall Responsibility For the QA/QC Program 6
2.3 Data Requestors/Users 6
2.4 Data Generators 7
2.4.I Sampling and QC Monitors 7
2.4.2 Analysis Monitor 8
2.4.3 Data Reviewers/Approvers 8
2.5 Responsibilities Of Analytical Laboratory 8
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 9
3.1 Precision 9
3.2 Accuracy 10
3.3 Representativeness 10
3.4 Completeness 10
3.5 Comparability 10
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11
4.1 Controlling Well Contamination 11
4.2 Controlling Depth to Groundwater Measurements 11
4.3 Water Quality QC Samples 11
4.3.I VOC Trip Blanks 1I
4.3.2 Equipment Rinsate Samples II
4.3.3 Field Duplicates 12
4.3.4 Defmition of"Batch" 12
5.0 CALIDRA TION 12
5.1 Depth to Groundwater Measurements 12
5.2 Water Quality 12
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 3 of61
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 12
6.1 Groundwater Head Monitoring 12
6.1.1 Location and Frequency of Groundwater Head Monitoring 13
6.1.2 Groundwater Head Monitoring Frequency 13
6.2 Ground Water Compliance Monitoring 13
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 13
6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.l.b) or I.E.l.c) of the GWDP 14
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP 14
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 14
6.2.5 Decontamination Procedure 15
6.2.6 Pre-Purging/ Sampling Activities 15
6.2. 7 Well Purging/Measurement of Field Parameters 15
6.2.8 Samples to be taken and order of taking samples 16
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 16
7.1 Field Data Worksheets 16
7.2 Chain-Of-Custody and Analytical Request Record I 7
7.3 Record Keeping 18
8.0 ANALYTICAL PROCEDURES AND QA/QC 18
8.1 Analytical Quality Control 19
8.1.2 Spikes, Blanks and Duplicates 19
8.2 Analytical Laboratory Procedures 20
9.0 INTERNAL QUALITY CONTROL CHECKS 24
9.1 Field QC Check Procedures 24
9.1.1 Review of Compliance With the Procedures Contained in this QAP 24
9.1.2 Analyte Completeness Review 24
9.1.3 Blank Comparisons 24
9.1.4 Duplicate Sample Comparisons 25
9.2 Analytical Laboratory QA Reviews 26
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 26
9.4 Analytical Data 27
10.0 CORRECTIVE ACTION 28
10.1 When Corrective Action is Required 28
10.2 Procedure for Corrective Action 28
Mill-Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 4 of 61
11.0 REPORTING 29
12.0 SYSTEM AND PERFORMANCE AUDITS 30
12.1 QA Manager to Perform System Audits and Performance Audits 30
12.2 System Audits 30
12.3 Performance Audits 31
12.4 Follow-Up Actions 31
12.5 Audit Records 31
13.0 PREVENTIVE MAINTENANCE 31
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 32
14.1 Ongoing QA/QC Reporting 32
14.2 Periodic Reporting to Management 32
15.0 AMENDMENT 32
16.0 REFERENCES 33
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENTS
Attachment 1 Field and Data Forms
Attachment 1-1 Quarterly Depth to Water Data Sheet
Date: 06-06-12 Revision 7.2
Page 5 of61
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example COC Forms
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures
Attachment 2-2 Decontamination Procedures
Attachment 2-3 Purging Procedures
Attachment 2-4 Sample Collection Procedures
Attachment 2-5 Field QC Samples
APPENDICES
Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
1.0 INTRODUCTION
Date: 06-06-12 Revision 7.2
Page 6 of61
This Groundwater Monitoring Quality Assurance Plan (the "QAP") details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental
analytical laboratories, data validation, and sampling and other corrective actions necessary
to comply with UAC R317-6-6.3(1) and (L) at the White Mesa Uranium Mill (the "Mill"), as
required under paragraph I.H.6 of State of Utah Groundwater Discharge Permit No.
UGW370004 (the "GWDP") for the Mill. This Procedure incorporates the applicable
provisions of the United States Environmental Protection Agency ("EPA") RCRA
Groundwater Monitoring Technical Enforcement Guidance Document (OSWER-9950.1,
September, 1986), as updated by EPA's RCRA Ground-Water Monitoring: Draft Technical
Guidance (November 1992).
Activities in an integrated program to generate quality data can be classified as management
(i.e., quality assurance or "QA") and as functional (i.e., quality control or "QC"). The
objective of this QAP is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, completeness, representativeness and comparability
required for management purposes and to comply with the reporting requirements established
by applicable permits and regulations.
2.0 ORGANIZATION AND RESPONSIBILITIES
2.1 Functional Groups
This QAP specifies roles for a QA Manager as well as representatives of three different
functional groups: the data users; the data generators, and the data reviewers/approvers. The
roles and responsibilities of these representatives are described below.
2.2 Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the QA/QC measures are properly employed is
the responsibility of the QA Manager. The QA Manager is typically not directly involved in
the data generation (i.e., sampling or analysis) activities. The QA Manager is designated by
Denison Mines (USA) Corp. ("DUSA") corporate management.
2.3 Data Requestors/Users
The generation of data that meets the objectives of this QAP is necessary for management to
make informed decisions relating to the operation of the Mill facility, and to comply with the
reporting requirements set out in the GWDP and other permits and applicable regulations.
Accordingly, the data requesters/users (the "Data Users") are therefore DUSA's corporate
management and regulatory authorities through the implementation of such permits and
regulations. The data quality objectives ("DQOs") required for any groundwater sampling
event, such as acceptable minimum detection limits, are specified in this QAP.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
2.4 Data Generators
Date: 06-06-12 Revision 7.2
Page 7 of61
The individuals who carry out the sampling and analysis activities at the request of the Data
Users are the data generators. For Mill activities, this involves sample collection, record
keeping and QA/QC activities conducted by one or more sampling and quality control/data
monitors (each a "Sampling and QC Monitor"). The Sampling and QC Monitors are
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors
perform all field sampling activities, collect all field QC samples and perform all data
recording and chain of custody activities in accordance with this QAP. Data generation at
the contract analytical laboratory (the "Analytical Laboratory") utilized by the Mill to
analyze the environmental samples is performed by or under an employee or agent (the
"Analysis Monitor") of the Analytical Laboratory, in accordance with specific requirements
of the Analytical Laboratory's own QA/QC program.
The responsibilities ofthe data generators are as follows:
2.4.1 Sampling and QC Monitors
The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in this
QAP;
b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the
samples, to the Analytical Laboratory in accordance with this QAP;
c) Maintaining records of all samples, tracking those samples through subsequent
processing and analysis, and, ultimately, where applicable, appropriately disposing
of those samples at the conclusion of the program;
d) Preparing quality control samples for field sample collection during the sampling
event;
e) Preparing QC and sample data for review by the QA Manager; and
t) Preparing QC and sample data for reporting and entry into a computerized database,
where appropriate.
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The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory.
These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and
analytical procedures, prior to receiving samples;
b) Receiving samples from the field and verifying that incoming samples correspond to
the packing list or chain-of-custody sheet; and
c) Verifying that Analytical Laboratory QC and analytical procedures are being
followed as specified in this QAP, by the Analytical Laboratory's QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program ("NELAP") certification.
2.4.3 Data RcviewcJ'S/ Approvers
The QA Manager has broad authority to approve or disapprove project plans, specific
analyses and final reports. In general, the QA Manager is responsible for reviewing and
advising on all aspects of QA/QC, including:
a) Ensuring that the data produced by the data generators meet the specifications set out
in this QAP;
b) Making on-site evaluations and submitting audit samples to assist in reviewing
QA/QC procedures;
c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate
sampling equipment and sample containers, in accordance with this QAP, to
minimize contamination; and
d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personnel.
2.5 Responsibilities Of Analytical Laboratory
Unless otherwise specified by DUSA corporate management, all environmental analysis of
groundwater sampling required by the GWDP or by other applicable permits, will be
performed by a contract Analytical Laboratory.
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The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with
the requirements for maintaining NELAP certification.
In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U. S. EPA Guideline SW-846 and, to the extent
consistent with NELAP and EPA practices, the applicable portions of NRC Regulatory
Guide 4.14.
The Analytical Laboratory will be chosen by DUSA and must satisfy the following criteria:
(1) experience in analyzing environmental samples with detail for precision and accuracy, (2)
experience with similar matrix analyses, (3) operation of a stringent internal quality
assurance program meeting NELAP certification requirements and that satisfies the criteria
set out in Section 8 below, (4) ability to satisfy radionuclide requirements as stipulated in the
applicable portions ofNRC Regulatory Guide 4.14, and (5) certified by the State ofUtah for
and capable of performing the analytical methods set out in Table 1. The analytical
procedures used by the Analytical Laboratory will be in accordance with Utah
Administrative Code R317-6-6.3L.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this QAP is to ensure that monitoring data are generated at the Mill that
meet the requirements for precision, accuracy, representativeness, completeness, and
comparability required for management purposes and to comply with the reporting
requirements established by applicable permits and regulations (the Field and Analytical QC
samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are
satisfied). Data subject to QA/QC measures are deemed more reliable than data without any
QA/QC measures.
3.1 Precision
Precision is defined as the measure of variability that exists between individual sample
measurements of the same property under identical conditions. Precision is measured
through the analysis of samples containing identical concentrations of the parameters of
concern. For duplicate measurements, precision is expressed as the relative percent
difference ("RPD") of a data pair and will be calculated by the following equation:
RPD = [(A-B)/{(A+B) /2}] X 100
Where A (original) and B (duplicate) are the reported concentration for field duplicate
samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the
percent recoveries for matrix spike and matrix spike duplicate samples) (EPA SW -846,
Chapter 1, Section 5.0, page 27-28).
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3.2 Accuracy
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Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and a known value. The accuracy of laboratory analyses is evaluated based
on analyzing standards of known concentration both before and during analysis. Accuracy
will be evaluated by the following equation:
%Recovery= (I A-B I /C) x 100
Where:
A = the concentration of analyte in a sample
B =the concentration of analyte in an unspiked sample
C = the concentration of spike added
3.3 Representativeness
Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an
environmental condition. Representativeness is controlled by performing all sampling in
compliance with this QAP.
3.4 Completeness
Completeness refers to the amount of valid data obtained from a measurement system in
reference to the amount that could be obtained under ideal conditions. Laboratory
completeness is a measure of the number of samples submitted for analysis compared to the
number of analyses found acceptable after review of the analytical data. Completeness will
be calculated by the following equation:
Completeness = (Number of valid data points/total number of measurements) x 100
Where the number of valid data points is the total number of valid analytical measurements
based on the precision, accuracy, and holding time evaluation. Completeness is determined
at the conclusion ofthe data validation.
Executive Secretary approval will be required for any completeness less than 100 percent.
3.5 Comparability
Comparability refers to the confidence with which one set of data can be compared to
another measuring the same property. Data are comparable if sampling conditions,
collection techniques, measurement procedures, methods, and reporting units are consistent
for all samples within a sample set.
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4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over
the surface casing and cementing the surface section of the drill hole. Wells have surface
covers of mild steel with a lockable cap cover. Radiation Safety staff has access to the keys
locking the wells.
4.2 Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.
4.3 Water Quality QC Samples
Quality assurance for groundwater monitoring consists of the following QC samples:
4.3.1 VOC Trip Blanks
Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds ("VOCs") through diffusion during sample transport and storage.
At a minimum (at least) one trip blank will be in each shipping container containing samples
to be analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site, and then returned to the Analytical Laboratory for analysis
along with the samples collected during the sampling event. The trip blank will be unopened
throughout the transportation and storage processes and will accompany the technician while
sampling in the field.
4.3.2 Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples. Rinsate blanks will be
collected after decontamination and prior to subsequent use. Rinsate blank samples for a
non-dedicated pump are prepared by pumping de-ionized water into the sample containers.
Rinsate blank samples for a non-disposable or non-dedicated bailerare prepared by pouring
de-ionized water over and through the bailer and into the sample containers. Equipment
rinsate blanks will be analyzed only for the contaminants required during the monitoring
event in which they are collected.
Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
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4.3.3 Field Duplicates
Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.
Field duplicate sampling procedures are described in Attachment 2-5.
4.3.4 Definition of "Batch"
For the purposes of this QAP, a Batch is defined as 20 or fewer samples.
5.0 CALIBRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance
with manufacturers' recommendations, and Analytical Laboratory equipment shall be
calibrated in accordance with Analytical Laboratory procedures.
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to each use as
noted in Attachment 2 to ensure that the Water Sounding Device is functional.
5.2 Water Quality
The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer's specifications (for
example, by using two known pH solutions and one specific conductance standard.)
Temperature will be checked comparatively by using a thermometer. Calibration results will
be recorded on the Field Data Worksheet.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS
6.1 Groundwater Head Monitoring
Groundwater head measurements ("depth to water") will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.
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6.1.1 Location and Frequency of Groundwater Head Monitoring
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Depth to groundwater shall be measured quarterly in the following wells and piezometers:
a) All Point of Compliance wells listed in the GWDP Parts I.E.1 (b) and (c) and
I.E.2;
b) Monitoring well MW-34;
c) All piezometers (P-1, P-2, P-3, P-4, P-5 and the Dry Ridge piezometers);
d) All contaminant investigation wells required by the Executive Secretary as part of
a contaminant investigation or groundwater corrective action (chloroform and nitrate
wells).
6.1.2 Groundwater Head Monitoring Frequency
Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5 day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an
electronic data management system (spreadsheet or database). The data from the quarterly
depth to water measurements will be included in the quarterly groundwater report.
The depth to groundwater measured immediately prior to purging/sampling will be recorded
on data sheet for each well. An example of a Field Data Work Sheet for Groundwater is
included in Attachment 1.
The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.
6.2 Ground Water Compliance Monitoring
6.2.1 Location and Frequency of Groundwater ompliance Monitorin-g
Groundwater quality shall be measured in the following wells at the following frequencies:
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a) Semi-annually in the following Point of Compliance wells: MW-1, MW-2, MW-
3, MW-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-
24, MW-27, MW-28, MW-29, and MW-32;
b) Semi-annually in the following General Monitoring Wells: MW-20 and MW-22;
c) Quarterly in the following Point of Compliance wells: MW-11, MW-14, MW-25,
MW-26, MW-30, MW-31, MW-35, MW-36 and MW-37; and
d) Quarterly in the Chloroform Investigation and Nitrate Corrective Action wells.
In addition, quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in Parts I.G.1 or I.G.2 of the GWDP. Sampling
personnel should coordinate with the QA Manager prior to conducting any monitoring well
sampling to determine if any parameters in any wells are subject to accelerated monitoring.
6.2.2 Quarhwly and Scmi..;A.bn ual Sampling Required Under Part I.E.l.b) m· I.E.l.c) ofthc
GWDP
All quarterly and semi-annual samples collected under.Parts I.E.l.b) or I.E.l.c) ofthe GWDP
shall be analyzed for the following parameters:
a) Field parameters-depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) and turbidity; and
b) Laboratory Parameters:
(i) All parameters specified in Table 2 of the GWDP; and
(ii) General inorganics -chloride, sulfate, carbonate, bicarbonate, sodium
potassium, magnesium, calcium, and total anions and cations.
6.2.3 Quartel'ly m· Monthly Sampling Regui1·ed Under Paragraphs 1.G.l or LG.2 of the GWDP
Any quarterly or monthly accelerated sampling required under paragraphs I.G.l. or I.G.2. of
the GWDP shall be analyzed for the specific parameters as required by previous sampling
results as determined by the QA Manager.
6.2.4 Sampling Equipment for· Gro,md:water Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.
Purging and sampling equipment is described in Attachment 2-3 of this QAP.
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Field parameters are measured by using a flow cell system that enables the measurements to
be taken on a real-time basis without exposing the water stream to the atmosphere;
6.2.5 Decontamination Procedure
Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.
6.2.6 Pre-Purging/ Sampling Activities
Pre-purging and sampling activities are described in Attachment 2-3 . The purging and
sampling techniques used at each well will be a function of the well's historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.
6.2.7 Well Purging/Measurement of Field Parameters
The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.
Purging wells prior to sampling removes the stagnant water column present in the well
casing and assures that representative samples of the formation water are collected. Purging
will be completed as described in Attachment 2-3.
There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
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6.2.8 Samples to be taken and order of taking samples
For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP . The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single
container due to like sampling requirements (filtering) and/or like preservation. The
container requirements will be determined by the Analytical Laboratory and specified with
the bottles supplied to the Field Personnel. Bottle requirements may change if the Analytical
Laboratory is changed or if advances in analytical techniques allow for reduced samples
volumes. The following list is a general guideline.
a) VOCs, 3 sample containers, 40 ml each;
b) Nutrients (ammonia, nitrate and nitrite), 1 sample container, 100 ml;
c) All other non-radiologies (fluoride, general inorganics, TDS, total cations and
anions), 1 sample container, 250 ml,; and
d) Gross alpha and heavy metals, 1 sample container, 1,000 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.
Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7.1 Field Data Worksheets
Documentation of observations and data from sampling provide important information about
the sampling process and provide a permanent record for sampling activities. All
observations and field sampling data will be recorded in waterproof ink on the Field Data
Worksheets, which will be maintained on file at the Mill.
The Field Data Worksheets will contain the following information:
• Name ofthe site/facility
• description of sampling event
• location of sample (well name)
• sampler's name(s) and initials(s)
• date(s) and time(s) of well purging and sample collection
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• type of well purging equipment used (pump or bailer)
• previous well sampled during the sampling event
• well depth
• depth to groundwater before purging and sampling
• field measurements (pH, specific conductance, water temperature, redox
potential, turbidity)
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type and condition of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory.
The Field Data Worksheets will also contain detailed notes describing any other significant
factors noted during the sampling event, including, as applicable: condition of the well cap
and lock; water appearance, color, odor, clarity; presence of debris or solids; any variances
from this procedure; and any other relevant features or conditions. An example of a Field
Data Worksheet that incorporates this information is attached in Attachment 1.
The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.
7.2 Chain-Of-Custody and Analytical Request Record
A Chain-of-Custody and Analytical Request Record form (the "COC Form"), provided by
the Analytical Laboratory, will accompany the samples being shipped to the Analytical
Laboratory. Examples of the Chain of Custody Forms used are attached as Attachment 2. If
the Chain of Custody Form changes at any time, the Company shall provide a copy of the
new or revised Chain of Custody Form to the Executive Secretary and substitute the new
form for the old form in Attachment 2. Standard Chain-of-Custody protocol is initiated for
each sample set. A COC Form is to be completed for each set of samples collected in a
shipping container (cooler) and is to include the following:
• sampler's name
• company name
• date and time of collection
• sample type (e.g., water)
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• sample location
• number of sample containers in the shipping container
• analyses requested
• signatures of persons involved in the chain of possession
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• internal temperatures of the shipping container when opened at the laboratory
• remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.
Chain-of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.
The person shipping the samples to the Analytical Laboratory will sign the COC Form,
document shipment method, and send the original and the second copy of the COC Form
with the samples. Upon receipt of the samples, the person receiving the samples will sign the
COC Form and return the second copy to the Mill's RSO.
Copies ofthe COC Forms and other relevant documentation will be retained at the Mill.
7.3 Record Keeping
The Field Data Worksheets are retained at the Mill.
Data from the Analytical Laboratory, showing the laboratory analytical results for the water
samples, are maintained at the Mill.
Copies of the current Utah certifications of the Analytical Laboratory or Laboratories and a
list of Utah Bureau of Laboratory Improvement approved parameters and methods used to
perform analysis during the monitoring events conducted during the quarter will be
maintained at the Mill. DUSA will ensure that the Analytical Laboratory or Laboratories
used, have certifications for each parameter and method required by Section 8.2, Table 1 of
the QAP.
Once all the data for the quarter (all wells sampled during the quarter) is completed, key data
from the Field Data Worksheets and from the data packages are managed using electronic
data management software The data management software will be managed and
administered by the QA Manager or designee. The Mill Personnel will have read-only
access to the electronic data management software.
8.0 ANALYTICAL PROCEDURES AND QA/QC
Analytical Laboratory QA provides a means for establishing consistency in the performance
of analytical procedures and assuring adherence to analytical methods utilized. Analytical
Laboratory QC programs include traceability of measurements to independent reference
materials and internal controls.
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8.1 Analytical Quality Control
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Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In
choosing and retaining the Analytical Laboratory, DUSA shall ensure that the Analytical
Laboratory is certified by the State of Utah and by NELAP, is capable of performing the
analytical procedures specified in Section 8.2, and that the QA/QC program of the Analytical
Laboratory includes the spikes, blanks and duplicates described in Section 8.1.2.
8.1.2 Spikes, Blanks and Duplicates
Analytical Laboratory QC samples will assess the accuracy and precision of the analyses.
The following describes the type of QC samples that will be used by the Analytical
Laboratory to assess the quality of the data. The following procedures shall be performed at
least once with each analytical Batch of samples:
a) Matrix Spike/Matrix Spike Duplicate
A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.
b) Method Blanks
Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.
c) Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis ofVOCs (or other organics only) shall be spiked with
surrogate compounds prior to purging or extraction. Surrogates are organic
compounds which are similar to analytes of interest in chemical composition,
extraction, and chromatography, but which are not normally found in environmental
samples. Surrogates shall be spiked into samples according to the appropriate organic
analytical methods.
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d) Check ample
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Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.
8.2 Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory will be as specified in
Table 1, or as otherwise authorized by the Executive Secretary. With respect to Chloroform
Investigation and Nitrate Corrective Action sampling, the analytical procedures for
parameters monitored under those programs are specified in Appendix A and B respectively.
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Contaminant Analytical
Methods
to be Used
Nutrients
Ammonia (as N) A4500-
NH3 Gor
E350.1
Nitrate & N itrite E353.1 or
(as N) E353.2
Heavy Metals
Arsenic E200.7 or
E200.8
Beryllium E200.7 or
E200.8
Cadmium E200.7 or
E200.8
Chromium E200.7 or
E200.8
Cobalt E200.7 or
E200.8
Copper E200.7 or
E200.8
Iron E200.7 or
E200.7
Lead E200.7 or
E200.8
Manganese E200.7 or
E200.8
Mercury E 245.1 or
E200.7 or
E200.8
Molybdenum E200.7 or
E200.8
Nickel E200.7 or
E200.8
Selenium E200.7 or
E200.8
Silver E200.7 or
E200.8
Thallium E200.7 or
E200.8
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Table 1
Reporting Maximum Sample Sample
Limit1 Holding Preservation Temperature
Times Requirement Requirements
s
0.05 mg/L 28 days H2S0 4 to .:5 6°C
pH<2
0.1 mg/L 28 days H2S04 to .:5 6°C
pH<2
5 j..tg/L 6 months HN03to pH<2 None
0.50 j..tg/L 6 months HN03to pH<2 None
0.50 j..tg/L 6 months HN03to pH<2 None
25 j..tg/L 6 months HN03to pH<2 None
10 j..tg/L 6 months HN03to pH<2 None
10 j..tg/L 6 months HN03to pH<2 None
30 j..tg/L 6 months HN03to pH<2 None
1.0 j..tg/L 6 months HN03to pH<2 None
10 j..tg/L 6 months HN03to pH<2 None
0.50 j..tg/L 28 days HN03to pH<2 None
10 1-lg/L 6 months HN03to pH<2 None
20 1-lg/L 6 months HN03to pH<2 None
5!-lgiL 6 months HN03to pH<2 None
10 1-lg/L 6 months HN03tO pH<2 None
0.50 1-lg/L 6 months HN03to pH<2 None
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Contaminant Analytical
Methods
to be Used
Tin E200.7 or
E200.8
Uranium E200.7 or
E200.8
Vanadium E200.7 or
E200.8
Zinc E200.7 or
E200.8
Radiologies
Gross Alpha E 900.0 or
E900.1
Volatile
Organic
Compounds
Acetone SW8260B
or
SW8260C
Benzene SW8260B
or
SW8260C
2-Butanone SW8260B
(MEK) or
SW8260C
Carbon SW8260B
Tetrachloride or
SW8260C
Chloroform SW8260B
or
SW8260C
Chloromethane SW8260B
or
SW8260C
Dichloromethane SW8260B
(Methylene or
Chloride) SW8260C
Naphthalene SW8260B
or
SW8260C
Tetrahydrofuran SW8260B
Date: 06-06-12 Revision 7.2
Page22 of61
Reporting Maximum Sample Sample
Limie Holding Preservation Temperature
Times Requirement Requirements
s
100 llg!L 6 months HN03to pH<2 None
0.30 11g/L 6 months HN03to pH<2 None
15 llgiL 6 months HN03to pH<2 None
10 llgiL 6 months HN03to pH<2 None
1.0 pCi/L 6 months HN03to pH<2 None
20 llgiL 14 days HCl to pH<2 ~6°C
1.0 11g/L 14 days HCl to pH<2 .::;6°C
20 11g/L 14 days HCl to pH<2 .::;6°C
1.0 11g/L 14 days HCl to pH<2 .::;6°C
1.0 11g/L 14 days HCl to pH<2 .::;6°C I
1.0 11g/L 14 days HCl to pH<2 .::;6°C
1.0 11g/L 14 days HCl to pH<2 .::;6°C
1.0 11g/L 14 days HCl to pH<2 .::;6°C
1.0 11g/L 14 days HCl to pH<2 .::;6°C
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Contaminant Analytical
Methods
to be Used
or
SW8260C
Toluene SW8260B
or
SW8260C
Xylenes (total) SW8260B
or
SW8260C
Others
Field pH (S.U.) A4500-H
B
Fluoride A4500-F C
or E300.0
TDS A2540 C
General
In organics
Chloride A4500-Cl
B or
A4500-Cl
E
or E300.0
Sulfate A4500-
S04 E or
E300.0
Carbonate as A2320 B
C03
Bicarbonate as A2320 B
HC03
Sodium E200.7
Potassium E200.7
Magnesium E200.7
Calcium E200.7
Date: 06-06-12 Revision 7.2
Page 23 of61
Reporting Maximum Sample Sample
Limit1 Holding Preservation Temperature
Times Requirement Requirements
s
1.0 ).lg/L 14 days HCl to pH<2 ~6°C
1.0 ).lg/L 14 days HCl to pH<2 <6°C
0.01 s.u. Immediate None None
0.1 mg/L 28 days None None
10 mg/L 7 days None <6°C
1 mg/L 28 days None None
1 mg/L 28 days None :S 6°C
1 mg/L 14 days None :::; 6°C
1 mg/L 14 days None S 6°C
0.5 mg/L 6 months HN03to pH<2 None
0.5 mg/L 6 months HN03to pH<2 None
0.5 mg/L 6 months HN03to pH<2 None
0.5 mg/L 6 months HN03to pH<2 None
1. The Analytical Laboratory will be requrred to meet the reportmg limits ("RLs") in the foregoing Table,
unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the
increased RL will be used, or unless otherwise approved by the Executive Secretary.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 24 of61
9.0 INTERNAL QUALITY CONTROL CHECKS
Internal quality control checks are inherent in this QAP. The QA Manager will monitor the
performance of the Sample and QC Monitors, and, to the extent practicable, the Analysis
Monitor to ensure that they are following this QAP. In addition, either the QA Manager or a
Sampling and QC Monitor will review and validate the analytical data generated by the
Analytical Laboratory to ensure that it meets the DQOs established by this QAP. Finally,
periodic system and performance audits will be performed, as detailed in Section 12 below.
9.1 Field QC Check Procedures
The QA Manager will perform the following QA/QC analysis of field procedures:
9.1.1 Review of Compliance With the PJ·ocedure Contained in this QAP
Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.
9.1.2 Analyte Completeness Review
The QA Manager will review all Analytical Results to confirm that the analytical results are
complete (i.e., there is an analytical result for each required constituent in each well). The
QA Manager shall also identify and report all instances of non-compliance and non-
conformance (see Part I.E.1(a) of the Permit. Executive Secretary approval will be required
for any completeness (prior to QAIQC analysis) less than 100 percent. Non-conformance
will be defined as a failure to provide field parameter results and analytical results for each
parameter and for each well required in Sections 6.2.2 and 6.2.3, for the sampling event,
without prior written Executive Secretary approval.
9.1.3 Blank Comparisons
Trip blanks, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).
Corrective actions for blank comparison non-conformance shall first determine if the non-
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will
1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory ofthe discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 25 of61
4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.
9.1.4 Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:
a) Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD :::._20%, unless the measured concentrations
are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review,
February 1994,9240.1-05-01, p. 25).
b) Radiologies Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting
variance that is equal to or less that 20% of the reported activity concentration. An error
term may be greater than 20% of the reported activity concentration when the sum of the
activity concentration and error term is less than or equal to the GWCL.
c) Radiologies, Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:
Where:
A = the first duplicate measurement
B = the second duplicate measurement
s/ = the uncertainty of the first measurement squared
sb 2 = the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is> 2.
(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 26 of61
Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non-
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
9.2 Analytical Laboratory QA Reviews
Full validation will include recalculation of raw data for a minimum of one or more analytes
for ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC
review which will include validating holding times and QC samples. Overall data
assessment will be a part of the validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality of the data based
on SW-846, the applicable portions ofNRC guide 4.14 and on analytical methods used. The
reviewer will check the following:
(1) sample preparation information is correct and complete,
(2) analysis information is correct and complete,
(3) appropriate Analytical Laboratory procedures are followed,
(4) analytical results are correct and complete,
(5) QC samples are within established control limits,
(6) blanks are within QC limits,
(7) special sample preparation and analytical requirements have been met, and
(8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation.
The Analytical Laboratory will report the data as a group of one batch or less, along with the
QA/QC data. The Analytical Laboratory will provide the following information:
(1) cover sheet listing samples included in report with a narrative,
(2) results of compounds identified and quantified,
(3) reporting limits for all analytes, and
(4) QA/QC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
a) Reporting Limit (RL) Comparisons
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 27 of61
The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are
in conformance with the reporting limits set out on Table 1. Non-conformance shall be
defined as:
1) a reporting limit that violates these provisions, unless the reporting limit must be increased
due to sample matrix interference (i.e., due to dilution); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical
Laboratory are those specified in Table 1, unless otherwise approved by the Executive
Secretary. Non-conformance shall be defined when the Analytical Laboratory uses
analytical methods not listed in Table 1 and not otherwise approved by the Executive
Secretary.
c) Holding Time Examination_
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.
d) Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received
by the Analytical Laboratory at a temperature no greater than the approved temperature listed
in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.
9.4 Analytical Data
All QA/QC data and records required by the Analytical Laboratory's QA/QC program shall
be retained by the Analytical Laboratory and shall be made available to DUSA as requested.
Analytical data submitted by the Analytical Laboratory should contain the date/time the
sample was collected, the date/time the sample was received by the Analytical Laboratory,
the date/time the sample was extracted (if applicable), and the date/time the sample was
analyzed.
All out-of-compliance results will be logged by the Analysis Monitor with corrective actions
described as well as the results of the corrective actions taken. All raw and reduced data will
be stored according to the Analytical Laboratory's record keeping procedures and QA
program. All Analytical Laboratory procedures and records will be available for on-site
inspection at any time during the course of investigation.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 28 of61
If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will
be consulted to establish more appropriate analytical approaches for problem samples.
10.0 CORRECTIVE ACTION
10.1 When Corrective Action is Required
The Sampling and QC Monitors and Analytical Laboratory are responsible for following
procedures in accordance with this QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. All deviations from
field sampling procedures will be noted on the Field Data Worksheets or other applicable
records. Any QA/QC problems that arise will be brought to the immediate attention of the
QA Manager. Analytical Laboratory deviations will be recorded by the Analysis Monitor in
a logbook as well.
When a procedural or systematic non-conformance is identified, DUSA shall:
a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. Ifthe non-conformance is deemed to
be systematic or procedural, DUSA shall determine the root cause, and provide
specific steps to resolve problems(s) in accordance with the procedure set forth in
Section 1 0.2. Any non-conformance with QAP requirements in a given quarterly
groundwater monitoring period will be corrected and reported to the Executive
Secretary on or before submittal of the next quarterly ground water monitoring
report.
b) When a sample is lost, sample container broken, or the sample or analyte was
omitted, resample within 1 0 days of discovery and analyze again in compliance with
all requirements of this QAP. The results for this sample(s) should be included in
the same quarterly monitoring report with other samples collected for the same
sampling event; and
c) For any other material deviation from this QAP, the procedure set forth in Section
10.2 shall be followed.
10.2 Procedure for Corrective Action
The need for corrective action for non-conformance with the requirements of this QAP, may
be identified by system or performance audits or by standard QA/QC procedures. The
procedures to be followed if the need for a corrective action is identified, are as follows:
a) Identification and definition of the problem;
b) Assignment of responsibility for investigating the problem;
c) Investigation and determination ofthe cause ofthe problem;
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 29 of61
d) Determination of a corrective action to eliminate the problem;
e) Assigning and accepting responsibility for implementing the corrective action;
f) Implementing the corrective action and evaluating its effectiveness; and
g) Verifying that the corrective action has eliminated the problem.
The QA Manager shall ensure that these steps are taken and that the problem which led to the
corrective action has been resolved. A memorandum explaining the steps outlined above
will be placed in the applicable monitoring files and the Mill Central Files, and the corrective
action will be documented in a Report prepared in accordance with Section 11.
11.0 REPORTING
As required under paragraph I.F.1 of the GWDP, the Mill will send a groundwater
monitoring report to the Executive Secretary on a quarterly basis. Both the Routine
Groundwater Monitoring Reports (pertinent to Part I.F.1 of the Permit) and Chloroform
Investigation and Nitrate Corrective Action Reports shall be submitted according to the
following schedule:
Quarter Period I Due Date
First January-March June 1
Second April-June September 1
Third July -September December 1
Fourth October-December March 1
The Routine Groundwater Monitoring Reports (pertinent to Part I.F .1 of the Permit) will
include the following information:
• Description of monitor wells sampled
• Description of sampling methodology, equipment an decontamination
procedures to the extent they differ from those described in this QAP
• A summary data table of groundwater levels for each monitor well and
piezometer
• A summary data table showing the results of the sampling event, listing all
wells and the analytical results for all constituents and identifying any
constituents that are subject to accelerated monitoring in any particular wells
pursuant to Part I.G.1 of the GWDP or are out of compliance in any particular
wells pursuant to Part I.G.2 of the GWDP
• Copies of Field Data Worksheets
• Copies of Analytical Laboratory results
• Copies of Chain of Custody Forms (included in the data packages)
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 30 of61
• A Water Table Contour Map showing groundwater elevation data for the
quarter will be contemporaneous for all wells on site, not to exceed a
maximum time difference of five calendar days.
• Evaluation of groundwater levels, gradients and flow directions
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this QAP and all corrective actions taken.
• Recommendations and Conclusions.
With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B to this document.
In addition, an electronic copy of all analytical results will be transmitted to the Executive
Secretary in comma separated values (CSV) format, or as otherwise advised by the Executive
Secretary.
Further reporting may be required as a result of accelerated monitoring under paragraphs
I.G.l and I.G.2 ofthe GWDP. The frequency and content ofthese reports will be defined by
DUSA corporate management working with the Executive Secretary.
12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
DUSA shall perform such system audits and performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined
by DUSA.
12.2 System Audits
System audits are qualitative evaluations of all components of field and Analytical
Laboratory QC measurement systems. They determine if the measurement systems are being
used appropriately. System audits will review field and Analytical Laboratory operations,
including sampling equipment, laboratory equipment, sampling procedures, and equipment
calibrations, to evaluate the effectiveness of the QA program and to identify any weakness
that may exist. The audits may be carried out before all systems are operational, during the
program, or after the completion of the program. Such audits typically involve a comparison
of the activities required under this QAP with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data
collection and management activities.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
12.3 Performance Audits
Date: 06-06-I 2 Revision 7.2
Page 31 of61
The performance audit is a quantitative evaluation of the measurement systems of a program.
It requires testing the measurement systems with samples of known composition or behavior
to evaluate precision and accuracy. With respect to performance audits of the analytical
process, either blind performance evaluation samples will be submitted to the Analytical
Laboratory for analysis, or the auditor will request that it provide results of the blind studies
that the Analytical Laboratory must provide to its NELAP accreditation agency on an annual
basis. The performance audit is carried out without the knowledge of the analysts, to the
extent practicable.
12.4 Follow-Up Actions
Response to the system audits and performance audits is required when deviations are found
and corrective action is required. Where a corrective action is required, the steps set out in
Section 10.2 will be followed.
12.5 Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records
will contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit fmdings or corrective actions.
13.0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.
Field instruments will be maintained as per the manufacturer's specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in
accordance with Section 5. Batteries will be charged and checked daily when these
instruments are in use. All equipment out of service will be immediately replaced. Field
instruments will be protected from adverse weather conditions during sampling activities.
Instruments will be stored properly at the end of each working day. Calibration and
maintenance problems encountered will be recorded in the Field Data Worksheets or
logbook.
The Analytical Laboratory is responsible for the maintenance and calibration of its
instruments in accordance with Analytical Laboratory procedures and as required in order to
maintain its NELAP certifications. Preventive maintenance will be performed on a
scheduled basis to minimize downtime and the potential interruption of analytical work.
Mill-Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 32 of61
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC Reporting
The following reporting activities shall be undertaken on a regular basis:
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding
progress of the applicable sampling program. The Sample and QC Monitors will
also brief the QA Manager on any QA/QC issues associated with such sampling
activities.
b) The Analytical Laboratory shall maintain detailed procedures for laboratory record
keeping. Each data set report submitted to the Mill's QA Manager or his staff will
identify the analytical methods performed and all QA/QC measures not within the
established control limits. Any QA/QC problems will be brought to the QA
Manager's attention as soon as possible; and
c) After sampling has been completed and final analyses are completed and reviewed, a
brief data evaluation summary report will be prepared by the Analytical Laboratory
for review by the QA Manager, by a Sampling and QC Monitor or by such other
qualified person as may be designated by the QA Manager. The report will be
prepared in accordance with NELAP requirements and will summarize the data
validation efforts and provide an evaluation of the data quality.
14.2 Periodic Reporting to Management
The QA Manager shall present a report to DUSA's ALARA Committee at least once per
calendar year on the performance of the measurement system and the data quality. These
reports shall include:
a) Periodic assessment of measurement quality indicators, i.e., data accuracy, precision
and completeness;
b) Results of any performance audits, including any corrective actions;
c) Results of any system audits, including any corrective actions; and
d) Significant QA problems and recommended solutions.
15.0 AMENDMENT
This QAP may be amended from time to time by DUSA only with the approval of the
Executive Secretary.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
16.0 REFERENCES
Date: 06-06-12 Revision 7.2
Page 33 of61
United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.
United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Teclmical Enforcement Guidance Document (TEGD), Office of Solid Waste and
Emergency Response, OSWER-9950.1.
United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Teclmical Guidance (DTG), Office of Solid Waste.
Standard Methods for the Examination of Water and Wastewater, 20th Edition, 1998.
American Public Health Association, American Water Works Association, Water
Environment Federation. Washington, D.C. p. 1-7.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENT 1
Field and Data Forms
Date: 06-06-12 Revision 7.2
Page 34 of61
Mill -Groundwater Discharge Pennit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Attachment 1-1
Quarterly Depth to Water Data Sheet
NAME: ----------------------------------DATE:
TIME WELL Static level TIME WELL Static Level TIME
Date: 06-06-12 Revision 7.2
Page 35 of61
WELL Static Level
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 36 of6l
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
o Ntsor!l MIN~S
lle5cziptiaa ofSmipJillc Evmt:
Field SmJpJe m
n. mdl'imefar ~ .__ ______ _, -~(ifdiftitnat)
WellPuqiDcEqaipUsed: @]pumpor @]NilK Wtlll'uq,(uo1hsthmBe!met)
-~ .... 7.1
l'lqiDc Metbod. Used: [§]2 CiiSinp [§)3 ~
Sampliac Ewat Pmr. Wtil$mwlltd mSampliacEwat I.._ ______ _,
pH:Bnffer7.o ._I ___ __. pHBuf&s-4.0
Spec:i&.c: ~ ~I ____ _,I!'MHOSI c:m Well.Depth(O.Olft):
Dlpth tu w-. Betm Purgiug ._1 ___ _,
Well WaterTaap. (~
Tm I I Gal.Pmpd I
Caadul:tmc!t I I pH I
Temp. "C I I
:R.edaPcMai:W Eh (aiV) I I
l'mbidity (NTU) I I
~ I I Gal.Purpd I
Ccuiadmce I I pH I
Temp. "C I I
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~ Vobm. (V} 4" wen:J ,(.653b)
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Time I I GalParpd. I I
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Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Mil--llisclwrp......m
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Date: 06-06-12 Revision 7.2
Page 37 of61
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In certan circumstances, samples slJbmijted to Energy Lab01atories, Inc, may be subcontracted to other c11rtilied laboratorles in order to complete the analysia requ""flci.
This !lerves as notice or this possibility. All sul>-contract data will be clearly notated on your enatytlc:.ot rapott.
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Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
OENISO
MINES
Date: 06-06-12 Revision 7.2
Page 39 of61
CHAIN OF CUSTODY
Samples
Shipped to:
Contact
Chain of Custody/Sampling Analysis Request
Project Samplers Name Samplers Signature
Date
Collecte Time
Sample 10 d Collected Laboratory Analysis Requested
Please notify Tanner Holliday of Receipt temperature on these samples Immediately!
Thank you.
Relinquished Date/Tim Received
By:(Signature) e By:(Signature) Date/Time
Relinquished Date/Tim Received
By: (Signature) e By:(Signature) Date/Time
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENT 2
Field Procedures
Date: 06-06-12 Revision 7.2
Page 40 of61
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 41 of61
Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures
Measure and record all depth to water data to the nearest 0. 01 feet.
Equipment Used For Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist -IT 300 or
equivalent device (the "Water Level Indicator").
Equipment Checks
Equipment used in depth to groundwater measurements will be checked prior to each use to
ensure that the Water Sounding Device is functional.
Check the Water Sounding Device as follows:
• Turn the Water Level Indicator on.
• Test the Water Level Indicator using the test button located on the instrument.
• If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.
Measurement of Depth to Water
All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:
• For monitoring wells -Measure depth to water from the top of the inner well casing
at the designated measurement point.
• For the piezometers -Measure depth to water from the top of the casing at the
designated measurement point.
• Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
• Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Attachment 2-2
Decontamination Procedures
Date: 06-06-12 Revision 7.2
Page 42 of61
Non-dedicated sampling equipment will be decontaminated usmg the following
procedures:
Water level meter
Decontaminate the water level meter with a detergent/deionized ("DI") water mixture
by pouring the solutions over the water level indicator.
Rinse the water level indicator with fresh DI water rinse by pouring the DI water over
the water level indicator.
Field Parameter Instrument (Hydrolab or equivalent)
Rinse the field parameter instrument probe unit with DI water pnor to each
calibration.
Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.
Non-Dedicated Purging/Sampling Pump
Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:
a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;
b) pump the detergent/DI water solution through the pump and pump outlet lines
into the drain line connected to Cell 1;
c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
d) submerge the pump into a 55-gallon drum ofDI water;
e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1 ;
f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 43 of61
g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;
h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).
All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP)
Attachment 2-3
Purging Procedures
The following equipment will be used for groundwater purging and sampling:
Page 44 of61
• Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These bailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
• Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
• Non-Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
• Field Parameter Meter: A meter used to measure ground water quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:
~ Water temperature;
~ Specific conductivity;
~ Turbidity;
~ pH;
~ Redox potential (Eh).
• Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
• Diesel Generator: Mobile power supply to provide power for submersible pump.
• 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
"bladder" pumps.
Additional supplies for purging and sampling are as follows:
• Field Data Sheets
• 45 micron in-line filters (when metals and gross alpha analyses are required)
• Calculator
• Clock, stopwatch or other timing device
• Buckets
• Sampling containers(as provided by the Analytical Laboratory)
• Field preservation chemicals (as provided by the Analytical Laboratory)
• Disposable gloves
• Appropriate health and safety equipment
• Sample labels and COCs (as provided by the Analytical Laboratory)
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Pre-Purging/ Sampling Activities
Date: 06-06-12 Revision 7.2
Page 45 of61
If a portable (non-dedicated) pump is to be used, prior to commencing the event's sampling
activities,
1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) into a cooler that will transport
the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC) samples
throughout the monitoring event.
Well Purging
The purging techniques described below will be used for all groundwater sampling
conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.
Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.
Turbidity measurement in the water should be .:S 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.
A flow-cell needs to be used for field parameters.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 46 of61
Procedure
a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)
b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;
c) Determine the casing volume (V) in gallons, where h is column height of the water
in the well (calculated by subtracting the depth to groundwater in the well from the
total depth ofthe well), V = 0.653*h, for a 4" casing volume and V = .367*h for a 3"
casing volume. Record the casing volume on the Field Data Worksheet;
If a portable (non-dedicated) pump is used:
• Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
• Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.
If a non-dedicated pump or dedicated pump is used:
(i) Commence pumping;
(ii) Determine pump flow rate by using a stopwatch or other timing device and a
calibrated bucket by measuring the number of seconds required to fill to the
one-gallon mark. Record this in the "pumping rate" section of the Field Data
Worksheet;
(iii) Calculate the amount of time to evacuate two or three casing volumes;
(iv)Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);
(v) If two casing volumes will be purged:
Take measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) during well purging, using the
Field Parameter Meter. These measurements will be recorded on the Field
Data Worksheet. Purging is completed after two casing volumes have been
removed and the field parameters pH, temperature, specific conductance,
redox potential (Eh) and turbidity have stabilized to within 10% RPD over at
least two consecutive measurements.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 47 of61
(vi)Ifthree casing volumes will be purged:
Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) after three casing volumes have
been purged immediately prior to sample collection using the Field Parameter
Meter. Record these measurements on the Field Data Worksheet.
(vii) If the well is purged to dryness:
Record the number of gallons purged on the Field Data Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.
Upon arrival at the well after recovery or when sufficient water is available
for sampling measure depth to water and record on the Field Data Worksheet.
Take one set of measurements of field parameters for pH, specific
conductance and temperature only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific
conductance and temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within
1 0% RPD the samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.
Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.
Purging using a disposable bailer
For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.
When a bailer is used, the following procedure will be followed:
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page48of61
(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.
(ii) Attach a disposable bailer to a rope and reel.
(iii) Lower the bailer into the well and listen for contact with the solution.
Once contact is made, allow the bailer to gradually sink in the well, being
careful not to allow the bailer to come in contact with the bottom sediment.
(iv)After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.
(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.
(vi)Take field measurements from the water in the buckets.
All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.
After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Sample Collection Order
Attachment 2-4
Sample Collection Procedures
Date: 06-06-12 Revision 7.2
Page 49 of61
Regardless of the purging method employed samples will be collected in the order specified
below.
All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.
VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologies (fluoride, general inorganics, TDS, total cations and anions); and
Gross alpha and heavy metals (filtered).
Sample Filtering
When sampling for heavy metals and for gross alpha, the following procedure shall be
followed:
a) Obtain the specifically identified sample container for the type of sample to be
taken, as provided by the Analytical Laboratory;
b) Add the quantity of specified preservative provided by the Analytical Laboratory to
each sample container;
c) When using a pump to sample:
(i) Place a new 0.45 micron filter on the sample tubing;
(ii) Pump the sample through the filter, and into the sample container containing
the preservative;
(iii) The pump should be operated in a continuous manner so that it does not
produce samples that are aerated in the return tube or upon discharge;
d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:
(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 50 of61
(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.
(iii) Place clean unused tubing in the peristaltic pump.
(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.
Procedures to Follow After Sampling
a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:
• Sample location
• Date and time of sample
• Any preservation method utilized
• Filtered or unfiltered
b) Immediately after sample collection, place each sample in an ice-packed cooler;
and
c) Before leaving the sampling location, thoroughly document the sampling event on
the Field Data Worksheet, by recording all pertinent data.
Upon returning to the office, the samples must be stored in a refrigerator at less than or equal
to 6° C. These samples shall be received by the Analytical Laboratory at less than or equal to
6° C. Samples will then be re-packed in the plastic ice-packed cooler and transported via
these sealed plastic containers by overnight delivery services to the Analytical Laboratory.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Field Duplicates
Attachment 2-5
Field QC Samples
Date: 06-06-12 Revision 7.2
Page 51 of61
Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.
Field duplicate samples should be as near to split samples as reasonably practicable.
Collection of field duplicates is completed as follows:
Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.
Field duplicate samples are labeled using a "false" well number such as MW-65 and MW-70.
Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples.
Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:
Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;
Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).
Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter "R" added (e.g. MW-llR).
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP)
Appendix A
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 52 of61
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Date: 06-06-12 Revision 7.2
Page 53 of61
This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Chloroform Investigation conducted pursuant to State of Utah Notice of Violation and
Groundwater Corrective Action Order (UDEQ Docket No. UGW-20-01) (the "Order").
Specifically, the Mill will use the same sampling regimen for the Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
forth below:
1) Dedicated Purge Pump/Sampling
Chloroform Investigation samples are collected by means of disposable bailer(s) the
day following the purging . The disposable bailer is used only for the collection of a
sample from an individual well and disposed subsequent to the sampling. The wells
are purged prior to sampling by means of a portable pump. Each quarterly purging
event begins at the location least affected by chloroform (based on the previous
quarters sampling event) and proceeds by affected concentration to the most affected
location. Although purging will generally follows this order, the sampling order may
deviate slightly from the generated list. This practice does not affect the samples for
these reasons: any wells sampled in slightly different order have either dedicated
pumps or are sampled via a disposable bailer. This practice does not affect the
quality or usability of the data as there will be no cross-contamination resulting from
sampling order. Decontamination of all sampling equipment will follow the
decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Chloroform Investigation Sampling Frequency, Order and Locations
The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under State of Utah Notice of Violation and Groundwater Corrective
Action Order UDEQ Docket No. UGW-20-01. Chloroform wells shall be purged
from the least contaminated to the most contaminated as based on the most recent
quarterly results.
• MW-4 • TW4-13
• TW4-1 • TW4-14
• TW4-2 • MW-26
• TW4-3 • TW4-16
• TW4-4 • MW-32
• TW4-5 • TW4-18
• TW4-6 • TW4-19
Mill -Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 54 of61
• TW4-7 • TW4-20
• TW4-8 • TW4-21
• TW4-9 • TW4-22
• TW4-10 • TW4-23
• TW4-11 • TW4-24
• TW4-12 • TW4-25
• TW4-26 • TW4-27
Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform
Investigation Program or the Groundwater Discharge Permit Monitoring Program.
3) Chloroform Investigation Sample Containers and Collection Volume
The chloroform investigation sampling program requires a specific number of
sampling containers and the collection of specific volumes of sample. Accordingly,
the following sample volumes are collected by bailer from each sampling location:
• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 100 ml container.
• For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements
Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Analytical Analytical
Parameter Method
Nitrate & Nitrite E353.1 or
(as N) E353.2
Carbon SW8260B
Tetrachloride or
SW8260C
Chloroform SW8260B
or
SW8260C
Dichloromethane SW8260B
(Methylene or
Chloride) SW8260C
Chloromethane SW8260B
or
SW8260C
Inorganic A4500-Cl B
Chloride or A4500-Cl
E
or E300.0
5) Field Parameters
Date: 06-06-12 Revision 7.2
Page 55 of61
Reporting Maximum Sample Sample
Limit Holding Preservation Temperature
Times Requirement Requirement
0.1 mg/L 28 days H2S04 to ::::; 6°C
pH<2
1.0 JlgiL 14 days HCl to pH<2 ::::; 6°C
1.0 JlgiL 14 days HCl to pH<2 ::::; 6°C
1.0 JlgiL 14 days HCl to pH<2 ::::; 6°C
1.0 Jlg/L 14 days HCl to pH<2 ::::; 6°C
1 mg/L 28 days None ::::; 6°C
Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. This includes the following wells: MW-4, MW-26,
TW4-4, TW-4-19 and TW-4-20. However, if a pumping well has been out of service
for 48 hours or more, DUSA shall follow the purging requirements outlined in
Attachment 2-3 of the QAP before sample collection.
Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.
6) Chloroform Investigation Reports
The Chloroform Investigation Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan
• Description of monitor wells
• Description of sampling methodology, equipment and decontamination
procedures
Mill -Groundwater Discharge Permit
Groundwater Monitoring .
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 56 of61
• Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples
c) Data Interpretation
• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
• Interpretation of all analytical results for each well, including a discussion
on: 1) a current chloroform isoconcentration map with one of the
isosconentration lines showing the 70 ug/L boundary, 2) graphs showing
chloroform concentration trends in each well through time and, 3)
analytical results for each well summarized in a data table, that includes
historic analytical results for each well.
• Calculate chloroform mass removed by pumping wells. Calculations
would include: 1) total historic chloroform mass removed, 2) total historic
chloroform mass removed for each pumping well, 3) total chloroform
mass removed for the quarter and, 4) total chloroform mass removed from
each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Chloroform Investigation
monitoring conducted during the quarter.
f) Copies of DUSA field records, laboratory reports and chain of custody forms.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill's
QAP.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP)
AppendixB
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 57 of61
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Date: 06-06-12 Revision 7.2
Page 58 of61
This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Nitrate Corrective Action Monitoring ("Nitrate Program") conducted pursuant to State of
Utah Stipulated Consent Agreement Docket Number UGW-09-03-A.
Specifically, the Mill will use the same sampling regimen for the Nitrate program that is
utilized for groundwater sampling under its groundwater discharge permit, as set forth in the
attached groundwater discharge permit Quality Assurance Plan (QAP), except as set forth
below:
1) Purge Pump/Sampling
The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s).The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.
Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross-
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Nitrate Program Sampling Frequency, Order and Locations
The Nitrate Program wells listed below are required to be monitored on a quarterly
basis under State of Utah Docket No. UGW-09-03-A. DUSA has submitted a
Corrective Action Plan ("CAP") as required by the Stipulated Consent Agreement.
In that CAP, DUSA has proposed the abandonment of a number of the wells listed
below. The implementation of the CAP, shall supersede any requirements contained
in this QAP and Appendix. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
• TWN-1
• TWN-2
• TWN-3
• TWN-4
• TWN-5*
• TWN-6**
• TWN-7
• TWN-8*
• TWN-9*
• TWN-10*
• TWN-11*
• TWN-12*
*Recommended for abandonment
Date: 06-06-12 Revision 7.2
Page 59 of61
• TWN-13*
• TWN-14**
• TWN-15*
• TWN-16**
• TWN-17*
• TWN-18
• TWN-19**
• Piezometer-0 1
• Piezometer-02
• Piezometer-03
**Recommended for depth to water measurements only. DUSA has proposed
that monitoring cease.
7) Nitrate Program Sample Containers and Collection Volume
The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Nitrate/Nitrite determinations, collect one sample into a 100 ml container.
• For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements
Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 06-06-12 Revision 7.2
Quality Assurance Plan (QAP) Page 60 of61
Analytical Analytical Reporting Maximum Sample Sample
Parameter Method Limit Holding Preservation Temperature
Times Requirement Requirement
Nitrate & Nitrite E353.1 or 0.1 mg/L 28 days H2S04 to S 6°C
(as N) E353.2 pH<2
Inorganic A4500-Cl B 1 mg/L 28 days None S 6°C
Chloride or A4500-Cl
E
or E300.0
9) Field Parameters
Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.
1 0) Nitrate Program Investigation Reports
The Nitrate Program Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan
• Description of monitor wells
• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples
c) Data Interpretation
• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
• Interpretation of all analytical results for each well, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
• Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
Mill -Groundwater Discharge Pennit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 06-06-12 Revision 7.2
Page 61 of61
mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate
mass removed from each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Nitrate Program monitoring
conducted during the quarter.
f) Copies ofDUSA field records, laboratory reports and chain of custody
forms.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill's
QAP.
Appendix L
Tailings and Slimes Drain Sampling Program,
Revision 2.1, July 30, 2012
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
TAILINGS CELLS, LEAK DETECTION SYSTEMS
AND SLIMES DRAINS
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Denison Mines (USA) Corp.
Suite 950, 1050 1 ih Street
Denver CO 80265
July 30, 2012
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
Contents
1.0 Introduction ............................................................................................................................... 3
2.0 Sampling Frequency and Monitoring Requirements ................................................................ 3
3.0 Field Sampling Procedures ....................................................................................................... 3
3.1 Tailings Cell Sampling .......................................................................................................... 4
3 .1.1 Sampling with a Peristaltic Pump .................................................................................. 4
3 .1.2 Sampling with a Ladle ................................................................................................... 5
3.1.3 Sampling with a Bailer ................................................................................................... 5
3.2 LDS Sampling ....................................................................................................................... 5
3.2.1 Cells 1, 2 and 3 LDS ...................................................................................................... 5
3.2.2 Cells 4A and 4B LDS .................................................................................................... 5
3.3 Slimes Drain Sampling .......................................................................................................... 5
3.4 Decontamination ................................................................................................................... 6
3.5 Field QC ................................................................................................................................ 6
3.5.1 Sample Duplicates ......................................................................................................... 6
3.5.2 Trip Blanks ...................................................................................................................... 6
3.5.3 Rinsate Blank Samples .................................................................................................. 6
4.0 QA and Data Evaluation ........................................................................................................... 7
5.0 Laboratory Analysis ................................................................................................................. 7
5.1 Analytical Quality Control ............................................................................................... 7
6.0 Reporting .......................................................................... ., ....................................................... 8
7.0 Agency Notification ................................................................................................................. 8
2
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
1.0 Introduction
This Sampling and Analysis Plan ("SAP") describes the procedures for sampling the tailings cells, Leak
Detection Systems ("LDS") and slimes drains at the White Mesa Mill in Blanding, Utah as required under
Part I.E.1 0 of the Groundwater Discharge Permit ("GWDP") No. UGW3 70004.
The objective of the tailings cell, LDS and slimes drain sampling is to collect annual samples from the
locations identified below as required by the GWDP. This SAP specifies the sample collection
requirements, procedures, analytical methodologies, and associated Quality Control ("QC") checks,
sample handling protocols and reporting requirements for the annual tailings, LDS and slimes drain
sampling program.
2.0 Sampling Frequency and Monitoring Requirements
The sampling frequency and sample monitoring requirements for the tailings cells, LDS and slimes drains
are as specified in the GWDP. Sampling is required to be conducted on an annual basis in August of each
year for the solutions in tailings Cells 1, 3, 4A, and 4B, the solutions in the slimes drains in Cells 2, 3, 4A,
and 4B (for Cells 3, 4A, and 4B after the commencement of dewatering), the solutions in the LDS in
Cells 4A and 4B and any detected solutions in the LDS in Cells 1, 2, and 3 at the time of the August
sampling event. Sampling locations are shown in Attachment 1.
3.0 Field Sampling Procedures
The field sampling and data collection program will obtain samples to be analyzed for the groundwater
compliance parameters listed in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using methods specified in the currently approved Denison Quality Assurance Plan
("QAP") for Groundwater. Additionally per the GWDP requirements, tailings cell, LDS and slimes drain
samples will be collected and analyzed for Semivolatile Organic Compounds ("SVOCs"). Per the
GWDP, the SVOCs will be analyzed by Environmental Protection Agency ("EPA") Method 8270D.
Minimum detection limits or reporting limits for tailings, LDS and slimes drain samples for those
analytes which have Groundwater Quality Standards (GWQSs") defined in Table 2 of the GWDP, will be
less than or equal to the GWQS. The minimum detection or reporting limits for total dissolved solids
("TDS") sulfate, chloride and SVOCs are specified in the GWDP and are:
• TDS will be less than or equal to 1,000 mg/L,
• Sulfate will be less than or equal to 1,000 mg/L,
• Chloride will be less than or equal to 1 mg/L, and
• SVOCs will have reporting limits less than or equal to the lower limit of quantitation for
groundwater listed in Table 2 ofEPA Method 8270D Revision 4, dated February 2007.
Field activities include collecting samples, recording field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling information will be recorded on the Tailings and Slimes Drain Field Sheet, (or its equivalent),
included in Attachment 2.
3
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
Sample handling and preservation requirements for tailings cell, LDS and slimes drain samples are as
specified in the QAP, except for SVOCs which are not routinely collected for any other Mill sampling
program. SVOCs do not require any chemical preservation per EPA Method 8270D; however, SVOCs
are required to be chilled. Receipt temperatures, for all analytes except SVOCs, are as specified in the
QAP. The receipt temperature requirement for SVOCs is less than or equal to 6°C.
Sample collection procedures for tailings cell, LDS and slimes drain samples are as described below.
Where more than one sampling method is described, field personnel will choose a sampling method based
on field conditions and safety considerations at the time of sampling.
The gross alpha and metals sample aliquots from the tailings cells, LDSs and slimes drains will not be
field filtered or field preserved due to safety concerns associated with the filtering apparatus and the
backpressure created by the increased viscosity of these samples. The gross alpha and metals aliquots
will be filtered and preserved by the analytical laboratory within 24 hours of receipt. Field preservation of
the gross alpha and metals sample aliquots may interfere with the laboratory's ability to filter the samples
upon receipt. It is important to note that field preservation of the samples is to preclude biological growth
and prevent the inorganic analytes from precipitating. Based on the 2011 field data, the tailings, LDS and
slimes drain samples were at a pH of 3.0 or less at the time of collection without additional preservative.
The addition of preservatives in the field would add minimal if any protection from biological growth or
precipitation. The VOC sample aliquots will be preserved in the field.
Clean sample containers utilized for this sampling effort will be provided by the analytical laboratory.
3.1 Tailings Cell Sampling
As noted in Section 2.0, sampling is required to be conducted on an annual basis in August of each year
for the solutions in tailings Cells 1, 3, 4A, and 4B.
Tailings cell samples may be collected using a ladle, a peristaltic pump or a bailer. The procedures for
each sampling method are described below. In all instances the sampling equipment will be either
disposable or dedicated and decontamination procedures and rinsate blanks will not be required.
Sampling equipment will be inert and non-reactive.
3 .1.1 Sampling with a Peristaltic Pump
Tailings samples may be collected using a peristaltic pump. Samples collected with the peristaltic pump
will be collected by extending collection tubing approximately 6ft. from the edge ofthe sampling station.
The tubing will be attached to a horizontal rod with sufficient tubing attached to lower the suction end of
the tubing to approximately 1/3 of the distance between the liquid surface and the underlying solids. The
collection tubing will be attached to a peristaltic pump. The tubing will be replaced prior to each use to
preclude cross contamination and to eliminate the need for decontamination of sampling equipment. Due
to the nature of the peristaltic pump, sample fluids do not come in contact with any surface other than the
interior of the tubing, and decontamination of the pump or rinsate blanks is therefore not required. The
sample containers will be filled directly from the peristaltic pump outflow. Field filtering and field
preservation of the gross alpha and metals sample aliquots will not be required, as noted in Section 3.0.
4
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
3.1.2 Sampling with a Ladle
Tailings samples may be collected using a ladle. Samples collected with the ladle will be collected by
dipping the ladle directly into the tailings solution taking care not to stir up any solids below the liquid
surface. Sample bottles will be filled directly from the ladle. Ladles used for sampling will be dedicated
to each location or will be disposed after each use to preclude cross contamination and to eliminate the
need for decontamination of sampling equipment. Field filtering and field preservation of the gross alpha
and metals sample aliquots will not be completed as noted in Section 3.0.
3.1.3 Sampling with a Bailer
Tailings samples may be collected using a disposable bailer. Samples collected with the bailer will be
collected by submerging the bailer into the tailings solution and allowing it to fill, taking care not to stir
up any solids below the liquid surface. The bailer will withdrawn from the tailings solution and the
sample bottles will be filled directly from the bailer. Bailers used for sampling will be disposed after each
use to preclude cross contamination and to eliminate the need for decontamination of sampling
equipment. Field filtering and field preservation of the gross alpha and metals sample aliquots will not be
required as noted in Section 3.0.
3.2 LDS Sampling
The LDS systems will be sampled as noted below.
3.2.1 Cells 1, 2 and 3 LDS
The Cells 1, 2 and 3 LDSs will only be sampled if there is fluid present during the August sampling
event. If fluids are present during the annual August sampling event, samples will be collected using the
dedicated pumps installed in the riser pipe. Fluid level will be measured using the electronic pressure
transducers currently installed in the LDS systems in the Cells. Samples will be collected directly from
the pump outflow lines into the sample containers. Field filtering and field preservation of the gross alpha
and metals sample aliquots will not be required as noted in Section 3.0.
3.2.2 Cells 4A and 4B LDS
Solution from the Cell 4A and 4B LDS will be collected into a dedicated stainless steel bucket. Sample
bottles will be filled from the stainless steel bucket using either the peristaltic pump or a ladle. If the
peristaltic pump is used to transfer the solution to the sample bottles, the tubing in the pump will be
disposed of and not reused, thereby eliminating the need for decontamination of equipment or rinsate
blanks. If a ladle is used to transfer the solution to the sample bottles, the ladle will be either disposed of
or will be dedicated to that location thereby eliminating the need for decontamination or rinsate blanks.
Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as
noted in Section 3.0.
3.3 Slimes Drain Sampling
Once a tailings cell has started de-watering procedures, a sample should be collected from the slimes
drain system. At this time Cell 2 is the only slimes drain that should be sampled. The location of the
slime drain for Cell2 is depicted on Attachment 1. While Cell 3,Cell4A and 4B are each equipped with a
5
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
slimes drain sample access location, these Cells have not started dewatering and the slimes drain will not
be sampled until dewatering operations are underway. Because dewatering in Cell 2 is ongoing, this cell
will be included in the annual sampling effort. The CeJJ 2 slimes drain will be sampled using a disposable
bailer.
A disposable bailer will be used to collect Cell 2 slimes drain samples and will be used to fill clean
sample containers. The bailer will be disposed of and not reused, thereby eliminating the need for
decontamination of equipment or rinsate blanks.
3.4 Decontamination
Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable
sampling equipment is used to collect samples. Decontamination procedures will be as described in the
approved QAP. Rinsate blanks will be collected daily after decontamination of sampling equipment. If
disposable or dedicated sampling equipment is used to collect samples, then rinsate blanks will not be
coJJected.
3.5 Field QC
The field QC samples generated during the annual tailings cell, LDS and slimes drain sampling event will
include sample duplicates, trip blanks, and rinsate blank samples as appropriate.
3.5 .l Sample Duplicates
Sample duplicates will be collected at a frequency of one duplicate per 20 field samples. Sample
duplicates will be collected by filling the sample container for a certain analytical parameter for the
duplicate immediately following the collection of the parent sample for that parameter.
3.5.2 Trip Blanks
Trip blank samples will be included in every shipment of samples that has field samples to be analyzed
for Volatile Organic Compounds ("VOCs"). Trip blank samples are VOC sample containers filled by the
analytical laboratory with laboratory grade deionized water and shipped to the site. Trip blank samples
are taken into the field with the sample containers, never opened, and kept with the field samples from
collection through shipment to the analytical laboratory for analysis. Trip blanks are analyzed to
determine if the sample concentration of VOCs have been effected by the "trip" from collection through
shipment.
3.5.3 Rinsate Blank Samples
Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated,
reusable sampling equipment is used to collect samples. If the sampling equipment has a disposable
component that comes in contact with the samples and the component is changed prior to sampling at
each location then a rinsate blank sample will not be collected. For example, if a peristaltic pump is used
to collect and filter tailings, LDS and slimes drain samples and the tubing used in the peristaltic pump is
changed at each location and never reused for more than one sample, no rinsate blank sample would be
required.
6
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
4.0 QA and Data Evaluation
The Permit requires that the annual tailings cell LDS and slimes drain sampling program be conducted in
compliance with the requirements specified in the Mill's approved QAP, the approved SAP and the
Permit itself. To meet this requirement, the data validation for the tailings cell LDS and slimes drain
sampling program will utilize the requirements outlined in the QAP, the Permit and the approved SAP as
applicable. The Mill QA Manager will perform a QA/QC review to confirm compliance of the
monitoring program with requirements of the Permit, QAP and SAP. As required in the QAP, data QA
includes preparation and analysis of field QC samples, review of field procedures, an analyte
completeness review, and quality control review of laboratory data methods and data.
The QAP and the Permit identifY the data validation steps and data quality control checks required for the
tailings cell LDS and slimes drain monitoring program. Consistent with these requirements, the Mill QA
Manager will performed the following evaluations: a field data QA/QC evaluation, a receipt temperature
check, a holding time check, an analytical method check, a reporting limit check, a trip blank check, a
QAIQC evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each
laboratory's reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
As previously stated, samples will be analyzed for the groundwater compliance parameters listed in Table
2 of the GWDP and SVOCs using the analytical methods specified in the approved QAP and EPA
Method 8270D for SVOCs. The Laboratories used for the tailings cell LDS and slimes drain sampling
program will be Utah certified as required by the GWDP Part l.E.6 (c). Laboratory data will be validated
as described in the approved QAP and as described in Section 4.0 above. Analytical QC is described
below.
5.1 Analytical Quality Control
Analytical QC samples and protocols are described in the approved QAP. Laboratory QC procedures will
meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for
by the State ofUtah.
The analytical QC samples included at least the following: a method blank, a laboratory control spike
("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where
applicable. It should be noted that:
• Laboratory fortified blanks are equivalent to LCSs.
• Laboratory reagent blanks are equivalent to method blanks.
• Post digestion spikes are equivalent to MSs.
• Post digestion spike duplicates are equivalent to MSDs.
• For method E900.1, used to determine gross alpha, a sample duplicate was used instead of a
MSD.
7
Tailings Cell, Leak Detections System and Slimes Drain
Sampling and Analysis Plan
Revision 2.1
July 30, 2012
All qualifiers, and the corresponding explanations reported in the QA/QC Summary Reports for any of
the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager.
The effect on data usability will be discussed in the evaluation section of the annual report.
6.0 Reporting
A Tailings Cells Wastewater Quality Sampling Report will be included with the 3rd Quarter Groundwater
Monitoring Report, due each year on December 151•
Each Tailings Cel1 Wastewater Sampling Report will include the following information:
• Introduction,
• A description of sampling methodology, equipment and decontamination
procedures identifY all quality assurance samples, e.g. trip blanks, equipment
blanks, duplicate samples,
• Analytical data interpretation for each tailing cell, slimes drain, and leak detection system
sample,
• A written summary and conclusions of analytical results,
• A table summarizing historic analytical results,
• A QA evaluation,
• All field data sheets accompanying the sampling event,
• Copies of the laboratory reports, and
• A "Tailings and Slime Drains System Sample Locations Map".
7.0 Agency Notification
At least 30 days advanced notice will be given to DRC prior to sampling activities described under
this Tailings and Slimes Drain Sampling Program in order to allow the Executive Secretary to collect
split samples of all tailing cell wastewater sources.
8
Attachment 1
9
,...
t 0 0..
MW..02 •
\
MW..03 •
5CO' 0 500' 1,000'
SCAlE: 1• a 1,000'
CELL 1
MW-17 •
33
PIEZ·2
PIEZ-3 •
•
OTW4..S
TW4·1flTW4•9
0 OTW4-3 OTW4-12
•1'bTW4·11 OTW4-13
TW4-~-8
OTW4·1
OTW4-4CTW4·14
OTW4·6
PIEZ-4 •
PIEZ-5 •
Denison Mines (USA) Corp
San Juan
Aurnor: unknown
ANNUAL TAILINGS
SAMPLE LOCATIONS
Qale: Aug. 2008 Orabel By:
10 .,
0 /t_
1.\ :c ·0 •··
CELL 1
LEAK
DETECTION
SAMPLE
-==-=====-------~·~~~--~~--~W4& LOCATION
32
1-21
MW-D2 •
CELL 48
MW-03 •
500' 1,000' -.......1'-----0 500'
SCALE: 1' •1,000'
MW-17 •
CELL 2
33
PIEZ·2 •
PIEZ-3 •
OTW4-6
M ~26 TW4·1PJW4-9
0 OTW4-3 OTW4·12
OJW4-13
1W4-n8.a
OTW4·1
PIEZ-4 •
PIEZ·5 •
Denison Mines (USA) Corp
REVISIONS roject: White Mesa Mill
Date By County: San Juan State: UT
oca110n: 1~00 .~G~M~----~----------------------~
SLIMES AND LEAK DETECTION
SAMPLE LOCATIONS
Aulhor. unknown DIBltod By:
Attaclunent 2
10
Field Data Record-Tailings, LDS and Slimes Drain Sampling
Location: _________ Sampling Personnel: _________ _
Is this a Slimes Drain? DYes D No
If this is a Slimes Drain, measure depth to wastewater immediately before sampling.
DTW immediately before sampling (slimes only): ___________ _
Weather Conditions at Time of Sampling: _________________ _
Field Parameter Measurements:
-pH
-Temperature (°C) -----------------
Analytical Parameters/Sample Collection Method:
Parameter Sample Taken Filtered i Sampling Method
"'= --
VOCs o Yes DNo DYes DNo
THF DYes DNo o Yes DNo
Nutrients o Yes DNo o Yes oNo
Other Non o Yes DNo DYes oNo
Radiologies
Gross Alpha DYes DNo DYes oNo
SVOCs DYes DNo o Yes oNo
Conductivity DYes DNo o Yes oNo
QC Samples Associated with this Location:
D Rinsate Blank
D Duplicate
Peristaltic r Bailer""
Pump
D D
D D
D D
0 D
D D
D D
D D
Duplicate Sample Name: ____________ _
Ladle
D
D
D
0
D
D
D
Lab
Name
Notes: __________________________________ _
Appendix M
Contingency Plan, 12/11 Revision: DUSA-4
White Mesa Mill-Standard
Operating Procedures
Book # 19-Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 1 of 15
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
As Contemplated by Part I.G.4(d)
of
State of Utah Groundwater Discharge Permit No.UGW370004
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver CO 80265
December 2, 2010
White Mesa Mill -Standard
Operating Procedures
Book # 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 2 of 15
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................... 3
2.0 PURPOSE ................................................................................................................ 3
3.0 GROUNDWATER CONTAMINATION ............................................................... 3
3.1 Notification ........................................................................................................... 4
3.2 Continuation of Accelerated Monitoring ............................................................. 4
3.3 Submission of Plan and Timetable ....................................................................... 4
3.4 Groundwater Remediation Plan ........................................................................... 5
4.0 MILL DISCHARGE VIOLATIONS-INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS ............................................................................................................... 6
4.1 Notifications ......................................................................................................... 6
4.2 Field Activities ..................................................................................................... 6
4.3 Request for Approvals and/or Waivers ................................................................ 7
5.0 DMT VIOLATIONS ............................................................................................... 7
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations ....... 7
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems .............. 8
5.3 Excess Cell4A Leak Detection System Fluid Head or Daily Leak Rate ............ 9
5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate ........... 10
5.5 Excess New Decontamination Pad Leak Detection System Fluid Head ........... 11
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad .... 11
5.7 Excess Elevation For Tailings Solids ................................................................. 12
5.8 Roberts Pond Wastewater Elevation .................................................................. 13
5.9 Feedstock Storage Area ....................................................................................... 13
5.10 Mill Site Chemical Reagent Storage .............................................................. 14
5.11 Failure to Construct as per Approval.. ............................................................ 15
5.12 Failure to Comply with Stormwater Management and Spill Control
Requirements ................................................................................................................ 15
White Mesa Mill-Standard
Operating Procedures
Book # 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 3 of 15
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No. UGW370004
1.0 INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
"GWDP") for Denison Mines (USA) Corp.'s ("Denison's") White Mesa Uranium Mill
(the "Mill"). The GWDP specifies the construction, operation, and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into the underlying aquifer.
2.0 PURPOSE
This Contingency Plan (the "Plan") provides a detailed list of actions Denison will take to
regain compliance with GWDP limits and Discharge Minimization Technology Plan
("DMT") and the Best Available Technology Plan ("BAT") requirements defined in Parts
I.C, I.D, and I.H.4 of the GWDP. The timely execution of contingency and corrective
actions outlined in this Plan will provide Denison with the basis to exercise the
Affirmative Action Defense provision in Part I.G.3.c) ofthe GWDP and thereby avoid
noncompliance status and potential enforcement action 1•
The contingency actions required to regain compliance with GWDP limits and DMT and
BAT requirements defined in Parts I.C, I.D, and I.H.4 of the GWDP are described below.
3.0 GROUNDWATER CONTAMINATION
Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
1 Part I.G.3.c) of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications, that the failure was
not intentional or caused by Denison's negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions ofUCA 19-5-107 have not been violated.
White Mesa Mill -Standard
Operating Procedures
Book # 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 4 of 15
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to Part I.G.2 of the GWDP.
When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:
3.1 Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part I.G.4.a) of the GWDP.
3.2 Continuation of Accelerated Monitoring
Denison will continue accelerated sampling for the parameter in that compliance
monitoring well pursuant to Part I.G.l ofthe GWDP, unless the Executive Secretary
determines that other periodic sampling is appropriate, until the facility is brought into
compliance, as required under Part I.G.4.b) of the GWDP.
If the accelerated monitoring demonstrates that the monitoring well has returned to
compliance with respect to a parameter in a well, then, with written approval from the
Executive Secretary, Denison will cease accelerated monitoring for that parameter, and
will continue routine monitoring for that parameter.
3.3 Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT or
BAT will be reestablished, as required under part I.G.4.c) of the GWDP. This plan will
normally include, but is not limited to:
a) The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
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b) A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
c) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
contamination. This will normally include a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone, the analytical parameters to be obtained, the
samples of ground water to be taken, and any other means to measure and
characterize the affected ground water and contamination zone; and
d) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions
to restore and maintain groundwater quality to ensure that permit limits will not
be exceeded at the compliance monitoring point and that DMT and BAT will be
reestablished, as well as actions that merely allow natural attenuation to operate
and actions that involve applying for Alternate Concentration Limits ("ACLs").
ACLs require approval of the Water Quality Board prior to becoming effective.
If groundwater remediation is required, Denison will prepare and submit for
Executive Secretary approval a Ground Water Remediation Plan, as described in
Section 3.4 below.
3.4 Groundwater Remediation Plan
If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary. The Ground Water Remediation Plan will
normally include, but is not limited to:
a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s) or other locations
approved by the Executive Secretary, by removing the contaminants, treating
them in place, or by other means as approved by the Executive Secretary;
b) A description of the remediation monitoring program to demonstrate the
effectiveness of the plan; and
c) Descriptions ofhow corrective action will apply to each source of the pollution.
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Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.
4.0 MILL DISCHARGE VIOLATIONS-INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS
Part I.C.2. of the GWDP provides that only lle.(2) by-product material authorized by the
Mill's State of Utah Radioactive Materials License No. UT-2300478 (the "Radioactive
Materials License") shall be discharged to or disposed of in the Mill's tailings cells.
Part I.C.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as lle.(2) material is prohibited.
In the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials") to the Mill's tailings cells, Denison will, subject to any specific requirements
ofthe Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
4.1 Notifications
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery.
4.2 Field Activities
a) Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
b) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill
personnel will nevertheless mark or record the location of the Unauthorized
Materials in the tailings cells;
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c) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from
the tailings cells; and
d) Denison will dispose of the removed Unauthorized Material under applicable
State and Federal regulations with the approval of the Executive Secretary.
4.3 Request for Approvals and/or Waivers
If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will, in accordance with a schedule to be approved by the
Executive Secretary:
a) Submit a written report to the Executive Secretary analyzing the health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
b) Apply to the Executive Secretary for any amendments that may be required to
the GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal ofthe Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health, safety and the environment; and
c) Make all applications required under the United States Nuclear Regulatory
Commission's ("NRC's") Non-lle.(2) Disposal Policy (NRC Regulatory Issue
Summary 2000-23 (November 2000), Interim Guidance on Disposal of Non-
Atomic Energy Act of 1954, Section 11 e. (2) Byproduct Material in Tailings
Impoundments), including obtaining approval ofthe Department of Energy as
the long term custodian of the Mill's tailings, in order to obtain approval to
permanently dispose of the Unauthorized Material in the Mill's tailings cells.
5.0 DMT VIOLATIONS
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations
Part I.D.2 and Part I.D.6.d) of the GWDP provide that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorized by the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet, as measured from the top of the flexible
membrane liner ("FML").
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In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirements of the Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Upon discovery, Mill personnel will cease to discharge any further tailings to
the subject tailings cell, until such time as adequate freeboard capacity exists in
the subject tailings cell for the disposal of the tailings;
d) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly pump
fluids from the subject tailings cell to another tailings cell until such time as the
freeboard limit for the subject tailings cell is in compliance. If there is no room
available in another tailings cell, without violating the freeboard limit of such
other cell, then, as soon as reasonably practicable, Mill personnel will cease to
discharge any further tailings to any tailings cell until such time as adequate
freeboard capacity exists in all tailings cells;
e) If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject
tailings cell will be reduced through natural evaporation; and
f) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems
Part I.D.3.b)l) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable, in accordance with the Mill's currently approved DMT Monitoring Plan, and
that for Cell3, this requirement shall apply only after initiation of de-watering operations.
Similarly, Part I.D.6.c) of the GWDP provides that after Denison initiates pumping
conditions in the slimes drain layer in Cell 4A, Denison will provide: 1) continuous
declining fluid heads in the slimes drain layer, in a manner equivalent to the requirements
found in Part I.D.3.b); and 2) a maximum head of 1.0 feet in the tailings (as measured
from the lowest point of the upper FML) in 6.4 years or less.
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In the event that the average wastewater head in the slimes drain access pipe for Cell2 or,
after initiation of de-watering activities, Cell 3 or initiation of pumping conditions in the
slimes drain layer in Cell 4A exceeds the levels specified in the DMT Monitoring Plan,
Denison will, subject to any specific requirements of the Executive Secretary as set forth
in any notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to minimize the chance of a recurrence.
5.3 Excess Cell4A Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.6.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
4A shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.6.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell4A shall not exceed 24,160 gallons/day.
In the event that the fluid head in the LDS for Cell 4A exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell4A LDS
exceeds 24,160 gallons/day, Denison will, subject to any specific requirements ofthe
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
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c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to remediate the exceedance and to minimize the chance of
a recurrence.
5.4 Excess Cell4B Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.13.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
4B shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.13.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell4B shall not exceed 26,145 gallons/day.
In the event that the fluid head in the LDS for Cell4B exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell4B LDS
exceeds 26,145 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
If not due to an identified equipment failure, Denison will perform a root cause analysis
of the exceedance and will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
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5.5 Excess New Decontamination Pad Leak Detection System Fluid Head
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 in each of the three settling tanks, a vertical
inspection portal has been installed between the primary and secondary containment of
each settling tank.
Section 3.1 (e) of the Mill's DMT Monitoring Plan provides that the fluid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete floor in
any ofthe three standpipes. Compliance is defined in Part I.D.l4 a) ofthe GWDP as a
depth to standing water present in any of the LDS access pipes of more than or equal to
6.2 feet as measured from the water measuring point (top of access pipe).
In the event that the fluid head in the standpipe for a settling tank exceeds 0.10 feet above
the concrete floor in the standpipe, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within the
ensuing 24 hours followed by a written notification within five days;
c) Mill personnel will promptly pump the fluid from the settling tank's LDS as
well as the fluids in the settling tank into another settling tank or into an active
tailings cell, or other appropriate containment or evaporation facility approved
by the Executive Secretary, until such time as the cause of the exceedance is
rectified or until such time as otherwise directed by the Executive Secretary; and
d) Denison will perform a root cause analysis of the exceedance and, if
appropriate, will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad.
Soil and debris will be removed form the wash pad of the NDP in accordance with the
currently approved DM1 Monitoring Plan. In the event that racks ofgreater than 1/8
inch (width) are observed on the concrete wash pad, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
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a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) The NDP shall be taken out of service and the cracks will be repaired utilizing
industry standard materials and procedures appropriate for the defect within five
working days of discovery. Following recommended cure times, the cracks or
deficiencies will be re-inspected and, if acceptable, the NDP will be placed back
into service.
c) A record of the repairs will be maintained as a part of the inspection records at
the White Mesa Mill.
5.7 Excess Elevation For Tailings Solids
Part I.D.3.c) ofthe GWDP provides that upon closure of any tailings cell, Denison shall
ensure that the maximum elevation of the tailings waste solids does not exceed the top of
the FML.
In the event that, upon closure of any tailings cell, the maximum elevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) To the extent reasonably practicable, without causing a violation ofthe
freeboard limit in any other tailings cell, Mill personnel will promptly remove
tailings solids from the subject tailings cell to another tailings cell, or other
location approved by the Executive Secretary, until such time as the maximum
elevation of the tailings waste solids in the subject tailings cell does not exceed
the top of the FML; and
d) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.
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5.8 Roberts Pond Wastewater Elevation
Date: 12/11 Revision: DUSA-4
Page 13 ofl5
Part I.D.3.e) of the GWDP provides that the Permittee shall operate Roberts Pond so as to
provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Celli within 72
hours of discovery, as specified in Part I.D.3.e) of the GWDP.
In the event that, Denison fails to remove the excess wastewater within 72 hours of
discovery, Denison will, subject to any specific requirements of the Executive Secretary
as set forth in any notice, order, remediation plan or the equivalent, implement the
following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.9 Feedstock Storage Area
Part I.D.3.f) and Part I.D.ll of the GWDP provide that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
eastern portion of the Mill site area described in Table 4 ofthe GWDP, and that storage
of feedstock materials at the facility outside that area shall be performed in accordance
with the provisions ofPart I.D.ll ofthe GWDP.
In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.f) and Part I.D.ll of the GWDP, Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Mill personnel will:
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(i) move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
(ii) ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in
accordance with the provisions ofPart I.D.11 ofthe GWDP; and
(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers or
otherwise dealt with in accordance with the provisions of Part I.D .11 of
the GWDP, and any impacted soils will be removed and will be deposited
into the Mill's active tailings cell; and
d) Denison will perform a root cause analysis of the non-compliant activity and
will implement new procedures or change existing procedures to minimize the
chance of a recurrence.
5.10 Mill Site Chemical Reagent Storage
Part I.D.3.g) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes ofreagent(s) that might be released at any individual storage area, and that for
any new construction of reagent storage facilities, the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.
In the event that Denison fails to provide the required secondary containment required
under Part I.D.3.g) of the GWDP, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and
c) Denison will promptly remediate any spilled re-agent resulting from the failure
to provide the required secondary containment under Part I.D .3 .g) of the
GWDP, by removal of the contaminated soil and disposal in the active tailings
cell.
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5.11 Failure to Construct as per Approval
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Part I.D.4 of the GWDP provides that any construction, modification, or operation of new
waste or wastewater disposal, treatment, or storage facilities shall require submittal of
engineering design plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.
In the event that, any new waste or wastewater disposal, treatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.12 Failure to Comply with Stormwater Management and Spill Control Requirements
Part I.D.lO ofthe GWDP provides that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the Mill facility in accordance with the
currently approved Stormwater Best Management Practices Plan.
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Storm water Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery; and
c) To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill's approved Storm water Best
Management Practices Plan. To the extent it is no longer practicable to so
manage any such spill, Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
Appendix N
lVhite Mesa Mill Containerized Alternate Feedstock Material Storage Procedure, PBL-19,
Revision: 1.0, December 18, 2012
No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 1 STANDARD OPERATING PROCEDURES Page 1 of3
Date: December 18, Title: Containerized Alternate Feedstock Material Storage
2012 Procedure
1.0 Purpose
The purpose of this procedure is to assure that storage of feedstock material is conducted in a
manner so as to preclude the release of Mill feed! material to the environment.
2.0 Scope
Feed materials delivered to the White Mesa Mill must be stored in a manner which precludes the
release of the materials to the environment. In the case ofbulk materials, such as unrefined
natural ores and alternate feeds delivered in inter-modal containers, these materials are offloaded
from the truck or shipping container directly onto the approved ore pad where migration of
material is precluded by the pad's design and operating procedures (i.e. low permeability pad
material, dust control procedures and limited stockpile height). However, certain feeds are
received in drums or other containers which serve to effectively contain the material during
storage and, as such, are amenable for storage either on the ore pad or at locations other than the
ore pad. It is the intent of this procedure to describe the environmental safety precautions
utilized for contained feed storage.
3.0 Procedure
3.1 Contained Feed Material Inspections
All contained feed materials received at the White Mesa Mill are inspected upon
arrival to determine that the containers are not leaking and to assure container
integrity prior to placing the material into storage. Each container will be
observed on all sides for damage or leakage of contents. All containers exhibiting
signs of leakage will be re-packed or placed in over-pack containers prior to
placing the materials into storage. Dented drums are acceptable if the dent is not
located near a seam or when the dent is n.ot accompanied by a damage crease on
the drum surface. Drums damaged by dents near the seam, crease damaged
drums or containers that have been otherwise compromised during shipment are
re-packed or placed in over-pack containers prior to storage. Containers which
are not damaged at the time of receipt are transferred directly for placement at the
storage location.
3.2 Storage Locations
3.2.1 Defined Feedstock Storage
Feedstock materials stored at the defined storage location indicated on the
map attached hereto as Attachment A) the "Defined Feedstock Area" can
be stored in containers or in bulk form and are subject to the routine
inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT) Monitoring Plan in
Section 3.3 of the Mill's Environmental Protection Manual.
I \
No.: PBL-19
Rev. No.: 1
!. ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 2 of3
Date: December 18,
2012
Title: Containerized Alternate Feedstock Material Storage
Procedure
3.2.2 Storage of Contained Feeds in Location Other Than the Defined Feedstock
Area
a) Over-pack Containers
Materials received or transferred into over-pack containers can be stored at
locations other than the Defined Feedstock Area absent a hardened ground surface
or containment berms due to the fact that the over-pack container provides a
secondary containment for the packaged material. Over-pack materials are
subject to the routine inspections described by the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT) Monitoring
Plan at Section 3.3.
b) Hardened Surface Storage Locations
Contained feed materials, including materials in containers which have not been
provided with over-pack protection, can be stored at locations other than the
Defined Feedstock Area when a hardened ground surface storage location is used
and has been provided with containment berms. These materials are subject to the
routine inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT) Monitoring Plan at Section
3.3.
c) Single Lined Containers Stored Outside the Defined Feedstock Area
Where Hardened Surfaces and Containment Berms Are Not Utilized
Contained feeds can also be stored in locations, other than the Defined Feedstock
Area, that have been selected to avoid impact by site drainage and/or pooling.
Prior to storage at these locations, planks or pallets are placed beneath the drum
storage locations in order to raise the container from the ground surface and avoid
corrosion from water which may accumulate during precipitation events (despite
site selection) and from rusting due to soil moisture when drums are stored
directly on the ground. These contained materials are subject to the more
particular storage protocols and inspections outlined below.
3.3 Storage Protocol Single Lined Containers
In accordance with MSHA requirements, container storage must be implemented
in such a manner as t limit the potential for a container to tip or fall onto a worker.
For drummed materials, the agency limits such stacks to three drums in height due
to stability considerations. In keeping with these concerns, Denison will
configure single lined storage drums (stored off the Designated Feedstock Area)
in rows no more than two containers wide at the base and may place a one-
container row either on top of a single row or in the middle of a lower two-
container row, in each case so as to straddle the tops of drums in the lower
container row(s). This stacking configuration distributes the single upper row
No.: PBL-19 ENERGY FUELS RESOURCES (USA) lNC.
Rev. No.: 1 STANDARD OPERATING PROCEDURES Page 3 of3
Date: December 18, Title: Containerized Alternate Feedstock Material Storage
2012 Procedure
across bottom row(s) of containers in such a manner as to hold the bottom row(s)
from leaning and allowing for limited stacking on top of these lower row(s).
accordingly, when stacking is necessary, this configuration minimizes the risk of
falling drums, limits stacking height for safety reasons and allows for a thorough
inspection of each of the individual containers from the outside of the container
row(s).
3.4 Single Lined Container Storage Area Inspections
The single lined container storage area(s) that are off of the Designated Feedstock
Area will be inspected on a weekly basis (and after significant precipitation
events) on both sides of any row in order to assure that the stored materials
remain intact, that standing water has not accumulated and that materials are not
leaking or migrating from the storage area.
3.5 Single Lined Container Storage Inspection Records
Denison will record all instances where single lined containers are received
damaged (or leaking) and require re-packing or the provision of an over-pack
container. This information will be recorded on a container receipt form (see
Attachment B) which documents the receipt of drummed materials to be stored in
locations other than the Defined Feedstock Area. Similarly, each weekly
inspection shall be recorded on the inspection form referred to in the White Mesa
Mill Tailings Management System Discharge Minimization Technology (DMT)
Monitoring Plan at Attachment A-3 and attached as Attachment C to this
procedure. Such inspections require the documentation of container condition,
the drainage conditions in the storage location, the presence of leakage, if any,
and any corrective actions taken due to leakage of containers or standing water at
the storage location.
Attachment A
(
l
)
Denison Mines (USA) Corp. JD
ProjBtt WHITE MESA MILL
Feedstock Storage Area Map
Attachment B
)
Containerized Alternate Feed Receipt
Inspection
Date:----------
Inspector:---------
Number of containers/drums in shipment:--------
Radiation Activity Levels:----------
Location of Storage:------------
Observations (note dented or damaged drums):
Corrective Action Taken for Damaged Drums:
Inspector Signature
Attachment C
( ( -
)
(
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-3
7/12 Revision: Denison12.1
Page 19 of26
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through _____ Date oflnspection:. _______ _
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: ___ _
comments: __________________________________ _
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no: __ _
comments (e.g., conditions of containers); ________________ _
Are all sumps and low lying areas free of standing solutions?
