DRC-2015-001267 - 0901a068804e33cc

January 27, 2015
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
DRC-2015-001267
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 4th Quarter of 2014
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell 4A
BAT Performance Standards Monitoring Report for the 4th Quarter of 2014, as required under Parts
I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
Yours ver~ul~, //
'{ad:lfo~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
4th Quarter
October through December
2014
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
January 27,2015
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... l
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED ....................................................... !
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING .................................. 2
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING ...................................................... 3
4 .1 GENERAL .............................................................................................................................................. .-.... , .. 3
4 .2 RESULTS FOR THE QUARTER .............................................................................................................. .-....•.. , .. 4
4 ,3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION .................................................................. , . .4
4.4 GRAPHIC COMPARISON TO PREVIOUS YEAR ..................................................... , .............. , ......................... , . .4
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ........................................... .4
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS OF
FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE AREA ................. 5
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ................................................................ 5
8.0 DECONTAMINATION PADS .................................................................................................................... 6
8.1 SUMMARY OF WEEKLY INSPECTIONS ........................................................................................................... 6
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ....................................................................... 7
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................. ., .............................. 7
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT ......................................... 7
9.1 LDS MONITORING ........................................................................................................................................ 7
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ........................................................... 7
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML ................................... 8
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS ................................................................. 9
9.2 MEASUREMENTOFWEEKLYWASTEWATER FLUIDS IN CELLS 4AAND4B ................................................. 10
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... lO
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING ......................................................................... 10
10.1 OPERATIONAL STATUS OF LDS PUMPING AND MONITORING EQUIPMENT ................................................. 10
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ....................................................... 11
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1, 2, AND 3 ................................................. 11
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... 11
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2014 .. 11
11.1 INDIVIDUAL SLIMES DRAIN RECOVERY HEAD FOR 2014 ............................................................................ 11
11.2 AVERAGE SLIMES DRAIN RECOVERY HEAD FOR 2014 ............................................................................... 12
11.3 TIME SERIES CHART ................................................................................................................................... 12
11.4 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION ................................... : .. : ................... : ........ 12
11.4.1 Permit Requirements ......................................................................................................................... 12
11.4.2 Demonstration of Compliance with Permit Requirements ................................................................ 12
12.0 QUARTERLY PRECIPITATION DATA ................................................................................................ 13
13.0 SIGNATURE AND CERTIFICATION .................................................................................................... 14
LIST OF TABLES
Table 1 -Summary of Waste Water Pool Elevations (In the Text)
Table 2-New Decontamination Pad Inspection Portal Level (In the Text)
Table 3-SDRE Data to be Used for Certain Years (Attachment C)
Table 4-SDRE Data Values to be Used for 2014 (Attachment C)
Table 5-Cell2 Slimes Drain Recovery Head and SDRE Values for 2014 (Attachment C)
Table 6-Cell 2 Slimes Drain Recovery Head and SDRE Values for 2013 (Attachment C)
Table 7-Cell2 Slimes Drain Recovery Head and SDRE Values for 2012 (Attachment C)
Table 8-Cell 2 Slimes Drain Recovery Head and SDRE Values for 2011 (Attachment C)
Table 9-Equation 1 Values (Attachment C)
Table 10-SDRE Compliance Calculations (Attachment C)
ATTACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to Part I.G.3 of the GWDP
C Quarterly Cell2 Slimes Drain Monitoring Data
D Graph of Cell 2 Slimes Drain Water Levels Over Time
E Cell Liner Repair Reports and Notices
F Ce114A and Cell4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables 1A and 1B, Cell4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.12)
H Weekly Feedstock Inspection Form-Feedstock Maps
I Quarterly Precipitation Data
11
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 4th QUARTER OF 2014
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the fourth quarter of 2014 (the "quarter") prepared by Energy Fuels
Resources (USA) Inc. ("EFRI"), as required under Part I.F.2 of the White Mesa Mill's (the
"Mill's") State of Utah Groundwater Discharge Permit No. UGW370004 (the "GWDP"), and the
Routine Cell 4A and Cell 4B Best Available Technology ("BAT") Performance Standards
Monitoring Reports for the quarter, as required under Part I.F.3 of the GWDP.
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED
During the quruter, the following DMT monitoring was performed or addressed, as required
under Part I.D.3, I.E.7, and I.F.ll of the GWDP:
• Weekly tailings wastewater pool elevations for tailings Cells 1 and 3 (Part
I.E.7(a));
• Quarterly slimes drain water levels in Cell2 (Part I.D.3(b)(l) and (2));
• Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.ll);
• Weekly wastewater level measurements in Roberts Pond (Part I.D.3(e) and Part
I.E.7(c));
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part I.D.3(f) and Parts I.E.?( d); and
(e));
• Any tailings cell and pond liner system repairs (Part I.E.7 (f) and Part I.E.(8)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g)) and
• Annual Decontamination Pad Concrete Inspection (Part I.F.11) (not required this
reporting period)
Also during the quarter, the following Cell 4A and 4B BAT performance standards monitoring
was performed, or addressed, as applicable and as required by Parts I.E.8 and I.E.12 of the
GWDP:
• Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.8.(a)), and Cell
4B (Part I.E.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.8 (a))
and Cell4B (Part I.E.12 (a)).
Attachments B, E, and G have been left blank because there were no notices, liner repair reports
or decontamination pad inspections this quarter.
1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in the Mill's tailings
cells during this quarter, to ensure compliance with the maximum wastewater elevation criteria
mandated by Patts I.E.7(a), I.E.8(a) and I.E.12(a) of the GWDP. The results of such
monitoring, reported as feet above mean sea level ("fmsl"), are included in Attachment A. Part
I.D.2 of the GWDP provides that under no circumstances shall the freeboard of any tailings cell
be less than three feet, as measured from the top of the flexible membrane liner ("FML"). The
top of the FML in Cell 1 is at 5,618.5 fmsl, and the top of the FML in Cell 4B is 5600.4 fmsl.
This means that the maximum wastewater pool elevations in Cells 1 and 4B permitted under Part
I.D.2 of the GWDP are 5,615.50, and 5597.40 fmsl, respectively.
The maximum wastewater pool elevations in Cells 1 and 4B, as measured during the quarter, are
summarized in the following Table 1. The requirements to meet freeboard elevation limits in
Cell 3 and Cell 4A were eliminated. The solution elevation measurements in Cell 4A are not
required for compliance with freeboard limits but are required for the calculation of the daily
allowable volume of fluids pumped from Cell 4A LDS and are collected for this purpose. The
freeboard limits established by the GWDP and the Mill's State of Utah Radioactive Materials
License No. UT 1900479 (the "License") are slightly different; accordingly, the stricter of the
two limits represents the regulatory standard for each cell. As indicated in Table 1, the applicable
freeboard limits were not exceeded during the Quarter for any cell.
Table 1 -Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measured During the Permitted Under Elevation Permitted
Quarter (fmsl) License Condition Under Part I.D.2 of
10.3 (fms1) the GWDP (fmsl)
Cell1 5612.48 5,615.40 5,615.50
Cel13 Not Measured-No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in Q 1 2011
Cell4A 5589.90-freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Ql 2011.
Ce114B 5583.30 5594.60 5597.40
*The Director approved the removal of the Ce113 freeboard hffilt and authonzed the use ofCell4B on January 27,
2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
**The Director granted a variance from the Cell 4A freeboard limit on January 13, 2011, and approved the removal
of the Cell 4A limit and authorized the use of Cell 4B on January 27, 2011. The previous freeboard limit noted
above for Cell 4A was not set out in the License. The freeboard limit of 5,593.74 for Cell 4A was set out in a letter
from the Director dated November 20, 2008. The approved DMT Plan, Revision 11.1 dated January 2011, included
the removal of the freeboard limit for Ce114A to be replaced by a freeboard limit for Cell 4B that will accommodate
the freeboard requirements of Cells 1, 4A, and 4B.
2
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b )(1) of the GWDP provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the DMT Plan. Part I.D.3(b)(3) of the GWDP
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Part I.D.6(c) of the GWDP provides that, after the Permittee initiates pumping conditions in the
slimes drain layer in Cell 4A, the Permittee will provide: 1) continuous declining fluid heads in
the slimes drain layer, in a manner equivalent to the requirements found in Part I.D.3(b), and 2) a
maximum head of 1.0 feet in the tailings (as measured from the lowest point of the upper FML)
in 6.4 years or less. Similarly, Part I.D.13(c) of the GWDP provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4B, the Permittee will provide: 1)
continuous declining fluid heads in the slimes drain layer in a manner equivalent to the
requirements found in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as
measured from the lowest point of the upper FML) in 5.5 years or less.
The GWDP, dated July 14, 2011, Part I.D.3 (b)(2) states "effective July 11, 2011, the Permittee
shall conduct a qua1terly slimes drain recovery test...". Monthly testing was conducted through
the second quarter of 2011. The frequency change dictated by the GWDP was implemented in
the third quarter 2011. The test ensures that each tailings cell meets the following minimum
requirements: 1) includes a duration of at least 90-hours, as measured from the time that
pumping ceases, and 2) achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements with no change in water level, as measured
to the nearest 0.01 foot.
At this time, dewatering operations have not commenced in Cell 3, Cell 4A, or Cell 4B. As a
result, the requirements in Part I.E.7(b) to monitor and record monthly the depth to wastewater in
the slimes drain access pipes as described in Part I.D.3 of the GWDP apply only to Cell 2 at this
time. Accordingly, this Report is limited to slimes drain recovery head information relating to
Cell2 only.
Pursuant to Parts I.E.7(b) and I.F.2 of the GWDP, Section 8.2 of the DMT Plan and
correspondence from DRC, dated February 7, 2008, the results of quarterly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Peiformance Standards Monitoring Report
and Cell 4A and Cell 4B BAT Performance Standards Monitoring Reports (the "DMT Reports").
Further, beginning in 2008, quarterly DMT Reports must include both the current year values
and a graphic comparison to the previous year. The annual slimes drain recovery head report for
2014, which addresses the requirements of Part I.F.11 of the GWDP and Section 8.2 of the DMT
Plan, are included in Section 11.0 and in Attachment C.
3
4.2 Results for the Quarter
In accordance with the requirements described above, the quarterly slimes drain recovery head
monitoring data for the quarter, which includes the date and time for the start and end of the
recovery test, the initial water level, and the final depth to stable water level for the quarter, are
included as Attachment C to this Report.
On November 23, 2014, the Mill experienced a power outage resulting from high winds (in
excess of 60+ mph) in the area. During the power outage the Cell 2 slimes drain ceased
pumping. Power was partially restored to portions of the Mill on November 23, 2014 and power
was fully restored to the entire Mill facility by 7:00 AM November 24, 2014. Pumping of the
Cell 2 slimes was restored within 24-hours of discovery. No official notifications to DRC were
required as the issue was rectified within 24-hours. DRC was notified by telephone that the issue
was resolved within the 24-hour window and no further actions were necessary.
4.3 Quality Assurance Evaluation and Data Validation
EFRI management has evaluated all slimes drain data collected, data collection methods, and all
related calculations required by the GWDP, and have verified the accuracy and reliability of both
the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, EFRI has concluded
that the 2009, and 2010 monthly slimes drain tailings fluid elevation measurements, the 2011
monthly (through June) and quarterly (July forward), and the quarterly 2012, 2013, and 2014
slimes drain tailings fluid elevation measurements to date meet the test performance standards
found in Part I.D.3(b)(2) of the GWDP and can be used for purposes of determining compliance
with the requirements of Part I.D.3(b)(2) of the GWDP.
4.4 Graphic Comparison to Previous Year
A graph showing the final depth to stable water level readings for 2009 through the current 2014
period is included as Attachment D.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
When fluid is present, Mill personnel are required to monitor and record weekly the wastewater
levels at Roberts Pond to determine compliance with the DMT operations standards in Part
I.D.3(e) of the GWDP. Part I.D.3(e) of the GWDP provides that the water level in Roberts Pond
shall not exceed an elevation of 5,624 fmsl.
During the quarter, Robert's Pond was dry. As noted in the first quarter 2014 DMT report,
submitted on May 13, 2014, damage in the FML of Roberts Pond was identified during routine
operations, apart from routine inspections. As a result of the FML damage, no fluids have been
added to Roberts Pond since the first quarter of 2014.