Yes: No: __ _
lf"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: ---Commeo~: _________________________________________________________ _
E:\Mill SOP MastcrCopy\Book II_Environmental Procedures\07 License Renewai\EFR\DMT Plan July 2012 Rev 12 l.doc
(
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
Other comments:
7/12 Revision: Denisonl2.1
Page 20 of26
E:\Mill SOP Master Copy\Book ll_Envlronmental Procedures\07 License Renewai\EFR\DMT Plan July 20 12 Rev 12 I. doc
Appendix 0
White Mesa Mill Chemical Inventory
Location Key
Chern Lab CL
Maintenance Shop/Ware house MSW
Bulk Around the Mill Mill
Chemical Name
1,10 Phenanthroline
1,10 Phenanthroline Ferrous Sulfate
1,2-Cyclohexylene Dinitrilo
Tetraacetic Acid
1,4 Dioxane
1,5 Diphenylcarbazone
1-Amino-2-Naphthol-4-Sulfonic Acid
1-Butanol
1-Ethyl-2( ( 1 ,4dimethy 1-2-phenyl-6-
pyrimidiny lidenemethal) Quinolinium
Chloride
1-Hydroxyethylidene diphosphoric acid
3, 6-disulfonic Acid Disodium Salt
2-(5-Bromo-2-pyridylazo )-5-
( diethy I amino )phenol
2,2-BiPyridine
2-Butoxy ethanol
2-Carboxy-2'-hydroxy-5'-Sulfoformazyl
2-Propanol (Isopropanol)
3,6-Disulfaric-Acid Disodium
3-(i-decoxy) Propanoic Acid
3-(n-octoxy-n-decoxy) Propanoic Acid
4,4,4-Trifluoro-1-(2-Thienyl)-1 ,3-
Butenediane
4-amine-1-naphthalene Sulfuric Acid
4-Amino-2-Naphthalene-Sulfonic Acid
5-( 4-Dime thy laminobenzy lidene)
Rhodamine
8-Hydroxyquinoline
Acetic Acid
Acetic Anhydride
Acetone
Acrysol II-935
Adogen 2382
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
90 g 1.25 72
3,400 g *
50 g 1.48 34
12,360 g 1.03 12,000
20 g 1.19 17
25 g 1.627 15
3,240 g 0.81 4,000
1 g *
435 g 1.45 300
0 g 0
5 g *
10 g 1.106 9
38 lb 0.9012 5
0 g 0
104,625 g 0.785 16,000
0 g 0
0 g 0
* 100
50 g 1.415 35
0 g 0
25 g 1.502 17
10 g 1.368 7
1,900 g 1.034 1,838
0 g 1.049 0
2,052 g 1.08 1,900
1,225 g 0.79 1,550
* 500
180 g 0.898 200
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 200 g
9 kg
mL 200 g
mL 47 L
mL 20 g
mL 10 g
mL 20 L
5 g
mL 10 g
mL 40 g
5 g
mL 1 L
gal 20 L
mL 5 g
mL 18 L
mL 10 g
mL 0.1 L
mL 0.1 L
mL 50 g
mL 0.1 L
mL 25 g
mL 10 g
mL 2 kg
mL 170 L
mL 34 L
mL 252 L
mL 1 L
mL 1 L
Chemical Name
Adogen 283
Adogen 382
AF9000
Alamine 308
Alamine 310
Alcohol Solvent, Denatured
Alcohol, Alfol 12LE
Alcohol, n-Amyl
Alcohol, Reagent
Aliquat 336
Alizarin Red
Alizarin Yell ow
Aluminum 1000 mg!L
Aluminum Chloride
Aluminum Hydroxide
Aluminum Metal, granular
Aluminum Nitrate Solution
Aluminum Nitrate, Nonahydrate
Aluminum Potassium Sulfate 12
Hydrate Crystal
Aluminum Powder
Aluminum Reagent 2
Aluminum STD 5000 ppm
Aluminum Sulfate Crystal
Aluminum Wire
Amber lite
AMCO Clear Turbidity 1.0 NTU
AMCO Clear Turbidity 10 NTU
AMCO Clear Turbidity 100 NTU
AMCO Clear Turbidity 1000 NTU
Ammonia Standard
Ammonium 1-Pyrrolidine
Carbodithioate
Ammonium Acetate
Ammonium Bicarbonate
Ammonium Bifluoride
Ammonium Chloride
Ammonium Fluoride
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
898 g 0.898 1,000
359 g 0.898 400
* 1,000
* 800
* 1,500
8,982 g 0.791 11,355
1,660 g 0.83 2,000
0 g 0
28 kg 0.79 35
1 g 0.88 1
25 g 1.06 24
10 g *
500 g 1 500
800 g 2.44 328
500 g 2.4 208
750 g 2.7 278
104,099 g 1.1 25
98,000 g 1.058 92,628
500 g 1.757 285
300 g 2.7 111
* 56
0 g 0
250 g 1.69 148
400 g 2.7 148
500 g 1.02 490
100 g 1 100
4,000 g 1 4,000
4,000 g 1 4,000
4,000 g 1 4,000
0 g 0
25 g *
3,000 g 1.07 2,804
11,150 g 1.586 7,030
4,536 g 1.5 3,024
5,268 g 1.52 3,466
1,600 g 1.11 1,441
Historic volume
or mass used
(1978-2013)
1cm 3 -1
mL Quantity Unit
mL 1 L
mL 1 L
mL 1 L
mL 8 L
mL 8 L
mL 40 L
mL 1 L
mL 1 L
L 4,156 L
L 1 L
mL 30 g
10 g
mL 7 L
mL 1 kg
mL 1.5 kg
mL 1 kg
gal 385 gal
mL 100 kg
mL 0.5 k_g
mL 5 kg
mL 0.06 L
mL 5 L
mL 1 kg
mL 0.5 kg
mL 0.5 kg
mL 16 L
mL 16 L
mL 16 L
mL 16 L
mL 1 L
30 g
mL 3 kg
mL 12 kg
mL 5 kg
mL 10 kg
mL 2 kg
Chemical Name
Ammonium Hydroxide
Ammonium Iodide
Ammonium Meta-Vanadate
Ammonium Molybdate-4-Hydrate
Crystal
Ammonium Nitrate
Ammonium Oxalate
Ammonium Peroxy Disulfate
Ammonium Persulfate
Ammonium Phosphate Monobasic
Ammonium Sulfate
Ammonium Thiocyanate
Ammonium Vanadate
Anion Exchange Resin
Antimony Potassium Tartrate
Antimony Powder
Arsenic 1000 mg/L
Arsenic Trioxide
Ascarite
Barbituric Acid
Barium 1000 mg/L
Barium 5000 ppm STD
Barium Chloranilate
Barium Chloride
Barium DiPhenylamine sulfonate
Barium Hydroxide Monohydrate
Barium Nitrate
Earlene, 310 I
Bentonite
Benzaldehyde
Benzoic Oxime
Beryllium 1000 mg/L
Beryllium Sulfate
Bismuth Powder
Boron 1000 mg/L
Boraxo
Boric Acid
Boron 1000 mg/L
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
38,165 g 0.898 42,500
4,000 g 2.51 1,594
650 g 2.32 280
2,300 g 2.498 921
11,022 g 1.72 6,408
19,300 g 1.5 12,867
3,000 g 1.98 1,515
2,100 g 1.98 1,061
5 lbs *
9,000 g 1.77 5,085
20,100 g 1.3 15,462
7,000 g 2.32 3,017
450 g 0.7 643
500 g 2.6 192
5 g 6.69 1
631 g 1.01 625
2,002 g 3.738 536
908 g 0.9 1,009
100 g 1.455 69
0 g 1.013 0
0 g 0
20 g *
6,800 g 3.856 1,763
10 g *
454 g 3.743 121
908 g 3.23 281
394 g 0.787 500
2,500 g 2.4 1,042
4,166 g 1.0415 4,000
700 g 1.13 619
* 250
113 g 2.443 46
20 g 9.8 2
0 g 0
0 g 1.73 0
30,000 g 1.435 20,906
0 g 1 0
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 64 L
mL 4 kg
mL 0.8 kg
mL 3 kg
mL 7.5 kg
mL 33 kg
mL 3 kg
mL 200 g
3 kg
mL 42 kg
mL 30 kg
mL 1 kg
mL 0.5 kg
mL 0.5 kg
mL 5 g
mL 5.5 L
oz. 5,010 g
mL 10 kg
mL 100 g
mL 0.125 L
mL 2 L
25 g
mL 63 kg
5 g
mL 10 kg
mL 1 kg
mL 0.5 L
mL 2.5 kg
mL 4 L
mL 1 kg
mL 250 mL
mL 0.2 kg
mL 20 g
mL 1 L
mL 25 kg
mL 10 kg
mL 0.5 L
Chemical Name
Brake Fluid
Bromine
Bromo Padap
Bromo Thymol blue
Bromocresol Green
Bromophenol blue
Bromothymol Blue
Brucine Sulfate
buffer solution 1 PH
buffer solution 1.65 PH
buffer solution 10 PH
buffer solution 12.45 PH
Buffer Solution 2 pH
Buffer Solution 4 pH
Buffer Solution 7 pH
Burco LAP-180
Burco LAF-6
Cadmium 1000 mg/mL
Cadmium 5000 ppm STD
Cadmium Metal
Cadmium Nitrate
Cadmium Powder
Calcium
Calcium 1000 mg!L
Calcium Acetate
Calcium Carbonate
Calcium Chloride Dihydrate
Calcium Chloride, Anhydrous
Calcium Cyanide
Calcium Fluoride
Calcium Hydroxide
Calcium Nitrate
Calcium Oxide
Calcium Sulfite
Calumet 400-500 solvent
Carbons, Granular
Gwar Carboxy Methyl
Carminic Acid
Appendix 0-1
Laboratory Chemical lnventol'y
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
974 g 1.03 946
* 50
5 g 1.39 4
60 g 1.25 48
5 g 0.981 5
68 g 0.954 71
0 g 0
10 g *
0 g 0
0 g 0
38,000 g 1 38,000
0 g 0
1,900 g 1 1,900
3,800 g 1 3,800
2,000 g 1 2,000
* 400
400 g 1 400
* 500
0 g 0
500 g 8.64 58
454 g 2.455 185
10 g 8.64 1
25 g 1.54 16
300 g 1 300
453 g 1.5 302
24,100 g 2.93 8,225
2,500 g 1.71 1,462
1,500 g 1.086 1,381
1,000 g 1.853 540
950 g 3.18 299
3,100 g 2.24 1,384
2,768 g 2.36 1,173
4,268 g 3.3 1,293
3,000 g 2.5 1,200
3,000 g 0.83 2
16,500 g 0.95 17,368
720 g *
10 g 1.87 5
Historic volume
or mass used
(1978-2013)
1cm 3 -1
mL Quantity Unit
mL 1 L
mL 0.1 L
mL 5 g
mL 100 g
mL 10 g
mL 310 g
mL 40 g
10 g
mL 158 L
mL 10 L
mL 158 L
mL 2 L
mL 147 L
mL 210 L
mL 194.5 L
mL 1 L
mL 1 L
0 0.5 L
mL 2 L
mL 0.5 kg
mL 0.5 kg
mL 0.5 kg
mL 25 g
mL 6.5 L
mL 0.5 kg
mL 100 g
mL 3 kg
mL 2 kg
mL 4 kg
mL 3 kg
mL 10 kg
mL 3 kg
mL 5 kg
mL 4 kg
L 4 L
mL 1 kg
1 kg
mL 10 g
Chemical Name
Caustlag
Ceric Ammonium Sulfate Dihydrate
Ceric Sulfate
Cerium Oxalate
Cesium Nitrate
Chem-FAC 100
Chesterton Moisture Shield
Chloramine-T-Hydrate
Chloride standard
Chloroform
Chromium 1000 mg/L
Chromium 5000 mg/L
Chromium Cr 6 Standard
Chromium Trioxide
Citric Acid Anhydrous
Citric Acid Monohydrate
Cobalt Chloride
Cobalt Metal
Cobalt Nitrate 6-Hydrate
Cobalt Powder
Compressed Gas (Argon)
Compressed Gas (Nitrogen)
Compressed Gas (Helium)
Compressed Gas (oxygen)
Compressed Gas (Ammonia
Anhydrous)
Compressed Gas Acetylene
Compressed Gas Nitrous Oxide
Compressed Gas Propane
Conductivity Calibration Standard,
NIST Traceable
Conductivity Traceable 1,000 !!S
Conductivity Traceable 150,000 j..tS
Conostan 75 base oil for AA diluent
Contract 70
. Copper
Copper 1000 mg/L
Com Starch
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
0 g 0
2,020 g *
500 g 3.01 166
0 g 0
5 g 3.685 1
* 250
397 g 0.8 496
10 g 1.4 7
0 g 1 0
1,484 g 1.484 1,000
70 g 1 70
100 g 1 100
0 g 2.7 0
100 g 2.7 37
5,100 g 1.542 3,307
0 g 0
250 g 3.35 75
600 g 1.03 583
500 g 1.88 266
5 g 8.9 1
6,000 cf *
5,500 cf *
10,000 cf *
5 cf *
8 cf *
0 cf
0 cf
500 cf *
927 g 1.03 900
9,500 g 1 9,500
1,000 g 1 1,000
0 g 0
21,200 g 1.06 20,000
430 g 8.92 48
203 g 1.014 200
454 g 0.67 678
Historic volume
or mass used
(1978-2013)
1cm 3 -1
mL Quantity Unit
mL 3 kg
3 kg
mL 3 kg
mL 1 kg
mL 5 g
mL 0.25 L
mL 0.5 kg
mL 25 g
mL 1 L
mL 1978 L
mL 1.5 L
mL 2 L
mL 0.125 L
mL 0.5 kg
mL 10 kg
mL 1 kg
mL 25 g
mL 1 kg
mL 0.5 kg
mL 5 g
497,364 cf
152,775 cf
30,583 cf
1,600 cf
1,600 cf
1,600 cf
1,600 cf
17,829 cf
mL 32 L
mL 26 L
mL 1 L
mL 1 L
mL 20 L
mL 1 kg
mL 3 L
mL 5 lb
Chemical Name
CP 1400P
CP 2000P
Crystal Violet
Crystalline silica
Cupferron Crystal
Cupric Sulfate 5-Hydrate
Cupric Sulfate Anhydrous
Curcumin Crystalline
Cyanex 923
Cyclohexane
Decyl Alcohol 99%
DEHPA
DEHPA in Kerosene
DF53A
DF-57-85-1
D-Gluconic Acid
D-Gluconic Acid Calcium Salt 99%
Dialkyl Methyl amine
Diaminocyclohexane
Diatamacious Earth
Dibenzoyl Methane 98%
Dibutyl phosphate
Digestion Solution for COD, (83%
sulfuric acid, 1% mercuric sulfate)
Dimethyl Sulfoxide
Dinitropheny lazo
Dioctylsodium Sulfosuccinate
DiPhenyl amine 4 sulfuric Acid
Diphenyl-carbazone
DiPhenylThioCarbazone
Diphonix Resin
DiPyridal
Disodium Ethylenediamine
Tetraacetate
Ditex 1812C
d-Tartaric Acid
Ecopol-LLDS
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
300 g *
50 g *
25 g 1.19 21
0 g 0
2,600 g *
2,300 g 2.284 1,007
454 g 3.603 126
10 g 1.279 8
24 Kg 0.88 28
18,285 g 0.7781 23,500
1,230 g 0.82 1,500
17,873 g 0.974 18,350
974 g 0.974 1,000
* 250
* 250
500 g 1.763 284
0 g 0
1,070 g 1.07 1,000
0 g 0.931 0
0 g 0.26 0
50 g 1.138 44
529 g 1.058 500
0 g 0
550 g 1.1 500
0 0
275 g 1.1 250
10 g *
1 g 1.19 1
5 g 1.2 4
13,300 g 0.3 44,333
5 g 1.106 5
500 g 1.01 495
* 1,000
10,300 g 1.8 5,722
1,000 g * 1,000
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
0.1 kg
0.1 kg
mL 25 g
mL 1 kg
23.8 kg
mL 3 kg
mL 0.5 kg
mL 10 _g
L 30 L
mL 20 L
mL 5 L
mL 1 L
mL X X
mL 0.25 L
mL 0.25 L
mL 0.5 kg
mL 0.1 kg
mL 1 L
mL 0.5 kg
mL 100 kg
mL 500 g
mL 0.5 L
mL 1 L
mL 0.5 L
0 50 g
mL 1 kg
110 g
mL 20 g
mL 20 g
mL 2 kg
mL 5 g
mL 0.5 kg
mL 1 L
mL 12 kg
mL 1 kg
Chemical Name
Elan 6100 DRC Set up/ Stab/ Masscal
Sol.
Elan DRC Smart Tune
Electrode filling solution (Ag/AgCl)
Electrode storage solution (KCl soln.)
Empigen BS/FQ
Eriochrome black
Escaid 115
Ethanol absolute
Ether Anhydrous
Ethyl Acetate
EthyleneDiamine Tetraacetic Acid
Ethylene Dinitrilo Tetraacetic acid
Ethylene Glycol Monobutyle Ether
Ferric Ammonium Sulfate
Dodecahydrate
Ferric chloride 6-Hydrate
Ferrous Ammonium Sulfate
Ferrous Chloride
Ferrous Sulfate
Ferrous Sulfate Heptahydrate
Elan 6100 DRC Wash Solution
Flexane 94 liquid
Floc 912 SH
Floc 920 SH
Floc Acrylamide Homopolymer
Floc ChemTreat P-802E
Floc DVS4F011
Floc Ethylene Oxide Polymer WSR
205 (2195)
Floc Ethylene Oxide Polymer WSR
Coagulant (2331)
Floc Hycem AF 102
Floc Hycem AF 104
Floc Hycem AF 105
Floc Hycem AF 205
Floc Hycem AF 306
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
* 800
* 1,000
0 mL * 0
0 g 0
* 500
35 g 1.109 32
* 20,000
3,156 g 0.789 4,000
2,854 g 0.7134 4,000
9,471 g 0.902 10,500
1,000 g 0.86 1,163
75 g 0.86 87
0 g 0
0 g 1.71 0
1,800 g 1.82 989
5,000 g 1.86 2,688
1,000 g 3.16 316
0 0
6,000 g 0.999 6,006
0 g 1 0
908 g * 1,000
0 g 0
0 g 0
0 g 0
0 lb 0
* 100
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 2 L
mL 12 L
mL 5 L
mL 20 L
mL 0.5 L
mL 10 g
mL 20 L
mL 4 L
mL 10 L
mL 15 L
mL 3.1 kg
mL 0.1 kg
mL 0.25 L
mL 2 kg
mL 3.75 kg
mL 144 kg
mL 1 kg
mL 5 kg
mL 43.5 kg
mL 0.5 L
mL 1 L
mL 150 g
mL 150 g
mL 50 g
gal 18 kg
mL 100 mL
mL 250 g
mL 250 g
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 20 g
Chemical Name
Floc Hycem AF 308
Floc Hycem AF 311
Floc Hycem NF 301
Floc Hycem NF 305
Floc Hyperfloc AF 104
Floc Hyperfloc AF 208
Floc Hyperfloc AF 250
Floc Hyperfloc AF 302
Floc Hy_perfloc AF 303
Floc Hyperfloc AF 304
Floc Hyperfloc AF 305
Floc Hyperfloc AF 306
Floc Hyperfloc AF 307
Floc Hyperfloc AF 308
Floc Hyperfloc AF 309
Floc Hyperfloc AF 312
Floc Hyperfloc AF 314
Floc Hy_perfloc AF MG 653
Floc Hyperfloc CB 478
.Floc Hyperfloc CP 624
Floc Hyperfloc CP 757
Floc Hyperfloc CP 902 H
Floc Hyperfloc CP 903
Floc Hyperfloc MG 653
Floc Hyperfloc MG 655
Floc Hyperfloc MG 656
Floc Hyperfloc NF 201
Floc Hyperfloc NF 301
Floc Hysperse 1015
Floc Hysperse 1016
Floc Hysperse 1018
Floc MagnaFloc 10
Floc MagnaFloc 1011
Floc MagnaFloc 156
Floc MagnaFloc 333
Floc MagnaFloc 336
Floc MagnaFloc 338
Floc MagnaFloc 342
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
50 g *
50 g *
100 g *
100 g *
100 g *
50 g *
50 g *
50 g *
50 g *
50 g *
50 g *
100 g *
100 g *
* 90
* 45
* 10
50 g *
50 g *
100 g *
40 g *
50 g *
40 g *
50 g *
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 25 g
50 g
50 g
100 g
100 _g
100 g
50 g
50 g
50 g
50 g
50 g
50 g
100 g
23 kg
mL 90 mL
mL 45 mL
gal 10 gal
50 g
50 g
100 g
40 g
50 g
40 g
50 _g
mL 0.1 L
mL 0.1 L
mL 0.1 L
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 80 g
Chemical Name
Floc MagnaFloc 351
Floc MagnaFloc 358
Floc MagnaFloc 371
Floc MagnaFloc 455
Floc MagnaFloc 7117
Floc MagnaFloc 7692
Floc MagnaFloc 919
Floc Nalco DVS4F011
Floc NEO NS 4507
Floc NEO NS 4525
Floc NEO NS 6500
Floc NEO NS 6501
Floc NEO NS 6502
Floc NEO NS 6502m
Floc NEO NS 6511
Floc NEO NS 6555
Floc Non-ionic
Floc Percol 156
Floc Percol 333
Floc Percol 336
Floc Percol 338
Floc Percol 342
Floc Percol 351
Floc Percol 352
Floc Percol 358
Floc Percol371
Floc Percol 408
Floc Percol 455
Floc Percol 727
Floc Percol 728
Floc Percol 919
Floc Percol E10
Floc Ucarfloc Polymer 30x B-6070
Floc Ucarfloc Polymer 30x B-6107
Floc Ucarfloc Polymer 30x Batch
155836
Floc Ucarfloc Polymer 30x C-6076
Floc Ucarfloc Polymer 30x C-6102
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
0 g 0
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 80 g
mL 250 mL
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 20 g
mL 23 kg
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 50 g
mL 0.25 kg
mL 0.25 kg
mL 0.25 kg
mL 0.25 kg
mL 0.25 kg
Chemical Name
Floc Ucarfloc Polymer 30x H-6049
Floc Ucarfloc Polymer 30x R-6046
Floc Ucarfloc Polymer 30x S-6045
Fluoride w/TISAB Std 1 ppm
Fluoride w/TISAB Std 10ppm
Fluoride w/TISAB Std 100ppm
Fluoride standard solution
Formaldehyde
Fritz EP-9LMwB
Gallium Metal
Gentian Violet
Glacial Acetic Acid
Glycerin
Gold 1000 mg/L
Greatfloc 5410
Greatfloc 5413
Greatfloc 5420
Hexanes
Hyamine, Hydroxide
Hydrazine Sulfate
Hydrobromic acid 49%
Hydrochloric acid
Hydrochloride (0.1N)
Hydrochloride (1N)
Hydroflouric Acid
Hydrogen Peroxide
Hydroiodic acid
Hydroquinone
Hydroxy Naphthol blue
Hydroxylamine Hydrochloride
Hydroxylamine Sulfate
ICP-MS Internal Standard
ICP-MS Interference Check Sol. #1
ICP-MS Interference Check Sol. #2
Iodine Monochloride Solution
Iodine Solution 1N
Iodine Sublimes
Ionquest 801
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
0 g 0
0 g 0
0 g 0
* 950
* 475
* 950
425 g 1 425
1,041 g 1.1 946
0 g 0
1 _g 5.904 0
100 g 1.19 84
11,020 g 1.0495 10,500
126 g 1.2636 100
* 125
0 g 0
0 g 0
0 g 0
13,000 g 0.66 20
467 g 0.933 500
1,600 g 1.37 1,168
10,200 g 1.49 6,846
39,100 g 1.15 34,000
* 100
13,800 g 1.15 12,000
2,500 g 1.25 2,000
2,260 g 1.13 2,000
1,000 g 1.96 510
600 g 1.32 455
26 g 2.13 12
1,500 g 1.67 898
1,000 g 1.86 538
* 500
* 125
* 125
1,060 g 1.06 1,000
500 g 1 500
454 g 3.835 118
* 350
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 0.25 kg
mL 1 kg
mL 0.5 kg
mL 5 L
mL 5 L
mL 5 L
mL 20.5 L
mL 1 L
mL 0.1 L
mL 1 g
mL 200 g
mL 40 L
mL 12 L
mL 125 mL
mL 50 g
mL 50 g
mL 50 g
L 25 L
mL 0.5 L
mL 5 kg
mL 12 kg
mL 4,826 L
mL 30 L
mL 30 L
mL 231 L
mL 92 L
mL 1 kg
mL 1 kg
mL 10 g
mL 19.5 kg
mL 1 kg
mL 4 L
mL 125 mL
mL 125 mL
mL 1 L
mL 2.5 L
mL 1 k_g
mL 1 L
Chemical Name
Iron 1000 mg/L
Iron 5000 ppm STD
Iron Metal
Iron Pyrites
Iron Sulfate Hydrate
!so-Octane
Jet Fuel Type A
KP5000
Lanthanum 1000 mg/L
Lanthanum Oxide
L-Ascorbic Acid
Lead (II) Acetate Trihydrate
Lead (II) Carbonate
Lead 1000 ~-tg/mL
Lead Metal
Lead Nitrate
Lead Oxide
Lithium 1000 ~-tg/mL
Lithium Fluoride
Lithium M -borate
Lithium borates (with Bromide)
Lithium borates (with Iodide)
Lithium Chloride
Lithium Tetra borate
LIX 664N-LV
LIX 984 N
Magnesium 1000 mg/L
Magnesium Carbonate
Magnesium Nitrate
Magnesium Nitrate Hexahydrate
Magnesium Oxide
Magnesium Perchlorate
Magnesium Sulfate
Manganese 1000 ~-tg/ mL
Manganese 5000 ppm STD
Manganese Carbonate
Manganese Chloride
Manganese Dioxide
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
508 g 1.015 500
0 g 0
3,000 g 7.86 382
5,436 g 5.1 1,066
2,500 g 3.097 807
40 Kg 0.692 58
16 Kg 0.8 20
0 g 0
500 g 1 500
520 g 6.51 80
4,150 g 1.954 2,124
500 g 2.55 196
500 g 6.14 81
408 g 1.02 400
34,050 g 11.34 3,003
454 g 4.53 100
2,400 g 9.53 252
0 g 1.03 0
3,400 g 2.64 1,288
100 g 1.4 71
19,000 g *
5,500 g 1.4 3,929
500 g 2.068 242
250 g 0.25 1,000
* 500
* 500
432 g 1.016 425
0 g 0
200 g 0.889 225
1,000 g 1.63 613
479 g 3.58 134
500 g 2.21 226
3,000 g 1.07 2,804
0 g 1.015 0
0 g 0
2,350 g 3.12 753
200 g 2.98 67
2,650 g 5.02 528
Historic volume
or mass used
(1978-2013)
1cm 3 -1
mL Quantity Unit
mL 6.5 L
mL 1 L
mL 1.2 kg
mL 6 kg
mL 3 kg
L 1,304 L
L 20 L
mL 1 kg
mL 1.25 L
mL 6.1 kg
mL 5 kg
mL 1 kg
mL 0.5 kg
mL 2.5 L
mL 100 lb
mL 0.5 kg
mL 3 kg
mL 2.5 L
mL 4 kg
mL 0.5 kg
25 kg
mL 20 kg
mL 1 kg
mL 1 kg
mL 0.5 L
mL 2 L
mL 7 L
mL 0.1 kg
mL 3.5 kg
mL 1 kg
mL 1 kg
mL 1 kg
mL 9 kg
mL 4 L
mL 1 L
mL 3 kg
mL 0.2 kg
mL 3 kg
Chemical Name
Manganese Flake
Manganese Sulfate
M-Cresol purple
Mercuric Acetate
Mercuric Chloride
Mercuric Iodide
Mercuric lithinate
Mercuric Nitrate ( .1410 N)
Mercuric Nitrate Monohydrate
Mercuric Sulfate
Mercury Cm Oxide
Mercury 1000 [!g/mL
Mercury Metal
Methanol
Methyl Red
Methyl Ethyl Ketone
Methyl isobutyl ketone
Methyl orange
Methyl Red Hydrochloride
Methyl Red Sodium Salt
Methyl violet
Methylene blue
Methylene Chloride
Molybdenum 1000 mg/L
Molybdenum Powder
Molybdenum STD 5000 ppm
Molybdenum Trioxide
Molybdic Anhydride
Monoethanol Amine
MS-811
MSA-1 (New Resin)
N-(lnaphthyl) ethylene Diarnine
Dihydrochloride
n-Amyl Alcohol
n-Butyl Acetate
n-Butyl-Phosphate
n-Decanal
NEA-96
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
0 g 7.3 0
2,800 g 3.25 862
26 g 1.37 19
100 g 3.29 30
250 g 5.44 46
150 g 6.36 24
0 g 0
35,120 g 4.39 8,000
1,500 g 4.3 349
113 g 6.47 17
100 g 11.14 9
g * 1,000
8 lb 13.54 251
7,515 g 0.791 9,500
2.5 g 0
3,220 0.805 4,000
18 g 0.802 23
195 g 0.987 198
125 g 0.8 156
60 g 0.791 76
100 g *
25 g 1 25
15,816 g 1.318 12,000
500 g 1 500
100 g 10.3 10
0 g 0
1,700 g 4.692 362
453 g 4.692 97
1,018 g 1.018 1,000
* 500
0 g 0
50 g *
398 g 0.8416 473
720 g 0.9 800
66,776 g 0.982 68,000
0 g 0
1,218 g 2.435 500
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 50 g
mL 0.5 kg
mL 395 g
mL 0.1 kg
mL 0.25 kg
mL 400 g
mL 0.1 kg
mL 274 L
mL 2 kg
mL 0.2 kg
mL 0.1 kg
mL 1 L
mL 10 kg
mL 154 L
mL 1 kg
mL 12 L
mL 152 L
mL 10 g
mL 10 g
mL 130 g
5 g
mL 200 g
mL 100 L
mL 4.5 L
mL 0.1 kg
mL 1 L
mL 2 kg
mL 1 kg
mL 1 L
mL 0.5 L
mL 0.5 L
50 g
mL 1 L
mL 1 L
mL 289 L
mL 1 L
mL 0.5 L
Chemical Name
Nesslers Reagent
Nickel
Nickel 1000 mg/L
Nickel 5000 mg!L
Nickel Nitrate
Nickel Powder
Niobium 1000 mg/L
Nitrate ISA
Nitrate, nitrogen STD
Nitrazine yellow
Nitric Acid
Nitrobenzene
NonEmulsifier 19N
Nonoxynol-4
N-Phenylbenzohydroxamic Acid
Octyl Acid Phosphate
Oleic Acid (Solution)
Oleic Acid (Solid)
Orform
ORP Standard
0-Tolidine Dihydrochloride
Oxalic Acid
Oxicol
P-802E Flocculent
Paraffin
PE Sciex Coolant
Pentyl Acetate
Perchloric Acid
Phenanthroline
Phenol Red
Phenolphtalein
Phosphoric Acid
Phosphorus 1000 f.tg/rnL
Phosphorus 5000 ppm STD
Polymer 300
Polymer 302
Polymer 304
Polyol
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g!cm3 Volume
1,600 g 1.28 1,250
110 g 8.9 12
0 g 1.014 0
0 g 0
3,000 g 2.05 1,463
10 g 8.9 1
* 105
3,111 g 1.31 2,375
2,500 g 1 2,500
20 g *
43,594 g 1.42 30,700
1,440 g 1.2 1,200
460 g 0.92 500
0 g 0
50 g 1.27 39
1,000 g 1 1,000
4,923 g 0.895 5,500
3,000 g 1.09 2,752
* 5,750
200 g 1 200
100 g 1.03 97
1,200 g 1.9 632
0 g 0
0 g 0
400 g *
* 5,000
1,000 g 0.876 1,142
4,184 g 1.6736 2,500
0 0
25 g 1.477 17
226 g 1.299 174
49,820 g 1.88 26,500
250 g 1 250
0 g 0
0 g 0
0 g 0
1,000 g *
1,100 g *
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
rnL 2.5 L
rnL 0.2 kg
rnL 3.5 L
rnL 1 L
rnL 3 kg
rnL 10 g
rnL 250 rnL
rnL 2 L
rnL 2 L
20 g
rnL 3,109 L
rnL 15 L
rnL 0.5 L
rnL 0.5 L
rnL 25 g
rnL 1 L
rnL 10 L
rnL 5 kg
rnL 6 L
rnL 1 L
rnL 100 g
rnL 5 kg
rnL 10 g
rnL 1 L
10 kg
rnL 25 L
rnL 1 kg
rnL 1,487 L
rnL 0.25 kg
rnL 25 g
rnL 0.25 kg
rnL 1,665 L
rnL 5.5 L
rnL 1 L
rnL 0.25 L
rnL 0.25 L
0.25 L
1 L
Chemical Name
Polyox
Polyox WSR Coagulant
Polyox WSR-205
Potassium 1000 f-lg/mL
Potassium 5000 r-tg/mL
Potassium Acetate
Potassium Bicarbonate
Potassium Biiodate
Potassium Biphthalate
Potassium Biphthalate Buffer
Potassium Bromate
Potassium Bromide
Potassium Carbonate
Potassium Chlorate
Potassium Chloride
Potassium Chloride solution 4 M
Potassium Chromate
Potassium Cyanide
Potassium dichromate
Potassium ferricyanide
Potassium Ferrocyanide trihydrate
Potassium Fluoride
Potassium Iodate
Potassium Iodide
Potassium Iodide-Iodate
Potassium Nitrate
Potassium Nitrite
Potassium Oxalate Monohydrate
Potassium Perchlorate
Potassium Permanganate
Potassium Permanganate Solution
Potassium Perrhenate
Potassium Persulfate
Potassium Phosphate
Potassium pyrosulfate
Potassium Sodium Tartrate 4-Hydrate
Potassium Sulfate
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g!cm3 Volume
1,000 *
500 g *
500 g *
304 g 1.013 300
0 g 0
250 g 1.57 159
500 g 2.17 230
50 g *
1,800 g 1.64 1,098
0 g 1.636 0
500 g 3.27 153
5,600 g 3.119 1,795
400 g 2.43 165
2,250 g 2.32 970
1,500 g 1.98 758
296 g 1 10
200 g 2.732 73
454 g 1.52 299
5,150 g 7.14 721
1,100 g 1.85 595
500 g 1.85 270
600 g 2.48 242
500 g 3.93 127
16,140 g 1.32 12,227
0 g 1 0
250 g 2.109 119
250 g 1.92 130
5,000 g 2.127 2,351
500 g 2.52 198
9,300 g 1.01 9,208
3,000 g 1 3,000
10 g 4.887 2
100 g 2.47 40
0 g 2.564 0
500 g 2.28 219
1,400 g 1.05 1,333
2,000 g 2.66 752
Historic volume
or mass used
(1978-2013)
1cm 3 -1
mL Quantity Unit
10 kg
1 L
0.5 L
mL 8 L
mL 1 L
mL 100 g
mL 0.5 kg
3 L
mL 2 kg
mL 2 L
mL 0.5 kg
mL 6 kg
mL 0.5 kg
mL 3 kg
mL 10 kg
oz 20 L
mL 0.2 kg
mL 1 kg
mL 6 kg
mL 1 kg
mL 0.5 kg
mL 0.5 kg
mL 0.5 kg
mL 0.5 kg
mL 0.5 L
mL 100 g
mL 0.25 kg
mL 392 kg
mL 3 kg
mL 50 kg
mL 1 L
mL 10 g
mL 0.2 kg
mL 50 g
mL 500 g
mL 1.5 kg
mL 1 kg
Chemical Name
Potassium Thiocyanate
Primene
Primene 81-R Amine
Primene JM-T Amine
PrimeneMD
Primene TOA Amine
Propylether Chloride Guar Gum
Pyridine
Pyrogallate Absorption stable solution,
(Potassium Hydroxide Solution)
Quinhydrone
Quinoline
Rantec KP5000
Red Gaye Oil
Rexyn 101
Rexyn 300
SAG 101
Salt (kiln dried)
Salt, Medium
Scandium 1000 mg/L
Sea sand
Selenium 1000 ~-tg/mL
Selenium Oxide
Silicon 1000 mg/L
Silicon 5000 mg/L
Silicon Carbide
Silver 1000 ~-tg/mL
Silver Chloride
Silver Nitrate (Solid)
Silver Nitrate (Solution)
Silver sulfate
Smart Tune Solution
Sodium 1000 mg/L
Sodium Acetate Anhydrous
Sodium Acetate trihydrate
Sodium Ammonium Phosphate
Sodium Arsenite
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
9,750 g 1.886 5,170
0 g 0
1,230 g 0.82 1,500
40,032 g 0.834 48,000
* 100
1,078 g 0.77 1,400
330 g 1.3 254
7,855 g 0.9819 8,000
0 g 0
2,100 g 1.32 1,591
545 g 1.09 500
920 g *
0 g 0.826 0
500 g 1.2 417
200 g 1.2 167
0 g 0
45 lb 1.199 17,024
270 g 1.199 225
* 450
10,000 g 2.6 3,846
0 g 1.02 0
10 g 4.81 2
485 g 0.97 500
0 g 0
0 g 0
125 g 1 125
0 g 0
2,600 g 4.35 598
69,600 g 4.35 16,000
200 g 5.45 37
* 1,000
405 g 1.013 400
2,300 g 1.528 1,505
2,450 g 1.45 1,690
950 g 1.54 617
500 g 1.87 267
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 4.5 kg
mL 8 L
mL 1 L
mL 100 L
mL 1 L
mL 1 kg
mL 1 kg
mL 47 L
mL 1 L
mL 5 kg
mL 0.5 L
1 kg
mL 2 L
mL 0.5 kg
mL 1.5 kg
mL 0.5 L
mL 50 kg
mL 50 kg
mL 0.5 L
mL 50 kg
mL 1.5 L
mL 10 g
mL 8 L
mL 1 L
mL 25 g
mL 1 L
mL 4 L
mL 24.5 kg
mL 32 L
mL 0.5 kg
mL 12 L
rnL 5 L
mL 37 kg
mL 36 kg
mL 4 kg
mL 1.5 kg
Chemical Name
Sodium Bicarbonate
Sodium Bisulfate
Sodium Borate
Sodium Carbonate, Anhydrous
Sodium Chlorate
Sodium Chloride
Sodium Chloride Solution
Sodium Citrate
Sodium Cyanide
Sodium Diphenylamine
Sodium Diphenylamine-4-Sulfonate
Sodium Fluoride
Sodium Hydrosulfide
Sodium Hydroxide
Sodium Hydroxide (1N)
Sodium Hydroxide (50%)
Sodium Hydroxide pellets
Sodium m-Bisulfite
Sodium Molybdate
Sodium Nitrate
Sodium Nitrite
Sodium Oxalate
Sodium Peroxide
Sodium Persulfate
Sodium phosphate deca-hydrate
Sodium Phosphate Tribasic
Sodium Phosphate, Dibasic 12-Hydrate
Sodium Pyrophosphate Decahydrate
P.A.
Sodium reconditioning solution
Sodium Salicylate
Sodium Silicate
Sodium Sulfate, 12-Hydrate
Sodium Sulfate, Anhydrous
Sodium Sulfide
Sodium Sulfite, Anhydrous
Sodium Sulfonate
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g!cm3 Volume
11,200 _g 2.16 5,185
3,000 g 2.1 1,429
400 g 1.73 231
8,500 g 2.53 3,360
6,555 g 2.49 2,633
10,950 g 1.199 9,133
0 g 1 0
6,000 g 1.008 5,952
500 g 1.6 313
20 g *
25 g *
10,050 g 1.02 9,853
3,500 g 1.79 1,955
5,791 _g 1.53 1
13,520 g 1.04 13,000
1,530 g 1.53 1,000
12,000 g 1.515 7,921
17,500 g 1.48 11,824
1,000 _g 3.78 265
17,000 g 1.1 15,455
7,500 g 2.168 3,459
400 g 2.34 171
500 g 2.8 179
150 g 2.4 63
500 g 1.82 275
1,350 g 1.62 833
750 g 1.52 493
500 g 2.534 197
2,850 g 1 2,850
400 g 0.35 1,143
600 g 2.33 258
0 g 0
4,500 g 2.68 1,679
0 g 0
12,000 g 2.63 4,563
0 g 1 0
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 15 kg
mL 10 kg
mL 1.5 kg
mL 125.5 kg
mL 10 kg
mL 96 kg
mL 10 L
mL 15 kg
mL 4 kg
100 g
60 _g
mL 70.6 kg
mL 1 kg
gal 42 kg
mL 256 L
mL 32 L
mL 30 kg
mL 25 kg
mL 1 kg
mL 20 kg
mL 10 kg
mL 1 kg
mL 3 kg
mL 0.5 kg
mL 0.5 kg
mL 1 kg
mL 1 kg
mL 0.25 kg
mL 3 L
mL 0.5 kg
mL 1 kg
mL 3 kg
mL 10 kg
mL 0.2 kg
mL 23 kg
mL 0.5 L
Chemical Name
Sodium Tartrate Dihydrate
Sodium Thiocyanate
Sodium Thiosulfate Anhydrous
Sodium tripoly phosphate
Sodium Tungstate, Dihydrate
Soltrol220 (Aliphatic Hydrocarbene)
Soluble Starch
Stannous Chloride, Dihydrate
Starch Solution
Starch, soluble potato, powder
Stearic Acid
Stilbene
Strontium 1000 f-tg/mL
Strontium Carbonate
Strontium Chloride
Succinic Anhydride
Sulfa salicylic Acid Dihydrate
Sulfa Ver 4 (sulfate reagent)
Sulfarnic Acid
Sulfanilamide
Sulfanilic Acid
Sulfate Anion STD
Sulfosalicy lie Acid
Sulfur I ,000 ppm
Sulfur Sublimed
Sulfuric Acid
Sulfuric Acid (.IN)
Sulfuric Acid (IN)
Surfactant, Tergitol NP-7
SX diluent (Conoco)
SX Solvent Extraction Diluent
TA-100 Sample
Tannic Acid
Tantalum I 000 J-tg/mL
TCHEM Defoamer 4I1 0
Tetrasodium (salt dihydrate)
TFE Paste
Thalic Nitrate
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
1,050 g 1.82 577
3,850 g 1.295 2,973
14,680 g 1.01 14,535
500 g 0.4 1,250
400 g 4.179 96
402 g 0.803 500
40 g 1.5 27
2,700 g 2.71 996
1,000 g 1 1,000
300 g 1.5 200
575 g 0.84 685
1 g 1.14 1
0 g 1 0
450 g 3.7 122
250 g 3 83
250 g 1.572 159
4,620 g 0.8 5,775
450 g 2.68 168
2,000 g 2.12 943
100 g 1.08 93
100 g 1.485 67
0 g 0
0 g 1.705 0
100 g I IOO
500 g 2.36 212
28,600 g I 28,600
I7,000 g I I7,000
3I,280 g 1.84 17,000
* 1,010
0 g 0
0 g 0
* I,300
I,400 g 2.I29 658
* 125
* 200
800 g *
* 118
25 g * 125
Historic volume
or mass used
(1978-2013)
lcm 3 -1
mL Quantity Unit
mL 2 kg
mL 5 kg
mL 20 kg
mL 0.5 kg
mL 0.5 kg
mL 1 L
mL 1 kg
mL 5 kg
mL 1.5 L
mL 3 kg
mL 25 g
mL 5 g
mL 0.125 L
mL 0.5 kg
mL 0.25 kg
mL 0.25 kg
mL 3 kg
mL 0.5 kg
mL 23.5 kg
mL 100 g
mL 200 g
mL 1 L
mL 1 kg
mL 2.5 L
mL I kg
mL 2,245 L
mL 30 L
mL 63 L
mL 1.5 L
mL 0.2 L
mL 0.5 L
mL 0.5 L
mL 2 kg
mL 2.6 L
mL I L
I kg
mL I20 mL
mL 25 g
Chemical Name
Thallium Nitrate
THAM (tris (Hydroxymethyl)
Amino methane) also TRIS
Tharin
ThenoylTriFluoroacetone
Thio Acetamide
Thorin
Thorium 1000 mg/L
Thymol blue
Tin Metal
TISAB Buffer Solution
TISAB Il w/CDTA
TISAB Ill w/CDTA
TISAB w/CDTA
Titanic Oxide
Titanium 1000 mg/L
Toluene
Trans-1,2-DiAminocyclohexane
Tetra Acetic Acid
Tricapryl Methyl Ammonium Chloride
Trichloroethylene
Triethanolamine
Triethanolamine
Triethylamine
Tri-N-Octylamine
Trioctylphosphine Oxide
Turbidity Standard
Uranium 1000 !lg/mL
Uranium Oxide
Uranyl Acetate
Urea
Vacuum Pump Oil
Vanadium 1000 !lg/mL
Vanadium 5000 !lg/mL
Vanadium Pentoxide
V anady 1 Sulfate
Varsol110 Solvent
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
1 g 5.55 1
5,010 g 1.353 3,703
0 g 0
50 g *
900 g 1.37 657
15 g *
625 g 1 625
10 g *
500 g 7.3 68
* 6,000
6,195 g 1.07 5,790
1,017 g 1.07 950
0 g 0
500 g 4.26 117
* 150
10,363 g 0.8636 12,000
0.5 g *
0 g 0
18,375 g 1.47 12,500
21,809 g 1.13 19,300
0 g 1.13 0
2,555 g 0.73 3,500
2,754 g 0.81 3,400
1,200 g 0.88 1,364
4,500 g 1 4,500
592 g 1.03 575
0 g 10.96 0
1,816 g 2.89 628
40,000 g 1.335 29,963
37 lb 0.9 5
* 500
0 g 0
800 g 6.11 131
250 g 2.5 100
3,699 g 0.822 4,500
Historic volume
or mass used
(1978-2013)
1cm 3 -1
mL Quantity Unit
mL 1 g
mL 10 kg
mL 50 g
50 g
mL 5 kg
15 g
mL 1.5 L
10 g
mL 0.5 kg
mL 20 L
mL 8 L
mL 3 L
mL 9 L
mL 0.5 kg
mL 1.5 L
mL 15 L
10 g
mL 0.1 L
mL 10 L
mL 3 kg
mL 255 L
mL 16 L
mL 24 L
mL 3 kg
mL 36 L
mL 10 L
mL 2 kg
mL 10 kg
mL 407 kg
gal 150 L
mL 5 L
ml 1 L
mL 100 g
mL 6.6 kg
mL 5 L
Chemical Name
Victawat 12
Vinegar
Viscocity Standard 100
Viscocity Standard 1000
Witbreak 770
Witbreak DRI-9026
Witbreak RTC-426
Witconate P-1020Bust
Witconol DNP-45
Witconol NP-40
YSl 3682 Zobell solution
Zinc 5000 ppm STD
Zinc Acetate
Zinc Metal
Zinc Sulfate
Zinc on
Zirconium 1000 mg/L
Zirconium Chloride
Zirconium Oxide
Zirconium Sulfate
Zirconyl Chloride
Appendix 0-1
Laboratory Chemical Inventory
Current Volume and Mass at the Mill
Quantity Unit Density g/cm3 Volume
0 g 0
0 g 0
* 3,000
* 1,000
1,020 g 1.02 1,000
* 500
118 g 1.18 100
250 g 1.05 250
500 g 1.06 500
500 g 1.06 500
* 0
0 g 0
700 g 1.84 380
1,500 g 7.14 210
500 g 1.005 498
2 g *
102 g 1.02 100
100 g 2.8 36
453 g 5.89 77
0 g 0
0 g 0
lcm3 -1
mL
mL
mL
rnL
mL
mL
rnL
mL
mL
rnL
mL
mL
mL
mL
rnL
mL
mL
mL
mL
mL
rnL
*Pursuant to Section I.E.9b) of the GWDP dated August 24, 2012, the Permittee shall provide
"Determination of volume and mass of each raw chemical currently held in storage at the facility."