4
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Depmtment, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the GWDP and that all alternate feedstock located outside the defined
feedstock area is maintained in compliance with the requirements of Part I.D.ll of the
GWDP. The results of these inspections are recorded on the Weekly Mill Inspection forms,
which are available at the Mill for inspection.
In the closeout letter for the first quarter 2013 DMT Report, dated July 23, 2013, DRC wrote
"EFRI noted standing water in one of the feedstock storage areas. Language in the report referred
to the standing water as a "small amount." The DRC requests that in future quarterly reports,
EFRI be more complete in quantifying and describing the location of standing water discovered
in feedstock storage areas." To comply with this request, EFRI has attached the Feedstock
Storage Area Maps ("Feedstock Maps") completed during the weekly Feedstock Storage Area
inspections as Attachment H. The Feedstock Maps include the areal extent (in feet) and depth
(in inches) of any standing water noted during the weekly inspections. During the quarter,
standing water was noted during the weekly inspections of October 2, October 10, December 19,
December 24, and December 31. Standing water noted was the result of precipitation received
during the reporting period.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, 3, 4A, and 4B were inspected on a daily basis. The results of
those inspections are recorded on the Mill's Daily Inspection Data sheets, which are available at
the Mill for review. The results of those inspections are recorded on the Weekly Mill Inspection
forms, which are available at the Mill for review.
Mill operations notified the EFRI Quality Assurance Manager on Thursday, March 13, 2014, of
a tear in the FML of Robetts Pond. The damage in the FML of Roberts Pond was identified,
during routine operations, apart from routine inspections. EFRI provided initial notification to
the DRC by telephone at approximately 2:45pm on Thursday, March 13, 2014, as contemplated
by Parts I.E.7 f) and I.G.3 of the Permit. Additionally, EFRI provided 5-day written notification
to DRC contemplated by Parts I.E.7 f) and I.G.3 of the Permit on March 18, 2014.
An Action Plan was submitted to DRC on May 12, 2014 and DRC approval was received by
letter dated June 16, 2014. EFRI started implementing the Action Plan on July 14, 2014. In
summary, the Roberts Pond Liner System will be removed. The soils underneath the liner will
be visually inspected for staining or other indications that they were impacted by the solutions.
Visually stained soils will be removed. Following the removal of the stained soils, cleanup
procedures will be completed to the levels specified in the Action Plan.
5
Implementation of the Action Plan has progressed during the quarter. Confirmation sampling as
specified in the Action Plan was completed during the quarter. A separate report detailing the
cleanup activities and the associated confirmation data will be submitted to DRC under separate
cover.
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Inspections
Part I.F.7 (g) of the GWDP and Section 3.1 of the DMT Plan require that a weekly inspection of
the New Decontamination Pad be performed, and that the vertical inspection portals on the New
Decontamination Pad, which are located between the primary and secondary containments, be
visually observed on a weekly basis as a means of detecting any leakage from the primary
containment into the void between the primary and secondary containments. The BAT
performance standards for the New Decontamination Pad are set out in Pmt I.D.14 of the
GWDP. Table 2 below indicates the water level measurements in each portal measured during
the quarter.
Table 2 -New Decontamination Pad Inspection Portal Level for the Quarter
Portal 1 Porta12 Portal3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
10/2/2014 0.00 0.00 0.00
10/9/2014 0.00 0.00 0.00
10/16/2014 0.00 0.00 0.00
10/23/2014 0.00 0.00 0.00
10/30/2014 0.00 0.00 0.00
11/6/2014 0.00 0.00 0.00
11113/2014 0.00 0.00 0.00
11120/2014 0.00 0.00 0.00
11126/2014 0.00 0.00 0.00
12/4/2014 0.00 0.00 0.00
12/1112014 0.00 0.00 0.00
12118/2014 0.00 0.00 0.00
12/24/2014 0.00 0.00 0.00
12/3112014 0.00 0.00 0.00
As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the quarter.
Any soil and debris identified during the weekly inspections was removed from the wash pad of
the New Decontamination Pad, in accordance with part I.D.14 (a) of the GWDP and Section 3.1
(e)(i)(F) of the DMT Plan. No cracks greater than 1/8" were observed during any weekly
inspections.
6
8.2 Annual Inspection of Existing Decontamination Pad
As required by Part I.F.12 of the Permit, annual inspections of the existing decontamination pad
must be conducted during the second quarter of each year. The documentation for the 2014
annual inspections was reported in the Second Quarter DMT report submitted July 22, 2014. The
2015 annual inspection will be conducted during the second quarter of 2015.
8.3 Annual Inspection of New Decontamination Pad
Annual inspections of the new decontamination pad are conducted during the second quarter of
each year. The documentation for the annual inspections was reported in the Second Quarter
DMT report submitted July 22, 2014. The 2015 annual inspection will be conducted during the
second quarter of 2015.
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report for the quarter, as required under Part I.F.3 of the GWDP.
9.1 LDS Monitoring
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for both of Cell 4A and Cell 4B, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment,
operated continuously during the quarter except as noted below.
Ce114A
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.8(a)(l) of the GWDP.
During the quarter there were two failures of the Cell 4A monitoring equipment which were
made operational within 24-hours of discovery, as required by Part I.E.8(a)(l) for Cell4A.
On October 13, 2014 Mill Personnel noted that the transducer was not recording fluid head
measurements. Based on the daily fluid level measurements recorded by the Mill Personnel
manually, no gallons of fluid were pumped and no data were lost. The equipment was reset
within several hours of noticing the malfunction, and full function was restored. No notifications
to DRC were required as the issue was rectified within 24-hours as required by Part I.E.8(a)(l)
for Cell 4A. It is important to note that these periodic malfunctions of the equipment are due to
the super-saturated nature of the fluids in the LDS system, which crystallize on the electronic
components and cause the components to malfunction and/or fail prematurely. EFRI inspects the
equipment daily to preclude data loss and maintains spare parts to replace the components on an
as needed basis.
7
As previously noted, on November 23, 2014, the Mill experienced a power outage resulting from
high winds (in excess of 60+ mph) in the area. During the power outage the Cell4A monitoring
equipment was not operating. Power was partially restored to portions of the Mill on November
23, 2014 and power was fully restored to the entire Mill facility by 7:00 AM November 24,
2014. Full functionality of the Cell 4A monitoring equipment was restored within 24-hours of
discovery. No official notifications to DRC required by Part I.E.8(a)(1) were completed because
the issue was rectified within 24-hours. EFRI informed DRC by telephone that the issue was
resolved within the 24-hour window and no further actions were necessary.