Both mass and volume are provided when specific gravity data are available.
Laboratory chemicals are stored in the laboratory or in the laboratory storage areas adjacent to the
laboratory.
Abbreviations:
lbs =pounds
gal = gallons
cf = cubic feet
ml =milliliters
g = grams
kg = kilograms
L =liters
oz =ounces
Historic volume
or mass used
(1978-2013)
Quantity Unit
10 L
4 L
5 L
3 L
1 L
0.5 L
1 L
0.25 L
0.5 L
0.5 L
0.125 L
1 L
1 kg
1.5 kg
1 kg
2 g
4 L
1 L
1 kg
0.1 kg
50 g
Appendix 0-2
Current Mill Chemical Inventory
Current Volume and Mass at the Mill4
Quantity Specific Gravity Approximate
Location Chemical Name (lbs) or Bulk Density Volume (gal)
Mill Alamine 336 Drums 0 0.80 sp.g 0
Alarnine 336 Totes 30,600 0.80 sp.g 4,592
Mill Ammonia (East) 55,554 5.15 lb/gal 1,295
Ammonia (West) 109,794 5.15 lb/gal 2,559
Mill Ammonium sulfate (North) 53,787 65.00 lb/cu.ft 99
Mill Ammonium sulfate (South) 50,248 65 .00 lb/cu.ft 93
Ammonium Sulfate Super
Mill Sacks 18,000 65.00 lb/cu.ft 33
Mill Caustic 50% 71,525 1.00 sp.g 8,586
De-Scaler (ChemSearch
Mill 150 or equivalent) 660 1.16 sp.g 68
Diatomaceous Earth Filter
Mill Aid 70,200 2.30 S.Q.g 3,664
Mill Flocculant 6551 39,600 0.80 sp.g 5,942
Mill Hydrogen Peroxide 50% 7,189 1.20 sp.g 722
Mill Hyper Floc 757 Coagulant 0 0.80 sp.g 0
Mill Kerosene 20,545 0.82 sp.g 3,026
Mill Liquified Natural Gas 89,425 0.40 sp.g 26,838
Mill Perlite Filter Aid 10,623 2.30 sp.g 554
Mill Propane 23,605 0.50 sp.g 5,622
Mill Salt 117,470 2.16 sp.g 6,529
Mill Soda ash silo 61,328 0.99 sp.g 7,437
Mill Soda ash Super Sacks 82,000 0.99 sp.g 9,943
Mill Sodium chlorate 1-50% 19,825 6.13 lb/gal 388
Mill Sodium chlorate 2-50% 67,171 6.13 sp.g 1,315
Mill Sodium chlorate 3-50% 0 6.13 sp.g 0
Sodium Chlorate Super
Mill Sacks 46,000 1.32 sp.g 4,199
Mill Sulfuric Acid 94% 3,752,986 1.84 sp.g 244,858
Mill Tri -decyl alcohol 3 23,485 0.83 sp.g 3,397
1The Mill uses a number of comparable polymer flocculants depending on the specific feed.
2 Current tertiary amine product name as purchased from BASF. Alternatively, the Mill has
and may continue to use other tertiary arnines with comparable chemical properties.
3Current alcohol used as modifier. Alternatively, the Mill has and may continue to use other
secondary and tertiary alcohols, including isodecanol, among others, to improve tertiary
arnine!U/kerosene solubility.
Historic volume or mass
used (1978-2013)
Quantity Unit
1,538,782 lbs
:j: lbs
34,861,910 lbs
:j:
44,266,008 lbs
:j: lbs
:j: lbs
42,332,116 lbs
3,960 lbs
1,000,000 lbs
1,149,225 lbs
537,973 lbs
1,395 lbs
15,067,139 lbs
23,371,465 lbs
604,158 lbs
7,309,158 lbs
63,111,955 lbs
76,472,417 lbs
:j: lbs
30,978,629 lbs
:j: lbs
:j: lbs
:j: lbs
757,297,581 lbs
967,383 lbs
4Pursuant to Section I.E.9b) of the GWDP dated August 24,2012, the Permittee shall provide
"Determination of volume and mass of each raw chemical currently held in storage at the
facility." Both mass and volume are provided when specific gravity data are available.
t -Historic values reported are the total quantity used at all locations. The historic quantities
are reported as a single total for the first location listed.
Abbreviations:
lbs =pounds
lb/gal-pounds per gallon
lb/cu.ft =pounds per cubic foot
sp.g = specific gravity
Appendix 0-3
Cleaners and Maintenance/Miscellaneous Chemicals
Historic volume or mass
Current used (1978-2013)
Location Cleaners Quantity Units Quantity Unit
MSW #2 EP Grease Shell Retinax LXZ 796 lbs 3300 lbs
MSW #5182 Pyroshield Grease I oil 4,560 lbs 21660 lbs
MSW #7 4 AB compound 334 lbs 1587 lbs
MSW 150 Gear Oil 880 gal 4312 gal
MSW 15-40w Motor Oil 2,035 gal 8435 gal
MSW 220 Gear Oil 5,720 gal 26000 gal
MSW 2-cycle oil 5.25 gal 20 gal
MSW 2pH Buffer 38.6 gal 206 gal
MSW 30w motor oil Rotella T 660 gal 2805 gal
MSW 460 Gear Oil 1,540 gal 6718 gal
MSW 4pH Buffer 39.6 gal 211 gal
MSW 5w-30 synthetic blend oil 110 gal 421 gal
MSW 680 gear oil 4,015 gal 17514 gal
MSW 7pH Buffer 46 gal 245 gal
MSW 80-90w gear oil 110 gal 110 gal
MSW Acetylene bottle 32,754 cf 141008 cf
MSW Air tool lubricant 16.4 gal 67 gal
MSW Ajax 164 gal 697 gal
CL Ajax 4,257 ml :j:
CL Alcon ox 5,500 g 500 kilos
CL Alcotabs 3,060 g 60 kilos
MSW Alumina Desiccant 1,500 lbs 1,500 lbs
MSW Aluminum spray paint 13 gal 61 gal
MSW Anti-Freeze 990 gal 4,377 gal
MSW Anti-seize lubricant 23 gal 109 gal
MSW Argon mixed gas 15,226 cf 63,114 cf
MSW Argon T -large 6,289 cf 27,074 cf
MSW Auto Trans Fluid 220 gal 1,096 gal
CL Baking Soda 5,235 g 60 kilos
MSW Blue spray _paint 20.98 gal 85 gal
MSW Brake cleaner 75 gal 338 gal
MSW Brake fluid 21 gal 101 gal
MSW Bredel hose lubricant 583 gal 2,857 gal
CL Chromerge 0 L 3 L
MSW Cutting oil coolant 24 gal 104 gal
CL Dawn (dish soap) 5,842 ml 300 L
MSW Devcon Brushable Ceramic 2 lbs 2 lbs
MSW Devcon Flexane Putty 92 lbs 437 lbs
MSW Donax TC-50 Transmission Oil 550 gal 3,529 gal
Appendix 0-3
Cleaners and Maintenance/Miscellaneous Chemicals
Historic volume or mass
Current used (1978-2013)
Location Cleaners Quantity Units Quantity Unit
MSW Dura pro cream 2 gal 2 gal
Electronic Instrument Componet
MSW Cleaner 4 gal 22 gal
Endurbond intermediate primer #2
MSW red 65 gal 438 gal
MSW Endurbond Primer # 1 green 55 _gal 438 gal
MSW Endurbond Tack Cement #3 Black 150 gal 920 gal
MSW Fantastik 444 gal 1,777 gal
CL Fantastik 946 ml :j:
MSW Ferric Chloride 660 gal 660 gal
MSW General Epoxey 0.31 gal 0 gal
MSW glass bead blast media 35 gal 35 gal
MSW Glossy black spray paint 248 _gal 1,054 gal
MSW Glossy white sprayiJaint 320.6 _gal 1,313 gal
MSW Go-Jo hand cleaner 918 lbs 4,004 lbs
MSW Gray primer spray paint 107 gal 438 gal
MSW Grease tubes 2,320 lbs 6,874 lbs
MSW Green Spray paint 8 gal 38 gal
MSW Hydraolic jack oil 24 gal 117 gal
MSW Hydraulic oil #68 4,455 gal 18,467 gal
MSW Industrial Degreaser 3 gal 20 gal
MSW Ingersol Rand Coolant 40 gal 40 gal
MSW Iso Heat gas line 6 gal 20 gal
CL Compound 454 g 100 g
MSW Juvenile Gray paint 6 gal 6 gal
MSW Laundry Soap 17,610 lbs 72,996 lbs
MSW Liquid Flexane 94 Devcon 104 lbs 460 lbs
CL Liqui-Nox Cleaner 0 200 L
MSW Long term grease cart. 4 lbs 4 lbs
MSW Lubriplate Polymer Grease Tube 2 gal 2 gal
CL Lysol 1,500 ml :j:
MSW Lysol 390 gal 1,543 gal
MSW Mask out paint -tan 1.22 gal 1 gal
MSW Metal Set A4 4 lbs 16 lbs
MSW Methyl Ethyl Ketone #366 605 gal 3,286 gal
MSW Mop&Glo 74 gal 338 gal
CL Mop&Glo 100 ml :j:
MSW Never wet spray coating kit 0.11 gal 0 gal
MSW Oil absorbent floor dry 7,950 lbs 31,800 lbs
Appendix 0-3
Cleaners and Maintenance/Miscellaneous Chemicals
Historic volume or mass
Current used (1978-2013)
Location Cleaners Quantity Units Quantity Unit
MSW Orange spray paint 27 gal 113 gal
MSW Oxygen Cylinder TOX 75,900 cf 303,600 cf
MSW paint marker 1 gal 7 gal
MSW Pipe Dope 39 gal 156 gal
MSW Plastic Epoxy 0.31 gal 0 gal
MSW Pledge (Lemon) 18.2 gal 75 gal
CL Pledge 2,124 g :j:
MSW Power Steering Fluid 80 gal 297 gal
CL Professional Drain Cleaner 950 mL 4 L
MSW PVC Cement #711 39 gal 158 gal
MSW PVC primer #9-70 purple 30 gal 132 gal
MSW Ridgid thread cutting oil 25 gal 109 gal
MSW Safety Red Paint 52 gal 52 gal
MSW Safety Yell ow Paint 24 gal 24 gal
MSW Safety Yell ow spray paint 143 gal 609 gal
MSW Scotch Kote, coating 1 gal 5 gal
MSW Silicone Adhesive 3 gal 15 gal
MSW Silicone Sealant 230 gal 955 gal
MSW small propane cylinders 96 lbs 409 lbs
MSW Spa Blue Paint 490 gal 1,182 gal
MSW Spa Blue Spray Paint 96 gal 265 gal
MSW Spraflex Lubricant 10 gal 46 gal
MSW Starting fluid 90 gal 307 gal
MSW Sullair Coolent 490 gal 2,259 gal
MSW Sweeping compound oil base 7,350 lbs 29,066 lbs
MSW T-Chlor liquid chlorine 12% 45 gal 96 gal
MSW Tellas 32 Hydroaulic oil 385 gal 385 gal
MSW The works bowl cleaner 21 gal 42 gal
MSW Tidy pearl pink liquid soap 185 _gal 787 gal
MSW WD-40 150 _gal 496 gal
MSW White Metal Marker 2 gal 9 gal
MSW Windex 240 gal 995 gal
CL Windex 968 ml :j:
MSW Windshield washer fluid 251 gal 1,053 gal
:j: -Historic values reported are the total quantity used at all locations. The historic quantities are
reported as a single total for the first location listed.
Abbreviations:
lbs =pounds
1 Location 1
gal = gallons
cf = cubic feet
ml = milliliters
g =grams
kilos = kilograms
L =liters
Appendix 0-3
Cleaners and Maintenance/Miscellaneous Chemicals
Historic volume or mass
Current used (1978-2013)
Cleaners Quantity I Units Quantity I Unit
Location. of
Storage or
Use
Leach circuit
Leach circuit
UraniumSX
Uranium SX
Appendix 0-4
Historic/Formerly Used Chemicals
Chemicals Formerly Used at Mill/No Longer Used or Present on Site 1
Time Period of Total Quantity
Chemical Form Use Used 2
Several months
Dry solid in during 1997 or No more than several
Ammoniu m Bi-tluoride SuperSaks 1998 thousand lbs.
Several months
during 1997 or No more than 10,000
Hydrochloric Acid Drummed liquid 1998 gallons
Several months
during 1997 or No more than 2,000
J-Mt primary amine Drummed Liquid 1998 .gallons
Several months
Tri octyl phosphine during 1997 or No more than 2,000
oxide ("TOPO") Drummed liquid 1998 gallons
Current Status
None on site
since 1998
None on site
since 1998 3
None on site
since 1998
None on site
since 1998
1. These reagents were used during processing of one alternate feed for 6 months in 1997/1998, and have not been
used before or since.
2. Total quantities used are also the total quantities purchased over life of the alternate feed project, that is, total on
site was this quantitiy or less.
3. Unused residual consumed from 1997 to 1999 for cleaning purposes.
1.0 INTRODUCTION 5
1.1 Background 5
1.2 Applicable Standards for Review and Approval of this Application 5
1.3 Background Groundwater Reports and Re-opening of Permit 9
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
2.2 Legal Location of the Facility (R317-6-6.3B) 18
2.3 Name and Type of Facility (R317-6-6.3.C)
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well, Drinking Water Source
Protection Zones, Topography, Springs, Water Bodies, Drainages, And Man-Made Structures Within A One-Mile
Radius Of The Discharge. (R317-6-6.3.D) 1!WJ
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317-6-6.3.E)
2.5.1 Groundwater Characteristics
2.5.1.1 Geologic Setting
2.5.1.2 Hydrogeologic Setting
2.5.1.3 Perched Zone Hydrogeology
2.5.1.4 Perched Groundwater Flow
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient OfThe Tailings Cells
2.5.2 Groundwater Quality
2.5.2.1 Entrada/Navajo Aquifer
2.5.2.2 Perched Groundwater Zone
2.5.3 Springs and Seeps
2.5.4 Topography
2.5.5 Soils
2.5.6 Bedrock
2.5.7 Agricultural and Land Use Description of the Area
2.5.8 Well Logs
2~
2019
2019
20
21~
25B
27~
28~
28~
28~
29~
3~
3~
3~
.2!~
31~
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of the Effluent or Leachate
to be Discharged (R317-6-6.3.F) 32a9
2.7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate Into or Adversely Affect
the Quality of any Other Waters of the State (R317-6-6.3.G) 33iQ
2.7.1 General 3339
2.7.2 Cells 1, 2 and 3 33M
2.7.2.1 Design and Construction of Cells 1, 2 and 3 33M
2.7.2.2 Improved Groundwater Monitoring 3~
2.7.2.3 Operational Changes and Improved Operations Monitoring 35~
2.7.2.4 Evaluation ofTailings Cell Cover System Design 35~
2.7.3 Ceii4A 36~
2.7.4 Ceii4B
1
2.7.5 Future Additional Tailings Cells
2.7.6 Roberts Pond
2.7. 7 Other Facilities and Protections
2.7.7.1 Feedstock Storage
2.7.7.2 Mill Site Reagent Storage
2.7.7.3 New Construction
2.7.7.4 Other
2.7.8 Surface Waters
2.7.9 Alternate Concentration Limits
41~
41~
42~
42~
4349
4349
4349
444±
444±
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information of the Quality of the
Receiving Ground Water (R317-6-6.3.H) ~
2.8.1 Existing Wells at the Time of Original Permit Issuance 45Q
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit 45Q
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.1) 4643
2.9.1 Groundwater Monitoring to Determine Groundwater Flow Direction and Gradient, Background Quality at
the Site, and the Quality of Groundwater at the Compliance Monitoring Point 46~
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit 46~
2.9.1.21ssuance of the Permit 4~
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit
2.9.1.4 Groundwater Flow Direction and Gradient
2.9.1.5 Background Quality at the Site
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point
2.9.2 Installation, Use and Maintenance of Monitoring Devices
2.9.2.1 Compliance Well Monitoring
2.9.2.2 Leak Detection System in Cell 4A and Cell 4B
2.9.2.3 Other DMT Monitoring Requirements
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring Points
2.9.4 Monitoring of the Vadose Zone
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation, Including Post-
Operational Monitoring 524&
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation 524&
2.9.5.2 Post-Operational Monitoring 524&
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where Applicable to Specified
Guidance 524&
2.9.6.1 Monitoring Well Construction 524&
2.9.6.2 Ground Water Sampling 2.§-Q
2.9.7 Description and Justification of Parameters to be Monitored 56-9
2.9.8 Quality Assurance and Control Provisions for Monitoring Data 57-9
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of Discharge Systems (R317-
6-6.3.J) 58i4
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-6-6.3.K)
2.11.1 General
2.11.2 Background Ground Water Quality in the Perched Aquifer
2.11.3 GWCL Determination for Field pH
2.11.4 Quality of Ground Water at the Compliance Monitoring Point
2.12 Compliance Sampling Plan (R317-6-6.3.L)
2.12.1 Tailings Cell Wastewater Quality Sampling Plan
2.12.2 White Mesa Seeps and Springs Sampling Plan
2
5855
58~
59~
64W
66~
2.12.3 Monitoring of Deep Wells
2.13 Description of the Flooding Potential of the Discharge Site (R317-6-6.3.M)
2.13.1 Surface Water Characteristics
2.13.2 Flood Protection Measures
2.14 Contingency Plan (R317-6-6.3.N)
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting Failure of the System
(R317-6-6.3.0) 7oei
2.15.1 Existing Tailings Cell Operation
2.15.2 Existing Facility DMT Performance Standards
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3
2.15.2.2 Slimes Drain Monitoring
2.15.2.3 Maximum Tailings Waste Solids Elevation
2.15.2.4 Wastewater Elevation in Roberts Pond
2.15.2.5 Inspection of Feedstock Storage Area
2.15.2.6 Monitor and Maintain Inventory of Chemicals
2.15.3 BAT Performance Standards for Ceii4A
7oe&
719&
719&
71~
72~
72~
7268
7368
7369
2.15.3.1 BAT Operations and Maintenance Plan 7369
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance Plan 7469
2.15.4 BAT Performance Standards for Ceii4B 75+-G
2.15.4.1 BAT Operations and Maintenance Plan 75+-G
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance Plan 75+-G
2.15.5 Stormwater Management and Spill Control Requirements 77':74
2.15.6 Tailings and Slimes Drain Sampling 77~
2.15.7 Additional Monitoring and Inspections Required Under the Mill License 77~
2.15.7.1 Daily Inspections 78~
2.15.7.2 Weekly Inspections 7873
2.15.7.3 Monthly Reports 7973
2.15.7.4 Quarterly Tailings Inspections
2.15.7.5 Annual Evaluations
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to Remedy any Violation
of Applicable Ground Water Quality Standards (R317-6-6.3.P) 81-1-5
2.16.1 Chloroform Investigation 81~
2.16.2 Nitrate Investigation 83-7e
2.17 Other Information Required by the Director (R317-6-6.3.Q) 8679
2.17.1 Chemical Inventory Report 8679
2.17.2 Southwest Hydrogeological Investigation 868Q
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-6.3.R) 8739
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent Ground Water
Contamination During the Closure and Post Closure Phases of Operation (R17-6-6.3.S) 8739
2.19.1 Regulatory Requirements for Uranium Mills 878Q
2.19.1.1 Long Term Custodian 878Q
2.19.1.2 Responsibility For And Manner Of Clean Up 87&±
2.19.1.3 Surface 88&±
2.19.1.4 Groundwater 88~
2.19.1.5 License Termination 88~
2.19.2 Current Reclamation Plan 89~
3
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan
2.19.4 Post-Operational Monitoring
3.0 CONCLUSIONS
4.0 SIGNATURE AND CERTIFICATIONS
5.0 REFERENCES
4
1.0 INTRODUCTION
1.1 Background
Prior to July 1, 2012, the Director of the Utah Division of Radiation Control ("Director") was
referred to as the Executive Secretary of the Utah Radiation Control and Board Co-Executive
Secretary of the Utah Water Quality Board. Documents referenced in this Application,
published prior to that date, refer to the Director, by one or both of these previous titles.
In accordance with R317 -6-6.7, this is an updated application (the "Application") to the Director
for renewal of the Permit for another 5-years under R313-6-6.7. fu this Application, Denison is
HOt proposing any modifleationc; to the terms and sonditions of lhe Permit.
The Mill is also subject to State of Utah Radioactive Materials License No. UT 1900479 (the
"Mill License"), which was issued on March 31, 19972 for 10-years and is currently in the
process of timely renewal under R313-22-363, and State of Utah Air Quality Approval Order
DAQE-AN0112050018-11 (the "Air Approval Order") which was re-issued on March 2, 2011
and is not up for renewal at this time. While the Mill License is referred to in this Application
from time to time in order to allow the Director to better understand Mill operations and
compliance with applicable regulatory requirements, this is not an application for renewal of the
Mill License or Air Approval Order.
1.2 Applicable Standards for Review and Approval of this Application
I PriartoJul y 25, 2.011. Energ)' UI':)S Rcsnul'Ci'S I s [nc. \ us numcrl ''Dt:njs n iJ.in •q I A) c~lm ("DMj:.:on'1)", Prior to
December 16, 2006, Denison was named "International Uranium (USA) Corporation."
2 The Mill License was originally issued by the United States Nuclear Regulatory Commission ("NRC") as a source
material license under 10 CFR Part 40 on March 31, 1980. It was renewed by NRC in 1987 and again in 1997.
After the State of Utah became an Agreement State for uranium mills in August 2004, the Mill License was re-
issued by the Executive Secretary as a State of Utah Radioactive materials license on February 16, 2005, but the
remaining term of the Mill License did not change.
3 A Mill License renewal application was submitted to the Executive Secretary on -February 28, 2007, pursuant to
R313-22-36.
5
In accordance with discussions between DeHisoH EFRI maHagemeHt and State of Utah Division
of Radiation Control ("DRC") staff on Mareh 12, 2009April 1, 2014, this Application includes
the information required under R31J ]-6-6.3.
In accordance with JHHR317-6-6.4C, the Director may issue (or renew) a ground water
discharge permit for an existing facility, such as the Mill, provided:
a) The applicant demonstrates that the applicable class total dissolved solids ("TDS")
limits, ground water quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) The applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by
facilities that produce similar products or services with similar production process
technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
ompleLcd and is·
6
contarrd nation.
Th moni1oring, re. ull f< r ach wdl I hat i ·· ·ampled are evaluated for compliance with standards
for 38 different constituents and. re2:ardless of whether standards are met, for trends in the data
that may show a need for further action.
chloroform monitoring wells.
mino.Led [!rQLlndwatcr rn April.
how this initial remediation effort has been effective
based on reduction of contaminant concentrations. Reductions of the contaminant concentrations
inclicarc bolh Lh<ll the pumping prooram is working nd that Lhere is no contintl
contaminants, as would be the case if the cells were leaking.
Durin2 a revi ew of he EFRI April 30. 2 0 ew Wells B ckeround Repo&t and other EFRl
reports, Nitrate + Nitrite (as N) (hereafter Nitrate) concentrations were observed above the Utah
Ground Wmer Qua lity Standar (I 0 mg!L) in ftv m oit01ine welli· in U1e mill ite are .
have since been abandoned.
pn of ilie ni trate corrective acti n .
7
EFRI has submitted two roporl5 to DR r garding the ele ntcd iu·ate concentrations. The
reports identifv the extent of the Nitrate plume but EFRI and DRC disagreed about what the
report · indicated aboul the likely ourcc of th plume. E " I doc. not believe that the results
adequately demonstrated an on-site source.
EFR · agreed to implement a corrective action plan to Lean up the plume. EFRl completed and
submitted the Nitrate Corrective Action Plan t the DRC on May 7, 2012. The Corrective
thi · initial remediation effort has been eft! ctive based on
evidence:
cell wastewater.
3. Sta lc h:otopes n Dissolved Sulfate. The
8
A-l#lough DeAiS(lfl is aot prOJ30Siag any :;ignitictml changer; to l:Be original Permit, lThis
Application has eeverH1elC!;S been performed prepared under the direction, and bears the seal, of
a professional engineer qualified to practice engineering before the public in the state of Utah
and professionally registered as required under the Professional Engineers and Professional Land
Surveyors Licensing Act rules (UAC 156-22).
1.3 Background Groundwater Reports and Re-opening of Permit
In the December 1, 2004 Statement of Basis (the "2004 Statement of Basis") prepared by DRC
in connection with the original issuance of the Permit, three monitoring wells (MW-14, MW-15,
and MW-17) located downgradient of the Mill's tailings cells were found to have long-term
increasing concentration trends for total uranium. These three wells and downgradient well
MW-3, had total uranium concentrations above the Utah Ground Water Quality Standard
("GWQS"), found in UAC R317-6-2 (see the 2004 Statement of Basis, pp. 6-7). These findings
were of concern to the DRC because they appeared to indicate that the tailings cells had possibly
discharged wastewater into the underlying shallow aquifer.
To resolve this concern, the Director required Deaisoa EFRI to evaluate groundwater quality
data from the thirteen existing wells on site, and submit a Background Ground Water Quality
Report for Director approval. The existing wells are those wells which were installed prior to the
issuance of the original GWDP on March 8, 2005 and include: MW-1, MW-2, MW-3, MW-5,
MW-11, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-26 (formerly called TW4-
9
15 and installed as part of the chloroform corrective action order), and MW-32 (formerly called
TW 4-17 and installed as part of the chloroform corrective action order). It is important to note
that MW -4 was installed prior to the issuance of the original permit; however, MW -4 is
monitored under the chloroform program and was not included in the Existing Background
Report. GWCLs have not been established for this well, and MW -4 is not a POC well under the
GWDP. One of the purposes of tflat:-Lh ba ·kgr und report was to provide a critical evaluation of
historic groundwater quality data from the facility, and determine representative background
quality conditions and reliable groundwater compliance limits ("GWCLs") for the Permit.
As required, Denison EFRI submitted the following reports:
• Revised Background Groundwater Quality Report: Existing Wells For Denison Mines
(USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, October 2007, prepared by
INTERA, Inc. (the "Existing Well Background Report"); and
• Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, November
16, 2007, prepared by INTERA, Inc. (the "Regional Background Report").
The Existing Well Background Report and the Regional Background Report included a detailed
quality assurance evaluation of all existing groundwater quality data collected prior to the date of
issuance for the thirteen exi~ting wells, in accordance with criteria established by DRC and
United States Environmental Protection Agency ("EPA") guidance. This resulted in a data-base
suitable for statistical and other analyses. Based on an analysis of this updated data-base, the
Existing Well Background Report and Regional Background Report concluded that there have
hnd been no impacts to groundwater from Mill activities, based on a number of factors, including
the following:
• There are-were a number of exceedances of GWQSs in upgradient and far downgradient
wells at the site, which cannot be considered to have been impacted by Mill operations to
date. Exceedances of GWQSs in monitoring wells nearer to the site itself are therefore
consistent with natural background in the area.
• There are-were numerous cases of both increasing and decreasing trends in constituents
in upgradient, far downgradient, and Mill site wells, which provide evidence that there
are natural forces at work that are impacting groundwater quality across the entire site.
• In almost all cases where there are-were increasing trends in constituents in wells at the
site, there are--were increasing trends in those constituents in upgradient wells.
Furthermore, in no case is--was there any evidence in the wells in question of increasing
trends in chloride, which is very mobile and a good indicator of potential tailings cell
leakage at the site.
See Section 2.11.2 below for a more detailed discussion of the Existing Well Background Report
and Regional Background Report and their conclusions.
10
The Permit also required nine new monitoring wells to be installed around tailings Cells 1 and 2,
followed by groundwater sampling and analysis, and later submittal of another Background
Ground Water Quality Report to determine reliable background conditions and groundwater
compliance limits for the new wells. The new wells are those wells which were installed after the
issuance of the original GWDP on March 8, 2005 and include: MW-3A, MW-23, MW-24, MW-
25, MW-27, MW-28, MW-29, MW-30, and MW-31. In response to this requirement, DeHisoH
EFRI installed the nine new wells, and submitted to the Director a Revised Addendum: --
Background Groundwater Quality Report: New Wells For Denison Mines (USA) Corp.'s White
Mesa Mill Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc. (the "New
Well Background Report"), and together with the Existing Well Background Report and the
Regional Background Report, are referred to as the "Background Reports").
The New Well Background Report concluded that the sampling results for the new wells confirm
that the groundwater at the Mill site and in the region is highly variable naturally and has not
been impacted by Mill operations and that varying concentrations of constituents at the site are
consistent with natural background variation in the area. See Section 2.11.2 below for a more
detailed discussion of the New Well Background Report and its conclusions.
During the course of discussions with DeHisoH EFRI staff, and further DRC review, DRC
decided to supplement the analysis provided in the Background Reports by commissioning the
University of Utah to perform a geochemical and isotopic groundwater study at White Mesa.
This resulted in the University of Utah completing a study entitled Summary of work completed,
data results, interpretations and recommendations for the July 2007 Sampling Event at the
Denison Mines, USA, White Mesa Uranium Mill Near Blanding Utah, May 2008, prepared by T.
Grant Hurst and D. Kip Solomon, Department of Geophysics, University of Utah (the
"University of Utah Study"). The purpose of the University of Utah Study was to determine if
the increasing and elevated trace metal concentrations (such as uranium) found in the monitoring
wells at the Mill were due to potential leakage from the on-site tailings cells. To investigate this
potential problem, the study examined groundwater flow, chemical composition, noble gas and
isotopic composition, and age of the on-site groundwater. Similar evaluations were also made on
samples of the tailings wastewater and nearby surface water ~ tared in the northern wildlife ponds
at the facility. Fieldwork for the University of Utah Study wru conducted fi: m July 17 -26 of
2007. The conclusions in the University of Utah Study supported DenisoA-+EFRl's conclu ions
in the Background Reports
As stated above, DUSA EFRI prepared Background Reports that evaluated all historic data for
the thirteen existing wells and nine new wells for the purposes of establishing background
groundwater quality at the site and developing GWCLs under the GWDP. Prior to review and
acceptance of the conclusions in these Background Reports, the GWCLs were set on an interim
basis in the GWDP. The interim limits were established as fractions of the state GWQSs for
drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells and the nine new wells based primarily on the conclusions and
analysis in the Background Reports. It should be noted, however, that, because the GWCLs have
been set at the mean plus second standard deviation, or the equivalent, un-impacted groundwater
would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
11
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
In addition to the thirteen existing wells and the nine new wells there are an additional 7
monitoring wells at the site which are included in the routine groundwater monitoring program·.
Those 7 wells are: MW-20, MW-22, MW-33, MW-34, MW-35, MW-36, and MW-37.
The GWDP dated January 20, 2010 required the completion of eight consecutive quarters of
groundwater sampling and analysis of MW-20 and MW-22, and later submittal of another
Background Rep l't to determine if wells MW-20 and MW-22 should be added as point of
compliance C POC:) monitoring wells. Data from MW-20 and MW-22 were analyzed in the pre-
operational and regional background addendum (INTERA 2007a); however there was not a
complete data set at the time. Although wells MW-20 and MW-22 were installed in 1994, they
were not sampled regularly until the second quarter of 2008. The eighth full round of sampling
was completed during the first quarter of 2010, and Deaisoa EFRI submitted to the Director the
Background Groundwater Quality Report for Wells MW-20 and MW-22 for Denison Mines
(USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, June 1, 2010, prepared by
INTERA, Inc. (the "MW-20 and MW-22 Background Report"). DRC classified MW-20 and
MW-22 a general m.onHoring weJJs~ and oo--GWCL · have n_Lb~en ealeu lated tabti hed for
tb e weU . MW-20 and M.W-22 _are amplcd emiannuaJJy.
Part I.H.6 of the +he-GWDP dated June -l-121 , ~2010, Puti: l.H.6 required the installation of
three hydraulically downgradient wells adjacent to Tailings Cell4B (MW-33, MW-34, and MW-
35) prior to placemen of fffiY potentinl tailing and/or wastewater in Cell 4R Th purpo e of
these monitoring wells was to provide early detection of tailings cell contamination of shallow
groundwater from Tailings Cell 4B. Deaisoa EFRI installed MW-33, MW-34, and MW-35 as
required. Of these three wells installed near tailings Cell 4B, only MW-35 was hydraulically
acceptable, with five feet or more of saturated thickne . MW-35 ha:s eeenwa ample-d quarterly
since fourth quarter 2010 to collect eight coaseeuti'le qU~;:t~i:·tati:tically alid data point for
the completion of the Background Report and calculation of GWCLs. MW-33 and MW-34 had
insufficient water for sampling, with saturated thicknesses less than five feet. MW -33 is
completely dry, and no samples or depth to water measurements are collected from this well.
Quarterly depth to water is measured in MW-34, but no sampling or analysis is required.
Part I.H.4 of the February 15, 2011 GWDP required the installation of two wells hydraulically
downgradient of Tailings Cell 4B as replacements for MW-33 and MW-34. Deaisoa EFRI
installed MW-36 and MW-37 as required. MW-36 and MW-37 H.a·;e beeawere sampled
quarterly since third quarter 2011 to collect eight eeaseeulive q~ull·ters o-f tali ticailv valid data
points for the completion of the Background Report and calculation of GWCLs.
1.4 Documents Referenced in This Application
12
The following documents are referenced in this Application,_ aRd are a part of this ApplicatioR:
a) The following Permits, Licenses, Statement of Basis, Plans and Related Reports:
(i) Slate of wh Omund Water Discharg--Permit No. UGW370 04 dat d Aut?.u ·t 24.
2012. (the "Permit") and previous versions of the Permit doted Janu~uy 10. 2010.
June 21 ,2010, Februarv 15.201 1. and July 14 .201 L
(ii) State of Utah Radioactive Materials License No. UT 1900479 (the "Mill
License");
(iii) Statement of Basis For a Uranium Milling Facility at White Mesa, South of
Blanding, Utah, Owned and Operated by International Uranium (USA)
Corporation, December 1, 2004, prepared by the State of Utah Division of
Radiation Control (the "2004 Statement of Basis");
(iv) Reclamation Plan White Mesa Mill Blanding, Utah, Source Material License No.
SUA-1358 Docket No. 40-8681 Revision 4:()3.2B, Novemeer 2009January 14.
2011 (the "Reclamation Plan"); and
(v) UMETCO Minerals Corporation: White Mesa Mill Drainage Report for Submittal
to NRC, January 1990;
b) The following Background Groundwater Quality Reports and Related Studies:
(i) Revised Background Groundwater Quality Report: Existing Wells For Denison
Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, October 2007,
prepared by INTERA, Inc. (the "Existing Well Background Report");
(ii) Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah,
November 16, 2007, prepared by INTERA, Inc. (the "Regional Background
Report");
(iii) Revised Addendum: --Background Groundwater Quality Report: New Wells For
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, April
30, 2008, prepared by INTERA, Inc. (the "New Well Background Report" and
together with the Existing Well Background Report and the Regional Background
Report, the "Background Reports"); and
(iv) Summary of work completed, data results, interpretations and recommendations
for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa
Uranium Mill Near Blanding Utah, May 2008, prepared by T. Grant Hurst and D.
13
Kip Solomon, Department of Geophysics, University of Utah (the "University of
Utah Study");
(v) Background Groundwater Quality Report for Wells MW-20 and MW-22 for
Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah, June
1, 2010, prepared by INTERA, Inc. (the "MW-20 and MW-22 Background
Report");
(vi) Background Groundwater Quality Report for Monitoring Wells MW-35, MW-36
and MW-37 White Mesa Mill Blanding, Utah, May 1, 2014, prepared by INTERA,
Inc. (the "MW-35, MW-36, and MW-37 Background Report".
c) The following environmental reports and analyses:
(i) Environmental Report, White Mesa Uranium Project San Juan County, Utah,
January 30, 1978, prepared by Dames & Moore (the "1978 ER"); and
(ii) Final Environmental Statement related to operation of White Mesa Uranium
Project Energy Fuels Nuclear, Inc., May 1979, Docket No. 40-8681, prepared by
the United States Nuclear Regulatory Commission (the "FES");
d) The following engineering, geological and hydrogeological reports:
(i) Umetco Groundwater Study, White Mesa Facilities, Blanding, Utah, 1993,
prepared by Umetco Minerals Corporation (Lh c perat r of th ill at th
and Peel Environmental Services;
(ii) Hydrogeological Evaluation of White Mesa Uranium Mill, July 1994, prepared by
Titan Environmental Corporation (the "1994 Titan Report");
(iii)
(iv)
Evaluation of Potential for Tailings Cell Discharge-White Mesa Mill, November
23, 1998, prepared by Knight-Piesold LLC;
Update Lo repoFl Investigation of Elevated chloroform concentrations in Perched
Groundwater at the White Mesa Uranium Mill Near Blanding, Utah, 2001,
prepared by Hydro Geo Chern, Inc.;
Hytiffl~lie Tes:ing ttt .'he White Mest1 UreRium Mill Netlr Blm1tlffig, Uf.B}l DuriHg
~002 Allgttst 22, 2002 prepares I:Jy Hydro Gee Caem lee.·
fvi-).(yl_Letter Report dated August 29, 2002, prepared by Hydro Geo Chern, Inc.;
(vii) Perclu:ti-Men:it&ring Well Jnstal!flfiert-and Testirtg til flw Whi~e Me.~e (;}nmium-l'lf.i.U
Af;F#-Thrrmgh hwe 2005, Augu:st 3, 'lGQ5 preptuea b,y Hydro Gee Cb:em lnc .. ;
14
('v111) She H.wi·r&gt't~lfJgy and l£:;1it~uaimr-ef GretmtA1•£l,"t'r Tttli'el Timet~ Tn The Perdwd
Zt:Pw WhUe MeNtt Urt:lRiHHt-Jil+ll Silt• l'lcttr B/(;lfl diRg, CJt.uh, Auglwt 27, 2009;-
prepared by Hydro Gee Chern, Inc.;
f:i*JtilHydrogeology White Mesa Uranium Mill Site Near Blanding, Utah, June 6, 2012,
prepared by Hydro Geo Chern, Inc.;
(*) Hydregealfft:Y ej rhe Pc.•rohed......frffltmeu.'t11er Zrme--emi t .. ssoeiateeJ St!ejiS fflNl
~g.Y Neer the White .~1esti Unmiiim J.l/ill Sile, BI8Rtiil18 Ult~h. Noveffiber t2
2010, prepared by Hydro Gee Chern. Inc.; ami
(xi)
e) The following plans and specifications relating to construction and operation of the
Mill's tailings cells:
(i) Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
(ii) Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by
D' Appolonia Consulting Engineers, Inc.;
(iii) Construction Report: Initial Phase-Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia
Consulting Engineers, Inc.;
(iv) Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc. (the
operator of the Mill at the time);
(v) Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation (Lhe op rator of the MiJI al lhe tim );
(vi) Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by Denison (then named International
Uranium (USA) Corporation Clh p · ralor of the Mill at the time»;
(vii) Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants;
(viii) Cell4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah,
July 2008, prepared by Geosyntec consultant · Aiy1;
(ix) Cell 4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007,
prepared by Geosyntec Consultants; and
15
(x) Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants.
f) The following documents relating to the chloroform investigation at the site:
(i) Preliminary Corrective Action Plan, White Mesa Mill Near Blanding, Utah,
August 20,2007, prepared by Hydro Geo Chern, Inc.; aatl
(ii)
(:-itt1(i) ,ontaminalion bwestigati " Reporr TW4-12 and TW4-27 Areas
Uranium Mill, Near Blanding Utllh. Januarv 2 .. 20 14 prepured b
Chern. Inc.;
gL__The following documents relating to the Ailraw and pH t and ther Out of Compliance
investigations at the site:
gt--
(i) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the First, Second, Third and Fourth Quarters of 2010 and First
Quarter 2011, June 13, 2011;
(ii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Second Quarter of 2011, September 7, 2011;
(ill) Plan and Time Schedule for Assessment of pH Under Groundwater Discharge
Permit UGW370004, April13, 2012 prepared by Hydro Geo Chern, Inc;
(iv) White Me. a Mill Srate v( Uwh rowzdwater Di. charge Permit U W370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
'u nstilll ms in !he Third Omu-ter o(2012. ecember 13. 20l2;
(V) White Meso Mill Swre of Uw h Groundwa1er Disduu·ge Permit U ~ 370004 Pllm
and Time Schedule Under part I.G.4 (d) for Violations of Part l.G.2 (or
urth Otwrrer o[2012. Mar h I 5. 2013;
( i) White Mesa Mill Stcu of tail Ground1 at •r Discharge Permit U lV. 70004 Plan
and Time Schedule Under part I.G.4 (d) (or Violations of Part l.G.2 for
Constituents in the First Quarter of2013. August 28. 2013:
( •ii)
16
o[ Part lG.2 for
(ix) Source Assessment Report. White Mesa Uranium Mill. Blandin g Utah. October
10,2012 prepared by INTERA. Inc;
(x) pH Report White Mesa Uranium Mill. Blanding Utctli , November 9, 2012
prepared by INTERA, Inc;
(xi }
(xiiJ
(xi ii)
(.tv )
h)
(i)
(ii)
(iii)
(iv)
(v)
Uranium Mill.
Blanding Utah. May 7. 201 .
Stipulated Consent Agreement Docket No. UGW12-03 between Denison Mines
(USA) Corp. and the Director of the Division of Radiation Control, July 12, 2012.
Revised Tolling Agreement, Revision 3, between DUSA and the Director,
Revision 2, dated August 21, 2011.
Revised Phase 1 (A through C) Work Plan and Schedule for Phase 1 A -C
Investigation, May 11, 2011, prepared by INTERA, Inc;
Revised Phase 2 through 5 Work Plan and Schedule, June 3, 2011, prepared by
INTERA, Inc;
Revised Phase 2 QAP and Work Plan, Revision 2.0, July 12, 2011; and
..~..(v~i~) ___ .Nitrate Corrective Action Plan, May 7, 2012, prepared by Hydro Geo Chern, Inc;.
Nilrate Contaminatiofl In vestigation Report. December 0. 2009, prepared b\
17
INTERA. Inc.
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
The Applicant is Deni:soe }.ofmes (U8:l\) Go:f}'). (' Denisofl") ami p rat r i. Energy "uel
Resources (USA) Inc. ("EFRI"). Deaisoa EFRI is the current holder of the Permit. The Mill is
owned by Deeisoe' s EFRI' s affiliate, Deeisoe "\Vhite MesaEFR White Mesa LLC
("D'.VMEFRWM").
The address for both DeaisoA and D'NM EFRI and EFRWM is:
1050 1th St. Suite 950225 Uni n Boulevard. Suit 600
-f>etwer. CO 80265Lak o I, CO 228
Telephone: [phone]
Fax: [phone]
Contacts at DeeisoaEFRI, all located at the foregoieg aforementioned office:
Harold R. Roberts, Executive Vice President, US Operu~and hief Operating Officer.
Direct telephone: [phone]
hrobert @deRisonm-ieesenergyfueJ .c m
Frank J. Filas
Vice Pre. idenL Permitling and Environmental Afl airc
David C. Frydeelued
Vice Presideat, Regulatory A:ffairs aad Geeeral Gouesel
Direct telephone: 303~97 4-4-1-3{)2146
dfn•dealuadlula, @denisoAm ineseneruvfud .com
Jo Aee TisefilerKatherine A. Weinel
Director, Complionce ttAd Pem1ittjngOuulitv A. uraJH.:e Manag--.;r
Direct telephone: [phone]~
jtischler@defrit;eR.mines.comkw inel@energ fu el . om
2.2 Legal Location of the Facility (R317-6-6.3B)
The Mill is regionally located in central San Juan County, Utah, approximately 6 miles (9.5 km)
south of the city of Blanding. The Mill can be reached by taking a private road for
approximately 0.5 miles west of Utah State Highway 191. See Figure 1.
Within San Juan County, the Mill is located on fee land and mill site claims, covering
approximately 5,415 acres, encompassing all or part of Sections 21, 22, 27, 28, 29, 32, and 33 of
T37S, R22E, and Sections 4, 5, 6, 8, 9, and 16 of T38S, R22E, Salt Lake Base and Meridian
C"SLBM"). See Figure 2.
18
All operations authorized by the Mill License are conducted within the eoafiaes of the existing
site boundary. The milling facility currently occupies approximately 50 acres, and the tailings
disposal cells encompass another 250 acres. See Figure 2.
2.3 Name and Type of Facility (R317-6-6.3.C)
The name of the facility is the White Mesa Uranium Mill. The facility is a uranium milling and
tailings disposal facility, which operates under a Radioactive Materials License issued by the
Director of the Utah Division of Radiation Control under UAC R313-24. In addition to uranium
in the form of U30 8, the Mill also produces vanadium, in the form of vanadium pentoxide
C:V20 5.. ammonia metavanad, te t:AMV.:J and anad iu m pregnant liquor • VPL_:), (rom
certain conventional ores and has produced other metals from certain alternate feed materials
(. pccifically niobium and tantalum · uLhorized under NRC Jicen ·e men ment numb r 4,
induded a<; Apo ndi. AJ. Alternate feed materials are uranium bearing materials other than
conventionally mined ores.
Construction of the Mill was completed and first operations commenced in May 1980. The Mill
does not have a set operating life, and can operate indefinitely, subject to available tailings
capacity and license and permit renewals. The conceptual and permitted total capacity is for the
quantity of Mill tailings produced from a 15-year operating period at a rate of 2,000 tons per day,
operating 340 days per year. Since it commenced operations in 1980, the Mill has operated on a
campaign basis, processing conventional ores and alternate feed materials as they become
available and as economic conditions warrant.
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well, Drinking
Water Source Protection Zones, Topography, Springs, Water Bodies, Drainages, And Man-Made
Structures Within A One-Mile Radius Of The Discharge. (R317-6-6.3.D)
There are five deep wells within a one mile radius of the Mill, two of which supply the Mill
facility. There are no Drinking Water Source Protection Zones or ordinances within this radius.
Routine groundwater monitoring wells have been established for monitoring under the Permit.
These monitoring wells are depicted on Figure 104 and have beea plotted oH 8aa Juaa County,
Utah plat maps in Appendix BA to this Application. The depth and purpose of each of these
wells is as shown in Table§. 1.2-1, 1.2-2, and 2.4-1.
See Section 2. 9 .1.3 below for a detailed description of the Mill's groundwater monitoring
program.
The surface topography vlithia this one mile zone is relatively flat, and man-made structures are
.J..i.mtt.etHe-t.fie-Mill facilities, h wn < n FLur s ore me I in Appendix B. See Sections 2.5.4 and
2.5.7 below for a more detailed discussion on local topography and land use.
The Mill area has several dry drainages, and the only nearby natural water bodies within one
mile are Westwater Creek, Corral Creek and Cottonwood Creek. In addition to these are Ruin
Spring and several other springs and seeps located within a 1.5 mile radius of the Mill. See
Sections 2.5.3 and 2.13 below for discussions relating to seeps and springs in the vicinity of the
site and to surface water and drainages, respectively.
19
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317-6-6.3.E)
2.5.1 Groundwater Characteristics
This Section is excerpted frombased on the Report entitled: ~Hydrogeology of the White
Me ·a Uranium Mill. Bhmdim: Utah fH~rt(tfttm e.f CrfJimdwe!er Travt•l Timc.'i ffi The
.fJ.e.Feht'd Zom: w;,,;,"C Me.w Urmrium Mill Sitt' ·"'lelir Blemclilr.~, U1ah, July Jun ·H)§, ~2014,
prepared by Hydro Geo Chern, Inc. ("HGC") (the "~2014 HGC Report" referred to as HGC,
~2014).
2.5.1.1 Geologic Setting
The Mill is located within the Blanding Basin of the Colorado Plateau physiographic province.
Typical of large portions of the Colorado Plateau province, the rocks underlying the site are
relati vely undefOJ~med. The average ele ation of the ite i. approximately 5,600 ft (1 707 m
ab ve meao sea lev I ·am I_ .
The site is underlain by unconsolidated alluvium and indurated sedimentary rocks consisting
primarily of sandstone and shale. The indurated rocks are relatively flat lying with dips generally
less than 3°. The alluvial materials consist mostly of aeolian silts and fine-grained aeolian sands
with a thickness varying from negligible to as much as 25 to 30 feet across the site. In some
portions of the site the alluvium is underlain by a few feet to as much as 30 feet of Mancos
Shale. In other areas, the Mancos Shale is absent. The alluvium and Mancos (where present) are
underlain by the Dakota Sandstone and Burro Canyon Formation, which are sandstones having a
combined total thickness ranging from approximately 55 to 140 feet (17 to 43 m). Beneath the
Burro Canyon Formation lies the Morrison Formation, consisting, in descending order, of the
Brushy Basin Member, the Westwater Canyon Member, the Recapture Member, and the Salt
Wash Member. The Brushy Basin and Recapture Members of the Morrison Formation, classified
as shales, are very fine-grained and have a very low permeability. The Brushy Basin Member is
primarily composed of bentonitic mudstone, siltstone, and claystone. The Westwater Canyon and
Salt Wash Members are primarily sandstones but are expected to have a low average vertical
permeability due to the presence of interbedded shales. See Figure 3 for a generalized
stratigraphic column for the region.
Beneath the Morrison Formation lies the Summerville Formation, an argillaceous sandstone with
interbedded shales, and the Entrada Sandstone. Beneath the Entrada lies the Navajo Sandstone.
The Navajo and Entrada Sandstones constitute the primary aquifer in the area of the site. The
Entrada and Navajo Sandstones are separated from the Burro Canyon Formation by
approximately 1,000 to 1,100 feet (305 to 355 m) of materials having a low average vertical
permeability. Groundwater within this system is under at1esian pressure in the vicinity of the site,
is of generally good quality, and is used as a secondary source of water at the site.
2.5.1.2 Hydrogeologic Setting
The site is located within a region that has a dry to arid continental climate, with average annual
precipitation of approximately 13.3 inches, and an average annual lake evaporation rate of
approximately 47.6 inches. Recharge to the principal aquifers (such as the Navajo/Entrada)
20
occurs primarily along the mountain fronts (for example, the Henry, Abajo, and La Sal
Mountains), and along the flanks of folds such as Comb Ridge Monocline.
Although the water quality and productivity of the Navajo/Entrada aquifer are generally good,
the depth of the aquifer (approximately 1,200 feet below land surface [ft bls]) makes access
difficult. The Navajo/Entrada aquifer is capable of yielding significant quantities of water to
wells (hundreds of gallons per minute [gpm]). Water in on-site wells completed within the
Navajo/Entrada rises approximately 800 feet above the base of the overlying Summerville
Formation.
The shallowest groundwater beneath the site consists of perched water hosted primarily by the
Burro Canyon Formation. Perched water is used on a limited basis to the north (upgradient) of
the site because it is much shallower and more easily accessible than the deep Navajo/Entrada
aquifer.
2.5.1.3 Perched Zone Hydrogeology
Perched groundwater originates mainly from precipitation and local recharge sources such as
unlined reservoirs (Kirby, 2008) and is supported within the Burro Canyon Formation by the
underlying, fine-grained Brushy Basin Member. Perched groundwater at the site has a generally
lewis generally of poor quality due to high total dissolved solids LTDS:.) in the range of
approximately 1,100 to 7,900 milligrams per liter (~mg/L:). Geneml ly It. relatively poor quality
is one reason that perched water is used primarily for stock watering and irrigation in areas
upgradient (north) of the site. Figure 4 is a contour map showing the approximate elevation of
the contact of the Burro Canyon Formation with the Brushy Basin Member, which essentially
forms the base of the perched water zone at the site. Based on Figure 4, the Burro Canyon
Formation/Brushy Basin Member contact generally dips to the south/southwest beneath the site.
Figure 5 is a perched groundwater elevation contour map for the first quarter, 2011.~. Based on
the contoured water levels, groundwater within the perched zone flows generally south to
southwest beneath the site. Beneath the tailings cells, perched groundwater flow is generally to
the southwest.
Perched groundwater discharges from outcrops of the Burro Canyon Formation in seeps and
springs along Westwater Creek Canyon and Cottonwood Canyon (to the west-southwest of the
millsite and tailings cells) and along Corral Canyon (to the east and northeast of the millsite and
tailings cells). Known discharge points include all-the seeps and springs shown in Figure 5
except Cottonwood Seep.
As discussed in .(HGC.l-2014), Cottonwood Seep is located more than 1,500 feet west of White
Mesa in an area where the Dakota Sandstone and Burro Canyon Formation (which hosts the
perched water system) are absent due to erosion, and at an elevation approximately 230 feet
below the base of the perched zone defined by the contact between the Burro Canyon Formation
and the underlying Brushy Basin Member. Cottonwood Seep occurs near the contact between the
slope-forming Brushy Basin Member and the underlying Westwater Canyon (sandstone)
Member.
21
Contact elevations shown in Figure 4 are based on perched monitoring well drilling and
geophysical logs and surveyed land surface elevations, and the surveyed elevations of Westwater
Seep and Ruin Spring. The elevations of Westwater Seep and Ruin Spring are included in the
kriged c n1. urs because they occur at the contact between the Burro Canyon Formation and the
underlying Brushy Basin Member (HGC, 2012a).
Groundwater elevations shown in Figure 5 include the surveyed elevations of all seeps and
springs except Cottonwood Seep. As discussed above, no evidence exists to connect Cottonwood
Seep to the perched water system. Although Cottonwood Seep may potentially receive some
contribution from perched water, its occurrence near the contact between the Brushy Basin
Member and the underlying Westwater Canyon Member indicates that its elevation is not
representative of the perched water system.
The permeabilities of the Dakota Sandstone and Burro Canyon Formation at the site are
generally low. No significant joints or fractures within the Dakota Sandstone or Burro Canyon
Formation have been documented in any wells or borings installed across the site (Knight
Piesold, 1998). Any fractures observed in cores collected from site borings are typically
cemented, showing no open space.
Porosities and water contents of the Dakota Sandstone have been measured in samples collected
during installation of former well MW-16 and well MW-17 (Figure 5). MW-16 was located
immediately downgradient of tailings Cell 3 and MW -17 is located south of tailings Cell 4A at a
location primarily cross-gradient with respect to perched water flow. Porosities of the Dakota
Sandstone range from 13.4% to 26%, averaging 20%, and water saturations range from 3.7% to
27.2%, averaging 13.5%. The average volumetric water content is approximately 3%. The
hydraulic c ndu tivily of the Dakota and -~one ba ed on packer te t in boring · in ·tall eel at the
ite prior t0 1994 range from 2.71 x to·6centimeter-per cond C.:cm/s~ to 9.12x 104 cm/,
with a geomelric average of3.89 x 10'5 ml (TITAN, 1994).
Extensive hydrogeologic characterization of the saturated Burro Canyon Formation has occurred
through hydraulic testing of perched monitoring wells and borings at the site. Hydraulic testing
of MW -series wells located up gradient, cross-gradient, downgradient, and within the millsite and
tailings cell complex, TW4-series wells located cross-gradient to upgradient of the millsite and
tailings cells, TWN-series wells located primarily upgradient of the millsite and tailings cells,
and DR-series piezometer . lo ai "d downgradlen l f Lhe Lnilings el l indicate that the hydraulic
conductivity of the perched zon tange.J from approx imately .;.1_x 10·& to 0.01 crnls.
22
HyQf!hl!ic tesl:ing of \veHs MW l MW 3, MW 5, ~AV.' t7, to.PN l8 MW 19, ~
MW 23 ~ MW~MW 27. MW 28, M'N 29, MW 30. :MVl 3 L NIW 3:!, MW 35 MW 36, ttfla
MV/ 37 (Figure 5) located up~ss gradjeFH dm•;ngradient and 't'<'ithin the area oF tRe
23
failings cel l~~~~~ed hydraulie-eeAtl~tie~ nmging from lif)proximtHely 2 N
-!-Q4 cmls to J J\ 10~-e-mls (HGC. 2002; HGC, 2005· HGC, 291Gfl.;-afld HGC, 20J Ia) H~~eJ.nt&He
testi-ng of MW 11 anel J!I.<JW I ·1 (Joei.lted '>Vithi n aRd ia1rneai •Hely dowagradient-eHt'te-ttt+H+.:f~· cell
compjex) ytd-Eietl-ftydraulie cond.l.f€ti¥fli~; of appfe*i.rnately 1 Jt l0-,3 c:mls aB:CI 7 x 1.0 ~
Fespeetively.
~e,·jes p~rneterts wen~ iflsltilled in May, 2011 to i•wesligale peffifled ;•one con~
ulhwe!ll (downgraElieatj·of the tailings eeiJ:; (Figure 5). Hydruulie t . tiag of DR 5, QR 8. OR
9. DR 1 0, DR 11 , DR 13, DR 111. 9R: 17 DR 19. DR 20. DR ") 1, DR 23. and DR 24 (f'igme 5)
yielded hydmulic eonuueti·.-ity eMimmes (bases OR-+be KGS sl, test analy:;i<r ofa.utoma~cally
ffiggeel eatttJ-·Htnging fron~ately 3 x lO...s--em/!i LO l x J 0 em!!. wits a geomelrie average
of approx-ima~ly l x 10~ ~
*7-t~pontry perciJea zone chlorofomlm:onitor.tng wells (TW4 serien wells ifl r•gure 5) and 19·
~ ~one Aitrate meRiiering--wetln (T\VM .,erie:; \'t'ells ia Figure 5) luwe-feen
in:>tulled lO ifr\le5t+gate ele•hlted niu·aleeoaceatrnhoA:S detected initially ifl }t4"W 4 LIBEl some of the
T\¥~ series wells . TW4 seees wells ore located northeusl (upgroclieru) lie ea5l (en~~s gradient} of
~he ~ilings cells and :Y\VN series well·• ex~end to t.fte-t'teftheast (upo-railieat) of the Alil lsite Lllld
Eailiags eeHB.
Hydraulie testing of Lhe TWN series wellti ) ieltleJ bydraltJ.ic eoeduct:ivilies ranging l'rom
apprmumawly 1 * 10..;: an/s to 0.0 I cm/s wilh a geometric .:werage of approximate~-1-9-!>
enlJls (HOC 2009). TestiAg of TW'J 20, TW4 21 . ana TW4 22 (HGG 2005) una T'.l/11 23 . TW~
24, aed TW1 25 (HGC 2007e) yjeleled hydmullc conductis.·ilies rMging from approximutely 4 1\
~ to approJ<:imately 2 x 10 Cil'l/~. Testing ol:.!f.\N1 4 yieleled a hy<iraulie eoRffiK-t-h·ily of
Bf'~I'&JH.ffia~ely J .7 n 10-:l emls, tuld testing of TW"+ 6, T\¥4 26. aAd TW4 27 (loemee
downg.radie nl of TW4 4) yielded hydruulie conduelivilies ri:l:Ag~prmtimate!y 7 x. LO~
emls to 2 x 10~ em/!; (HGC, 20 LOe-a-tffi.-14 GC 1 01 l h) .• '\:nalysis of Lhe drawtlown dttta ceJlecteEl
~na terRl pum~ing lesL eo:B:eucied at MW 4, TW·I 19, and M'W" 26 using TW1 s ·
v.·eJ!s ~ observaLien wells yieleed hydraulic conductivity estimate, rane;ing -froFH-t~pprmtiml~ely ~ ~ -~".,(."ffiRi lO 1 * 10 Ciu/5 (J.JGC, 200'1).
Some of tl=te courser grainee and congk}merutit mt:Heriuls ee:counlered within the perched LOae
during .inMulhttion--~e TW4 series wells are eelieved to be par::ly eeRLi:Ruous with or a1 least
a:ssocitued wiU1 a rel~mn relatively contim.IOtHl zoae-ef hjgherpeffl7eu.l:JiliLy (International
Yntnium [USA] Corpnralion [lUS.'\1 and HGC, 200J ). The ftigher pefillCOl3ility zone-€1efined by
•.veJis completed in the zone is geAera lly located eru;t to nor~hea'it of tae tai lings cells at the site,
t\nd is hydra-elicaHy em::~s gradient lo uporodieat of tbe Hli linas cells whh respecl lO ~erched
~
·sed oa-tH'l&!yses or flliRlpiRg resls ~H: M\V 4 ttliEI driUing logs Cram Hearby temporary wells, the
~ie conductivity of Lhi$ Fehu iYely ~fiin coar<;er grai ned zone was estimareelle be flff-high as
2.5 x. 10-:4 cm/!9. Rektl-Wely-fligf-1 wnducrMiies me~sured at MW J J. located 01~ lhe so~:tlheastern
:!Bftrgin of the aowngradienl edge of tailings Cell 3, ~:md <:H MW J 1, loetueel on !he clowngraejent
edge of tltilings Cei.J 4-A, of J. 'l x-I{) oml!; artd 7.5 '* W4 cmls, respect ivel y (UMETCO 1993),
fl'Hiy-indieate that this zone e.xtena!'. he nee:L:b the sou Lheastem portion of lhe tailiags cell complex .
24
-lttwever bttsetl en hydra · , ·~'tel' perrneabiJity-El· . t-a~ar to exffit
withm LRe-sffit:lrated wee dewngruffieftl--(3ouliHetH:I't'Nesl) of lbe lftili:ng:, cells nor to lhe south of
T\V4 '1. The apparenl abseooe-ef the zett u1i1 of TW,.~ ·1 aed south Aouthwest ef the tai.J.i-~TgS
cells suggests that it "13iaches out" (HGC, 2007a).
The appareRt pinching out of this zon~with h;drat:~lie tests at tempe~-k
TVl4 6, T'N4 26 aad T'N4 27 (located dowagradieat of TW 4 4), and tests at DR series
pieli:lm ers (leGated dovrttgfadieAt of the teiliRgs cell cornp , ). As discussed abo'¥e, the
flydnHJlie coaducti·vilies of TW4 6.1'V/JI 1 6 6:ftd TVPI 27 raJTgetl from apprmlimately 7 Jt W-+--ffi
2 * H.ra.~s, approximately two to three orders of magnitude lo·.ver iJ:tan the eoRdl:lotivity aF
+-W4 4 (ap_p~llt*ely '2 * 1-G..J -€fflls). The hyc}m~i-Ytt~tf-dH~ DR '!eries piezomelt~FS
(bused eft-a:Balysis of automatically logged slug tes~ eata usinv Lhe KGS solul ion) raaged fn~m
appf'OAimately 3 }1: lO · t·o 1 J> 10-'~ em/!;, (one to :fh•e order'1 of magnifatle lo• .... er Lhan ctt MW-+1-1
with a geelnelri£ avera"e of approximately I Jl 10-j cmh> (two nrders of magnttuEI:e lower llmfl al
MV·/ 11). The eHeel of this muJsil::ion from higl:ler to lovw'er per!Tleabilily in to reduc-e-Hte rate of
~<Wefl:leJtt-s lh of TW4 '1 and south seuthv.-es! of taillng!i Cel:l4A.
The extensive hydraulic testing of perched zone wells at the site indicates that perched zone
permeabilities are generally low with the exception of the apparently isolated zone of higher
permeability associated with the chloroform plume east to northeast (cross-gradient to
upgradient) of the tailings cells. The geometric average hydraulic conductivity (approximately 1
x 10-5 cm/s) of the DR-series piezometers which cover an area nearly half the size of the total
monitored area at White Mesa (excluding MW-22), is nearly identical to the geometric average
hydraulic conductivity of 1.01 x 10-5 cm/s reported by TITAN (1994), and is within the range of
5 to 10 feet per year (ft/yr) [approximately 5 X w-6 cm/s to 1 X 10-5 cm/s] reported by Dames and
Moore (1978) [the 1978 ERJ for the (saturated) perched zone during the initial site investigation.
Because of the generally low permeability of the perched zone beneath the site, well yields are
typically low (less than 0.5 gpm), although sustainable yields of as much as 4 gpm (for example,
at TW4-19, shown in Figure 5) are possible in wells intercepting the relatively large saturated
thicknesses within the higher permeability zone located east to northeast (cross-gradient to
upgradient) of the tailings cells at the site. Sufficient productivity can generally be obtained only
in areas where the saturated thickness is greater, which is one reason that 1) some perched zone
we.l l complete u ar the n rthcrn w11 li e pontl · are rdaliv ly producti c nd 2) the perched
zone has been used on a limited basis as a water supply to the north (upgradient) of the site.
2.5.1.4 Perched Groundwater Flow
Perched groundwater flow at the site has historically been to the south/southwest. Figure 5
groundwater elevations indicate that beneath and south of the tailings cells, in the west central
portion of the site, perched water flow is south-southwest to southwest. Flow on the western
margin of White Mesa is generally south, approximately parallel to the mesa rim (where the
Burro Canyon Formation [and perched zone] is terminated by erosion). On the eastern side of the
site .. perched water flow is also generally southerly. Near the wildlife ponds, flow direction
ranges locally from westerly (west of the ponds) to easterly (east of the ponds) resulting in a
generally north-south perched water divide along a line connecting the ponds. Cones of
depression result from pumping of •hl roform we lls wells MW-4, TW4-4, TW4-19, TW4-20,
25
and ~VV-26_an=· ~d~n~iu~·a~'~~~~~~~~~:=~~~~~=-~~~
pumped to reduce chloroform and nitrate mass in the perched zone east and northeast of the
tailings cells.
In general, perched groundwater elevations have not changed significantly at most of the site
monitoring wells since installation, except in the vicinity of the wildlife ponds and the pumping
wells. For example, relatively large increases in water levels occurred between 1994 and 2002 at
~-4 and ~VV-19, located in the east and northeast portions of the site. tts di5eussecl in HGC
(2007a). These water level increases in the northeastern and eastern portions of the site are the
result of seepage from wildlife ponds located near piezometers PIEZ-1 through PIEZ-5 shown in
Figure 5, which were installed in 2001 for the purpose of investigating these changes. The
mounding associated with the wildlife ponds and the general increase in water levels in the
northeastern portion of the site have resulted in a local steepening of groundwater gradients over
portions of the site. Conversely, pumping of bl roform wells ~W-4, TW4-4, TW4-19,
TVV4-20, and ~-26 and nitrate w Jls T WN--· 4-_2, TW4-24, and TW -25 has depressed
the perched water table locally and reduced average hydraulic gradients to the south and
southwest of these wells. At the request f DRC. water has not been deli red to the northern
wildli~ ponds ~ince March. 2012. T he p r hed water mound~ . iated \ ilh re barge lrom
tbe:e p nd. i. liminishin= and i e. pe fl:d to conlinue to di mini~h. ther by redWJi ng hydraulic
gradients downg:railicnt of the pond.'\, in parti ulnr to the south and southwest.
As discussed above, perched water discharges in springs and seeps along VV estwater Creek
Canyon and Cottonwood Canyon to the west-southwest of the site, and along Corral Canyon to
the east of the site. The known discharge points located directly downgradient of the tailings
cells are Westwater Seep and Ruin Spring. These features are located more than 2,000 feet west-
southwest and more than 9,000 feet south-southwest of the tailings cells at the site as shown in
Figure 5.
DR-8, located approximately 4,000 feet southwest of the tailings cells, is located near the mesa
rim above Cottonwood Seep along a line between the tailings cells and Cottonwood Seep.
Although tihere is no evidence to connect Cottonwood Seep to the perched water system a. it i
eparated ti·om the p rch d warcr by appro, imal Jv 2 0 f~.::el f 1 v perme· bi litv sh le and
mudstones. However, under hypothetical conditions that Cottonwood Seep receives some
contribution from perched water, perched water passing beneath the tailings cells would
presumably pass by DR-8 before continuing on an unidentified potential pathway toward
Cottonwood Seep.
Figure e-+5 shows perched water pathlines southwest of the tailings cells based on first quarter,
~2014 perched water level data. Paths 1 and 3 represent the shortest pathlines to discharge
points VVestwater Seep and Ruin Spring, respectively. Path 2 is the shortest pathline to DR-8,
located near the edge of the mesa above Cottonwood Seep. A potential pathline is drawn from
DR-8 to Cottonwood Seep. Although tb r i · no vidence to connect ' tt nwood ecp t the
per hed wat r ·y tern . this p t nlial patl1J in i. repres nled t allo ~ r lh pos:ibiliLy of ll D as
yet unidentified connection. Westwater Seep is downgradient of tailings Cell 1 and the western
portions of Cells 2, 3, and 4B. DR-8 is downgradient of tailings Cells 2, 3 and 4B. Ruin Spring is
downgradient of Ce114A, and the eastern portions of Cells 2, 3, and 4B.
26
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient Of The Tailings Cells
The perched zone hydrogeology southwest (downgradient) of the tailings cells is similar to other
areas of the site except that the saturated thicknesses are generally smaller, portions of the
perched zone are dry, and hydraulic gradients and hydraulic conductivities are relatively low.
The combination of shallow hydraulic gradients, relatively low permeabilities, and small
saturated thicknesses, results in rates of perched water movement that are among the lowest on-
site.
In the immediate vicinity of the tailings cells, perched water was encountered at depths of
approximately ~53 to -~ l L 7 fl below the top of casing ("btoc") as of the first quarter of
2014.g, (Figure 7). Beneath tailings Cell 3, depths to water ranged from approximately 6&1 feet in
the eastern portion of the cell, to approximately -l--l-§--117 ft btoc at the southwest margin of the
cell. Assuming an average depth of the base of tailings Cell 3 of 25 feet below grade, this
corresponds to perched water depths of approximately ~2 to 9Q-92 feet below the base of the
cell, and an average depth of approximately ~65_feet beneath the base of the cell.
Beneath tailings Cell 4B, depths to water ranged from approximately 106 ft btoc in the
northeastern portion of the cell (at MW-5), to approximately 112ft btoc at the southwest margin
of the cell (at MW-35). Assuming an average depth of the base of tailings Cell 4B of 25 feet
below grade, this corresponds to perched water depths of approximately 81 to 87 feet below the
base of the cell, and an average depth of approximately 84 feet beneath the base of the cell.
The saturated thickness of the perched zone in the immediate vicinity of the tailings cells as of
the first quarter of ~q.._20J4 ranges from approximately 8J-80 feet to negligible (Figure 8).
Beneath tailings Cell 3, the saturated thickness varies from approximately ~60 feet in the
eastern portion of the cell to approximately 7 feet in the western portion of the cell. Beneath
tailings Cell 4B, the saturated thickness varies from approximately 21 feet in the southeastern
portion of the cell to negligible in the southwestern portion of the cell, where a dry zone, defined
by MW-33 and former (historically dry) well MW-16, is present.
Saturated thicknesses in the southwest area of the site are affected by n-lhe ridge-like high in the
Burro Canyon Formation/Brushy Basin Member contact ( Figur • 4 ). The iaflueaee of this
paleoridge is discussed ia HGC (2012a). As shown in Figures 5 and 8~ dry eoaditioas orto low
saturated thickness conditions are associated with this paleoridge.
South-southwest of the tailings cells, the saturated thickness ranges from negligible at MW-21
(historically dry) to approximately 25 feet at DR-9. Small saturated thicknesses (less than 3 feet)
near DR-6, DR-7, and DR-9 (west and southwest of Cell4B) result from this-the paleoridge. The
average saturated thickness based on measurements at MW-37, DR-13, MW-3, MW-20, and
DR-21, which lay close to a line between the southeast portion of tailings Cell 4B and Ruin
Spring, is approximately 8 feet. The average saturated thickness based on measurements at MW-
35, DR-7, and DR-6, which are the points closest to a line between the southeast portion of
tailings Cell 3 and Westwater Seep, is approximately 5 feet.
27
northea..;;l to Ruin
&~te--\¥H:ie.--pef0hed zofle hydraulic gmdimw> l1'i of the fimt quetner of 20112 nmge froffif\
I'Jl8X:imum of oppreximately 0.07 feet per foe~ :L of util:i:ng;, Cell 2 to upprE»:.in'lately
0-:-QO l ftlft iJT--l-1-le nonbeuzilern portioe of the site (betweeA TWM 15 and M\V I). HycffiH:tli-e
~radienLs in Lhe soullw•esl per~ a--ef-1~-te are Lypi-ea~ly close to 0.0 I ftlfL etlt lhe gradient is
less lhan 0.005 ft/ft wesllsot:t4:fi.we';l of tailings Gell 4B between CeiJ 'IB and DR 8. Tb _
hydraulic gradient between the west dike of tailings Cell 3 and Westwater Seep is approximately
0.0122 ft/ft, and between the south dike of tailings Cell 4B and Ruin Spring, approximately
0.0118 ft/ft
2.5.2 Groundwater Quality
2.5.2.1 Entrada/Navajo Aquifer
The Entrada and Navajo Sandstones are prolific aquifers beneath and in the vicinity of the site.
Water :Llpply wells at the site are screened in both of these units, and therefore, ·f, r the purp , e
of this eli cu ion, they will be treated as a single aquifer. Water in the Entrada/Navajo Aquifer
is under artesian pressure, rising 800 to 900 ft above the top of the Entrada · cont act with th
overlying Summervillle Formation; static water levels are 390 to 500 ft below ground surface.
Within the region, this aquifer is capable of yielding domestic quality water at rates of 150 to 225
gpm, and for that reason, it serves as a secondary source of water for the Mill. Additionally, two
domestic water supply wells drawing from the Entrada/Navajo Aquifer are located 4.5 miles
southeast of the Mill site on the Ute Mountain Ute Reservation. Although the water quality and
productivity of the Navajo/Entrada aquifer are generally good, the depth of the aquifer (>1,000 ft
bls) makes access difficult.
Table 2.5.2.1-1 is a tabulation of groundwater quality of the Navajo Sandstone aquifer as
reported in the FES and subsequent sampling. TDS ranges from 244 to 1,110 mg/liter in three
samples taken over a period from January 27, 1977, to May 4, 1977. High iron (0.057 mglliter)
concentrations are found in the Navajo Sandstone. Because the Navajo Sandstone aquifer is
isolated from the perched groundwater zone by approximately 1,000 to 1,100 ft of materials
having a low average vertical permeability, sampling of the Navajo Sandstone is not required
under the Mill's previous NRC Point of Compliance monitoring program or under the Permit.
However, samples were taken at two other deep aquifer wells (#2 and #5) on site (See Figure 9
for the locations of these wells), on June 1, 1999 and June 8, 1999, respectively, and the results
are included in Table 2.5.2.1-1.
2.5.2.2 Perched Groundwater Zone
Perched groundwater in the Dakota/Burro Canyon Formation is used on a limited basis to the
north (upgradient) of the site because it is more easily accessible. The quality of the Burro
Canyon perched water beneath and downgradient from the site is poor and extremely variable.
28
The concentrations of TDS measured in water sampled from upgradient and downgradient wells
range between approximately 600 and 5,300 mg/1. Sulfate concentrations measured in three
upgradient wells varied between 670 and 1,740 mg/1 (Titan, 1994). The perched groundwater
therefore is used primarily for stock watering and irrigation. The saturated thickness of the
perched water zone generally increases to the north of the site. See the-Section 2.11.2 below for
a more detailed discussion of background ground water quality in the perched aquifer.
2.5.3 Springs and Seeps
As discussed in Section 2.5.1.4, perched groundwater at the Mill site discharges in springs and
seeps along Westwater Creek Canyon and Cottonwood Canyon to the west-southwest of the site,
and along Corral Canyon to the east of the site, where the Burro Canyon Formation outcrops.
Water samples have been collected and analyzed from springs and seeps in the Mill vicinity as
part of the baseline field investigations reported in the 1978 ER (See Table 2.6-6 in the 1978
ER).
During the period 2003-2004, Denison EFRI implemented a sampling program for seeps and
springs in the vicinity of the Mill which had been sampled in 1978, prior to the Mill's
construction. Four locations were designated for sampling, which areas shown on Figure 9.
These are Ruin Spring (G3R), Cottonwood Seep (G4R), west of Westwater Creek (G5R) and
Corral Canyon (G 1R). During the 2-year study period only two of the four locations \vere able
tecould be sampled, Ruin Spring and Cottonwood Canyon. The other two locations, Corral
Creek and the location west of Westwater Creek were not flowing (seeping), and samples could
not be collected. With regard to the Cottonwood seep, while water was present, the volume was
not sufficient to complete all determinations, and only organic analyses were conducted. +he
results of the organic aAnalysis of the ollom · od Seep \ ater ~uno! s did not detect any
detectable organics.
Samples at Ruin Spring were analyzed for major ions, physical properties, metals, radionuclides,
volatile and semi-volatile organic compounds, herbicides and pesticides, and synthetic organic
compounds. With the exception of one chloromethane detection, all organic determinations were
at less than detectable concentrations. The detection of chloromethane is not uncommon in
groundwater and can be due to natural sources. In fact, chloromethane has been observed by
Denison EFRI at detectable concentrations in field blank samples during routine groundwater
sampling events. The results of sampling for the other parameters tested are shown in Table
2.5.3-1. The results of the 2003/2004 sampling did not indicate the presence of mill derived
groundwater constituents and are representative of background conditions.
As required by Part I.E.6 of the Permit, the Mill has implemented a Sampling Plan for Seeps and
Springs. Per Part I.E.6 -of the Permit, sampling of seeps and springs in required annually. A
copy of the approved Sampling Plan for Seeps and Springs Revision lG, dated March 17,
~June 10, 2011,-is included as Appendix B-~to this Application. Denison EFRI submitted
Revision 1.0 on June 10, 2011. Revision 1.0 is currently undergoing review by the Director. See
Section 2.12.2 below for a more detailed description of the Plan. The first sampling under the
Plan was completed in August, 2009. A summary of sampling results from the 2009, 2010, and
2Q.i--l.through -2013 sampling events, performed under the approved Sampling Plan for Seeps and
Springs, is provided in Table 2.5.3-2 through Table 2.5.3-5.
29
2.5.4 Topography
The Mill site is located on a gently sloping mesa that, from the air, appears similar to a
peninsula, as it is surrounded by steep canyons and washes and is connected to the Abajo
Mountains to the north by a narrow neck of land. On the mesa, the topography is relatively flat,
sloping at less than one (1) percent to the south and nearly horizontal from east to west. See also
Figure 6.
2.5.5 Soils
The majority (99%) of the soil at the Mill site consists of the Blanding soil series (1978 ER,
Section 2.10.1.1). The remaining 1% of the site is in the Mellenthin soil series. Because the
Mellenthin soil occurs only on the eastern-central edge of the site (1978 ER, Plate 2.10-1), the
FES (Section 2.8) concluded that it should not be affected by Mill construction and operation.
The Mill and associated tailings cells are located on Blanding silt loam, a deep soil formed from
wind-blown deposits of fine sands and silts. Although soil textures are predominantly silt loam,
silty-clay-loam textures are found at some point in most profiles (See Appendix G-IlJo this
Application-Results of Soil Analysis at Mill Site). This soil generally has a 4 to 5 inch reddish-
brown, silt-loam A horizon and a reddish-brown, silt-loam to silty-clay-loam B horizon. The B
horizon extends downward about 12 to 16 inches where the soil then becomes calcareous silt-
loam or silty-clay-loam, signifying the C horizon. The C horizon and the underlying parent
material are also reddish-brown in color.
The A and B horizon both are non-calcareous with an average pH of about 8.0, whereas the C
horizon is calcareous with an average pH of about 8.5. Subsoil sodium levels range up to 12% in
some areas, which is close to the upper limit of acceptability for use in reclamation work (1978
ER, Sect. 2.1 0.1.1 ). Other elements, such as boron and selenium, are well below potentially
hazardous levels. Potassium and phosphorus values are high in this soil (1978 ER, Table 2.10-2)
and are generally adequate for plant growth. Nitrogen, however, is low (1978 ER, Sect. 2.10.1.1)
and may have to be provided for successful revegetation during final reclamation.
With well-drained soils, relatively flat topography (see Section 2.5.4), and limited annual
precipitation (see Section 2.5.1.2), the site generally has a low potential for water erosion.
However, the flows resulting from thunderstorm activity are nearly instantaneous and, without
the Mill's design controls, could result in substantial erosion. When these soils are barren, they
are considered to have a high potential for wind erosion. Although the soil is suitable for crops,
the low percentage of available moisture (6 to 9%) is a limiting factor for plant growth;
therefore, light irrigation may be required to establish native vegetation during reclamation.
2.5.6 Bedrock
Subsurface conditions at the Mill site area were investigated as part of the 1978 ER by drilling,
sampling, and logging a total of 28 borings which ranged in depth from 6.5 to 132.4 ft. Of these
borings, 23 were augured to bedrock to enable soil sampling and estimation of the thickness of
the soil cover. The remaining 5 borings were drilled through bedrock to below the perched water
table, with continuous in situ permeability testing where possible and selective coring in
30
bedrock. The soils encountered in the borings were classified, and a complete log for each
boring was maintained. See Appendix A of Appendix H of the 1978 ER.
Borings in the footprint of the existing tailings cells reported calcareous, red-brown sands and
silts from the surface to a depth of 15 ft, averaging over 7 ft. Borings in the general area of the
Mill site and the tailings cells reported calcareous, red-brown sands and silts from the surface to
a depth of 14 ft, averaging over 9 ft. Downgradient of the tailings cells, calcareous sands and
silts extend to a depth of 17 ft of the surface. The calcareous silts and sands of the near-surface
soils grade to weathered claystones or weathered sandstones, inter-layered with weathered
claystone and iron staining. At depth, the weathered claystone or weathered clayey sandstone
grade into sandstone with inter-layered bands of claystone, gravel, and conglomerate. Some
conglomerates are cemented with fLCalcareous matrix.
2.5.7 Agricultural and Land Use Description of the Area
Approximately 65.8% of San Juan County is federally owned land administered by the U.S.
Bureau of Land Management, the National Park Service, and the U.S. Forest Service. Primary
land uses include livestock grazing, wildlife range, recreation, and exploration for minerals, oil,
and gas. Approximately 22% of the county is Native American land owned either by the Navajo
Nation or the Ute Mountain Ute Tribe. The area within 5 miles of the Mill site is predominantly
range land owned by residents of Blanding. The Mill site itself, including tailings cells,
encompasses approximately 300 acres.
A more detailed discussion of land use at the Mill site, in surrounding areas, and in southeastern
Utah, is presented in the FES (Section 2.5). Results of archeological studies conducted at the site
and in the surrounding areas as part of the 1978 ER are also documented in the FES (Section
2.5.2.3).
2.5.8 Well Logs
Well/boring logs for wells MW-1, MW-2, MW-3, MW-4 (not a compliance well under the
Permit), MW-5, MW-11, MW-12, MW-14, MW-15, MW-16 (not a compliance well under the
Permit and abandoned during the construction of Tailings Cell4B), MW-17, MW-18, and MW-
19, are included as Appendix A to the 1994 Titan Report. A copy of the 1994 Titan Report was
previously submitted under separate cover.
Lithologic and core logs for wells MW-3A, MW-23, MW-24, MW-25, MW-27, MW-28, MW-
29, MW-30 and MW-31 are included as Appendix A to the Report: Perched Monitoring Well
Installation and Testing at the White Mesa Uranium Mill April Through June 2005, August 3,
2005, prepared by Hydro Geo Chern, Inc. A copy of that Report was previously submitted under
separate cover.
Lithologic and core logs for well MW-26 (previously named TW4-15) and well MW-32
(previously named TW 4-17) are included as Appendix A to the Letter Report dated August 29,
2002, prepared by Hydro Geo Chem, Inc. and addressed to Harold Roberts.
Lithologic and core logs for well MW-33, MW-34 and well MW-35 are included as Appendix A
to the Installation and Hydraulic Testing of Perched Monitoring Wells MW-33, MW-34, and
31
MW-35 at the White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chern,
Inc. October 11, 2010. A copy of that Report was previously submitted under separate cover.
Lithologic and core logs for well MW-36 and well MW-37 are included as Appendix A to the
Installation and Hydraulic Testing of Perched Monitoring Wells MW-36 and MW-37 at the
White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chern, Inc. June 28,
2011. A copy of that Report was previously submitted under separate cover.
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of the
Emuent or Leachate to be Discharged (R317-6-6.3.F)
The Mill is designed not to discharge to groundwater or surface waters. Instead, the Mill
utilizes tailings and evaporation Cells for disposal or evaporation of Mill effluents as indicated
below:
• Cell 1: -dedicated to evaporation of Mill waste solutions;
• Cell 2:_-contains Mill tailings, has an interim cover and is closed to future tailings
disposal;
• Cell 3: -contains Mill tailings and is in the final stages of filling;
• Cell4A: -receives Mill tailings and is used for evaporation of Mill solutions; and
• Cell 4B: -aulb l'iz d lo receive Mill tailing atltl-but currently i. u ed onl y for
evaporation of Mill solutions.
See Sections 2.7.2 through 2.7.4 below for a more detailed discussion of the Mill's tailings
cells.
The projected chemical and radiological characteristics of tailings solutions were assessed by
Energy Fuels Nuclear, Inc., a predecessor operator of the Mill, and NRC in 1979 and 1980,
respectively. In addition, early samples were assessed by D' Appolonia Engineering as the Mill
started operations to further evaluate and project the character of the solutions. Samples of
tailings after the Mill was fully operational were collected by NRC (1987),
DeaisoeEFRI/UDEQ (2003), and DeHiseH EFRI (2007 -2013), DeHiseH (2008) and DeHiseH
(2009). Samples collected in 2003 were obtained under the oversight of DRC personnel. The
Samples collected in 2007 and 2008 were obtained by DeHiseH EFRI on a voluntary basis as the
then proposed Tailings and Slimes Drain Sampling Plan (the "Tailings Sampling Plan") had not
been approved by the Director at that time. The 2009 samples were collected on August 6,
2009 under the appre·1ed Tailings Sampling Plan tbat was appro cd at lhat time. Subsequent
annual amplinghas been pedormed in Aug\.1 t 2010. 20 11. 20 12 and ~2013 under an t-Re
approved Tailings Sampling Plan. of this writiRg, DeAisetl bas st:lbR-1iHed Revbioa 2.0 of
tl:ie TailiAgs SampliAg Plifll. wlti€fl-is curreml·y-tHHlergeing nniew by the Di rector. A copy of
th urrently appr ved Tailin 2. Sampling Plan is included as Agp nd.L'\. L.
The chemical and radiological characteristics of the solutions held in the tailings cells, based on
the sample results described above, are provided in the tables included in Appendix D,E, which
list the concentration of parameters measured in accordance with the Permit.
There is no active discharge from the tailings Cells; therefore, an estimation of the flow rate
C:gpd:_) is not applicable in this instance. However, when operating at full capacity, the Mill
32
discharges approximately 2000 tons per day of dry tailings and approximately 600 gpm of
tailings solutions to the Mill's tailings cells.
2.7 Information Which Shows that the Discharge can be ControiJed and Will Not Migrate Into or
Adversely Affect the Quality of any Other Waters of the State (R317-6-6.3.G)
2. 7.1 General
The Mill has been designed as a facility that does not discharge to groundwater or surface water.
All tailings and other Mill wastes are disposed f permanently into the Mill's tailings system.
Excess waters are disposed of in the tailing r evaporati n -cells, where they are subject to
evaporation, or re-processed through the Mill circuit. See Section 2.6.
The Mill was also designed and constructed to prevent runon or runoff of storm water by a)
diverting runoff from precipitation on the Mill site to the tailings cells; and b) diverting runoff
from surrounding areas away from the Mill site.
The Permit therefore does not authorize any discharges to groundwater or surface water, but is
intended to protect against potential inadvertent or unintentional discharges, such as through
potential failure of the Mill's tailings system.
The Mill's tailings system is currently comprised of four tailings cells (Cells 2, 3 4A, and 4B)
and one evaporation pond (Cell 1). Diagrams showing the Mill facility layout, including the
existing tailings cells are included as Figures 10 and 11 to this Application. In addition, the Mill
ha .. a lined catchmenr ba jJl, u ed for temporary torage of Mill pn~ces up el fl uid , known a
Rober Pond'. Robens P nd i about 0.4G-l_acr in .ize and round l med approximately
180 feet west of the Mill building and about 200 feet east of the northeast corner of Cell 1.
The following sections describe the primary Discharge Minimization Technology ("DMT") and
Best Available Technology ("BAT") features of the Mill, which demonstrate that the wastes and
tailings at the Mill can be controlled so that they do not migrate into or adversely affect the
quality of any waters of the State, including groundwater and surface water.
2.7.2 Cells 1, 2 and 3
2. 7.2.1 Design and Construction of Cells 1, 2 and 3
Tailings Cells 1, 2 and 3 were each constructed more than 25 years ago. Construction of Cell 2
was completed on May 3, 1980, construction of Cell 1 was completed on June 29, 1981, and
construction of Cell 3 was completed on September 15, 1982.
33
Each of Cells 2 and 3 also has a slimes drain collection system immediately above the FML,
comprised of a nominal 12-inch thick protective blanket layer of soil or comparable material, on
top of which is a network of PVC perforated pipe laterals on a grid spacing interval of about 50-
feet. These pipe laterals gravity drain to a perforated PVC collector pipe which also drains
toward the south dike and is accessed from the ground surface via a non-perforated access pipe.
At cell closure, leachate head inside the pipe network will be removed via a submersible pump
installed inside the access pipe
See Part I.D.1 of the Permit for a more detailed description of the design of Cells 1, 2 and 3.
After review of the existing design and construction and consultation with the State of Utah
Division of Water Quality, the Director determined, in connection with the issuance of the
Permit in 2005, that the DMT required under the groundwater quality protection rules (UAC
R317 -6-6.4( c )(3)) for Cells 1, 2 and 3 that pre-dated those rules will be defined by the current or
existing disposal cell construction, with a-few-modifications that were included in the Permit (see
page 25 of the 2004 Statement of Basis). These modifications focus on changes in monitoring
requirements, and on improvements to facility closure. The goal of these improvements is to
ensure that potential wastewater losses are minimized and local groundwater quality is protected.
Th modifications are described in Sections 2.7.2.2, 2.7.2.3 and 2.7.2.4 below.
2.7.2.2 Improved Groundwater Monitoring
Improvements were made to the Mill's groundwater monitoring network at the time of issuance
of the Permit, to meet the following goals:
34
a) Early Detection
Three monitoring wells (MW-24, MW-27 and MW-28) were added immediately adjacent to Cell
1, in order to detect a potential release as early as practicable.
b) Discrete Monitoring
In order to individually monitor each tailings cell and to be able to pinpoint the source of any
potential groundwater contamination that may be detected, the Permit required the addition of
three monitoring wells (MW-29, MW-30 and MW-31) between Cells 2 and 3, in addition to the
addition of wells MW-24, MW-27 and MW-28 immediately adjacent to Celll.
The addition of monitoring wells MW-24, MW-27, MW-28, MW-29, MW-30 and MW-31,
together with the existing monitoring wells at the site provides a comprehensive monitoring
network to determine any potential leakage from Cells 1, 2 and 3. See Figure 4 and Figure 10 for
a map showing the locations of the existing compliance monitoring wells for the site.
2. 7.2.3 Operational Changes and Improved Operations Monitoring
The Permit also required changes to disposal cell operation in order to increase efforts to
minimize potential seepage losses, and thereby improve protection of local groundwater quality.
Examples of these changes are:
c) Maximum Waste and Wastewater Pool Elevation
Part I.D.3 of the Permit requires that Denison EFRI continue to ensure that impounded wastes
and wastewaters for all of the Mill's tailings Cells and Roberts Pond are held within an FML.
d) Slimes Drain Maximum Allowable Head
Part I.D.3(b) of the Permit requires that the Mill provide constant pumping efforts to minimize
the accumulation of leachates over the FML in Cell 2, and upon commencement of dewatering
activities, in Cell 3, and thereby minimize potential FML leakage to the foundation and
groundwater. See the discussion in Section 2.15.2.2 below.
2. 7.2.4 Evaluation of Tailings Cell Cover System Design
35
See Section 2.19 below for a more detailed discussion of post -closure requirements for the Mill.