Cell 4B
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.12(a)(l) of the GWDP.
During the quarter there were two failures of the Cell 4B monitoring equipment which were
made operational within 24-hours of discovery, as required by Part I.E.12(a)(l) for Cell4B.
As previously noted, on November 23, 2014, the Mill experienced a power outage resulting from
high winds (in excess of 60+ mph) in the area. During the power outage the Cell4B monitoring
equipment was not operating. Power was partially restored to portions of the Mill on November
23, 2014 and power was fully restored to the entire Mill facility by 7:00 AM November 24,
2014. Full functionality of the Cell 4B monitoring equipment was restored within 24-hours of
discovery. No official notifications to DRC required by Part I.E.8(a)(1) were completed because
the issue was rectified within 24-hours. EFRI informed DRC by telephone that the issue was
resolved within the 24-hour window and no fmther actions were necessary.
On November 25, 2014 Mill Personnel noted that the Cell 4B LDS was pumping, but the flow
meter was malfunctioning and was not recording the volume of fluid pumped from the LDS.
The flow meter was reset immediately upon noticing the malfunction. Full function was
restored, however, the volume of fluid pumped was not recovered. The LDS system was
correctly reporting and recording the LDS fluid head in the sump and no loss of fluid head data
resulted from the flow meter malfunction. The flow meter malfunction was likely caused by the
power outage noted above. Upon review of the fluid head data, EFRI noted that the pumping
was completed when the fluid levels in the LDS reached the trigger level and there was no
exceedance of the fluid head criteria in Section 9 .1.2 noted below. The malfunction only
resulted in the loss of gallons pumped. EFRI estimated the fluid volume pumped based on the
average number of gallons pumped during the quarter and added the estimated volume to the
quarterly total. The estimated gallons pumped are shown in Attachment F. No official
notifications to DRC were required as the issue was rectified within 24-hours of discovery as
required by Part I.E.l2(a)(l) for Cell4B.
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML
The measurements of the fluid head above the lowest point in the secondary FML for Cells 4A
and 4B are provided in Attachment F.
8
As can be seen from a review of Attachment F, at no point in the quarter did the fluid head in the
Cell 4A LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring, this 1-foot distance equates to 2.28 feet
[27.36 inches] above the LDS system transducer), as stipulated by Part I.E.8(a)(2) of the GWDP.
During the quarter, the fluid head in the Cell4A LDS sump did not exceed 14.4 inches above the
LDS transducer.
As can be seen from a review of Attachment F, at no point in the quarter did the fluid head in the
Cell 4B LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor, as stipulated by Part I.E.12(a)(2) of the GWDP. For the purposes of compliance
monitoring, this 1-foot distance equates to 2.25 feet (27 inches) above the LDS system. During
the quarter, the fluid head in the Cell 4B LDS sump did not exceed 14.75 inches above the LDS
transducer.
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS
The measurements of the volume of fluids pumped are provided in Attachment F.
Cell4A
As can be seen from a review of Attachment F, 11,689 gallons of fluid were pumped from the
Cell 4A LDS for the quarter. Accordingly, the average daily LDS flow volume in Cell 4A did
not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the GWDP.
The daily allowable volume of fluids pumped from the Cell 4A LDS have also been calculated
based on weekly tailings cell fluid measurements using the calculations provided in the Cell 4A
BAT Operations and Maintenance Plan. A letter from the Director dated January 27, 2011 that
approved the use of Cell4B, and a subsequent letter dated March 15, 2011, stated approval of the
DMT and Cell 4A O&M Plans, which effectively eliminated the former freeboard elevation
requirements for tailings Cell 4A. Pursuant to the receipt of the March 15, 2011 letter, freeboard
limits in Cell 4A were no longer required. However, the weekly wastewater elevations are
documented in order to calculate the maximum daily allowable flow volume, in accordance with
the Cell 4A BAT Operations and Maintenance Plan. Based on the wastewater pool elevation
surveys conducted during the quarter, and the maximum head recorded on the FML during the
quarter of 34.35 feet, the allowable flow rate would be approximately 587.5 gallons/acre/day
(23,500 gallons/day for the cell), as determined by Table 1A of the Mill's Cell 4A and 4B BAT
Operations and Maintenance Plan, and assuming a liner elevation of 5555.55 feet and
approximately 39.32 acres of liquid area. The average daily flow volume in Cell 4A did not
exceed the calculated flow volume of 23,101 gallons/day. As mentioned above, a total of 11,689
gallons of fluid were pumped from the Cell 4A LDS during the quarter and did not exceed the
calculated maximum allowable daily flow volume. The allowable flow rate calculation for the
quarter for Cell 4A along with Table 1A is included in Attachment F of this report.
Cell4B
As can be seen from a review of Attachment F, 80,300 gallons of fluid were pumped from the
Cell4B LDS for the quarter. The average daily LDS flow volume in Cell4B did not exceed the
9
26,145 gallons/day limit, as stipulated by Part l.E.12(a)(3) of the GWDP.
Based on the wastewater pool elevation surveys conducted during the quarter, the maximum
head recorded on the FML during the quarter was 25.80 feet. The allowable flow rate would
therefore be approximately 475.6 gallons/acre/day (17,079 gallons/day for the cell), as
determined by Table 1B of the Mill's Cell 4A and 4B BAT Operations and Maintenance Plan,
and assuming a liner elevation of 5557.5 feet and approximately 35.91 acres of liquid area. The
average daily flow volume in Cell 4B did not exceed the calculated flow volume of 17,079
gallons/day based on the calculations (i.e. weekly gallons pumped divided by 7 days) in the
approved DMT Plan Section 3.1a). The allowable flow rate and average daily flow rate
calculations for the quarter for Cell 4B are included along with Table 1B in Attachment F of this
report.
9.2 Measurement of Weekly Wastewater Fluids in Cells 4A and 4B
Weekly fluid elevations for Cells 4A and 4B for the quarter are provided in Attachment A along
with elevations for Cell 1.