2.7.3 Celi4A
Construction of Cell 4A was completed on or about November 1989. Cell 4A was used for a
short period of time after its construction for the disposal of raffinates from the Mill's vanadium
circuit. No tailings waste or wastewater had been disposed of in Cell 4A since the early 1990s.
This lack of waste disposal, and exposure of the FML to the elements, caused Cell 4A to fall into
disrepair over the years.
Although the original design of Cell4A was an improvement over the design of Cells 1, 2 and 3
(it had a one-foot thick clay liner under a 40 ml high density polyethylene ("HDPE") FML, with
a more elaborate leak detection system), it was constructed in 1989 and did not meet today' s
BAT standards.
Cell 4A was re-lined in 2007-2008 and was re-authorized for use in November 2008. With the
reconstruction of Cell 4A, BAT was required, as mandated by Part I.D.4 of the Permit and as
36
stipulated by the Utah Ground Water Quality Regulations at UAC R317-6-6.4(A). With BAT
for Cell 4A, there are also new performance standards that require daily leak detection system
monitoring, weekly wastewater level monitoring, and slimes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Section 2.15.3 below for a more
detailed discussion relating to the BAT performance standards and monitoring requirements for
Cell4A.
Tailings Cell 4A Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part I.D.5 of the Permit and consist of
the following:
e) Dikes -consisting of existing earthen embankments of compacted soil, constructed by
a previous Mill operator between 1989-1990, and composed of four dikes, each
including a 15-foot wide road at the top (minimum). On the north, east, and south
margins these dikes have slopes of 3H to 1 V. The west dike has a slope of 2H to 1 V.
Width of these dikes varies. Each has a minimum crest width of at least 15 feet to
support an access road. Base width also varies from 89-feet on the east dike (with no
exterior embankment), to 211-feet at the west dike.
f) Foundation -including existing subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. The floor of Cel14A has an average
slope of 1% that grades from the northeast to the southwest corners.
g) Tailings Capacity -the floor and inside slopes of Cell 4A encompass about 40 acres
and have a maximum capacity of about 1.6 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
h) Liner and Leak Detection Systems -including the following layers, in descending
order:
(i) Primary FML -consisting of an impermeable 60 mil HDPE membrane that
extends across both the entire cell floor and the inside side-slopes, and is anchored
in a trench at the top of the dikes on all four sides. The primary FML is in direct
physical contact with the tailings material over most of the Cell 4A floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) Leak Detection System-includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4A, and drains to a leak
detection sump in the southwest corner. Access to the leak detection sump is via
an 18-inch inside diameter (ID) HDPE pipe placed down the inside slope, located
between the primary and secondary FML liners. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 10 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
(iii) Secondary FML -consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. This FML also extends across the
37
entire Cell 4A floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
(iv) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay liner
CGCL:) composed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
i) Slimes Drain Collection System -including a two-prut system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
(i) Horizontal Strip Drain System -is installed in a herringbone pattern across the
floor of Cell 4A that drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated .. two-patt geo-composite drain material
(solid polymer drainage strip) core surrounded by an envelope of non-woven
geotextile filter fabric. The strip drains are placed immediately over the primary
FML on 50-foot centers, where they conduct fluids downgradient in a
southwesterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
fabric filled with well graded filter sand to protect the drainage system from
plugging.
(ii) Horizontal Slimes Drain Collection Pipe System -includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection CSDC:)
pipe found at the downgradient end of the strip drain lines. This pipe is in turn
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southwest corner of Cell 4A where it joins the slimes drain
access pipe.
(iii) Slimes Drain Access Pipe -consisting of an 18-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell 4A at the southwest corner, above the
primary FML. Said pipe then merges with another horizontal pipe of equivalent
diameter and material, where it is enveloped by gravel and woven geotextile that
serves as a cushion to protect the primary FML. A reducer connects the
horizontal 18-inch pipe with the 4-inch SDC pipe. At some future time, a pump
will be set in this 18-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
j) North Dike Splash Pads-three 20-foot wide splash pads have been constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings slurry.
These pads consist of an extra layer of 60 mil HDPE membrane that has been installed
in the anchor trench and placed down the inside slope of Cell 4A, from the top of the
dike, under the inlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope.
k) Emergency Spillway - a concrete lined spillway has been constructed near the
southwestern corner of the west dike to allow emergency runoff from Cell 4A to Cell
4B. At this time, all stormwater runoff and tailings wastewaters not retained in Cells
38
2, 3, and 4A will be managed and contained in Cell 4B, including the Probable
Maximum Precipitation and flood event.
I) BAT Performance Standards for Tailings Cell 4A -DenisonEFRI shall operate and
maintain Tailings Cell 4A so as to prevent release of wastewater to groundwater and
the environment in accordance with an Operations and Maintenance Plan, as currently
approved by the Director, pursuant to Part I.H.19. At a minimum these performance
standards shall include:
(i) Maximum Allowable Daily Head-on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer.:.;
(iv) M~Lximum Da*y Wastewater LeYel to ensure compliance wilh 1he minimum
+t:eeooord ret:Juiremeats for Cell .:!A, and f3revenl tliselHtf"~ of wastewnters \'ia
overtopping.
See Part I.D.5 of the Permit for a more detailed discussion of the design of Cell 4A. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix :g_F to this Application.
2.7.4 Cell 4B
Construction of Cell4B was completed in November ~2010.
Tailings Cell 4B Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part I.D.12 of the Permit and consist of
the following:
a) Dikes -consisting of newly constructed dikes on the south and west side of the cell,
each including a 20-foot wide road at the top (minimum). The exterior slopes of the
southern and western dikes have slopes of 3H to 1 V. The interior dikes have slopes of
2H to 1 V. Limited portions of the Cell 4B interior sidelopes in the northwest corner
and southeast corner of the cell (where the slimes drain and leak detection sump are
located) have a slope of 3H to 1 V. Width of these dikes varies. The base width of the
southern dike varies from approximately 92 feet at the western end to approximately
190 feet at the eastern end of the dike, with no exterior embankment present on any
other side of the cell.
b) Foundation -including existing sub grade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. The floor of Cell4B has an average
slope of 1% that grades from the northwest to the southeast corner.
c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass about 40 acres
and the cell has a maximum capacity 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in descending
order:
(i) Primary FML -consisting of an impermeable 60 mil HDPE membrane that
extends across both the entire cell floor and the inside side-slopes, and is anchored
39
in a trench at the top of the dikes on all four sides. The primary FML is in direct
physical contact with the tailings material over most of the Cell4B floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) Leak Detection System -includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4B, and drains to a leak
detection sump in the southeast corner. Access to the leak detection sump is via
an 18-inch inside diameter C.~ID:_',) HDPE pipe placed down the inside slope,
located between the primary and secondary FML liners. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 15 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
(iii) Secondary FML -consisting of an impermeable 60-rnil HDPE membrane found
immediately below the leak detection geonet. This FML also extends across the
entire Cell 4B floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
(iv) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay liner
C.~GCL:) composed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
e) Slimes Drain Collection System -including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
(i) Horizontal Strip Drain System -is installed in a herringbone pattern across the
floor of Cell 4B that drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated two-part geo-composite drain material
(solid polymer drainage strip) core surrounded by an envelope of non-woven
geotextile filter fabric. The strip drains are placed immediately over the primary
FML on 50-foot centers, where they conduct fluids downgradient in a
southeasterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
fabric filled with well graded filter sand to protect the drainage system from
plugging.
(ii) Horizontal Slimes Drain Collection Pipe System -includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC)
pipe found at the downgradient end of the strip drain lines. This pipe is in turn
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southeast corner of Cell 4A where it joins the slimes drain
access pipe.
(iii) Slimes Drain Access Pipe-consisting of an 18-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell4B at the southeast corner, above the primary
40
FML. Said pipe then merges with another horizontal pipe of equivalent diameter
and material, where it is enveloped by gravel and woven geotextile that serves as
a cushion to protect the primary FML. A reducer connects the horizontal 18-inch
pipe with the 4-inch SDC pipe. At some future time, a pump will be set in this
18-inch pipe and used to remove tailings wastewaters for purposes of de-watering
the tailings cell.
f) North and East Dike Splash Pads -nine 20-foot wide splash pads have been
constructed on the north and east dikes to protect the primary FML from abrasion and
scouring by tailings slurry. These pads consist of an extra layer of 60 mil HDPE
membrane that has been installed in the anchor trench and placed down the inside slope
of Cell4B, from the top of the dike, under the inlet pipe, and down the inside slope to a
point 5-feet beyond the toe of the slope.
g) Emergency Spillway - a concrete lined spillway has been constructed near the
southeastern corner of the east dike to allow emergency runoff from Cell4A into Cell
4B. This spillway is limited to a 6-inch reinforced concrete slab, with a welded wire
fabric installed within its midsection, set directly atop a cushion geotextile placed
directly over the primary FML in a 4-foot deep trapezoidal channel. A 100-foot wide,
60-mil HDPE membrane splash pad is installed beneath the emergency spillway. No
other spillway or overflow structure will be constructed at Cell 4B_unless and until the
construction of Cells SA and 5B. At this time, all stormwater runoff and tailings
wastewaters not retained in Cells 2, 3, and 4A will be managed and contained in Cell
4B, including the Probable Maximum Precipitation and flood event.
h) BAT Performance Standards for Tailings Cell 4B -DenisonEFRI shall operate and
maintain Tailings Cell 4B so as to prevent release of wastewater to groundwater and
the environment in accordance with the currently-approved Cell4B BAT, Monitoring,
Operations and Maintenance Plan. At a minimum these performance standards shall
include:
(i) Maximum Allowable Daily Head-on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer,
(iv) Maximum Daily Wastewater Level -to ensure compliance with the minimum
freeboard requirements for Cell 4B, and prevent discharge of wastewaters via
overtopping.
See Part I.D.12 of the Permit for a more detailed discussion of the design of Cell 4B. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix B--F to this Application.
2.7.5 Future Additional Tailings Cells
Future additional tailings cells at the Mill will require Director approval prior to construction and
operation. All--ffuture tailings cells at the Mill will be required to satisfy BAT standards at the
time of construction.
2.7.6 Roberts Pond
41
Roberts Pond receives periodic floor drainage and other wastewaters from Mill process upsets, is
frequently empty, and was re-lined with a new FML in May, 2002.
In order to minimize any potential seepage release from Roberts Pond, the Director has
determined tool iffi ap19ropriale DMT opembions s~aAdurd would be two fold, us reqliired
eyrequired the following in Part I.D.3( e) of the Permit:
(i) EFRI "shall operate this wastewater pond [Rob Pond] so as to orovide a minimu m
2-foot freeboard at all times. Under no circumstances shall the water level in the pond
exceed an elevation of 5,624 feet amsl. In the event that the wastewater elevation
exceeds this maximum level, the Permittee [EFRil shall remove the excess wastewater
and plac" it int containment in Tailing ell l within 72-h urs of disc very."A
mipulalioR thnl tl:!e Mill mftintain a minimal was~e·water heud iA lb:is pond-l:'ltl!led OA a+
foot:-t=Feeboard limit uno a 1 fool adtlitioncll epemting limil: nne
(ii) At the time of Mill site closure, Denison~FRI will excavate and remove the liner,
berms, and all contaminated subsoils in compliance with an approved final reclamation
plan under the Mill License.
2.7.7 Other Facilities and Protections
2.7.7.1 Feedstock Storage
In order to constrain and minimize potential generation of contaminated stormwater or leachates,
Part I.D.ll of the Permit requires the Mill to continue its existing practice of limiting open air
storage of feedstock materials to the historical storage area found along the eastern margin of the
Mill site (as defined by the survey coordinates found in Permit Table 4). The intent of Section I.
D.l l. (ba:ed on l'he OB for the 2 09 GWDP). i ' Lo require lhllt feeJ, to k storage olltsiue of the
area ·p Hi d in Table 4 hall meel lhe following requirem nrs:; tlfld oAe of U1e fo llowiRg lht=ee
~ractioes: 11 Store reeds leek muteria:f:; in ·.vuter tight contAins, or 2) Plaee feed!:toc lt containers in
'<¥iller liglit overpack eo:nlffiJ'lers, or 3) pJaee feedstoele coRtainers on a hardeneekurfuee that
eon forms to fhe requirerHetl£S speUeel Ol:ll in the permit part J.D . II d) I thro~
a) ecd rock materjals will be ~t r d al ali time in wat.er-ti1Ih l c nwiner . and ai ·]
feedstock container. or
storage, or
42
3) A storage area that provides containment berms to control storm water run-on and run-
off. and
4) Stormwater dminage w
art I.D.I L
of the renewed GWDP be revised as set out above.
2. 7. 7.2 Mill Site Reagent Storage
~~tential reagenl tunk ~;pil ls or leit ' ~hat cottki-Te-J.et¥.ie-eeA1aminm=t~i-le
soils or groundwater. anEI to prm':ide pffiper spill pt"e.,·enli:en ttA d coB:!fe-1., Part I.D.3(g) of the
Permit requires the Mill to demonstrate that it has adequate provisions for spill response,
cleanup, and reporting for reagent storage facilities,_. _ nnd EO iae!ude tbese i:a ttTb ·e pr visi n
are detailed in the Stormwater Best Management Practices Plrul', ' hicb is tl iened to prev nl
p Lenti 11 reagenl tank pill" or I aks that cou ld relca c contnminru1l! to site soil· or groundwater.
and to pro id pr per ·pjlJ preventi n and nlr l. Contents of this plan are stipulated in Part
I.D.8 of the Permit, and submittal and approval of the plan is required under Part I.H.17 of the
Permit. For existing facilities at the Mill, secondary containment is required, although such
containment may be earthen lined. For new facilities constructed at the Mill, or reconstruction of
existing facilities, Part I.D.3(eg) requires fhe-g_higher standard of secondary containment that
would prevent contact of any potential spill with the ground surface.
A copy of the Mill's Stormwater Best Management Practices Plan, Revision 1.~2: Juae 12,
~September 2012 is attached as Appendix F-G to this Application.
2. 7. 7.3 New Construction
Part I.D.4 of the Permit requires submittal of engineering plans and specifications and Director
approval easures that all prior to the construction, modification, or operation of waste or
wastewater disposal, treatment, or storage facilities requires submittal of eagiaeeriag plaas aad
speeifieatioas aad prior Director approval. In these plans and specifications, the Mill is required
to demonstrate how BAT requirements of the Groundwater Quality Protection Rules have been
met. After Director Approval, a construction permit may be issued, and the Permit modified.
2. 7. 7.4 Other
The White Mesa Mill TttiUngs Mtttutgentent System ttmi Discharge Minimization Technology
(DMT) MonitorirP Plan, .Q-1112 Revj ion: Denison+h-SL2.J ~the DMT Pl an ), and th White
Mesa Mill Tailing Mcmagernent -vswm, 7/20 12 Revi ion l2.1 (the Tailing Management
Plan ), u co~ of \Uhich it: are attached as Appendix G-H and Appendix I to this Application ..
r pe li ely., _is ft@_aesigned asTh ·e plan. pre vide a systematic program for constant
surveillance and documentation of the integrity of the tailings system .. including monitoring the
leak detection systems. The DMT Plan requires daily, weekly, quarterly, monthly and annual
43
inspections and evaluations and monthly reporting to Mill management. See Section 2.15.2
below for a more detailed discussion of the requirements of the DMT Plan.
2.7.8 Surface Waters
The Mill has been designed as a facility that does not discharge to surface waters. AlHiailings
and other Mill wastes are disposed of permanently into the Mill's tailings system. Further, as
mentioned above, the Mill was designed and constructed to prevent runon or runoff of storm
water by a) diverting runoff from precipitation on the Mill site to the tailings cells; and b)
diverting runoff from surrounding areas away from the Mill site. As a result, there is no pathway
for liquid effluents from Mill operations to impact surface waters.
Under the Mill License, the Mill is required to periodically sample local surface waters to
determine if Mill activities may have impacted those waters. The primary pathway would be
from air particulate§. freflrgenerated during Mill operations that may have landed on or near
surface waters, or that may have accumulated in drainage areas that could feed into surface
waters. Sampling results since inception of Mill operations show no trends or other impacts of
Mill operations on local surface waters. See the Mill's Semi-Annual Effluent Report for the
period July_] to December 31, 201..J3_, a copy of which has previously been provided to the
Director.
2.7.9 Alternate Concentration Limits
The Mill does not discharge to groundwater or surface water, nor is it designed to do so.
Therefore, no alternate concentration limits are currently applicable to the site.
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information of the
Quality of the Receiving Ground Water (R317-6-6.3.H)
Groundwater classification was assigned by the Director in the Permit on a well-by-well basis
after review of groundwater quality characteristics for the perched aquifer at the Mill site. A
well-by-well approach was selected by the Director in order to acknowledge the spatial
variability of groundwater quality at the Mill, and afford the most protection to those portions of
the perched aquifer that exhibited the highest quality groundwater. These groundwater
classifications are set out in Part I. A and Table 1 of the Permit.
The primary element used by the Director in determining the groundwater classification of each
monitoring well at the site, is the TDS content of the groundwater, as outlined in UAC 317-6-3.
Groundwater quality data collected by the Mill show the shallow aquifer at the Mill has a highly
variable TDS content, with TDS averages ranging from about 1100 to over 7900 mg/L. Another
key element in determination of groundwater class is the presence of naturally occurring
contaminants in concentrations that exceed their respective GWQS. In such cases, the Director
has cause to downgrade aquifer classification from Class IT to Class Ill (see UAC R317-6-3.6).
Using all available TDS data and background data, for 24 of the POC and general monitoring
wells the Director determined that 4 of those wells exhibit Class IT drinking water quality
groundwater. The remaining 20 wells exhibited Class lll or limited use groundwater at the site.
The Director determined that MW -35 will be classified as having Class IT drinking water quality
44
groundwater until sufficient background data have been collected and the applicable Background
Report is submitted. Wells MW-36 and MW-37 have not been classified at this time.
2.8.1 Existing Wells at the Time of Original Permit Issuance
The Director required DenisonEFRI to evaluate groundwater quality data from the thirteen
existing wells on site, and submit a Background Ground Water Quality Report for Director
approval. One of the purposes of that report was to provide a critical evaluation of historic
groundwater quality data from the facility, and determine representative background quality
conditions and reliable GWCLs for the Permit.
DU8A EFR1 (then Den L on) prepared the Existing Well Background Report that evaluated all
historic data for the thirteen existing wells for the purposes of establishing background
groundwater quality at the site and developing groundv1ater COHlflliance limits GWCLs under the
GWDP. Prior to review and acceptance of the conclusions in the Existing Well Background
Report, the GWCLs were set on an interim basis in the GWDP. The interim limits were
established as fractions of the state GWQSs for drinking water, depending on the quality of water
in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality for the
thirteen existing wells, based primarily on the analysis performed in the Existing Wellls Background
Report. It should be noted, however, that, because the GWCLs have been set at the mean plus
second two standard deviation~, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit
Because the Permit called for installation of nine new monitoring wells around the tailings cells,
background groundwater quality had to be determined for those monitoring points. To this end,
the Permit required the Mill to collect at least eight quarters of groundwater quality data, and
submit the New Well Background Report for Director approval to establish background
groundwater quality for those wells.
DU8A EFRI (then Denison) prepared the New Well Background Report that evaluated all
historic data for the nine new wells for the purposes of establishing background groundwater
quality at the site and developing groundvlater compliance limits GWCLs under the GWDP.
Prior to review and acceptance of the conclusions in the New Well Background Report, the
GWCLs were set on an interim basis in the GWDP. The interim limits were established as
fractions of the state GWQSs for drinking water, depending on the quality of water in each
monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed in the New Well :SBackground
Report. It should be noted, however, that, because the GWCLs have been set at the mean plus
second standard deviation, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are
45
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.1)
The groundwater monitoring plan is set out in the Permit. All groundwater monitoring at the site
is in the perched aquifer. The following sections summarize the key components of the Mill's
sampling and analysis plan.
2.9.1 Ground ¥water Monitoling to Detcnnine Ground-W1_ater Flow Dir ction and Gradient,
Background Quality at the Site, and the Quality of Ground..W~ater at the Compliance Monitoring
Point
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit
At the time of renewal of the Mill license by NRC in March, 1997 and up until issuance of the
Permit in March 2005, the Mill implemented a groundwater detection monitoring program te
ens:tJre cornpliailCe Lo 10 CFR Part ·10 i\ppeH~, in accordance with 10 CFR Part 40,
Appendix A and the provisions of then Mill License condition 11.3A. The detection monitoring
program was implemented in accordance with the report entitled, Points of Compliance, White
Mesa Uranium Mill, prepared by Titan Environmental Corporation, submitted by letter to the
NRC dated October 5, 1994. Under that program, the Mill sampled monitoring wells MW-5,
MW-11, MW-12, MW-14, MW-15 and MW-17, on a quarterly basis. Samples were analyzed
for chloride, potassium, nickel and uranium, and the results of such sampling were included in
the Mill's Semi-Annual Effluent Monitoring Reports that were filed with the NRC up until
August 2004 and with the DRC subsequent thereto.
Between 1979 and 1997, the Mill monitored up to 20 constituents in up to 13 wells. That
program was changed to the Points of Compliance Program in 1997 because NRC had concluded
that:
• The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer; and
• The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
2.9.1.2 Issuance ofthe Permit
On March 8, 2005, the Director issued the Permit, which includes a groundwater monitoring
program that superseded and replaced the groundwater monitoring requirements set out in Mill
License Condition 11.3A. Condition 11.3A has since been removed from the Mill License.
Groundwater monitoring under the Permit commenced in March 2005, the results of which are
included in the Mill's Quarterly Groundwater Monitoring Reports that are filed with the
Director.
On September 1, 2009, DenisonEFRI filed a Groundwater Discharge Permit Renewal
Application. A1 Lhe reque ·t of [he DirecLOr of the Utah Di i ion f adiati n nlrol. ~RI
46
ubmitted an updated version of the enr .mber I,_ 0 rene a! applic Lion n July 13.2012. At
the request of the Director of the Utah Div.U·jon of Radiation ControL EFRI is submittin!! this
updaLed r. ion f t.he Julv 2012 r newal application.This document is afl: amendment and
~-e--e:f.-tfle-Refl~·.-al Af.)VIi~~ in being subn'litted at rhe reques1 ef the Director. The
Permit remains in timely renewal status awaiting completion of review of the Renewal
Application by the Director.
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit
The current groundwater monitoring program at the Mill under the Permit, which is used to
determine ground water flow direction, and-gradient, and quality of the ground water at the
compliance monitoring points-. hi. pro.,ram consists of monitoring at 25 point of compliance
monitoring wells: MW-1, MW-2, MW-3, MW-3A, MW-5, MW-11, MW-12, MW-14, MW-15,
MW-17,MW-18,MW-19,MW-23,MW-24,MW-25,MW-26,MW-27,MW-28,MW-29,MW-
30, MW-31, MW-32, MW-35, MW-36, and MW-37. The locations of these wells are indicated
on Figure 410. Depth to water is measured quarterly in MW-34, but due to limited water is not
sampled for POC compliance. MW-33 is completely dry and is not sampled for POC
compliance.
Part I.E.l.( d) of the Permit requires that each point of compliance well must be sampled for the
constituents listed in Table 2.9.1.3-1.
Further, Part I.E.l.( d) 1) of the Permit, requires that, in addition to pH, the following field
parameters must also be monitored:
• Depth to groundwater
• Temperature
_• _Specific conductance,
• Redox potential C"Eh")
and that, in addition to chloride and sulfate, the following general organics must also be
monitored:
• Carbonate, bicarbonate, sodium, potassium, magnesium, calcium, and total anions and
cations.
Sample frequency depends on the speed of ground-water flow in the vicinity of each well. Parts
I.E.1 (b) and (c) provide that quarterly monitoring is required for all wells where local
groundwater average linear velocity has been found by the Director to be equal to or greater than
10 feet/year, and semi-annual monitoring is required where the local groundwater average linear
velocity has been found by the Director to be less than 10 feet/year.
Based on these criteria, quarterly monitoring is required at MW-11, MW-14, MW-25, MW-26
and MW-30, and MW-31, and semi-annual monitoring is required at MW-1, MW-2, MW-3,
MW-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24, MW-27, MW-
28, MW -29 and MW -32.
47
Prior to the February 15 .. 2011 revision of the GWDP, DeHisoHEFRI collected quarterly
groundwater samples from MW-20 and MW-22 for development of background v lues and
potential GWCLs. Part I.E.l.c).3) in the currently approved July 201lAugu ·t _4, 2012 revision
of the GWDP now requires that MW-20 and MW-22 be monitored on a semi-annual basis as
"General Monitoring Wells," but they are not subject to GWCLs.
2.9.1.4 Groundwater Flow Direction and Gradient
Part I.E.3 of the Permit requires that, on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.1 and described in Section 2.9.1.3 above, the Mill
shall measure depth to groundwater in the following wells and/or piezometers:
i) The point of compliance wells identified in Table 2 of the Permit, as described in
Section 2.9.1.3 above;
j) Piezometers-:-P-1, P-2, P-3, P-4 and P-5;
k) Existing monitoring wells-:-MW-20, MW-22, and MW-34;
1) Contaminant investigation wells-:-_-_ any well required by the Director as a part of a
contaminant investigation or groundwater corrective action (at this time this includes
atl-lhe chloroform and nitrate investigation wells); and
m) Any other wells or piezometers required by the Director.
While it is not a requirement of the GWDP, DeHisoHEFRI also measures depth to water in the
DR piezometers which were installed during the Southwest Hydrogeologic Investigation. As-a
result of these measuremeHts, tihe Mill u e. these measurements to prepare-s groundwater
isocontour maps each quarter that sbow the groundwater flow direction and gradient. The
isocontour map for the first quarter of ~ 2014 i attached as Figure 5.
2.9.1.5 Background Quality at the Site
A significant amount of historic groundwater quality data had been collected by DeHisoHEFRI
and previous operators of the Mill for ~some wells at the facility. In some cases these data
extend back more than 30 years to September 1979. A brief summary of some of the various
studies that had been performed prior to the original issuance of the Permit is set out in Section
2.0 of the Regional Background Report.
48
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality assurance
issues. Such an examination needed to include such things as justification of any zero
concentration values reported, adequacy of minimum detection limits provided (particularly with
respect to the corresponding GWQS), adequacy of laboratory and analytical methods used,
consistency of laboratory units or reporting, internal consistency between specific and composite
types of analysis (e.g., major ions and TDS), identification and justification of concentration
outliers, and implications of concentration trends (both temporal and spatial).
As discussed in Section 2.11.2 below, the Director also noted several groundwater quality issues
that needed to be resolved prior to a determination of background groundwater quality at the site.
These were: 1) a number of constituents exceeded their respective GWQS (including nitrate in
one well and manganese, selenium and uranium eaeft-in several wells); 2) long term trends in
uranium in downgradient wells MW-14, MW-15 and MW-17; and 3) a spatial high of uranium in
those three downgradient wells. See pages 5-8 of the 2004 Statement of Basis for a more
detailed discussion of these points.
As a result of the foregoing, the Director required that the Background Reports be prepared to
address and resolve these issues.
Further, because background groundwater quality at the Mill site had not yet been approved at
the time of original Permit issuance, the Director was not able to determine if any contaminant is
naturally occurring and therefore detectable or undetectable for purpose of selecting GWCLs in
each well. Consequently, the Director initially assigned GWCLs as if they were "undetectable"
(i.e., assuming that all natural background concentrations were less than a fraction of the
respective GWQS).
As discussed in Section 1.3 above and 2.11.2 below, DeHisoHEFRI submitted the Background
Reports to the Director. Both the Existing Well Background Report and the New Well
Background Report provided GWCLs for all of the constituents in the existing wells and new
wells, respectively, based on a statistical intra-well approach. The Director has approved the
Background Reports.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells and the nine new wells based primarily on the analysis performed
in the Background Reports. It should be noted, however, that, because the GWCLs have been set
at the mean plus second standard deviation, or the equivalent, un-impacted groundwater would
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point
There are over 30 years of data for some constituents in some wells at the site, but not for all
constituents iH aHy wells. However, with the exception of tin, which was added as a monitoring
constituent in 2007, all currently required monitoring constituents have been sampled in all-the
49
wells that were in existence on the date of the original issuance of the Permit commencing with
the first quarter of 2005. Further, all constituents in aH-the new compliance monitoring wells
have been sampled upon installation of those wells, commencing either in the second or third
quarters of 2005.
All of tbeThe analytical results from this sampling are reported quarterly in Groundwater
Monitoring Reports, which are filed with the Director pursuant to Part LF.l of the Permit.
2.9.2 Installation, Use and Maintenance of Monitoring Devices
Compliance monitoring at the Mill site is accomplished in three ways: the compliance well
monitoring program; monitoring the leak detection moni !oring system in Cells 4A and 4B; and
various DMT monitoring requirements. Each of these are discussed below.
2.9.2.1 Compliance Well Monitoring
Compliance for tailings Cells 1, 2 and 3 and the remainder of the Mill site, other than Cells 4A
and 4B, is accomplished by quarterly or semi-annual sampling of the network of compliance
monitoring wells at the site. See Figure 104 for a map that shows the compliance monitoring
well locations, and Section 2. 9 .1.3 for a description of the monitoring program.
2.9.2.2 Leak Detection System in Cell 4A and Cell4B
With the recotl5t:fl:l€fi.en of Cell 4A, BAT was required, as mandated in Part LD.4 of the Permit
and as stipulated by UAC R317-6-6.4(a) for the reconstruction of Cell4A and the construction of
Cell 4B . Because tailings Cells 1, 2 and 3 were constructed more than 25 years ago, and after
review of the existing design and construction, the Director determined that DMT rather than
BAT is required for Cells 1, 2 and 3 (see the discussion in Section 2.7.2 above).
BAT for Cell4A and Cell4B included the construction of a modern leak detection system. See
Section~ 2.7.3 and 2.7.4 above for a description of the key design elements of Cell 4A and d L
4B te pecti ely, inclu Ling ·i-ffi-thei r leak detection. sy tem.§.. With BAT for Cell 4A nd II 4 ,
there are new performance standards in the Permit that require daily leak detection system
monitoring, weekly wastewater level monitoring, and slimes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Section§. 2.15.3 and 2.15.4 below for a
more detailed discussion of the BAT monitoring requirements for Cell 4A and II 48
respectively.
Because Cell 4A and Cell 4B has-have a-modern leak detection system= that meets BAT
"tandard and ffi-.~monitored daily the leak dete tion y te ...: in Cell 4A..:<::;:;tn..,d:....==-.....:.=.
considered to be a point of compliance monitoring device§..
2.9.23 Let~!c DeteetitJn System in CeU 4/J
~EIHired for CeiJ ~B . e. aAeloled in Parl I.DA of the Pennlt and as Slipulated by UAC
R317 6 6.4(a).
50
See-Section 2.7A a~or 1:1 description of lbe l~ey Elesi"fl elemenl:fj of Cell fB .i:ncluding it!,
.J.eaJi-c~-ieft--sy&~;em. Perfonmmce standard!; for Cell 4:8 jn lhe Permil req1:1ire elai ly leak
del:ection sysleffi ffiOflitorjng, '+'+1eek:ly ""'astewA:~~e>fe~-H'*ffl·~~riFig ana slimes dmin recovery
head meftitoriag. The BAT monitoring resell!; are required lobe reported &Ad smnmacizecl in lhe
~ tffie DMT aRd-BAT Performance StaA€1-~ffit.efi·ng Repoi"t-s-:---See 8eelfeR ~.15.4 below
for a more deHi:Hed diieli!,Sioa of U1e 131\T moflii:Oring reEJUiremeeb ffit· Cell 4B.
Beca;~se CeU 4B hEt:l a·tnodem-leak-det·et.;>{ffln sys~em that-meetn BAT sla:ndard~-efeEI
Eht:ily, lhe leak detection system iA CeU 48 can be considered ~o be a point of eomplianee
monitoring device.
2.9.2.4J.. Other DMT Monitoring Requirements
In addition to the foregoing, the additional DMT performance standard monitoring discussed in
detail in Section 2.15 below is required to be performed under the Permit
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring
Points
The compliance monitoring area at the site is the area covered by the groundwater compliance
monitoring wells. Figure 4-10 shows the mest-current locations of the compliance groundwater
monitoring wells at the site.
At the time of original Permit issuance, the Director reviewed the then recent water table contour
maps of the perched aquifer. Those maps identified a significant western component to
groundwater flow at the Mill site, which the Director concluded appeared to be the result of
wildlife pond seepage and groundwater mounding (see page 23 of the 2004 Statement of Basis).
As a consequence, new groundwater monitoring wells were required, particularly along the
western margin of the tailings cells, in addition to the monitoring wells already in existence at
that time. The Director also concluded that new wells were also needed for DMT purposes and
to provide discrete monitoring of each tailings cell. This resulted in the addition of the following
compliance monitoring wells to the then existing monitoring well network: MW-23, MW-24,
MW-25, MW-26 (which was then existing chloroform investigation well TW4-15), MW-27,
MW-28, MW-29, MW-30, MW-31 MW-32 (which was then existing chloroform investigation
well TW4-17), MW-35, MW-36, and MW-37. As previously stated MW-33, and MW-34 were
installed but are not currently sampled due to limited water and saturated thickness. MW-20 and
MW -22 are not POC wells but are general monitoring wells and are sampled semiannually for
information purposes only.
Based on groundwater flow direction and velocity, the compliance monitoring network, with the
foregoing additional new wells, was considered to be adequate for compliance monitoring in the
perched aquifer at the site.
Further, as mentioned in Section 2.9.2.2 and 2.9.2.3 above, the leak detection systems in Cell4A
and 4B can also be considered to be compliance monitoring areas for these cells.
51
2.9.4 Monitoring of the Vadose Zone
Monitoring is not performed in the vadose zone at the site.,-tmd Lhere are .ao curret1L inlen~
perform ooy fulure moAitoring in the vttdese zoAe at the site.
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation,
Including Post-Operational Monitoring
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation
Please see Section 2.19 below for a detailed discussion of the measures to prevent ground-water
contamination after the cessation of operations.
2.9.5.2 Post-Operational Monitoring
Groundwater monitoring will continue during the post-operational phase through final closure
until the Permit is terminated. DenisonEFRI understands that the final closure will take place
and the Permit will be terminated upon termination of the Mill License and transfer of the
reclaimed tailings cells to the United States Department of Energy pursuant to U.S.C. 2113. See
Section 2.19 .1.1 below.
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where
Applicable to Specified Guidance
2.9.6.1 Monitoring Well Construction
a) New Wells
All new compliance monitoring wells installed after the original issuance of the Permit were
installed in accordance with the requirements of Part I.E.4 of the Permit. Part I.E.4 requires that
all-new groundwater monitoring wells installed at the facility Malt-comply with the following
design and construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other
potential origin of groundwater pollution;
b) Screened and completed in the shallow aquifer;
c) Designed and constructed in compliance with UAC R317-6-6.3(I)(6), including
the EPA RCRA Ground Water Monitoring Technical Enforcement Guidance
Document, 1986, OSWER-9950.1 (the "EPA RCRA TEGD"); and
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
As-built reports for all new groundwater monitoring wells were submitted to the Director for his
approval, in accordance with Part I.F.6 of the Permit. Part I.F.6 requires those reports to include
the following information:
52
a) Geologic logs that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs were prepared by a
Professional Geologist licensed by the State of Utah or otherwise approved
beforehand by the Director ;
b) A well completion diagram that details all physical attributes of the well
construction, including:
1) Total depth and diameters of boring;
2) Depth, type, diameter, and physical properties of well casing and screen,
including well screen slot size;
3) Depth intervals, type and physical properties of annular filterpack and seal
materials used;
4) Design, type, diameter, and construction of protective surface casing; and
5) Survey coordinates prepared by a State of Utah licensed engineer or land
surveyor, including horizontal coordinates and elevation of water level
measuring point, as measured to the nearest 0.01 foot; and
c) Aquifer permeability data, including field data, data analysis, and interpretation of
slug test, aquifer pump test or other hydraulic analysis to determine local aquifer
hydraulic conductivity in each well.
Between April and June 2005, DeRisoREFRI installed wells MW-23, MW-24, MW-25, MW-27,
MW-28, MW-29, MW-30, and MW-31. On August 23, 2005, DeRisoREFRI submitted a
Perched Monitoring Well Installation and Testing at the White Mesa Uranium Mill April
through June 2005 Report, prepared by Hydro Geo Chern, Inc., that documented how these wells
had been installed in accordance with requirements of the Permit. A copy of that Report was
previously submitted under separate cover.
Between August 30 and September 2, 2010, DeRisoREFRI installed wells MW-33, MW-34, and
MW-35. On October 11, 2010, DeRisoREFRI submitted Installation and Hydraulic Testing of
Perched Monitoring Wells MW-33, MW-34, and MW-35 at the White Mesa Uranium Mill Near
Blanding Utah, prepared by Hydro Geo Chern, Inc. that documented how these wells had been
installed in accordance with requirements of the Permit. A copy of that Report was previously
submitted under separate cover. _During the week of April 25, 2011, DeRisoREFRI installed
wells MW-36, and MW-37. On June 28, 2011, DenisonEFRI submitted Installation and
Hydraulic Testing of Perched Monitoring Wells MW-36, and MW-37 at the White Mesa Uranium
Mill Near Blanding Utah, prepared by Hydro Geo Chern, Inc. that documented how these wells
had been installed in accordance with requirements of the Permit. A copy of that Report was
previously submitted under separate cover.
b) Existing Wells
The Existing Wells, MW-1, MW-2, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-
18, MW-19, MW-26 and MW-32 as well as wells MW-16, MW-20 and MW-22, which are not
compliance monitoring wells, and piezometers P-1, P-2, P-3, P-4 and P-5, were all constructed
and installed prior to original issuance of the Permit. Some of those wells date back to 1979.
During several site visits and four split groundwater sampling events between May 1999 and the
date of original issuance of the Permit, and a review of available as built information, DRC staff
53
noted the need for remedial construction, maintenance, or reprur at several of these wells,
including:
(i)
(ii)
16 of the ex1stmg monitoring wells failed to produce clear groundwater in
conformance with the EPA RCRA TEGD, apparently due to incomplete well
development. Consequently, the Permit required that MW-5, MW-11, MW-18,
MW-19, MW-26, TW4-16, and MW-32 be developed to ensure that groundwater
clarity conforms to the EPA RCRA TEGD to the extent reasonably achievable;
The Permit required the Mill to install protective steel surface casings to protect
the exposed PVC well and piezometer casings for piezometers P-1, P-2, P-3, P-4,
and P-5 and wells MW-26 and MW-32; and
(iii)
A.
Several problems were observed with the construction of MW-3, including:
A review of the MW -3 well as-built diagram showed that no geologic log was
provided at the time of well installation. Consequently, the Director was not
able to ascertain if the screened interval was adequately located across the base
of the shallow aquifer;
B.
c.
D.
MW-3 was constructed without any filter media or sand pack across the
screened interval;
An excessively long casing sump (a 9 or 10 foot long non-perforated section of
well casing), was constructed at the bottom of the well; and
The well screen appeared to be poorly positioned, based on the low
productivity of the well, aa€1--(there is no geologic log to verify proper
positioning}.
As a resul~he Permit, requin~el Denison lo verify the def»J:\. ~e lhe up~er contact f
ffie fum;hy BL1:1in Member of the MorriSOFI Foimalion in the imme4·ftt:e 'licinity of
'Neil 'MVl 3. Tiie Permit aloo LeqH:ireEl-t.buL :in the tn·enl thul lhe Direcler determ.ifted
he well sefPen has been i naee~t•ately q1nstrueted the Mm shall relrefil, recanslfucr
or replace moaitoriag well M'N 3.
The Mill developed the wells as required and installed the protective casings required. The
Director concluded that DeaisoaEFRI had fulfilled the requirements and sent DeaisoaEFRI a
Closeout Letter on August 5, 2008.
With respect to the concerns raised about MW-3, the Mill installed MW-3A approximately 10
feet southeast of MW -3, in order to verify the depth to the upper contact of the Brushy Basin
Member of the Morrison Formation (the "UCBM"). After installation, the Director reviewed the
geologic log for MW -3 and the as-built reports for both MW -3 and MW -3A and concluded that
the well screen for MW-3A is 2.5 feet below the UCBM and the well screen for MW-3 is 4.5
feet above the UCBM. Therefore MW-3 is a partially penetrating well; whereas MW-3A is fully
penetrating. The Director concluded that semiannual sampling must continue in both wells until
sufficient data is available and the DRC can make a conclusion regarding the effects of partial
well penetration and screen length. As a result, the GWDP was modified to require that MW-3A
be completed with a permanent surface well completion according to EPA RCRA TEGD. EFRI
c mpl led MW-3A as required, and on Augu . I 5, 200 t.h R · ·e.nr EFRI a lose ul Leucr.
Both MW-3 and MW-3A are currently sampled semiannually.
54
Denisol'l coRTf*~·ed; BAd Oft Aogt1st 5 2008 l.fte DRC seM-"9eAisoA a
Closeout Letter.
Subsequent to original Permit issuance, on January 6, 2006, DRC staff performed an inspection
of the compliance groundwater monitoring wells at the Mill. During the inspection, well MW -5
was found to have a broken PVC surface casing. The repair of MW-5 was added to the Permit
compliance schedule to require the Mill to repair the broken PVC casing to meet the
requirements of the Permit.
The Permit required DeeisoeEFRI to submit an As-Built report for the repairs of monitoring well
MW-5 on or before May 1, 2008. DeeisoeEFRI submitted the required report, and on August 5,
2008 the DRC sent DeeisoeEFRI a Closeout Letter.
The groundwater monitoring program at the Mill has historically had numerous wells with
elevated turbidity, turbidity levels which could not stabilize to within 10% Relative Percent
Difference (10% RPD) or both. Identification of equipment problems and improvements to field
sampling practices did not result in improvements to measured turbidities. Ongoing turbidity
issues were the result of monitoring requirements which were most likely ill-suited to the site
geology. It is suspected that many wells at the Mill might not be capable of attaining a turbidity
of 5 NTU due to the natural conditions in the formation hosting the perched monitoring wells
(the Burro Canyon Formation and Dakota Sandstone). Clay interbeds occur in both the Burro
Canyon Formation and Dakota Sandstone, and friable materials occur within the Burro Canyon
Formation. Saturated clays and friable materials will likely continue to be mobilized using
standard purging techniques currently in use for the sampling program at the Mill. Mobilized
kaolinite (a cementing material within the formation) is expected to be an additional continuing
source of turbidity in perched wells. DeeisoeEFRI discussed the turbidity issues with DRC, and
Bfld, despite the facl that Lhe available evideA£e tlemoAst::ri:tl:e<llhalltlfl:lidity i:JS~:~es are caused by
the formatioe, Deeisoe agreed to complete a redevelopment program for the appropriate selected
wells at the Mill in a "good-faith" effort to .reduce the turbiditv level. Surging, bailing, and
overpumping were determined to be the preferred well development techniques. The rationale
for u ing urging and bailing followed by overpumping i cousi te nt with U.S. Environment.al
Protection Agency t EPA:.,) guidance and guidance provided in other techni.cal paper and
publications.
Select, nonpumping, chloroform, nitrate and groundwater POC, wells were redeveloped during
the period from fall2010 to spring 2011 by surging and bailing followed by overpumping.
The results of the redevelopment are provided in the Report entitled:_Redevelopment of Existing
Perched Monitoring Wells White Mesa Uranium Mill, Near Blanding Utah, prepared by Hydro
Geo Chern, Inc. September 30, 2011 (the "Redevelopment Report"). The Redevelopment Report
provides a qualitative description of turbidity behavior before and after redevelopment and
provides a number of conclusions and recommendations. A copy of the Redevelopment Report
was previously submitted under separate cover. The Redevelopment Report is curreetly
-uftEiefwas review by lhe Dii:eclorclosed out by the Direclor in a letter d· ted No mber J 5. 2012.
The closeout denied EFRI recommendations. However. due t other moclili ation L lbe
55
As described above, aH-the existing wells have been reviewed by the Director, and repairs,
modifications, retrofits, etc. have been made as required to conform those wells to the
requirements of Part I.E.4 of the Permit, to the extent reasonably practicable.
2.9.6.2 Ground Water Sampling
Ground water sampling is performed in accordance with the requirements of Part I.E.5 of the
Permit, which requires that all monitoring shall be conducted in conformance with the following
procedures:
a) Grab samples shall be taken of the groundwater, only after adequate removal or
purging of standing water within the well casing has been performed;
b) All sampling shall be conducted to ensure collection of representative samples, and
reliability and validity of groundwater monitoring data. All groundwater sampling
shall be conducted in accordance with the currently approved Groundwater Monitoring
Quality Assurance Plan;
c) All analyses shall be performed by a laboratory certified by the State of Utah to
perform the tests required;
d) If any monitor well is damaged or is otherwise rendered inadequate for its intended
purpose, DenisonEFRI shall notify the Director in writing within five days of the
discovery; and
e) Immediately prior to each monitoring event, DenisonEFRI shall calibrate all field
monitoring equipment in accordance with the respective manufacturer's procedures
and guidelines. DenisonEFRI shall make and preserve on-site written records of such
equipment calibration in accordance with Part II.G and H of the Permit. Said records
shall identify the manufacturer's and model number of each piece of field equipment
used and calibration.
In accordance with the requirements of Part I.E.1(a) of the Permit, ii-1+-groundwater sampling at
the Mill is performed in accordance with the White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP) (the "QAP"), which has been approved by the
Director. The QAP complies with UAC R317-6-6.3(1) and (L) and by reference incorporates the
relevant requirements of the Handbook of Suggested Practices for Design and Installation of
Ground-Water Monitoring Wells (EP A/600/4-89/034, March 1991 ), ASTM Standards on Ground
Water and Vadose Investigations (1996), Practical Guide for Ground Water Sampling
EPA/600/2-851104, (November 1985) and RCRA Ground Water Monitoring Technical
Enforcement Guidance Document ( 1986), unless otherwise specified or approved by the
Director ~r virtue-e-10-fti&-ttppro-.-ing the QAP. A copy of the current version of the QAP, Date: 6-
06-12 Revi ion 7.2 i inCluded a Appendix HK.
2.9.7 Description and Justification of Parameters to be Monitored
The groundwater parameters to be monitored are described in Table 2.9.1.3-1. The process of
selecting the groundwater quality monitoring parameters for the original Permit included
examination of several technical factors. EacA. of tA.ese is discussedThese factors are listed
56
below and discussed in detail in Section 4 on pages 9-19 of the 2004 Statement of Basi ·.:...;--ttRti
iaclude the followiag:
a) The number and types of contaminants that might occur m feedstock materials
processed at the Mill;
b) Mill process reagents as a source of contaminants;
c) Source term abundance in the Mill's tailings cell solutions, based on l-imited historic
wastewater quality sampling and analysis that had been done at the Mill's tailings cells;
and
d) A consideration of contaminant mobility in a groundwater environment, based on site
specific ~ information where available and lowest ~ values in the literature where
site specific ~ information is not available.