9.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping of the Cell4A or Cell4B slimes drain systems at this time,
monthly recovery head tests and fluid level measurements are not required at this time pursuant
to Part I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING
The requirement in Section 3.1(a) of the DMT Plan to monitor the LDS for Cells 1, 2, and 3 is a
requirement of the License, and not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP. However, DRC has requested that the LDS monitoring for Cells 1,
2, and 3 be included on the DMT inspection forms and that the results of the monitoring be
reported in the quarterly DMT reports. The Cells 1, 2, and 3 LDS monitoring data are included
in Attachment F.
10.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 1, Cell 2, and Cell 3, including,
but not limited to, the submersible pump, pump controller, head monitoring, and flow meter
equipment, operated continuously during the quarter except as noted below.
As previously noted, on November 23, 2014, the Mill experienced a power outage resulting from
high winds (in excess of 60+ mph) in the area. During the power outage the Cell 1, 2, and 3
monitoring equipment was not operating. Power was partially restored to portions of the Mill on
November 23, 2014 and power was fully restored to the entire Mill facility by 7:00 AM
November 24, 2014. Full functionality of the Cell 1, 2, and 3 monitoring equipment was
restored within 24-hours of discovery. No official notifications to DRC required by Part
I.E.8(a)(l) were completed because the issue was rectified within 24-hours. EFRI informed
10
DRC by telephone that the issue was resolved within the 24-hour window and no further actions
were necessary.
For Cell 1, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 2, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 3, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
10.2 Measurement of the Volume of Fluids Pumped from the LDS
No fluids were pumped from the Cells 1, 2 or 3 LDSs during the quarter because no fluids were
detected in the Cells 1, 2 or Cell 3 LDSs.
10.3 Measurement of Weekly Wastewater Fluids in Cells 1, 2, and 3
A summary of the fluid elevations for the Cells 1, 2 and 3 LDSs for the quarter are provided in
Attachment F. The LDS for Cells 1, 2, and 3 were dry during the quarter.
10.4 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping in the Cell 1 or Cell 3 slimes drain system at this time,
monthly recovery head tests and fluid level measurements are not required at this time.
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2014
This section constitutes the annual slimes drain recovery head repott for calendar year 2014, as
required under Parts I.D.3 (b) and I.F.11 of the Permit and Section 8.2 of the DMT Plan.
11.1 Individual Slimes Drain Recovery Head for 2014
The individual slimes drain recovery head monitoring data for calendar year 2014, which
includes the date and time for the start and end of the recovery test, the initial water level, and
the final depth to stable water level, is included as Attachment C to this Report. The equivalent
recovery water level elevation is determined by subtracting the final depth to stable water
measurement (as recorded on the sheets in Attachment C) from the elevation of the measuring
11
point. Hereafter, the water level measurements are referred to as the slimes drain recovery
elevations ("SDRE").
11.2 Average Slimes Drain Recovery Head for 2014
The slimes drain recovery head for Cell2 for calendar years 2011, 2012, 2013, and 2014 are
shown in Tables 5, 6, 7, and 8 in Attachment C.
11.3 Time Series Chart
Included in Attachment Dis a time series chart that shows trends in the monthly recovery water
level elevations in the Cell 2 slimes drain over time, using data that meet the test performance
standards found in Part I.D.3(b )(2) of the Permit. See Section 11.4 below.
11.4 Quality Assurance Evaluation and Data Validation
EFRI has evaluated all data collected, data collection methods, and all related calculations
required by the Permit, and has verified the accuracy and reliability of both the data and
calculations repmted. As a result of its quality assurance evaluation and data validation review,
EFRI has concluded that the 2009, 2010, 2011, 2012, 2013, and 2014 monthly slimes drain
tailings fluid elevation measurements meet the test performance standards found in Part
I.D.3(b)(2) of the Permit and can be used for purposes of determining compliance with the
requirements of Part I.D.3(b)(2) of the Permit. While the 2009 and 2010 data are not used for
the calendar year 2014 calculations, the quality assurance evaluation and data validation are
included here for completeness.
11.4.1 Permit Requirements
Part I.D.3 of the Permit provides that annual slimes drain compliance shall be achieved when the
average annual wastewater recovery elevation in the slimes drain access pipe, as determined
pursuant to the DMT Plan, meets the conditions in Equation 1 in the GWDP and in Attachment
C.
Part I.D.3 provides that failure to satisfy conditions in Equation 1 shall constitute DMT failure
and non-compliance with the Permit, and that for Cell 3, this requirement shall apply after
initiation of de-watering operations.
11.4.2 Demonstration of Compliance with Permit Requirements
The SDRE values that meet the test performance standards found in Part I.D.3(b )(2), reported in
units of FMSL are shown in Attachment C. The calculations used to determine compliance with
the Permit requirements are also shown in Attachment C.
Based on the calculations in Attachment C, the annual slimes drain compliance has been
achieved for Cell 2 in 2014, in accordance with Part I.D.3 of the Permit.
12
12.0 Quarterly Precipitation Data
Pursuant to a verbal request from DRC personnel, EFRI is providing the quarterly precipitation
data in the quarterly DMT reports. The data are collected at the Mill, by the EFRI Field Staff,
using an on-site rain gauge. The data are included as Attachment I to this report.
13
13.0 SIGNATURE AND CERTIFICATION
This document was prepared by Energy Fuels Resources (USA) Inc. on January 27, 2015.
Energy Fuels Resources (USA) Inc.
Scott A. Bakken
Director, Permitting and Environmental Affairs
14
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Scott A. Bakken
Director, Permitting and Environmental Affairs
Energy Fuels Resources (USA) Inc.
15
Attachment A
Date Celll Cell3 1 Cell4A 2 Cell4B 3 Roberts Pond
Freeboard 5615.40-RML 5593.74-RML 5594.60 -RML
Limit 5615.50-GWDP 5595.50-GWDP 5597.40-GWDP 5624.00 -GWDP
10/3/2014 5612.48 No Longer Required 5589.90 5583.30 DRY
10/9/2014 5612.41 No Longer Required 5589.83 5583.23 DRY
10/16/2014 5612.33 No Longer Required 5589.77 5583.09 DRY
10/23/2014 5612.30 No Longer Required 5589.76 5583.02 DRY
10/30/2014 5612.23 No Longer Required 5589.68 5582.88 DRY
1116/2014 5612.20 No Longer Required 5589.65 5582.83 DRY
11/16/2014 5612.20 No Longer Required 5589.65 5582.83 DRY
11120/2014 5612.19 No Longer Required 5589.61 5582.75 DRY
11126/2014 5612.16 No Longer Required 5589.60 5582.67 DRY
12/4/2014 5612.15 No Longer Required 5589.65 5582.72 DRY
12/1112014 5612.15 No Longer Required 5589.73 5582.68 DRY
12/18/2014 5612.17 No Longer Required 5589.82 5582.75 DRY
12/24/2014 5612.17 No Longer Required 5589.82 5582.73 DRY
12/3112014 5612.17 No Longer Required 5589.80 5582.63 DRY
1Cell 3 is nearly full of solids, and is undergoing pre-closure steps. The freeboard limit is no longer required and the weekly measurements are no
longer required per the January 27 and March 14, 2011letters from DRC.
2 The previous freeboard limit of 5,593.74 for Cell4A is set out in a letter from the Director dated November 20, 2008. EFRI proposed in the DMT
Plan revision dated November 12, 2010 the removal of the freeboard limit for Cell4A to be replaced by a freeboard limit for new Cell4B that will
accommodate the freeboard requirements of Cells 2, 3, 4A, and 4B. The Director granted a variance from the Ce114A freeboard limit on January 13,
2011 and approved the removal of the Cell4A limit and the use of Cell4B on January 27, 2011. The weekly measurements are no longer required for
compliance with freeboard limts, but are required for the calculation of the daily allowable volume of fluids pumped from the Cell4A LDS .
3 The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A pool surface area of 40 acres is used
because there are no beaches present in Cell 4B at this time.
Attachment B
This attachment has been deliberately left blank.
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 3/14/2014 -3/20/2014
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
3/14/14 3/15/14 3/16/14 3/17/14 3/18/14 3/19/14 3/20/14
700 35.28 24.51 23.73 23.52 23.05
800 34.01 24.45 23.72 23.51 23.00
900 33.07 24.37 23.70 23.49 23.00
1000 32.24 24.31 23.68 23.47 23.00
1100 31.73 24.24 23.67 23.47
1200 31.30 24.18 23.66 23 .45
1300 30.98 27.10 25.54 24.12 23.65 23.41
1400 30.65 24.06 23.64 23.37
1500 30.32 23.97 23.62 23.34
Comment Final reading for the quarter is 23.00.
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 6/19/14 -6/25/14
Slimes Cell# 2
Sampler: Garrin Palmer
Tanner Holliday
06/19/14 06/20/14 06/21/14 06/22/14 06/23/14 06/24/14 06/25/14
700 34.42 27.95 23.59 23.12
800 33.66 27.85 23.58 23.12
900 33.20 27.76 23.56 23.12
1000 32.68 27.64 23.53
1100 32.21 27.52 23.52
1200 31.76 27.40 23.51
1300 31.40 27.29 23.46
1400 31.07 27.17 23.43
1500 30.71 27.04 25.22 24.35 23.89 23.40
Comments: Final reading was 23.12.
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 9/23/14 -9/29/14
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
9/23/14 9/24/14 9/25/14 9/26/14 9/27/14 9/28/14 9/29/14
600 33.98 25.50
700 33.64 27.50 25.46 24.47 22.62
800 32.96 27.40 25.43 24.44 22.61
900 32.27 27.29 25.40 24.40 23.01 22.60
1000 31.84 27.18 25.35 24.36 22.58
1100 31.38 27.08 25.27 24.33 22.56
1200 31.01 26.96 25.23 24.29 22.54
1300 30.72 26.85 25.19 24.23 22.52
1400 30.40 26.73 25.15 24.18 22.50
1500 30.23 26.62 25.10 24.12 23.36 22.50
1600 29.91 26.52 25.04 24.09 22.50
Comment Final reading was 22.50.
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 11/11/14 -11/17/14
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
11/11/14 11/12/14 11/13/14 11/14/14 11/15/14 11/16/14 11/17/14
600 22.78
700 27.55 25.42 24.43 23.53 23.06 22.78
800 33.90 27.41 25.37 24.37 22.78
900 33.42 27.26 25.32 24.31
1000 32.82 27.12 25.26 24.26
1100 32.27 27.01 25.21 24.20
1200 31.77 26.90 25.13 24.15
1300 31.32 26.79 25.05 24.10
1400 30.98 26.69 24.97 24.05
1500 30.64 26.59 24.93 23.99
1600 30.39 26.49 24.89 23.95
Comment! Final reading was 22.78.
Annual Slimes Drain Compliance for Cell 2 Slimes Drain, White Mesa Mill
Groundwater Discharge Permit UGW370004 Section I.D.3
Equation 1:
[~Ey + ~y-1 + ~ y-21 I Ny + N y-1 + N y-21 < [~Ey-1 +~y-2+ ~ y-31 IN y-1 + N y-2+ N y-31
Where:
L.Ey =
Ny-t =
Ny-2 =
Ny-3 =
Sum of all monthly slimes drain tailings fluid elevation measurements that meet
the test performance standards found in 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 DMT Plan, these recovery
tests are to be conducted monthly and the SDRE values reported in units of feet
above mean sea level (amsl).
Sum of all SDRE measurements made in the year previous to the calendar year of
interest.
Sum of all SDRE measurements made in the second year previous to the calendar
year of interest.
Sum of all SDRE measurements made in the third year previous to the calendar
year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b )(2), conducted during the calendar year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b )(2), conducted in the year previous to the calendar year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b)(2), conducted in the second year previous to the calendar year of
interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b )(2), conducted in the third year previous to the calendar year of
interest.
Part I.D.3 further provides that prior to January 1, 2013, the following values for E and N in
Equation I shall be based on SDRE data from the following calendar years.