Please--se~I_'Hlges 9 19 of th~04 8tutemeAt of Ba:;is feF-·a-more detailed dif;cuS!'ien
a~ · ·J.Fttioa Mtljustifiealion of J3a:rameteffi te-be atOflil:efefi.:.
One additional parameter, tin, was added to the list of groundwater monitoring constituents in
2007. Tin was not originally a required groundwater monitoring parameter in the Permit, and
was omitted from the original Permit due to non-detectable concentrations reported by
DeaisoaEFRI in three tailings leachate samples (2004 Statement of Basis, Table 5). With the
addition of the alternate feed material from Fansteel Inc., tin was expected to eJ(perieace aa
estimated _!Q_increase from 9 to 248 tons in the tailings inventory-.ffem 9 lO 24 8 tow.,. The
Director concluded that, with an estimated ~ of 2.5 to 5, tin is not as mobile in the groundwater
environment as other metals; however, with the high-acid ic conditions in the tailings wastewater,
tin could stay in solution and not partition on aquifer materials. As a result, tin was added as a
monitoring constituent to Table 2 of the Permit.
2.9.8 Quality Assurance and Control Provisions for Monitoring Data
Part I.E.l (d) of the Permit sets out some special conditions for groundwater monitoring. Under
those conditions, the Mill must ensure that all groundwater monitoring conducted and reported
complies with the following:
a) Depth to groundwater measurements shall always be made to the nearest 0.01 foot;
b) All groundwater quality analyses reported shall have a minimum detection limit or
reporting limit that is less than its respective GWCL concentration defined in Table 2
of the Permit; and
c) aAll gross alpha analysis reported with an activity equal to or greater than the GWCL
shall have a counting variance that is equal to or less than 20% of the reported activity
concentration. An error term may be greater than 20% of the reported activity
concentration when the sum of the activity concentration and error term is less than or
equal to the GWCL.
As mentioned in Section 2.9.6.2 above, Part I.E.l(a) of the Permit requires that all groundwater
sampling shall be conducted in accordance with the currently approved QAP. The detailed
quality assurance and control provisions for monitoring data are set out in the QAP, a copy of
which is attached as Appendix H-K to this Application.
57
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of Discharge
Systems (R317 -6-6.3.J)
As discussed in Section 2. 7.1 above, the Mill has been designed as a facility that does not
discharge to groundwater or surface water. All-tiailings and other wastes associated with Mill
operations are designed to be permanently disposed of in the Mill's tailings cells. The Mill's
tailings cells can therefore be considered the Mill's discharge system in that they permanently
dispose contain sf-discharges from the Mill's process circuits and all other Mill tailings and
wastes.
The following plans and specifications and as built reports relating to tailings Cells 1, 2, 3, 4A
and 4B are referenced in this Application and were previously submitted on the dates noted
below under separate cover:
a. Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
b. Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by D' Appolonia
Consulting Engineers, Inc.;
c. Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia Consulting
Engineers, Inc.;
d. Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc.;
e. Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation;
f. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by DenisonEFRI (then named
International Uranium (USA) Corporation);
g. Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants; and
h. Cell4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah, July
2008 prepared by Geosyntec consultants (disk only).
1. Cell4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007, prepared
by Geosyntec Consultants
j. Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317 -6-6.3.K)
2.11.1 General
The ground water most likely to be affected by a potential discharge from Mill activities is the
perched aquifer.
The deep confined aquifer under White Mesa is found in the Entrada and underlying Navajo
Sandstones, is hydraulically isolated from the perched aquifer, and is therefore extremely
58
unlikely to be affected by any such potential discharges. The top of the Entrada Sandstone at the
site is found at a depth of approximately 1,200 feet below land surface (see the discussion in
Sections 2.5.1.1 and 2.5.1.2 above). This deep aquifer is hydraulically isolated from the shallow
perched aquifer by at l~ast two shale members of the Morrison Formation, including the Brushy
Ba in (approximately 295 feet thick) and the Recapture (approximately 120 feet thick) Members.
Other fermaliions ge I gic unit! are al o found between the perched and deep confined aquifers,
Lbat ftlfte-include many layers of th.i.n hale interbeds that contribute to hydraulic isolation of these
two 1!1' ·undwater ·ystem , incJ udittg: the Morrison Formation Westwater eCanyon
(approximately 60 feet thick), and Salt Wash (approximately 105 feet thick) Members, and the
Summerville Formation (approximately 100 feet thick). Artesian groundwater conditions found
in the deep Entrada/Navajo Sandstone aquifer also reinforce this concept of hydraulic isolation
from the shallow perched system. See the discussion on page 2 of the 2004 Statement of Basis.
2.11.2 Background Ground Water Quality in the Perched Aquifer
This Section describes the groundwater quality in the perched aquifer. See Sections 2.5.1.3,
2.5.1.4 and 2.5.1.5 above for a more detailed description of the perched aquifer itself, the depth
to ground water, the saturated thickness, flow direction, porosity, hydraulic conductivity and
flow system characteristics of the perched aquifer.
As mentioned in Section 2.9.1.5 above, a significant amount of historic groundwater quality data
had been collected by DenisonEFRI and previous operators of the Mill for many wells at the
facility.
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality assurance
issues. The Director also noted several groundwater quality issues that needed to be resolved
prior to a determination of background groundwater quality at the site, such as a number of
constituents that exceeded their respective GWQS and long term trends in uranium in
downgradient wells MW -14, MW -15 and MW -17, and a spatial high of uranium in those three
downgradient wells.
As a result of the foregoing, the Director required that the Existing Well Background Report be
prepared to address and resolve these issues. DUSA prepared the Existing Well Background
Report that evaluated all historic data for the thirteen existing wells for the purposes of
establishing background groundwater quality at the site and developing groundwater compliance
limits GWCLs under the GWDP. Prior to review and acceptance of the conclusions in the
Existing Well Background Report, the GWCLs were set on an interim basis in the GWDP. The
interim limits were established as fractions of the state GWQSs for drinking water, depending on
the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells based primarily on the analysis performed in the Existing Well
background Report. It should be noted, however, that, because the GWCLs have been set at the
mean plus second standard deviation, or the equivalent, un-impacted groundwater would
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
59
represent impacts to groundwater from Mill operations.
As required by the Permit, the Existing Well Background Report addressed all available historic
data, which includes pre-operational and operational data, for the compliance monitoring wells
under the Permit that were in existence at the date of issuance of the Permit. The Regional
Background Report focuses on all-the pre-operational site data and all-the available regional data
to develop the best available set of background data that could not conceivably have been
influenced by Mill operations. The New Well Background Report, which was required by the
Permit, analyzed the data collected from the new wells, which were installed in 2005, to
determine background concentrations for constituents listed in the Permit for each new well.
The purpose of the Existing Well Background Report and the New Well Background Report was-
were prepared to satisfy several objectives-:--'-fifstFirst, in the case of the Existing Well
Background Report, to perform a quality assurance evaluation and data validation of the existing
and historical on-site groundwater quality data in accordance with the requirements of the
Permit, and to develop a database consisting of historical groundwater monitoring data for
"existing" wells and constituents.
Second, in the case of the New Well Background Report, to compile a database consisting of
monitoring results for new wells, which were collected subsequent to issuance of the Permit, in
accordance with the Mill's QAP data quality objectives.
Third, to perform a statistical, temporal and spatial evaluation of the existing well and new well
data bases to determine if there have been any impacts to groundwater from Mill activities.
Since the Mill is an existing facility that has been in operation since 1980, such an analysis of
historic groundwater monitoring data was required in order to ensure verify that the monitoring
results to be used to determine background groundwater quality at the site and GWCLs have not
been impacted by Mill activities.
Finally, since the analysis demonstrategs that groundwater has not been impacted by Mill
activities, to develop a GWCL for each constituent in each well.
The Regional Background Report was prepared as a supplement to the Existing Well
Background Report to provide further support to the conclusion that Mill activities have not
impacted groundwater.
In evaluating the historic data for the existing wells, INTERA used the following approach:
• If historic data for a constituent in a well do not demonstrate a statistically significant
upward trend, then the proposed GWCL for that constituent is accepted as representative
of background, regardless of whether or not the proposed GWCL exceeds the GWQS for
that constituent. This is because the monitoring results for the constituent can be
considered to have been consistently representative since commencement of Mill
activities or installation of the well; and
• If historic data for a constituent in a monitoring well represent a statistically significant
upward trend or downward trend in the case of pH, then the data is further evaluated to
60
determine whether the trend is the result of natural causes or Mill activities. If it is
concluded that the trend results from natural causes, then the GWCL proposed in the
Existing Well Background Report will be appropriate.
After applying the foregoing approach, INTERA concluded that, other than some detected
chloroform and related organic contamination at the Mill site, which is the subject of a separate
investigation and remedial action, and that is the result of pre-Mill activities, and some elevated
nitrate concentrations in certain wells which were considered to be associated with the
chloroform plume, there have been no impacts to groundwater from Mill activities (See Section
2.16.1 below relating to the chloroform contamination and Section 2.16.2 relating to the nitrate
contamination).
In reaching this conclusion, INTERA noted that, even though there are a number of increasing
trends in various constituents at the site, none of the trends are caused by Mill activities, for the
following reasons:
• Chloride ~ U::llEJtlestieatH*y-the best iadicalor parumeter, and tl:lefe are Ae sigRificafl!-
trends in chloride in any of the v;ells;
• There are no noteworthy correlations between chloride and uranium in wells with
increasing trends in uranium, other than in upgradient wells MW-19 and MW-18, which
INTERA concluded are not related to any potential tailings seepage. INTERA noted that
it is inconceivable to have an increasing trend in any other parameter caused by seepage
from the Mill tailings without a corresponding increase in chloride;
• There are significant increasing trends upgradient in MW-1, MW-18 or MW-19 in
uranium, sulfate, TDS iron, selenium, thallium, ammonia and fluoride and far
downgradient in MW-3 in uranium and selenium, sulfate, TDS and pH (decreasing
trend). INTERA concluded that this provides very strong evidence that natural forces at
the site are causing increasing trends in these constituents (decreasing in pH) in other
wells and supports the conclusion that natural forces are also causing increasing trends in
other constituents as well; and
• On a review of the spatial distribution of constituents, it is quite apparent that the
constituents of concern are dispersed across the site and not located in any systematic
manner that would suggest a tailings plume.
INTERA concluded that, after extensive analysis of the data, and given the conclusion that there
have been no impacts to groundwater from Mill activities, the GWCLs set out in Table 16 of the
Existing Well Background Report are appropriate, and are indicative of background ground
water quality. INTERA did advise, however, that proposed GWCLs for all the trending
constituents should be re-evaluated upon Permit renewal to determine if they are still appropriate
at the time of renewal. See Table 16 of the Existing Well Background Report for INTERA's
calculation of background ground water quality as represented by the proposed GWCLs. See
Section 6.0 of the Existing Well Background Report for a discussion of the statistical manner
used to calculate each proposed GWCL.
61
In evaluating the new well data, INTERA used the same approach in the New Well Background
Report that was used in the Existing Well Background Report for existing well data. In addition,
INTERA compared the groundwater monitoring results for the new wells to the results for the
existing wells analyzed in the Existing Well Background Report and to the pre-operational and
regional results analyzed in the Regional Background Report. This was particularly important
for the new wells because there is no historic data for any constituents in those wells that
geesgating back to commencement of Mill operations. A long-term trend in a constituent may
not be evident from the available data for the new wells. By comparing the means
concentrations of fer-the constituents in the new wells to the results for the existing wells and
regional background data, INTERA was able to determine if the constituent concentrations ef
in the new wells are-were consistent with background at the site.
INTERA concluded that after applying the foregoing approach, there have been no impacts to
groundwater in the new monitoring wells from Mill activities. INTERA concluded that the
groundwater monitoring results for the new wells are consistent with the results for the existing
wells analyzed in the Existing Well Background Report and for the pre-operational and regional
wells, seeps and springs analyzed in the Regional Background Report. INTERA noted that there
were some detections of chloroform and related organic contamination and degradation products
and nitrate and nitrite in the new wells, which are now the subject of two separate investigations
(see Sections 2.16.1 and 2.16.2), but that such contamination was the result of pre-Mill activities.
M-a-res til of the foregoifln the Director required leat Lhe New WeU Backgrounel Report be
prepared lo address end resolve lhes · ues. DUSi\ prepared the New Well BuckNound Repe11
~l~al e\'tHuated al l hisl'offi:Hiotu for the Rine new welb fer lRe pt'lfJ*7SCS of e::;tablisloling biwlcgrouad
62
gro~:tndv+'lller quRiiLy at 11'\e site a:Ad de¥elepieg G\VCLs tlAder lRe GW9P. Prior to re-view--ai*i
a€eeJ*a~e-e(*l€.1u:;ion!< in the New--WeH Bat:k"rol:lfl&-Report, !he G\VCL; 11vere 5iel ee ttn
imerim basis jn the GWDP . The jnle.fi.ffl-limits were estai:Htshe<l ns frRclions of the stule G\VQSs
for driA~ Jffig-en rl=te quttJily of 'NUter in eacll moffiwring well aH-A~
The University of Utah Study confirmed INTERA's conclusions in the Background Reports that
groundwater at the site has not been impacted by Mill operations (see the discussion in Section
1.3 above).
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed during the New Well
Background Report. It should be noted, however, that, because the GWCLs have beenwere set at
the mean plus second two standard deviation§., or the equivalent, un-impacted groundwater
would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
Part I.G.2 of the Permit provides that out-of-compliance status exists when the concentration of a
pollutant in two consecutive samples from a compliance monitoring point exceeds a GWCL in
Table 2 of the Permit. Per the requirements of Part I.G.4(c) of the Permit, DenisonEFRI is
required to prepare and submit written plans and time schedules, for Director approval, to fully
comply with the requirements of Part I.G.4(c) of the Permit relating to any such out-of-
compliance situation, including, but not limited to:
(i) submittal of a written assessment of the source(s);
(ii) submittal of a written evaluation of the extent and potential dispersion of said
groundwater contamination; and
(iii) submittal of a written evaluation of any and all potential remedial actions to restore and
maintain ground water quality at the facility, for the point of compliance wells and
contaminants in question, to ensure that: 1) shallow groundwater quality at the facility
will be restored and 2) the contaminant concentrations in said point of compliance wells
will be returned to and maintained in compliance with their respective GWCLs.
+we-ven p,flan and tTjme·. _cheduJe, and i ource A c m nt Rep 1t: (' AR '') have
been submitted to address consecutive exceedances other than pH which have been noted in
wells since the establishment of the GWCLs in the January 20, 2010 GWDP. The Plans and
tiime -s.S,chedules and the SARs are included in Table 2.11.2-1 the Initial Plan and Schedule and
lhe Q2 20 I I Plan and Schedule--te--addres:,~ anruy her !has pl:I in oul of compilanee sttltus.
Those plans were submitted June 13, and September 7, 2011, respecti•1ely.
Time chedules and 'ARs were pr iously ·ubmitted under parate over.
!J!hose plan•; will-be irflfJJemenled COACLlHent ·.vilh Lhe pH inveSU 0 illiOA described belO'iiV aOO
~cribea is the pH pion and Time sc hedule submiued ro l:heDireclor Ofl: i\pfil l3 2012. The
plans were pre-viow,ly submittee 1::1mler separale
63
Sub ·cgoent Plan and Tim appr 'ed bv the
Director in letters to EFRI. The submission dates and the associated DRC approval dates of the
Plans and Time Schedules and the associated SARs are listed on Table 2.11.2-1.
Given the varied background groundwater quality at the site, previously identified rising trends
in some wells and other factors, it cannot be assumed that consecutive exceedances of a
constituent in a monitoring well means that contamination has been introduced to groundwater in
that well. The exceedances may very well be the result of background influences. The approach
in these Plans therefore is to first determine if the recent exceedances are the result of
background influences. If they are determined to be the result of background influences, then no
remedial actions are required. If, however, they are determined to not be the result of natural
background influences, then further analyses will be required.
Based on the information available at this time, DeHisoHEFRI believes that the GWCL
exceedances observed are the result of natural influences and reflect the need to adjust some of
the GWCLs for the site.
During the completion of the 4th Quarter 201 0 Quarterly Groundw ter Monitoring Report,
~R noted eleven perched groundwater monitoring well · with pH mea urements below
the· GWCLs. The e weLl s are located upgradient cro -g1:adient, and -downgradient of the Mill
and tailings cells. Investigation into the eleven pH GWCLs in question indicated that the
GWCLs for groundwater pH in all wells established in the January 20, 2010 GWDP were
erroneously based on historic laboratory results instead of field measurements as contemplated
by Table 2 of the GWDP. DenisonEFRI notified DRC that the existing GWCLs for groundwater
pH were incorrectly based on laboratory results rather than field measurements and proposed to
submit revised descriptive statistics for field pH to be used as revised pH GWCLs by the end of
the second quarter 20 11.
DeHisoHEFRI received approval from DRC to proceed with the revision of the pH GWCLs based
on field measurements. The data processing and statistical assessments necessary to revise the
GWCLs based on historic field pH data were completed. The data processing and statistical
assessments completed were based on the DRC-approved methods in the logic flow diagram
included as Figure 17 of the New Well Background Report. Following the statistical evaluation
of pH data, ~en-.. .;RJ compared the Mill's groundwater pH data from the 2nd Quarter of
2011, including accelerated sampling results through June 2011, and noted that all of the June
2011 groundwater results, and many of the other results from the 2nd Quarter, were already
outside the revised GWCLs to be proposed based on the logic flow diagram.
64
It was noted that the historical trend of decreasing pH, which was addressed in the Background
Study Reports, appeared to be present in nearly all wells throughout the Mill site area, including
upgradient, downgradient, and cross-gradient wells in the groundwater monitoring program. As
of June 2011, all groundwater monitoring wells demonstrated a downward trend in the field pH
data over time.
DenisonEFRI notified DRC that the 2nd Quarter 2011 data exceeded the recalculated GWCLs.
DenisonEFRI advised DRC that, as a result of these findings, DenisonEFRI did not believe it
was appropriate to continue with its efforts to reset the GWCLs for pH based on field pH data, as
originally planned, but instead it appeared that it would be more appropriate to undertake a study
to determine whether the decreasing trends in pH are due to natural influences and, if so, to
determine a more appropriate way to determine GWCLs.
DenisonEFRI and DRC htwe-agreed on further investigations to be completed, as well as the
steps and milestone dates to be incorporated into a pH PlanReport. The procedures for
in e~ · 2aling in ,•esUgation law the decreasing site-wide pH trends is documented in the Plan to
Investigate pH Exceedances in Perched Groundwater Monitoring Wells White Mesa Uranium
Mill Blanding, Utah, Prepared by Hydro Geo Chern, Inc, April 13, 2012 (the "pH Plan and Time
Sche ule ). The pH Plan ur d Time S he lule de ribe~g lhe pH inve ·tigation.:. hich \Va
incorp rated int fo pursuant to the July 12, 2012a Stipulated Consent Agreement referred to
above. The pH Plan and Time Sch du [e was previously submitted under separate cover.
The pH Report consists of a statistical and geochemical evaluation of the decline in pH in
groundwater wells at the Mill. The primary conclusion from the pH Report was that the
historical trend of decreasing pH, which was addressed in the Background Study Reports,
appears to be present in nearly all wells throughout the Mill site area, including upgradient,
downgradient, and crossgradient wells in the groundwater monitoring program, and there seems
to be no abatement of the trend. The wide-spread nature of the decrease in pH in upgradient,
downgradient, and crossgradient wells suggests that the pH decreases result from a natural
phenomenon unrelated to Mill operations, which is also confirmed by the indicator parameter
analysis conducted as part of the pH Report. As discussed in The Pyrite Report, the most likely
cause of declining pH across the site appears at this time to be the oxidation of pyrite, possibly
due to increasing water levels at the site attributed primarily to recharge of wildlife ponds and/or
the introduction of oxygen into the perched water zone as a result of increased groundwater
sampling frequency. Based on the conclusion that the pH trend was caused by natural
phenomenon, the pH Report recalculated the Groundwater Compliance Limits ("GWCLs") for
all compliance monitoring wells at the site.
65
The Pyrite Report evaluated and quantified the presence of pyrite throughout the Mill site, and
identified and quantified the mechanism by which it contributes to the sitewide decline in pH.
The results of the investigation support pyrite oxidation as the most likely mechanism to explain
decreases in pH and increases in sulfate concentrations in site wells and indicates that pyrite
must be considered in assessing perched water chemistry in the future. The complex interaction
of the various naturally occurring factors identified at the site, including the presence of pyrite at
varying concentrations, variable oxygen transport, and variable carbonate species concentrations,
is expected to result in relatively large background variations in pH, sulfate (and therefore TDS)
concentrations, as well as variations in background concentrations of pH sensitive analytes such
as metals. The expected impact of these various factors on pH and analyte concentrations, all of
which are unrelated to Mill operations, is generally consistent with site analytical results,
suggesting that pyrite oxidation plays a significant role in perched water chemistry at the site.
The primary conclusion from the activities conducted to date and de c.:ribed u e is that the pH
tr nd · are not due t p t nlial tailine:' I aktt e r Mill a li ilit: . but to~~ ·
dee reasiftg-fJH, ~"Nhich was addressed ifl the Bac~m:J Repert:; uppeurs to b~e:tll in netwly
ttll well·; throBglloul the Mill si~e arei:i, ineli:Kliee upgru.dieet downgrudienl, aB£1 cros!:>gratl-ioo~
wells in the groundwater moaiteriAg pregram aAd there seef!'ls te be no aeatemenl or tB:e trena.
Tfie wide spread eature of the decrease ie pH ie upgradieBt, dm.vegradieet aed erossgradieet
wells, suggests that the pH decrease results from a natural phenomenon unrelated to Mill
operations.
ln an effort to ~ni ·b anv i{ lflese lrends thal may have re ul ted in whole or in part
from increasing water levels attributed to the Wildlife ponds at the Mill, DenisonEFRI ha&
committed to stopdiscontinued recharging the two most northern of these ponds, commencing in
March 2012.
2.11 .~ Quality of Ground Water at the Compliance Monitoring Point
-A-~The analytical results from groundwater sampling are reported quarterly in Groundwater
Monitoring Reports, which are filed with the Director pursuant to Part I.F.l of the Permit.
2.12 Compliance Sampling Plan (R317-6-6.3.L)
The Mill's plan for sampling groundwater compliance monitoring points is discussed in detail in
Section 2.9.1.3 above, and the plan for sampling the leak detection systems in Cells 4A and 4B is
discussed in Section 2.15.3 below. This 8ectioe section 2.12 will addresses other sampling
required under the Permit. As the Mill is designed not to discharge to ground-water, there are no
flow monitoring requirements in the Permit.
2.12.1 Tailings Cell Wastewater Quality Sampling Plan
Part I.E.l 0 of the Permit requires that, on an annual basis, DeeisoBEFRI ml¥.Tf-collect wastewater
quality samples from each wastewater source at each tailings cell at the facility, including
\ a. l wat -r in urface impoundeEim nt ' wastewaters, and , lime drai n~ 'tVEt~ilewalers. All such
The sampling reust beis conducted in August of each calendar year in compliance with an
approved plan. The Tailings SAP (dated No-..'ereber 21, 2008July 30. 2012) was approved by the
Director on March 3, 2009Acum t 2, 2012. A copy of the approved Tailings and Slimes Drain
66
Sampling Program, Revision Qil, No¥ember 2Q, 2QQ8July 30, 2012 is attached as Appendix H
II h' A 1' 0 A f 11" 0
• T'\An;~ A B ·~ ~ R: 0 0 J l l ' A 0 _'tl..J_lo t IS pp 1catwn. ns o H:IS wntmg, ~oAas so mHeevl:::.lOf\ _ . w ue •s
l:lfldergoiHg review by the Director.
The purpose of the Tailings SAP is to characterize the source term quality of all tailings cell
wastewaters, including impounded wastewaters or process waters in the tailings cells, and
wastewater or leachates collected by internal slimes drains. The Revision Qil,_Tailings SAP
requires:
• Collection of samples from the pond area of each active cell and the slimes drain of each
cell that has commenced de-watering activities;
• Samples of tailings and slimes drain material will be analyzed at an offsite contract
laboratory and subjected to the analytical parameters included in Table 2 of the Permit
and general inorganics listed in Part I.E.1(d)(2)(ii) of the Permit, as well as semi-volatile
organic compounds;
• A detailed description of all sampling methods and sample preservation techniques to be
employed;
• The procedures utilized to conduct these analyses will be standard analytical methods
utilized for groundwater sampling and as shown in Section 8.2 of the QAP;
• The contracted laboratory will be certified by the State of Utah in accordance with UAC
R317-6-6.12A; and
• 30-day advance notice of each annual sampling event must be given, to allow the
Director to collect split samples of all tailings cell wastewater sources.
The tailings and slimes drain sampling events '<vill beare subject to the currently approved QAP,
unless otherwise specifically modified by the Tailings SAP to meet the specific needs of this type
of . ampling. T he QAP ha been approved by th Director and ·ati fie. th e rno L ~~roprmle
L ppli abl-requirement of the fo llewing references tmle therwi. e pecified by lhe Director
through his approval of the Tailings SAP:
• Standard Methods for the Examination of Water and Wastewater, twentieth edition,
1998; Library of Congress catalogue number: ISBN: 0-87553-235-7;
• E.P.A. Methods for Chemical Analysis of Water and Wastes, 1983; Stock Number EPA-
600/4-79-020;
• Techniques of Water Resource Investigations of the U.S. Geological Survey, (1998);
Book 9;
• Monitoring requirements in 40 CFR parts 141 and 142, 2000 ed., Primary Drinking
Water Regulations and 40 CFR parts 264 and 270, 2000 ed.; and
• National Handbook of Recommended Methods for Water-Data Acquisition, GSA-GS
edition; Book 85 AD-2777, U.S. Government Printing Office Stock Number 024-001-
03489-1.
+Ae-anreetly approved Tailings SAP is a~ed 1.0 rhis Application. As previausly stated,
DeAisan has su9miUed Revision 2.1 ·.vhieh i'i m;dergoing rSJf'iew by th~ r.
67
2.12.2 White Mesa Seeps and Springs SampJing Plan
The initial Permit required DeeisonEFRI to submit a plan for groundwater sampling and analysis
of all seeps and springs ("SSSP") found downgradient or Jalenl:l cross gradient from the tailings
cells for Director review and approval. The Director approved the plan on e&-March 17, 2009.
A copy of the Sampling Plan for Seeps and Springs in the Vicinity of the White Mesa Uranium
Mill, Revision: Ql, March 17, 2009June 10, 2011, is attached as Appendix B-~to this
Application. A · of tl1i. writing ~on has-stl-Bmiued Revisi n 1.0~1-flt-efl of this SAP i
undergoing review by the Director.
Under the 888PSeeps and Springs SAP, seeps and springs sampling will beis conducted on an
annual basis between May 1 and July 15 of each year, to the extent sufficient water is available
for sampling, at six identified seeps and springs near the Mill. The sampling locations were
selected to correspond with those seeps and springs sampled for the initial Mill site
characterization performed in the 1978 ER, plus additional sites located by DenisonEFRI, the
United States Bureau of Land Management and Ute Mountain Ute Indian Tribe representatives.
Samples will beare analyzed for all ground-water monitoring parameters found in Table 2 of the
Permit. The laboratory procedures utilized to conduct the analyses of parameters listed in Table
2 will be thoseare the same as utilized for groundwater sampling and as shown in Section 8.2 of
the QAP. In addition to these laboratory parameters, the pH, temperature and conductivity of
each ample will be mea. qred and rec rded in the field: Laboratorie selected by ~I
to perform analyse of :eeps and spdng ample .,.•ill hear requi red Lo be certified by U1e tate
of Utah in accordance with UAC R317-6-6.12.A.
The seeps and springs sampling events will beare subject to the currently approved QAP, unless
otherwise specifically modified by the S8SfL ecp. and pri ngs AP to meet the specific needs
of this type of sampling. The QAP has been approved by the Director and satisfies the mest
appropriateapplicable requirements of the references listed in Section 2.12.1 above, unless
otherwise specified by the Director through his approval of the 888PSeeps and Springs SAP.
P!eane:-see the atrached cop:; of the SSSP f~ delttils.
2.12.3 Monitoring of Deep Wells
Due to the fact that the deep confined aquifer at the site is hydraulically isolated from the
shallow perched aquifer (see the discussion in Section 2.11.1 above) tie-monitoring of the deep
aquifer is not required under the Permit.
2.13 Description of the Flooding Potential of the Discharge Site (R317 -6-6.3.M)
2.13.1 Surface Water Characteristics
As discussed above, tThe Mill site is located on White Mesa, a gently sloping (1% SSW) plateau
that is physically defined by the adjacent drainages which have cut deeply into regional
sandstone formations. There is a small drainage area of approximately 62 acres (25 ha) above
the site that could yield surface runoff to the site. Runoff from the mesa is conveyed by the
general surface topography to either Westwater Creek, Corral Creek, or to the south into an
68
unnamed branch of Cottonwood Wash. Local porous soil conditions, topography and low
average annual rainfall of 13.3 inches (reported as 11.8 by Dames and Moore in historic reports)
cause these streams to be intermittently active, responding to spring snowmelt and local
rainstorms (particularly thunderstorms). Surface runoff from approximately 624 acres of the
Mill drains westward and is collected by Westwater Creek, and runoff from another 384 acres
drains east into Corral Creek. The remaining 4,500 acres of the southern and southwestern
portions of the site drain indirectly into Cottonwood Wash (1978 ER, p. 2-143). The site and
vicinity drainages carry water only on an intermittent basis. The major drainages in the vicinity
of the Mill are depicted in Figure 12 and their drainage areas are tabulated in Table 2.13 .1-1.
Total runoff from the mesa (total yield per watershed area) is estimated to be less than 0.5 inch
annually (1978 ER, p. 2-143).
There are no perennial surface waters on or in the vicinity of the Mill site. This is due to the
getJtle lope of the me a on which the site i located, the low average annual rainfall of 13.3
tfe1eeF"i:e-d as 1 L.8 by Dames and Moore in l1i~1eri c rep !$f-inches per year at Blanding, local soil
charac~eri lie and tbc p.orou nature of local :tream channels. Prior to Mill construction, three
~mall ephemeral cat h ba ins were presenl oe the :;ite to the northwest and northeast of the Mill
site.
Corral Creek is an intermittent tributary to Recapture Creek. The drainage area of that portion of
Corral Creek above and including drainage from the eastern portion of the site is about 5 square
miles. Westwater Creek is also an intermittent tributary of Cottonwood Wash. The Westwater
Creek drainage basin covers nearly 27 square miles at its confluence with Cottonwood Wash 1.5
miles west of the Mill site. Both Recapture Creek and Cottonwood Wash are similarly
intermittently active, although they carry water more often and for longer periods of time due to
their larger watershed areas. They both drain to the south and are tributaries of the San Juan
River. The confluences of Recapture Creek and Cottonwood Wash with the San Juan River are
approximately 18 miles south of the Mill site. The San Juan River, a major tributary for the
upper Colorado River, has a drainage of 23,000 square miles measured at the USGS gauge to the
west of Bluff, Utah (1978 ER, p. 2-130).
Storm runoff in these streams is characterized by a rapid rise in flow rates, followed by rapid
recession primarily due to the small storage capacity of the surface soils in the area. For
example, on August 1, 1968, a flow of 20,500 cubic feet per second was recorded in Cottonwood
Wash near Blanding. The average flow for that day, however, was only 4,340 cfs. By August 4,
the flow had returned to 16 cfs (1978 ER, p. 2-135). Monthly streamflow summaries as updated
from Figure 2.4 of the FES are presented in Figure 13 for Cottonwood Wash, Recapture Creek
and Spring Creek. Flow data are not available for the two smaller water courses closest to the
Mill site, Corral Creek and Westwater Creek, because these streams carry water infrequently and
only in response to local heavy rainfall and snowmelt, which occurs primarily in the months of
April, August, and October. Flow typically ceases in Corral Creek and Westwater Creek within
6 to 48 hours after precipitation or snowmelt ends.
2.13.2 Flood Protection Measures
As mentioned above, tihe Mill was designed and constructed to prevent runon or runoff of storm
water by a) diverting runoff from precipitation on the Mill site to the tailings cells; and b)
69
diverting runoff from surrounding areas away from the Mill site via three drainage ditches that
have been constructed north (upslope) of the Mill facility.
See Lhe UMETCO 44i·lero 19 Co··po··at;3'l' '·\14:le Weso ·'1 il ' Drcjncgt· '?"·n··• ftr Su 1Jwi1'9 1 '() ... . " , • ~ , , n , . , , , J 1.-r • • , , ., 'T· , ~ r If .. • , • , • •
NRC, JanuaTy 1990, ~]'--ek¥fl.k:>.ft-fte EHlpaAies this Af713J.i.ettties , for aA more detailed
description of the flooding potential of the site, including the 6-hour probable maximum
precipitation (which is more conservative than the 100-year flood plain), and applicable flood
protection measures '· pro icled in Lhe UM!::.7CO Minerals Corporation: Whju~ Mest1 Mill
Drainage Reporr fo r ubmiftal to NRC, Jam arv 1990.
In addition to the foregoing designed control features, the facility has developed a Stonnwater
Best Management Practices Control Plan which includes a description of the site drainage
features and the best management practices employed to ensure appropriate control and routing
of stormwater. A copy of the Mill's Stormwater Best Management Practices Plan is included as
Appendix F-G to this Application.
2.14 Contingency Plan (R317-6-6.3.N)
As required by Part I.H.15 of the Permit, the Mill currently has a Contingency Plan for regaining
and maintaining compliance with the Permit limits and for re-establishing best available
technology as defined in the Permit. A copy of the most current approved version of the Mill's
Contingency Plan is included as Appendix J-M to this Application.
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting Failure
of the System (R317-6-6.3.0)
Part I.D. of the Permit sets out a number ofDMT and BAT standards that must be followed. Part
I.E. of the Permit sets out the Ground Water Compliance and Technology Performance
Monitoring requirements, to ensure that the DMT and BAT standards are met. These provisions
of the Permit, along with the DMT Plan, Cell 4A GJtd Cell 4B BAT Monitoring Operations and
Maintenance Plan and other plans and programs developed pursuant to these Parts, set out the
methods and procedures for inspections of the facility operations and for detecting failure of the
system.
In addition to the programs discussed above, the following additional DMT and BAT
performance standards and associated monitoring are required under Parts I.D and I.E. of the
Permit
2.15.1 Existing Tailings Cell Operation
Part I.D.2 of the Permit provides that authorized operation and maximum disposal capacity in
each of the existing tailings Cells, 1, 2 and 3 shall not exceed the levels authorized by the Mill
License and that under no circumstances shall the freeboard be less than three feet, as measured
from the top of the FML. Part I.E.7(a) of the Permit requires that the wastewater pool elevations
in Cells 1 and 3 must be monitored weekly to ensure compliance with the maximum wastewater
elevation criteria mandated by Condition 10.3 of the Mill License. Howe er, leuer from the
Director dated January 27, 2011, which approved the use of Cell 4B, and a subsequent letter
dated March 14, 2011, stated that authorization of the use of Cell 4B an aQpr val of the DMT
70
Part I.D.2 further provides that any modifications by DeaisoaEFRI to any approved engineering
design parameter at these existing tailings cells requires prior Director approval, modification of
the Permit and issuance of a construction permit.
2.15.2 Existing Facility DMT Performance Standards
Part I.D.3 of the Permit requires DeaisonEFRI to operate and maintain certain Mill site facilities
and the existing tailings disposal cells to minimize the potential for wastewater release to
groundwater and the environment, including, but not limited to the following additional DMT
measures:
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3
Parts I.D.3 (a) and (d) require that at all times DeaisonEFRI flffiSt-operate and maintain Cells 1, 2
and 3 to prevent groundwater quality conditions in any nearby monitoring wells from exceeding
the GWCLs in Table 2 of the Permit. This is moaitored for detecting failure of the system
tlu ougl<l tThe ground-water com..pHance m nit01j ng program d~ cribcd in detail in Section
2.9.1.3. is designed to provide early detection of a svstern failure in these tailings cells. above.
2.15.2.2 Slimes Drain Monitoring
Part I.D.3(b)(l) of the Permit requires that DenisonEFRI mu-st-at all times maintain the average
wastewater head in the slimes drain access pipe to be as low as reasonably achievable (ALARA)
in each tailings disposal cell, in accordance with the approved DMT Plan. Compliance will beis
achieved when the average annual wastewater recovery elevation in the slimes drain access pipe,
determined pursuant to the currently approved DMT Plan .. meets the conditions in Equation 1of
specified in Part I.D.3(b)(3) of the Permit.
Part I.E.7(b) of the Permit requires that Deaison,EFRI fffiiSf-monitor and record quarterly the
depth to wastewater in the slimes drain access pipes as described in the currently approved DMT
Plan at Cell 2, and upon commencement of de-watering activities, at Cell 3, in order to ensure
compliance with Part I.D.3(b)(3) of the Permit. At thi · li me. le-wa1erin., f ·II h . not
commenced.
71
The GWDP was amended in July 20 l 1 to 'ha ngc the frequ -ncy of Lbe ·limes drain te ling fr m
m nthly to guarler.ly. The averal!e urmua l a ·t· · lt:r re-cove ry elevation jn th ~l ime · drain pipe
has been in compliance (that is. less than lh previous vear's running average) since the
m ni l ring fregueo y changed Jrom monthly to quarterly in July 201 L
2.15.2.3 Maximum Tailings Waste Solids Elevation
Part I.D.3(c) of the Permit requires that upon closure of any tailings cell, DenisonEFRI must
ensure that the maximum elevation of the tailings waste solids does not exceed the top of the
FML liner.
2.15.2.4 Wastewater Elevation in Roberts Pond
Part I.D.3(e) of the Permit requires that Roberts Pond be operated so as to provide a minimum 2-
foot freeboard at all times, and that under no circumstances will the water level in the pond
exceed an elevation of 5,624 feet above mean sea level. Part I.D.3(e) also provides that in the
event the wastewater elevation exceeds this maximum level, DenisonEFRI must remove the
excess wastewater and place it into containment in Cell 1 within 72 hours of discovery.
Part I.E.7(c) of the Permit requires that the wastewater level in Roberts Pond must be monitored
and recorded weekly, in accordance with the currently approved DMT Plan, to determine
compliance with the DMT operations standard in Part I.D.3(e) of the Permit;
2.15.2.5 Inspection of Feedstock Storage Area
Part I.D.3(f) of the Permit requires that open-air or bulk storage of all feedstock materials at the
Mill facility awaiting Mill processing must be limited to the eastern portion of the Mill site (the
"ore pad") described by the coordinates set out in that Part of the Permit, and that storage of
feedstock materials at the facility out ide of. this defined area mu t meet the requirements of Part
I.D.ll of the Permit. Part I.D.ll require !:hal Deffi5eftEFRT fFH:tSl:--L t re and manage feedstock
materials outside the defined ore storage pad in accordance with an approved Feedstock
Management Plan. On June 20, 2008, Oenisen____Rl submitted a White Mesa Mill Containerized
Alternate Feedstock Material Storage Procedure for Director review and approval. A copy of
that procedure is included as Appendix ~N__to this Application. The Director is currently
reviewing that procedure.
Part I.E.7(d) of the Permit requires that DenisonEFRI inspect the feedstock storage areas weekly
to:
a) Confirm that the bulk feedstock materials are maintained within approved feedstock
storage defined by Table 4 of th Permit; and
b) Verify that all alternate feedstock materials located outside the feedstock storage area
defined in Table 4 are stored in accordance with the requirements found in Part I.D.ll.
72
Part I.E.7(d) further provides that DeaisonEFRI must implement the Feedstock Material Storage
Procedure immediately upon Director approval.
The Mill's .StaAdard Operuting Preeedure procedure under the Mill License for inspection of the
Mill's ore pad is contained in Section 3.3 of the DMT Plan, a copy of which is attached as
Appendix G-H to this Application.
2.15.2.6 Monitor and Maintain Inventory of Chemicals
Part I.D.3(g) of the Permit requires that for all chel.'llical reageats stored at e,;~dstiag storage
facilities aH:d held for Hse ia the l.'llilliag process, DeaisoaEFRI TRttSt-!Q_provide secondary
containment to capture and contain all volumes of reagent(s) that might be released at any
individual storage area. Tlli: 1 quirement appli ~ L all ch mical reagents "·tored at existing
. tora2 fac · 'tie, and h ·ld for u c in the milling proce: . Response to spills, cleanup thereof, and
required reporting must comply with the provisions of an approved Emergency Response Plan as
found in aH--the approved Storm water Best Management Practices Plan, stipulated by Parts I.D.1 0
and I.D.3(g)_of the Permit. Part I.D.3(g) further provides that for any new construction of
reagent storage facilities, such secondary containment and control must prevent any contact of
the spilled or otherwise released reagent or product with the ground surface.
Part I.E.9 of the Permit requires that DeaisoaEFRI ffiHSt-monitor and maintain a current
inventory of all chemicals used at the facility at rates equal to or greater than 100 kg/yr. This
inventory TfHffi'~-_i _t_be maintained on-site, and must include:
(i) Identification of chemicals used in the milling process and the on-site laboratory;
and
(ii) Determination of volume and mass of each raw chemical currently held in storage
at the facility.
A copy of the Mill's chemical Inventory is attached as Appendix b-Q_to this Application.
A copy of the Mill's Stormwater Best Management Practices Plan, Revision l.l4; October
~September 2012 is attached as Appendix F-G to this Application.
2.15.3 BAT Performance Standards for Cell 4A
2.15.3.1 BAT Operations and Maintenance Plan
Part I.D.6 of the GWDP pro','ides thatrequires DeaisonEFRI fflHSt-!Q_operate and maintain Cell
4A so as to prevent release of wastewater to groundwater and the environment in accordance
w'it'h a BAT Operation and Maintenance Plan..:.> as approved by the Direc~or, puPlU61~l to Pilrl
1.1-t 19 of the P-ermit. and that at a minimum . uch plan mu t include t.be fo.Uowin g performance
standards:
a) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
b) The leak detection system maximum allowable daily leak rate shall not exceed 24,160
gallons/day;
73
c) After DenisonEFRI initiates pumping conditions in the slimes drain layer in Cell 4A,
DenisonEFRI will provide continuous declining fluid heads in the slimes drain layer, in
a manner equivalent to the requirements found in Part I.D.3(b) for Cells 2 and 3; and
d) Under no circumstances shall the freeboard be less than 3-feet in Cell 4A, as measured
from the top of the FML.
The BAT Operations and Maintenance Plan required under Part I.H.19I.D.6 was submitted on
September 16, 2008 and approved by the Director on September 17, 2008December 21, 2011. A
copy of the most currently-approved BAT Operations and Maintenance Plan Revision 2.3 dated
:fuly 201 t is included as Appendix B-F to this Application.
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.8 of the Permit provides that, after Director approval of the Tailings Cell 4A BAT
Operations and Maintenance Plan, ~t LH .J9 er lhe Permit, DenisOfiEFRI must
immediately implement all monitoring and recordkeeping requirements contained in the plan. At
a minimum, such BAT monitoring shall include:
a) Weekly Leak Detection System (LDS) Monitoring-including:
(i) .f) ·, A m.-u:il p~ontinuous operation of the leak detection system pumping
and monitoring equipment, including, but not limited to, the submersible pump,
pump controller, head monitoring, and flow meter equipment approved by the
Director. Failure of any pumping or monitoring equipment not repaired and made
fully operational within 24-hours of discovery shall constitute failure of BAT and
a violation of the Permit;
(ii) Denison HTUst measurem nl f the fluid head above the lowest point on the
secondary FML by the use of procedures and equipment approved by the
Director. Under no circumstance shall fluid head in the leak detection system
sump exceed a 1-foot level above the lowest point in the lower FML on the cell
floor. For purposes of compliance monitoring this 1-foot distance shall equate to
2.28 feet above the leak detection system transducer;
(iii) f}eni so n must measurement of the volume of all fluids pumped from the leak
detection system. Under no circumstances shall the average daily leak detection
system flow volume exceed 24,160 gallons/day; and
(iv) Denie•Ofl musl operate aAe-.-mtr~Rktttlopcration and maintenance of wastewater
levels to provide a 3-foot Minimum of vertical freeboard in tailings Cell 4A.
Such measurements must be made to the nearest 0.1 foot.
b) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4A slimes drain system,
monthly recovery head tests and fluid level measurements '+Vill beare to be made in accordance
74
with the requirements of Parts I.D.3 and I.E.7(b) of the Permit and any plan approved by the
Director.
2.15.4 BAT Performance Standards for Cell 4B
2.15.4.1 BAT Operations and Maintenance Plan
Part I.D.13 provides requires that DenisonEFRI ffiH'St-!Q_operate and maintain Cell 4B so as to
prevent release of wastewater to groundwater and the environment in accordance with a BAT
Operations and Maintenance Plan, as approved by lAC Director, pursuaRl lo Part J.H.I9 of lhe
PerFH:it, and that at a minimum such plan must include the following performance standards:
e) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
f) The leak detection system maximum allowable daily leak rate shall not exceed 26,145
gallons/day;
g) After DenisonEFRI initiates pumping conditions in the slimes drain layer in Cell 4B,
DenisonEFRI will provide continuous declining fluid heads in the slimes drain layer, in
a manner equivalent to the requirements found in Part I.D.3(b) for Cells 2, 3 and 4A;
and
h) Under no circumstances shall the freeboard be less than 3-feet in Cell 4B, as measured
from the top of the FML.
As mentioned above, the BAT Operations and Maintenance Plan~ v1as submitted on
September 16, 2008 and approved by the Director on Saf3tembet December l7, 200821. 2 11. A
copy of the most currently-approved BAT Operations and Maintenance Plan, Revision 2.3 dated
July ::!0 II, is included as Appendix B.E to this Application.