Table 3 -SDRE Data to be Used for Certain Years
Report Source of Data By Calendar Year for Equation 1 Variables (right
for side)
Calendar Ey-1 Ey-2 Ey-3 Ny-1 Ny-2 Ny-3
Year
2010 2009 2009 2009 2009 2009 2009
2011 2010 2009 2009 2010 2009 2009
2012 2011 2010 2009 2011 2010 2009
The GWDP does not specify the source of data by calendar year for 2014. The source of data for
the 2014 calendar year compliance determination is shown in Table 4 below
Table 4 -SDRE Data to be Used for 2014
Report Source of Data By Calendar Year for Equation 1 Variables (right
for side)
Calendar Ey-1 Ey-2 Ey-3 Ny-1 Ny-2 Ny-3
Year
2014 2013 2012 2011 2013 2012 2011
Table 5
Cell2 Slimes Drain Recovery Head and SDRE Values for 2014
2014 Test Closing Date Elevation of Reported Level SDRE Values
Measurement Point (feet) (Reported as
(fmsl)** fmsl)
3/20/2014 5618.73 23.00 5595.73
6/25/2014 5618.73 23.12 5595.61
9!29/2014 5618.73 22.50 5596.23
11/17/2014 5618.73 22.78 5595.95
.... II L.E2o14* 67150.56
N2o14* 12
*Per the requirement of the GWDP Part I.D.3 when monthly and qumterly
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.
Table 6
Cell2 Slimes Drain Recovery Head and SDRE Values for 2013
2013 Test Closing Date Elevation of Reported Level SDRE Values
Measurement Point (feet) (Reported as
(fmsl)** 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
1I!19/2013 5618.73 22.35 5596.38
LE2o13* 67158.93
N2o13 * 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 20 II. This change in elevation
has no effect on the resulting slimes drain elevation values listed in and used in the
calculations.
Table 7
Cell2 Slimes Drain Recovery Head and SDRE Values for 2012
2012 Test Closing Date Elevation of Reported Level SDRE Values
Measurement Point (feet) (Reported as
(fmsl) fmsl)
3/12/2012 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
L.E2o12* 67167.72
N2o12 * 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.
Table 8
Cell2 Slimes Drain Rc.cove ry Head and SDRE Values for 2011
2011 Test Closing Date Elevation of Reported Level SDRE Values
Measurement Point (feet) (Reported as
(fmsl) fmsl)
l/21/2011 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
7119/2011 *** 5611.76 12.59 5599.17
12119/2011 *** 5611.76 12.86 5598.90
L.E2o11* 67192.97
N2011 * 12
*Per the requirement of the GWDP Part I.D.3 when monthly and quarterly
measurements are combined in the GWDP required equation, the quarterly values shall
be multiplied by a coefficient of three (3).
**The standpipe elevation was extended and surveyed in 2011. This change in elevation
has no effect on the resulting slimes drain elevation values listed in and used in the
calculations.
***Per the Permit Part I.D.3.(b).2 effective July 11, 2011, the frequency of the Cell 2
slimes drain recovery tests was changed from monthly to quarterly.
..
Calendar Year
Value in Equation 1
Calculated Value from
Tables 5 through 8
IEy+IEy_1 +IEy-2
201477.21
Table 9
Equation 1 V aloes
2014 2013
IEy IEy_1
67150.56 67158.93
Ny=12 Ny_1=12
Table 10
SDRE Complaince Calculations
NY+ Ny-1 + Ny-2 IEy_1+IEy_2+IEy_3
36 201519.62
2012
IEy_2
67167.72
Ny_2=12
Ny-1 + Ny-2 + Ny-3
36
IEy+IEy_1+IEy-21Ny+Ny-1 + Ny-2 IE~_1 +IEy_2+IEy_31Ny_1 + Ny-2 + Ny-3
201477.21/36 201519.65/36
5596.59 5597.77
2011
IEy_3
67192.97
Ny_3=12
Attachment D
n tt) --N ' ~ --· VI 3 Ill ~ iii. tt) ~ "' c
Ql -::::s
I
N 0 0 c: \0 :J
Ill .. Ill ..... N v; 0 ro :J. ~ ro Vl 0 ~ ..
N 0
~
~ ...
N
0
~
N ..
N
0 ~ w
20
N 0 ~ ~
N .j::.
0 0
Feet Below Top of Standpipe
N N 0 0
N 0 0 0
t-' 00 0 0
t-' en 0 0
t-' .j::.
0 0
I 1 1 •tr =-iJ 1 113o;2oo9
• 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
11/30/2013
1/31/2014
3/31/2014
5/31/2014
7/31/2014
9/30/2014
Attachment E
This attachment has been deliberately left blank.
Attachment F
October 2014
Date
10/2/2014
10/9/2014
10116/2014
10/23/2014
10/30/2014
Cell 4A LDS Monitoring Information
Weekly measurements in inches
from transducer at the bottom of
the LDS sump.
11.1
6.0
8.2
8.4
6.2
Flow Meter in Gallons
356326
359542
359542
359542
362531
Highest level for the month based on the daily data was 13.0 inches and the lowest level for the month was
3.8 inches. Total number of gallons pumped was 6,205.
November 2014
Date
1116/2014
11113/2014
11120/2014
11/26/2014
Weekly measurements in inches
from transducer at the bottom of
the LDS sump.
10.4
8.9
10.3
8.5
Flow Meter in Gallons
362531
362531
362531
365118
Highest level for the month based on the daily data was 12.9 inches and the lowest level for the month was
6.4 inches. Total number of gallons pumped was 2,587.
December 2014
Weekly measurements in inches
from transducer at the bottom of
Date the LDS sump. Flow Meter in Gallons
12/4/2014 10.8 365118
1211112014 11.5 365118
12/18/2014 8.6 368015
12/24/2014 9.6 368015
12/31114 11.1 368015
Highest level for the month based on the daily data was 14.4 inches and the lowest level for the month was
8.2 inches. Total number of gallons pumped was 2,897.
For the 4th Quarter 2014, the highest level was 14.4 inches and the lowest level was 3.8 inches and 11,689
gallons were pumped.
The daily fluid pumped is not calculated for Cell 4A because the total pumped for the entire quarter does not
exceed the daily allowable volume and therefore the calculation is not necessary.
Cell 4B LDS Monitoring Information
October 2014
Weekly measurements in inches
from transducer at the bottom Flow Meter in Gallons Gallons
Date of the LDS sump. Gallons pumped/week Pumped/day*
10/2/2014 14.75 62861
10/9/2014 8.90 82250 19389 2770
10/16/2014 13.90 82250 0 0
10/23/2014 8.07 99914 17664 2523
10/30/2014 12.24 99914 0 0
Highest level for the month based on the daily data was 14.75 inches and the lowest level for the month was 6.39
inches and 37,053 gallons were pumped.