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.12 of the Permit provides that DenisonEFRI must implement all monitoring and
recordkeeping requirements contained in the Tailings Cell 4B BAT Operations and Maintenance
Plan. At a minimum, such BAT monitoring includes:
c) Weekly Leak Detection System (LDS) Monitoring-including:
(i) Denison must provide continuous operation of the leak detection system pumping
and monitoring equipment, including, but not limited to, the submersible pump,
pump controller, head monitoring, and flow meter equipment approved by the
Director. Failure of any pumping or monitoring equipment not repaired and made
fully operational within 24-hours of discovery shall constitute failure of BAT and
a violation of the Permit;
(ii) Denison must mea ·urem nl of lhe fluid head above the lowe. l poim n the
secondary FML by the use of procedures and equipment approved by the
Director. Under no circumstance shall fluid head in the leak detection system
sump exceed a 1-foot level above the lowest point in the lower FML on the cell
75
floor. For purposes of compliance monitoring this 1-foot distance shall equate to
2.25 feet above the leak detection system transducer;
(iii) Denison must measurement of the volume of all fluids pumped from the leak
detection system. Under no circumstances shall the average daily leak detection
system flow volume exceed 26,145 gallons/day; and
(iv) &ellison must operate £md r'Aain~ainop ration an 1 maintenance of -wastewater
levels to provide a 3-foot Minimum of vertical freeboard in tailings Cell 4B.
Such measurements must be made to the nearest 0.1 foot.
d) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4B slimes drain system,
monthly recovery head tests and fluid level measurements will-are to be made in accordance with
the requirements of Patts I.D.3 and I.E.7 (b) of the Permit and any plan approved by the Director.
J . .J5.1.J lmpkmenlalie11 tJj'Me11i11JFiRg Requirem~nls Y~rdeFihe llt\1' ().pe(·eliens end Meintell6rt~e
PhHt
.J2.aft l.E.l2 of the Peru=t:it provffies that. arter Director a~re,.·aL of the Tailings Cell 4B Of!el1ttions
and Maintenance Plan Denison musl immediately iFnplemeat all raanitoFing and recordkeeping
req1:1irements centrtined in rhef3lmt:--Ai-~1un1, !iuch 'BAT monitoring tdutll iee-~
a) \71/eckly beai~Qe~ction Sy.,~em (:60S) Monitoring iflcludiflg:
(i) Denison mus1 pro,· ide eominuo1:1s operaLion of lhe leak del-eefien systeffi flUmpirlg
und ffiOiliWring eq~em ind1:1tl:i-agrl3ul not Jimi~ed to, the submersiale pump.
j*tmp eoutreller, head moAiloring, and Row--FAeter equif>ment approved by lhe
Director. Fai l uflHtf~ . . . ::. . ~nd maae
fully epet:ational within "~4 hours of discovery ::;hnll uoo~tilute failu1·e of BAT and
a ·iiolatien of the Permit;
(ii) Denisoa must measure lhe fluiEI--heu£1 abo•f'e the lowest point on lhe seeondary
Mh-9y-t-l:le-'tf~e of procedures and equif*llent approved by the Director. Under
no ei remr~shmce bluill [I u iu hencl ifl lfte lenk: deleetioe sysLem su rnp exceed a l
feolte'l·el Llbove lhe lowest peffit in the tower FML on the eell..fleor.--For purpO!i ·
of eompliwwe monitorjno tb:is J fool Eltslaaee sball eql:lale to 2.25 feet abo·re Lke
lealc detectiofl Sj'stem traflsducer;
Fti) Denit.on mu&t mea:;ure the '<'Oiume of all fluids pumped [rom I:Ae leak deteerion
sy.,tem. Unser no circumslancec; !'hall t.Re average daHy leRJt detection :;ysttffil-
flov; volume exceed 26,14 5 gallons,lday; and
(+¥) Dooi-son musl openne an~tflf:tinraja wastewater levels to~\'ide a 3 foo!-
Minim~:~m of "J'erli:c:'J u:eeboard Jn-t:Clili:ags CeH 48. Such measurements musl be
made to the nearest 0.1 foot.
76
f) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4B slimes drain system,
flWA-llliy reeovery head leSLH and fluid J~trements wiU be made in accordanee-wti:IH:fle
~:et:Tteftts of Pnfts I.D.3 ana f.fi.7(b) of lhe Permit and any plae aj:)proved by U1e Direeter.
2.15.5 Stormwater Management and Spill Control Requirements
Part I.D.1 0 of the Permit requires that DenisonEFRI will-!Q_manage all contact and non-contact
stormwater and control contaminant spills at the facility in accordance with an approved
stormwater best management practices plan. Such plan must include the following minimum
provisions:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R317 -6-6.3(G) and R317 -6-6.4(C);
b) Prevent, control and contain spills of stored reagents or other chemicals at the Mill site;
c) Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
d) Report reagent spills or other releases at the Mill site to the Director in accordance with
UAC 19-5-114.
The Mill's Stormwater Best Management Practices Plan dated June 12, 2008, was approved by
the Director on July 1, 2008. A copy of the most recently approved Mill's Stormwater Best
Management Practices Plan Revision dated 1.24 September 20120ctober 2011, is included as
Appendix F--G to this Application.
2.15.6 Tailings and Slimes Drain Sampling
Part I.E.1 0 of the Permit requires that on aH annual basis, DenisonEFRI mu-st-to annually collect
wastewater quality samples from each wastewater source at each tailings cell at the facility,
including surface impounded wastewaters, the leak detection systems (if present) and slimes
drain wastewaters. All such sampling must be conducted in August of each calendar year in
compliance with the approved :J!i:\i I ing!l Cell-Tailings Sampling Plan.
See Section 2.12.1 above for a more detailed description of this program.
The Mill's Tailings and Slimes Drain Sampling Program was approved by the Director. The
most recently approved version is included as Appendix I-.L_to this Application. As of this
wrHing, DenisoA [195 submitted Revisien 2.1 v:hioh is ~=tneergoiag l'eview by tbe Direetor.
2.15.7 Additional Monitoring and Inspections Required Under the Mill License
Under r,he Mill Lice11 e daily, weekly, and monthly inspection reporting and monitoring are
required ~i n ccordancc with NRC Regulatory Guide 8.31, Information Relevant to Ensuring
that Occupational Radiation Exposures at Uranium Recovery Facilities will be As Low As is
Reasonable Achievable, Revision 1, May 2002 ("Reg Guide 8.31"), by Section 2.3 of the Mill's
77
ALARA Program and by the Mill's Environmental Protection Manual ("EPM")1.....3 ~
requi rement ru over and above the inspections described above that are required under the
Permit.
eftisefl-feC-eFH:~l7fl.litted for--Btreetor appro.,.a1. a re•{i:seEJ.Addilional dai ly. week ly. m nlhly.
quarterly. and annual insp eli n and rep rting r quirem nt are ~R illcd in lbc EFRl DMT Plan
and Tailings Management System Procedure (Section 3.1 of the EPM) to separate the RML
9MT reql::lirements from ~he GWDP DMf re£-Juirtlmenls, into two separate documents. As of
this writiag, eelh~Hl:tese plaAs are t:mdergoing revie•.v by the Di:reetor. The DMT Plan and
Tailings M<magem nl SysLcm are in ludcd a. Appendix H and Appendix I to this Appli ulion .
respectively.
2.15.7.1 Daily Inspections
Three types of daily inspections are performed at the Mill under the Mill License:
a) Radiation Staff Inspections
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the Mill's Radiation Safety Officer ("RSO") or
designated health physics technician should conduct a daily walk-through (visual) inspection of
all work and storage areas of the Mill to ensure proper implementation of good radiation safety
procedures, including good housekeeping that would minimize unnecessary contamination.
These inspections are required by Section 2.3.1 of the Mill's ALARA Program, and are
documented and on file in the Mill's Radiation Protection Office.
b) Operating Foreman Inspections
30 CFR Section 56.18002 of the Mine Safety and Health Administration regulations requires that
a competent person designated by the operator must examine each working place at least once
each shift for conditions which may adversely affect safety or health. These daily inspections are
documented and on file in the Mill's Radiation Protection Office.
c) Daily Tailings Inspection
Section 3.1 of the Mill's EPM requires that during Mill operation, the Shift Foreman, or other
person with the training specified in paragraph 2.4 of the Tailings Management Procedure,
designated by the RSO, will perform an inspection of the tailings line and tailings area at least
once per shift, paying close attention for potential leaks and to the discharges from the pipelines.
Observations by the Inspector are recorded on the appropriate line on the Mill's Daily Inspection
Data form.
2.15.7.2 Weekly Inspections
Three types of weekly inspections are performed at the Mill under the Mill License:
a) Weekly Inspection of the Mill Forms
78
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the RSO and the Mill foreman should, and
Section 2.3.2 of the Mill's ALARA Program provides that the RSO and Mill foreman, or their
respective designees, shall .. conduct a weekly inspection of all Mill areas to observe general
radiation control practices and review required changes in procedures and equipment. Particular
attention is to be focused on areas where potential exposures to personnel might exist and in
areas of operation or locations where contamination is evident.
b) Weekly Ore Storage Pad Inspection Forms
Paragraph 3.3 of the DMT Plan and Part I.E.7.(d of the Permit requires that weekly feedstock
storage area inspections will-be performed by the Radiation Safety Department, to confirm that
the bulk feedstock materials are stored and maintained within the defined area of the ore pad and
that all alternate feed materials located outside the defined ore pad area are maintained in
accordance with the requirements of the Permit. The results of these inspections are recorded on
the Mill's Ore Storage/Sample Plant Weekly Inspection Report.
c) Weekly Tailings and DMT Inspection
Section 3.1 of the EPM requires that weekly inspections of the tailings area and DMT
requirements be performed by the radiation safety department.
2.15.7.3 Monthly Reports
Two types of monthly reports are prepared by Mill staff:
a) Monthly Radiation Safety Reports
At least monthly, ([he RSO reviews the results of daily and weekly inspections, including a
review of all monitoring and exposure data for the month .. and provides to the Mill Manager a
monthly report containing a written summary of the month's significant worker protection
activities (Section 2.3.4 of the ALARA Program).
b) Monthly Tailings Inspection Reports
Section 3.1 of the EPM, requires that a Monthly Inspection Data form be completed for the
monthly tailings inspection. This inspection is typically performed in the fourth week of each
month and is in lieu of the weekly tailings inspection for that week.
Mill staff also prepares a monthly summary of all daily, weekly, monthly and quarterly tailings
inspections.
2.15. 7.4 Quarterly Tailings Inspections
Section 3.1 of the EPM requires that the RSO or his designee perform a quarterly tailings
inspection.
79
2.15.7.5 Annual Evaluations
The following annual evaluations are performed under the Mill License, as set out in Section 3.1
of the EPM.
a) Annual Technical Evaluation
An annual technical evaluation of the tailings management system must be performed by a
registered professional engineer (PE), who has experience and training in the area of
geotechnical aspects of retention structures. The technical evaluation includes an on-site
inspection of the tailings management system and a thorough review of all tailings records for
the past year. The Technical Evaluation also includes a review and summary of the annual
movement monitor survey (see Section (b) below).
All tailings cells and corresponding dikes are inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches are inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations were performed for the receipt of alternate feed
material during the year, the capacity evaluation forms and associated calculation sheets will be
reviewed to ensure that the maximum tailings capacity estimate is accurate. The amount of
tailings added to the system since the last evaluation will also be calculated to determine the
estimated capacity at the time of the evaluation.
As discussed above, tailings inspection records consist of daily, weekly, monthly, and quarterly
tailings inspections. These inspection records are evaluated to determine if any freeboard limits
are being approached aDd ro ld ntifv any area. of p tcnlial concern . Records will a-lso be
revie\Yed EO sttmtnalize observa~i ons or pol:eatil±l concem. The evaluation also involves
discussion with the Environmental and/or Radiation Technician and the RSO regarding activities
around the tailings area for the past year. During the annual inspection, photographs of the
tailings area are taken. The training of individuals is also reviewed as a part of the Annual
Technical Evaluation.
The registered engineer obtains copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These
copies are then included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 1st of every year to
the Directing Dam Safety Engineer, State of Utah, Natural Resources.
b) Annual Movement Monitor Survey
A movement monitor survey is conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes
3-S, 4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data
generated from this survey is reviewed and incorporated into the Annual Technical Evaluation
Report of the tailings management system.
80
c) Annual Leak Detection Fluid Samples
Annually, the leak detection system fluids in Cells 1, 2, 3, 4A and 4B V<'ill beare sampled when
present as described in the Tailings Sampling Plan in Section 2.12.1.
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to Remedy
any Violation of Applicable Ground Water Quality Standards (R317-6-6.3.P)
There are two circumstances where applicable groundwater standards have been exceeded at the
site that are not associated with natural background: chloroform contamination, and nitrate
contamination. As discussed below, none of these circumstances appear to be related to
discharges from milling activities. See Section 2.11.2 for a discussion of the current
investigation into exceedances of GWCLs for certain constituents and decreasing pH trends at
the site, which DenisonEFRI believes are associated with natural background.
2.16.1 Chloroform Investigation
In May, 1999, excess chloroform concentrations were discovered in monitoring well MW-4, ffi
which is screened in the the shallow perched aquifer along the eastern margin of the Mill site.
Because these concentrations were above the GWQS for chloroform, the Executive Secretary of
the Utah Water Quality Board initiated enforcement action against the Mill on August 23, 1999
through the issuance of a Groundwater Corrective Action Order (UDEQ Docket No. UG0-20-
01), which required completion of: 1) a contaminant investigation report to define and bound the
contaminant plume, and 2) a groundwater corrective action plan to clean it up. Repeated
groundwater sampling by both the Mill and DRC have confirmed the presence of chloroform in
concentrations that exceed the GWQS along the eastern margin of the site in wells that are
upgradient or cross gradient from the tailings cells. Other VOC contaminants and nitrate and
nitrite have also been detected in these samples. After installation of 27 new monitoring wells at
the site, groundwater studies appear to have defined the boundaries of the chloroform plume.
Based on the location of the plume and characterization studies completed to date, the
contamination appears to have resulted from the operation of temporary laboratory facilities that
were located at the site prior to and during construction of the Mill facility, and septic drainfields
that were used for laboratory and sanitary wastes prior to construction of the Mill's tailings cells.
Interim measures have been instituted in order to contain the contamination and to pump
contaminated groundwater into the Mill's tailings cells. To that end, the Mill has equipped .§-five
of the wells (MW-4, TW4-4, MW-26 (previously named TW4-15), TW4-19 and TW4-20) with
pumps to recover water impacted by chloroform and to dispose of such water in the Mill's
tailings cells.
In the 2004 Statement of Basis, DRC noted on page 3 that, while the contaminant investigation
and groundwater remediation plan are not yet complete, the DRC believes that additional time is
available to resolve these requirements based on the following factors: 1) hydraulic isolation
found between the shallow perched aquifer in which the contamination has been detected and the
deep confined aquifers which are a source of drinking water in the area, 2) the large horizontal
distance and the long groundwater travel times between the existing groundwater contamination
on site and the seeps and springs where the shallow aquifer discharges at the edge of White
81
Mesa, and 3) lack of human exposure for these shallow aquifer contaminants along this travel
path.
MinimiZe-et'--jJFe'l'ent-fH.fi:.Aer dovmgra&ient migration of the c:Riowferm plmne hy a con=tbination
of pumping end rel in nee on naluntl aHenuaL:ioa;
Prevent ehloroform concentra~ion~-eeeflffio the acfion le\·el froFA FnigraLing soulh or soutlwrest
of the tailiags cells;
Mooitor te track chaRges in-.eoncentralions •.vithin the f)lume--ftflfi..-t:e-estab!ish whe ther tbe plume
boundtt:ries are eKpanding. conEr!:lEH·ing or sk:lhle:-
Pro'ride contingenay plans to address poteAtial continued t*pcrasion of the p:tume and the need
.f-oHtdGitional monitoring imd/or pumping points; an&
Ultitftalely £educe ch::loroform eoncentre~Lions al ull moe:itorie:g 1oonLion:s to Lhe octiun level
below.
To achieYe !hese objecti~lle proposed CorrclctiYe AeHon Plan J3Foposes a phased ~tpproac+.
!J:he tirst plt&.ie consists of £! comb}nution of "eclive and pit5siye .. sl:rategies. The aCii't'e
str"~tegy eoasis!s of ret:ao•!':iAg eh-loroform tll~5-ntf-*dly as 19ractiea1 by pwnp~s-t.flttt..ftt:we
~fl a relative bAc;is) both high ehlereferm coAeeAiraL:ioAs, aad high prociLtetivily. Continued
tHenitn•ing •.viUU:a aad outside the plume is considere~ of the active slrategy. The pa·;sh·a
Slntlegy coosisP.; of relying OA Aflturnl aueountien processes lo refftOYe clilorefonB: m<Hi~ ancl
reffi:lee-eaHeefltrn-tion9 . Redtlctions in eontentrttLion:; wo&l&-t1e achieved hy physjcal -processes
sucb as volatilization hyElrodyfl:llil'lie dispef£ien, ami abiotic Elegradtuion. i±Bd Lhrough atffiffit-!
biological degrndation of ehloroferm. These are essentially rhe same processes thal have eeen
relied UflOB ia the iaterim aetioa.
~t-l--i:ttiefl.~teFt-ki--~e€H~-feeUce ehlorofof!ll concentrations vtilh-ifl-H~e entire :Plum
HoweYer within upgtadienl poFtiOfl:S o:f lbe plume tfi.al aeeur .HI l1igbeF pern=1eabWty mtueri~:~Js
thnt are affteeable te pumping, direct mass removal via pumping ·Nill be the primary meant> to
reduce eoneentratioss. In downgradief!l poftioas of lhe plume where permeabilities nre lew,
~ten f'£Hes are lmv , and mass remfWttl-1:1-y pum~ing is A:OL praclica:l because
-aehievabJe pumping ruLes wetti-EI be very low na~f:ten will be the-pffiflffi.'j'-ffieaflfr-
reduce eoReeRtratioas.
The second phetse rel ie:. on naturctl t\ltenual:ioa (witheul pumping) to reduce eltloroform
eetlCeftf:ffifiens al:-aJI meAilering locations to acli ofl--1.e¥~ncenlrations duriag Phase 1
are-judged k~l-ffieiently lo'N that Phase1 will be effeuti ·,,e.
82
As patt of the active strategy in the first phase of the Corrective Action Plan, DenisonEFRI has
operated a chloroform capture system, referred to as the "Long-term Pump Test" continuously
since January 31, 2010. The purpose of the test is to serve as an interim action that will remove a
significant amount of chloroform-contaminated water while gathering additional data on
hydraulic properties in the area of investigation. Chloroform-contaminated water is captured by
pumping six wells located within the identified chloroform plume, and transferred via an above-
ground piping network to Tailings Cell 1 for disposal.
Effecli en ss of the fir t phas of tbe orrecUve Action i. eva luated and documen ed in
quarter:ly report to the Director. DeaisoaEFRI e t.imates that to EltHear of the fir t quarter of
-14, ~99 Jb ·. f chl oroform ba e been extrc,tcted thr ll0 b the captu re y tern.
2.16.2 Nitrate Investigation
During review of the New Well Background Report and other reports, a Nitrate contaminant
plume was identified by DRC staff in five monitoring wells in the Mill site area, including wells:
MW-30, MW-31, TW4-22, TW4-24, and TW4-25. TW4-25 is located upgradient of the Mill's
tailings cells. Elevated concentrations of chloride also appear to be associated with the nitrate
plume.
On September 30, 2008, the Director issued a request for a voluntary plan and schedule for
DenisonEFRI to investigate and remediate this Nitrate contamination. On November 19, 2008
DenisonEFRI submitted a plan and schedule prepared by INTERA, Inc., which identified a
number of potential sources for the contamination, including several potential historic and offsite
sources. On January 27, 2009, the Director and DenisonEFRI signed a Stipulated Consent
Agreement ("SCA") by which DenisonEFRI agreed to conduct an investigation of the Nitrate
contamination, determine the sources of pollution, and submit a report by January 4, 2010.
DenisonEFRI submitted a Contaminant Investigation Report ("CIR") on December 30, 2009. On
October 5, 2010 the Director issued a Notice of Additional Required Action ("NARA") letter
that notified DenisonEFRI of the Director's determination that the 2009 CIR was incomplete.
On December 20, 2010 DenisonEFRI and the Director entered into Revision 0 of a Tolling
Agreement.. allowing a tolling period until April 30, 2011 in order to provide time for
DenisonEFRI to prepare a Plan and Schedule for Director review addressing additional
investigations to resolve open issues identified in the October 5, 2010 NARA, and to execute a
revised SCA.
DenisonEFRI submitted a Plan and Schedule on February 14, 2011 and a revised Plan and
Schedule on February 18, 2011. theThe Director provided hls-comments on the revised Plan and
Schedule on March 21, 2011. In an April 20, 2011 meeting, DenisonEFRI and the Director
agreed that the Plan and Schedule to conduct additional nitrate investigations would be
composed of four to five phases of study, including geoprobe drilling and soil sampling/analysis
to investigate natural nitrate salt reservoir sources in the vadose zone beyond the Mill site,
potential Mill sources, and other potential sources; groundwater sampling and analysis of
existing monitoring wells for non-isotopic analytes; deep bedrock core sampling/analysis of
83
possible natural nitrate reservoir and potential nitrate source locations; stable isotopic
sampling/analysis of groundwater in existing monitoring wells; and stable isotopic
sampling/analysis of soil/core samples, if needed.
On April 28, 2011, DeH:isoHEFRI and the Director entered into Revision 1 of the Tolling
Agreement to extend the Tolling Period through June 30, 2011 and adopt the agreements made
on April 20, 2011. Under the Tolling Agreement Revision 1, DeH:isoHEFRI agreed to submit a
Revised Phase 1 (A through C) Work Plan on or before May 6, 2011 and a Revised Phase 2
through 5 Work Plan and Schedule on or before June 3, 2011.
DeHisoHEFRI submitted a May 6, 2011 Revised Phase 1 Work Plan and Schedule for the Phase 1
A - C investigation for Director review. DeHisoHEFRI conducted field and laboratory work for
the Phase 1 A-C study in May and June, 2011.
DeHisoHEFRI submitted a Revised Phase 2 through 5 Work Plan and Schedule for Director
review on June , 20 L 1. The Director provided comments on this document on June 23, 2011
and advised eni~on ·FRJ that in order to revise the 2009 SCA to incorporate needed
deliverables and timelines, the Phase 2 through 5 Work Plan would need to be expanded to the
same level of detail as was provided for Phase 1 in Attachment 1 of the Revision 1 Tolling
Agreement.
On June 30, 2011, DeH:isoHEFRI and the Director entered into Revision 2 of the Tolling
Agreement extending the Tolling Period to August 31, 2011, to facilitate the revision of the
Phase 2 through 5 Work Plan to provide the required level of detail to construct a replacement
SCA. DeH:isoHEFRI submitted a separate July 1, 2011 detailed Revision 0 of the Work Plan and
Quality Assurance Plan ("QAP") for the Phase 2 investigation. The Director provided comments
on this document on July 7, 2011. DeHisofiEFRI provided a July 12, 2011 Revision 1.0 to the
Phase 2 QAP and Work Plan, which DRC conditionally approved in a letter dated July 18, 2011.
On August 1 and 2, 2011 DeHisoHEFRI submitted by email preliminary laboratory results for the
Phase 1 A-C study to the Director.
On August 4, 2011, DeH:isoHEFRI provided a Revision 1.0 to the Phase 2 - 5 Work Plan for
Director review. The Director provided comments on the Phase 2-5 Work Plan, Revision 1.0 and
the August 1, 2011 preliminary laboratory results on August 11, 2011. DeHisoHEFRI submitted
Revision 2.0 of the Phase 2-5 Work Plan for Director review on August 11, 2011.
On August 25, 2011, the Director determined that based on review of the Revision 2.0 Phase 2-5
Work Plan, a finalized Plan and Schedule that meets the satisfaction of the Director, and which
would allow the preparation of a replacement SCA, was not possible at that time; and that the
development of a replacement SCA for continued contaminant investigation activities was not
supported.
At a meeting on August 29, 2011, DeHisoHEFRI and DRC agreed that:
1. After more than two years of investigation it has been determined that there are site
conditions that make it difficult to determine the source(s) of the contamination at the
White Mesa site;
84
2. As a result, resources will be better spent in developing a CAP in accordance with UAC
R317-6-6.15(D), rather than continuing with further investigations as to the source(s) of
the contamination.
In discussions during October 2011, DenisonEFRI and the Director acknowledged that it has not
been possible to date to determine the source(s), cause(s), attribution, magnitudes of
contribution, and proportion(s) of the local nitrate and chloride in groundwater, and thereby
cannot eliminate Mill activities as a potential cause, either in full or in part, of the contamination.
As a result, DenisonEFRI and the Director agreed that resources will be better spent in
developing a Corrective Action Plan in accordance with UAC R317-6-6.15(D), rather than
continuing with further investigations.
On October 3, 2011 Denison_BFRI and the Director entered into a revised Stipulated Consent
Agreement which required DenisonEFRI to submit a Corrective Action Plan for Director review
wh-tel:r-ifl~Sf-+he Following three phaaes l1f acti'l·i~that inclllded plan . t :
Phase I --te-determine the physical extent of soil contamination observed at the
Ammonium Sulfate Crystal Tanks, and provide a control measure consisting of either
removal of the areal extent of contamination down to bedrock, or a Plan and Schedule for
covering the areal extent of contamination with at least 6 inches of concrete, followed by
removal action during or before site closure.
Phase II-to ineludeimplement near term active remediation of the nitrate contamination
by pumping contaminated water into the Mill's tailings cells for disposal. This phase is
to inclllde development, implementation, operation, and monitoring fer--Q[_a pumping
well network to contain and hydraulically control the nitrate plume; monitoring of
chloride concentrations; and any required increases to the Mill's surety for activities in
this Phase.
Phase III -·if necessary, to includcde elop. if nece. ary. a comprehensive long-term
solution for the nitrate contamination at the Mill Site. This Phase is to be determined
after public participation and Director approval, and may include continuation of Phase I
and II activities alone or in combination with any of the following: monitored natural
attenuation, additional remediation and monitoring, determination of additional
hydrogeologic characterization, contaminant travel times, points of exposure to public or
wildlife, risk analysis, cost/benefit analysis, and possible development and petietion of
the Board for alternate t£orrective action concentration limits.
DenisonEFRI submitted a Draft Corrective Action Plan on November 30, 2011. The Director
provided comments on the Draft Corrective Action Plan on January 19, 2012. DenisonEFRI
provided Revision 1.0 of the Corrective Action Plan on February 27, 2012, and received
comments from the Director on March 19, 2012. Pursuant to the revised SCA, ~ n FRI
provided Revision 2.0 to the Director on May 7, 2012.
The Director prepared a drAft StiptiiB:IteA Rnd Consent Order Md a £talemefll efBasi!.l on J~
~
85
EFRl to fullv irnol ment all elements of the Mav 7, 2012 CAP.
2.17 Other Information Required by the Director (R317-6-6.3.Q)
2.17.1 Chemical Inventory Report
Part I.H.1 of the Permit requires that DenisonEFRI complete a historical review and conduct an
inventory of all chemical compounds or reagents stored, used, or currently in use at the facility.
including th types of chemicals and the total volumes present, and historically used, as data is
available. -&etltwnEFRI submitted a chemical inventory report on June 7, 2005, and submitted
additional related information on November 17, 2006.
Part I.H.1 requires that at the time of Permit renewal, the Permittee shall submit an updated
inventory report. Part I.E.9 requires that the -inventory address chemicals used in the milling
process and the on-site laboratory. The updated inventory report is provided in Appendix b-Q_of
this Application.
2.17.2 Southwest Hydrogeological Investigation
Part I.H.6 of the Permit required that DenisonEFRI perform a detailed Southwest Hydrogeologic
Investigation to define, demonstrate and characterize: 1) the hydraulic connection and lo al
groundwater flow directions between the area near Tailings Cell 4B, and the weslefffl-wcstem
margin of White Mesa, and 2) the full physical extent of the unsaturated area between former
well MW-16, MW-33 and the western margin of White Mesa.
During 2011, DenisonEFRI installed 18 piezometers to demon.stt:ate-define the geologic and
physical extent of the apparent unsaturated structural high between Tailings Cell 4B and the
western margin of White Mesa, and to demonstrate the location and direction of groundwater
flow paths between Tailings Cell 4B and Westwater and Cottonwood Seeps and Ruin Spring.
Consistent with Part I.H.6.c) of the Permit, DenisonEFRI submitted an investigation report, the
Hydrogeology of the Perched Groundwater Zone in the Area Southwest of the Tailings Cells,
White Mesa Uranium Mill Site (the "Southwest Hydrogeology Report"), prepared by Hydro
gGeo_ Chern, on January 12, 2012. The Director provided comments in a conference call during
May 2012, and in a letter dated May 30, 2012. In an additional conference call following
f)effison s receipt of the May 30 let.ffir Denison and lhe Di rector agreed thttl Denison would
86
• repeat slu2 testing of piezometer DR-08.
• recal ulate b d.raulic propcrtie. , and
• recalculate travel times if necessary based on new data.
from
No other infon:tUtfiea--has-been t:ipeeiftea.U.y-required by the DireeleF-to be iAeluded 1n IAts
AtlPiienLion at this Lime . DeAison wil l provide additioB£11 iAfoffl'HH.ion as ;ecji,•esLed by lhe
DH=eetor
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-6.3.R)
This Application has been performed under the direction, and bears the seal, of Harold R.
Roberts, E culive Vice Pre~ident and Chjef Operating Officer ExecutP.•e Vice President. US
Operatiorts of DeHisortEFRI. Mr. Roberts is a Registered Professional Engineer in the State of
Utah, No. 165838.
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent Ground
Water Contamination During the Closure and Post Closure Phases of Operation (R17 -6-6.3.8)
2.19.1 Regulatory Requirements for Uranium MiHs
2.19.1.1 Long Term Custodian
One unique feature of the regulatory scheme for uranium mill tailings is that Section 83 of the
Atomic Energy Act of 1954, as amended by the Uranium Mill Tailings Radiation Control Act of
1978 ("UMTRCA") (the Atomic Energy Act of 1954 as so amended is referred to herein as the
"AEA")4 requires that, prior to license termination, title to uranium mill tailings (11e.(2)
byproduct material) must be transferred to the United States Department of Energy ("DOE") or
the State in which the activity occurred, if the State so elects, for custody and long term care. 10
CFR 40.28 provides a general license to DOE or the State for that purpose.
2.19.1.2 Responsibility For And Manner Of Clean Up
UMTRCA amended the AEA to require that all Title II facilities (i.e., active mills) will-comply
with the decontamination, decommissioning, and reclamation standards prescribed by the
Commission5 and to require that such facilities post reclamation bonds or surety6.
4 See 42 U.S.C. 2113.
5 See 42 U.S.C. 2113.
6 See 42 U.S.C. 2201.
87
Responsibility for reclamation of Title ll fa ilitiesrests with the licensee. 10 CFR Part 40
Appendix A Criterion 6A requires the adoption of a Director-approved reclamation plan for the
site, Criterion 9 requires that financial surety must be established to fund the cost of reclamation
in accordance with such plan, and Criterion 10 requires that each licensee include in its financial
surety an amount equivalent to $250,000 (1978 dollars) to cover the costs of long-term
surveillance by the long-term government custodian (DOE). Criteria 6, 9 and 10 have been
incorporated by reference into the Utah rules by UAC R313-24-4.
2.19.1.3 Surface
The reclamation plan adopted by the Mill at the outset, as required by 10 CFR Part 40, Appendix
A, Criterion 9, flffiSt-addresses the decontamination and decommissioning of the Mill and Mill
iLe and reclamali.on of aay-tailing .. ar<m I oth r waste di .. po. al area .
As is the case for most uranium mills, the Mill's reclamation plan ~require~ that ... upon
closure, all mill buildings, unsalvageable equipment, contaminated soils (impacted by Mill
operations within the Mill site itself as well as surrounding areas that may be impacted by
windblown radioactive dusts from milling operations) etc. 'fl'lflSt-be deposited in the tailings cells
and the tailings cells capped in place.
Appendix A, Criterion 6(6) sets the standard for determining when all impacted areas, other than
the tailings impoundments have been adequately cleaned up. Criterion 6(6) provides that
byproduct material containing concentrations of radionuclides other than radium in soil, and
surface activity on remaining structures, must not result in a total effective dose equivalent
(TEDE) exceeding the dose from cleanup of radium contaminated soil to the benchmark standard
of 5pCi/g concentration of radium in the surface upper 15 em (6 in) of surface soils and 15 pCi/g
concentration of radium in the subsurface soils, and must be at levels which are ALARA. If
more than one residual radionuclide is present, the sum of the ratios for each radionuclide present
will not exceed "1" (unity). Further details on the NRC's approach to evaluating reclamation
plans and release criteria for uranium mill sites, including the manner of modeling the release
standard set out in Criterion 6(6), are contained in NUREG-1620, Rev 1, Standard Review Plan
for the Review of a Reclamation Plan for Mill Tailings Sites Under Title II of the Uranium Mill
Tailings Radiation Control Act of 1978, Final Report, June 2003 ("NUREG-1620").
2.19.1.4 Groundwater
Each uranium mill is required to have a groundwater monitoring program. In the case of the
Mill, the Permit implements the applicable requirements of U AC R317 -6. If there is
groundwater contamination after cessation of operations, the requirements of UAC R317-6.15
must be satisfied.
2.19.1.5 License Termination
Section 83.7 of the AEA7 provides that material and land transferred to the long term custodian
must be transferred without cost to the long-term custodian other than administrative and legal
7 See 42 U.S.C. 2113.
88
costs incurred in carrying out such transfer.
In order to cover the costs of long-term surveillance, Criterion 10 requires that a minimum
charge of $250,000 (1978 dollars) must be paid by each mill operator to the general treasury of
the United States or to an appropriate State agency prior to the termination of a uranium mill
license.
In most cases if there is a groundwater contamination problem, the problem must be remediated
prior to license termination, or an alternate corrective action concentration limit under R317 -6-
6.15.G must be ~htaineda hi ·ved l Htl L pr tecli e of pub lic h aJLh and the environmc.nt;-t-ker-eby
resolving the proelem. In some circumstances DOE may agree to take some additional actions
after it takes title to the site, such as additional monitoring, if not onerous and provided adequate
funding is provided.
Upon the Director and Lh NR being satisfied that all regulatory requirements have been met
and the site is reclaimed in a manner that satisfies all applicable standards, the Mill's license will
be terminated upon transfer of the tailings to DOE. 10 CFR 40.28 provides a general license in
favor of the long-term custodian for custody of and long-term care of the tailings impoundments
and any surrounding lands transferred to it. 8 The surrounding areas not transferred to DOE
would generally be free-released.
2.19.2 Current Redamation PJan
The Mill's Reclamation Plan, Revision 4-:G3.2B, was approved by DRC under the Mill License
ffi...-.Qn_January~ 2011. The Reclamation Plan sets out the requirements to be met by
DenisonEFRI for the final reclamation and closure of the Mill facility, including the tailings cells
and all impacted surrounding areas, in accordance with the requirements of 10 CFR Part 40,
Appendix A (which have since been incorporated by reference into UAC R313-24). A copy of
the Mill's Reclamation Plan, Revision 4.0 was previously submitted to the Director in November
2009 and is on file at the DRC.
8 In circumstances where the facility has a groundwater contamination plume, additional lands may be acquired by
the licensee in order to bound the plume. In these circumstances these additional lands would be transferred along
with the capped tailings impoundments, to DOE.
89
Reclamation Plan.
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan
The Mill License is currently in timely renewal. As part of the Mill License Renewal, DRC is
re-examining the Mill's Reclamation Plan for content and adequacy. At the time of original
issuance of the Permit .. the Director had not completed his review of the Mill's Reclamation
Plan. As a result, new requirements were added to the Permit to ensure that the final reclamation
design approved by the Director on his re-examination of the Reclamation Plan will provide
adequate performance criteria to protect local groundwater quality.
To this end, three requirements were included in Part I.D.8 of the Permit to ensure that the cover
system for each tailings cell will be designed and constructed to:
a) Minimize the infiltration of water into the radon barrier and underlying tailings waste;
b) Prevent the accumulation of leachates within the tailings that might create a bathtub
effect and thereby spill over the maximum elevation of the FML inside any disposal
cell; thereby causing a release of contaminants to the environment; and
c) Protect groundwater quality at the compliance monitoring wells by ensuring that
contaminant concentrations there do not exceed their respective GWQS or GWCL
defined in Part I.C.l and Table 2 of the Permit.
To provide consistency with the performance criteria stipulated by the Director at other lle.(2)
disposal operations, a 200-year minimum performance period was required for all three of these
criteria.
In addition, Part I.D.9 was included in the Permit, which provides that upon commencement of
decommissioning, DeaisoaEFRI will reclaim the Mill site and all related facilities, stabilize the
tailings cells, and construct a cover sy tern over the tailings cells in compliance with all
engineering design and specifications ~f Lh approved reclamation plan. Part I.D.7 also
provides that the Director reserves the right to require modifications to the Mill's Reclamation
Plan for purposes of compliance with the Utah Ground Water Quality Protection Regulations,
90
including but not limited to containment and control of contaminants, or discharges, or potential
discharges to waters of the State.
Finally, Part I.D.9 was added to the Permit to provide the Director an opportunity to ensure that:
a) The post-closure performance requirements for the tailings cell cover system in Part
I.D.8 is fully and adequately integrated into the Mill's Reclamation Plan. Part I.H.2
was also added to the Permit to require DenisonEFRI to complete an infiltration and
contaminant transport model of the final tailings cell cover system to demonstrate the
long-term ability of the cover to protect nearby groundwater quality. As a part of this
cover system performance modeling required by Part I.H.2, the Director will determine
if changes to the cover system are needed to ensure compliance with the Part I.D.8
performance criteria;
b) All other facility demolition and decommissioning activities outlined in the
Reclamation Plan will be done in a manner adequate to protect local groundwater
quality. Issues or concerns to be considered and resolved include:
(i) Identification, isolation, and authorized disposal of any un-used chemical reagents
held in storage at the Mill site at the time of closure;
(ii) Demolition, excavation, removal, and authorized disposal of all contaminated
man-made structures, including, but not limited to: buildings, pipes, power lines,
tanks, access roads, drain fields, leach fields, fly-ash disposal ponds, feedstock
storage areas, Mill site wastewater storage ponds, solid waste disposal landfills,
and all related appurtenances; and
(iii) Excavation, removal, and authorized disposal of all contaminated soils found
anywhere outside of the tailings cells at the facility.
Through this process, the Director will be able to ensure that DMT has been adequately
established for both the final tailings cell cover system and reclamation of the facility.
respon
91
2.19.4 Post-Operational Monitoring
Monitoring will continue under the Permit after cessation of operations, during reclamation and
after reclamation has been completed until such time as the Mill License and Permit are
terminated and the reclaimed tailings impoundments are transferred to the Department of Energy
for perpetual care and maintenance.
3.0 CONCLUSIONS
This Application describes the key monitoring and DMT performance standard requirements and
other protections contained in the Permit.
DeaisoaEFRI believes that with this Application, the accompanying Background Reports and
other documentation, the Director has been provided sufficient information to determine that:
a) DeaisoaEFRI has demonstrated that the applicable class TDS limits, ground water
quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) Defl:isoaEFRI utilizes treatment and discharge minimization technology at the Mill
commensurate with plant process design capability and similar or equivalent to that
utilized by facilities that produce similar products or services with similar production
process technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
DeaisoA would be pleased to provide at+y-fi.u'lber information re~H:te-9tf€€tef:.
92
4.0 SIGNATURE AND CERTIFICATIONS
By:
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Frank J. Filas
Vice Pt·-ident, Permilting and Envir ~
Vice Presideat, Regulatory Affairs arJ:d Geaeral Couasel
CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that the foregoing Application has been prepared under my direction, that I have
reviewed this Application, that I am familiar with the Mill facilities, and attest that this
Application has been prepared in accordance with good engineering practices.
Harold R. Roberts
93
Registered Professional Engineer
State of Utah No. 165838
(seal)
94
5.0 REFERENCES
American Society for Testing and Materials. 1996. Standards on Ground Water and Vadose
Investigations.
Dames & Moore. January 30, 1978. Environmental Report, White Mesa Uranium Project San
Juan County, Utah.
D' Appolonia Consulting Engineers, Inc. June 1979. Engineers Report: Tailings Management
System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. May 1981. Engineer's Report: Second Phase Design-
Cell3 Tailings Management System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. February 1982. Construction Report: Initial Phase-
Tailings Management System, White Mesa Uranium Project Blanding, Utah.
Division of Radiation Control, Utah. December 1, 2004. Statement of Basis For a Uranium
Milling Facility at White Mesa, South of Blanding, Utah, Owned and Operated by
International Uranium (USA) Corporation.
EFRI. August 2000. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -
Tailings Management System. Prepared by EFRI (formerly International Uranium (USA)
Corporation).
Energy Fuels Nuclear, Inc. March 1983. Construction Report: Second Phase Tailings
Management System, White Mesa Uranium Project.
Energy Fuels Nuclear, Inc. January 14, 2011. Revised Phase 2 QAP and Work Plan, Revision
2.0.
Energy Fuels Nuclear, Inc. July 12, 2011. Reclamatin Plan for the White Mesa Mill, Blanding,
Utah. Source material License No.SUA-1358 Docket No. 40-8681 Revision.
Environmental Protection Agency. March, 1991. Handbook of Suggested Practices for Design
and Installation of Ground-Water Monitoring Wells (EP N600/4-89/034 ).
Environmental Protection Agency. November, 1985. Practical Guide for Ground Water
Sampling (EPN600/2-85/104).
GeoSyntec Consultants. January 2006. Cell 4A Lining System Design Report For The White
Mesa Mill Blanding, Utah.
Geosyntec Consultants. July 2008. Cell 4A Construction Quality Assurance Report, White
Mesa Mill Blanding, Utah.
Geosyntec Consultants. November 2010. Construction Quality Assurance Report.
95
Geosyntec Consultants. December 8, 2012, -Cell4B Design Report, White Mesa Mill, Blanding
Utah
Hydro Geo Chern, Inc. 2001. Update to report: Investigation of Elevated chloroform
concentrations in Perched Groundwater at the White Mesa Uranium Mill Near Blanding,
Utah.
Hydro Geo Chern, Inc. August 29,2002. Letter Report.
H;tdro Gee Chem. lBe. A~:~gust 22, 2002. Hydraulic Tes1ing ut the 'f/hi~e Me·•e U~
Near Blandiag, Utah During July 2002.
F')'El·re Gee Chem. [.nc. August 29. 2002. LeHer Report.
Hydro Gee Ghem. Jne. Augusl3, 2005. Perched Me!titafi..flg Well lflsftd-1-aftet:t ancl Te·ltiAg at the
White Mesa Uraaium Mill April Throueh June 2005.
Hydro Geo Chern, Inc. August 20, 2007. Preliminary Corrective Action Plan, White Mesa Mill
Near Blanding, Utah.
Hydro Geo Chern, Inc. April 13, 2012. (2012a). Plan and Time Scheduler for Assessment of pH
Uner Groundwater Discharge Permit UGW370004.
Hydro Geo Chern, Inc. May 7, 2012. (2012b). Nitrate Corrective Plan.
Hydro Geo Chern, Inc. December 7, 2012. (2012c). Investigation of Pyrite in the Perched Zone,
White Mesa Uranium Mill, Blanding, Utah.
#)4=o Geo Chern lac. Nov~07 . Preliminary ContamiALUion l:nvestigution RepoF~
White Mesa Mill Near Blandiag, Utah.
~·o Geo Chern. Inc. Auom.t 27, 2009. Site Hydrogeology and &tifflation of Groundv.'ater
+f.a\·el Times In The Perched Zone While Mesa Urafti±tm Mill Site }-kar Bla:ndiAg UHtlr.
.f=J.ytlro Gee Chen1 1Ac. October H , 3010 Inslal lalion tlild H~·8:ra1:1lie Testing Elf Perched
Monitoring Well" MW 33, M\¥ 3'1 anEI M\¥ 35 at the Whft.e-Meso UntAium M iU Nett£
Blandiag Utah.
:Hydro Gee Chem,IR~er 12, 20 I 0 Hydrogee-logy of tf1e Perched Groundwater Zone
flfld .«.sseeiuted Seeps ar1d Spring5 Near L-Re Wltite Me~iQ lh-aaium MHl Sile. Slalll#Ag
tJ.t.a!:t:
~eo Cf:lem h'le. Jtme 28, 20 I 1 I11stal~ und Hydraul ic Testing of PerchecJ-Menitering
We!.Jt;-MW 36 HAd MW 37 itt the Whi te Me:ou Unmffim....M.H.I Near BlaHEI-ing Uralr.
96
Hydro Geo Chern, Inc. May 8, 2012June 6, 2014 8-ae-Hydrogeology ilfl:d EstimatioB of
GrouBdvlater Tra'rel Times iB the Perehed ZoBeof the White Mesa Uranium Mill Site
Near Blanding, Utah.
INTERA, Inc. October 2007. (2007a). Revised Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. November 16, 2007. (2007b). Revised Addendum:--Evaluation of Available Pre-
Operational and Regional Background Data, Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. April 30, 2008. Revised Addendum: --Background Groundwater Quality Report:
New Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County,
Utah.
INTERA, Inc. December 30, 2009 Nitrate Contamination Investigation Report White Mesa
Uranium Mill Site Blanding, Utah.
INTERA, Inc. June 1, 2010 Background Groundwater Quality Report for Wells MW-20 and
MW-22 for Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County,
Utah:.':';"
INTERA, Inc. May 11, 2011. Revised Phase 1 (A through C) Work Plan and Schedule for Phase
1 A - C Investigation.
INTERA, Inc. June 3, 2011. Revised Phase 2 through 5 Work Plan and Schedule.
INTERA, Inc. October 10, 2012. Source Assessment Report, White Mesa Uranium Mill,
Blanding Utah:.INTERA, Inc. November 9, 2012. pH Report White Mesa Uranium Mill,
Blanding Utah:.,
INTERA, Inc. May 7, 2013. Source Assessment Report for TDS in MW-29, White Mesa
Uranium Mill, Blanding Utah.
INTERA, Inc. August 30, 2013.Source Assessment Report for Selenium in MW-31, White Mesa
Uranium Mill, Blanding Utah.
INTERA, Inc. December 17, 2013. Source Assessment Report for Tetrahydrofuran in MW-01,
White Mesa Uranium Mill, Blanding, Utah.
97
INTERA, Inc. January 13, 2014. Source Assessment Report for Gross Alpha in MW-32, White
Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. March 19, 2014. Source Assessment Report for Sulfate in MW-01 and TDS in
MW-03A, White Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. May 1, 2014. Background Groundwater Quality Report for Wells MW-35, MW-
36 and MW-37 for Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
Kirby. 2008. Geologic and Hydrologic Characterization of the Dakota-Burro Canyon Aquifer
Near Blanding, San Juan County, Utah. Utah Geological Survey Special Study 123.
Knight-Piesold LLC. November 23, 1998. Evaluation of Potential for Tailings Cell Discharge
-White Mesa Mill.
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