November 2014
Weekly measurements in inches
from transducer at the bottom Flow Meter in Gallons Gallons
Date of the LDS sump. Gallons pumped/week Pumped/day
11/6/2014 5.40 118866 18952 2707
11113/2014 9.75 118866 0 0
11120/2014 14.24 118866 0 0
11/26/2014 7.22 118888 16078 2297
Highest level for the month based on the daily data was 14.75 inches and the lowest level for the month was 5.40
inches and 35,030 gallons were pumped.
As noted in Section 9 .1.1, on 11/25114, Mill Personnel noted that the Cell 4B LDS was pumping, but the flow
meter was malfunctioning and was not recording the volume of fluid pumped from the LDS. Based upon
decrease in the LDS head measurement from 14.24 on 11120/14 to 7.22 inches on 11126/14 it is apparent that the
LDS pumped. To estimate the gallons pumped, the 4 gallons pumped measurements from the quarter were
averaged. The average is 16055 gallons. The Mill Personnel noted 22 gallons manually pumped on 11/26114
during the function check, which was added to the average of 16055 for an estimated total of 16078 pumped the
week of 11/23114.
December 2014
Weekly measurements in inches
from transducer at the bottom Flow Meter in Gallons Gallons
Date of the LDS sump. Gallons pumped/week Pumped/day
12/4/2014 11.40 118888 0 0
12111/2014 13.95 118888 0 0
12118/2014 7.22 127105 8217 1174
12/24/2014 8.90 127105 0 0
12/3112014 9.75 127105 0 0
Highest level for the month based on the daily data was 14.75 inches and the lowest level for the month was 6.39
inches and 8,217 gallons were pumped.
For the 4th Quarter 2014, the highest level was 14.75 inches and the lowest level was 5.40 inches and 80,300
gallons were pumped.
* Pursuant to Section 3.1a) of the approved DMT Plan, the total volume of all fluids pumped from the LDS on a
weekly basis shall be recovered from the data collector. The weekly fluid pumped will be used to calculate an
average pumped per day.
~ Consuftrmts Table 1A
Ctlculated .Adlon la1kap Races for Varloul Head COndtuons
Cell 4A, White Mesa Mill
Blandin& Utah
Head Above Uner (»; ....... Adlan lNIIRII Illite
System (feet) (Jallum/lcre/day)
5 222.04
18 314.0
15 384.58
20 444.08
25 496.5
30 549.88
35 587.5
37 604.0
Geosyntec Consultants Tbble 18
I
talcufated Action Lealcase Rates for Various Head CondltJons
Cel148, Wblte Mela Mill
Blandlns, Utah
Head Above Uner System Clfculltetl Action I.Nklp Rate
(Mt) (llflons/acre/clayJ
5 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
35 570.0
37 58L2
Max head on Cell 4A FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1A (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4A -Q4 2014
5589.90
5555.55
34.35
587.5
39.32
23,101
Max head on Ceii4B FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1B (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B-Q4 2014
5583.30
5557.50
25.8
475.6
35.91
17,079
Calculation of Maximum Daily Allowable LDS Flow Volume for Varying Head Conditions in
Cells 4A and 4B
The equation for the calculation of maximum daily allowable flow volume in Cells 4A and 4B is
as follows:
Step 1)
Where:
Step 2)
Step 3)
Step 4)
Elevation !-Elevation 2 =Head (ft.)
Elevation 1 is the maximum elevation in feet measured during the reporting
period.
Elevation 2 is the FML elevation in feet.
Determine Calculated Action Leakage Rate from Table lA (for Ce114A) or Table
1B (for Cell4B) using the head calculated in Step 1 above. If the head calculated
in step 1 above falls between two values in the Head Above Liner System (feet)
column, then the closer of these two values will be used to determine the
Calculated Action Leakage Rate.
Calculate the acres of tailings cell fluids based on the area of the base of the cell,
the head, and the angle of the sideslopes of the cell.
Action Leakage Rate (from Table 1A or 1B) X Acres of Tailings Cell Fluids =
Maximum Daily Allowable Flow Volume
Cell 1, Cell 2, and Cell 3 LOS Monitoring Information -Fourth Quarter 2014
Cell1 Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LOS sump. bottom of the LOS sump. bottom of the LOS sump.
10/2/2014 Dry 10/2/2014 Dry 10/2/2014 Dry
10/9/2014 Dry 10/9/2014 Dry 10/9/2014 Dry
10/16/2014 Dry 10/16/2014 Dry 10/16/2014 Dry
10/23/2014 Dry 10/23/2014 Dry 10/23/2014 Dry
10/30/2014 Dry 10/30/2014 Dry 10/30/2014 Dry
Cell1 Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LOS sump. bottom of the LOS sump. bottom of the LOS sump.
11/6/2014 Dry 11/6/2014 Dry 11/6/2014 Dry
11/13/2014 Dry 11/13/2014 Dry 11/13/2014 Dry
11/20/2014 Dry 11/20/2014 Dry 11/20/2014 Dry
11/26/2014 Dry 11/26/2014 Dry 11/26/2014 Dry
Cell1 Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LOS sump. bottom of the LOS sump. bottom of the LOS sump.
12/4/2014 Dry 12/4/2014 Dry 12/4/2014 Dry
12/11/2014 Dry 12/11/2014 Dry 12/11/2014 Dry
12/18/2014 Dry 12/18/2014 Dry 12/18/2014 Dry
12/24/2014 Dry 12/24/2014 Dry 12/24/2014 Dry
12/31/2014 Dry 12/31/2014 Dry 12/31/2014 Dry
Attachment G
This attachment has been deliberately left blank.
Attachment H
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White Mesa Mill-Discharge Minimization Technology Monitoring Plan
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Attachment I
(
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014 Month October
Rain Snow Rain Snow
17
18
19
20
21
22
23
24
.,..07 25
• D l 26
27
28
29
30
31
Combined
Total: 2D8
(
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014 Month November
Rain Snow Rain Snow
17
18
19
20
21
22
23
24
25
26
27
28
29
~3S 30
" 23 31
Combined
Total: .56
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014 Month December
Rain Snow Rain Snow
1 17 .)I
2 18
3 19
4 20
·' 0 5 21 .o~
6 22 jj')S
7 23
8 ~
9 25 'o/
10 26
11 27
12 28
13 29
14 30 a 33
15 31
16
Combined
Total: • J I