DRC-2017-002143 - 0901a068806d7654

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.coin
March 23,2017
Div of Waste Management
and Radiation Control
Sent VIA OVERNIGHT DELIVERY MAR 21 2017
Mr. Scott Anderson WOZOn-0O2i43’
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Transmittal of Revised Tailings Management System Procedure for the White Mesa Uranium
Dear Mr. Anderson:
This letter transmits Energy Fuels Resources (USA) Inc.’s (“EFRI’s”) proposed revisions to the White Mesa
Mill Tailings Management System procedure. These revisions include changes made to:
1. Incorporate changes to the Tailings Management System procedure in response to requirements for
operating mill tailings specified by the Environmental Protection Agency (“EPA”) in 40 CFR Part 61,
Revisions to National Emissions Standards for Radon Emissions From Operating Mill Tailings.
2. Correct typographical errors.
For ease of review we have provided both redline/strikeout and clean versions of the document.
If you should have any questions regarding these plans please contact me.
Yours very truly.
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Harold R. Roberts
Mark S. Chalmers
David E. Turk
Logan Shumway
Scott Bakken
Mill
REDLINE
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
Revision 2.4-5
December 2016March 2017
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill - Standard Operating Procedures 4-2A1403/17 Revision: EFR 2.45
Book 11: Environmental Protection Manual, Section 3.1 Page 2 of 37
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..................................................................................................................1544
6.3.1. Cell 1...................................................................................................................................15
6.3.2. Cell 2...................................................................................................................................15
6.3.3. Cell 3...................................................................................................................................15
6.3.4. Cell 4A...........................................................................................................................164A
6.3.5. Cell 4B...........................................................................................................................16L5
7. OTHER INSPECTIONS............................................................................................................194S
8. REPORTING REQUIREMENTS............................................................................................194S
8.1. Monthly Tailings Reports.........................................................................................................19
APPENDICES
Appendix A Forms
Appendix B Tailings Inspector Training
Appendix C Certification Form
Appendix D Example Freeboard Calculations for Cell 4B
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-3/4403/17 Revision: EFR 2.45
Page 3 of 37
1. INTRODUCTION
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, and inspection of the 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 Energy Fuels Resources (USA) Inc. (“EFRI”)
develop the initial DMT Plan in response to GWDP requirements. In developing the initial DMT
Plan, EFRI combined the existing Tailings Management System procedure set out as Chapter 3.1 of
the Mill’s Environmental Protection Manual with a number of new DMT requirements from the
GWDP to form the initial DMT Plan. The initial DMT Plan and subsequent revisions (through
revision 11.5) maintained the requirements from the RML (i.e., Chapter 3.1 of the Mill’s
Environmental Protection Manual) and the DMT requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. 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
enforced under the requirements of the GWDP and this Tailings Management System procedure to
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
43/4603/17 Revision: EFR 2.45
Page 4 of 37
be managed, inspected and enforced under the requirements of the RML.
In addition, EFRI has incorporated in this plan the requirements for operating mill tailings specified
by the Environmental Protection Agency (“EPA”) in 40 CFR Part 61, Revisions to National
Emissions Standards for Radon Emissions From Operating Mill Tailings.
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”) 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 1, 2, and 3 and to address
anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the evaporation cells (Cell 1 and Cell
4B) and the fetmtailings 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 1,2, and 3 will be
recorded on the Daily Inspection Data form included as Attachment A-l 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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
j-2Ak603/17 Revision: EFR 2.45
Page 5 of 37
Areas to be inspected include the following: Cell 1, 2, 3,4A and 4B, the liners of Cells 1, 2, and 3,
Dikes 4A-S, 4A-E, and 4B-S, wind movement of tailings, effectiveness of dust minimization
methods, spray evaporation, Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A 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, Cell
4A or Cell 4B; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
b) Cell 1.
c) Cell 2.
d) Cell 3.
e) Cell 4A.
f) Cell 4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S.
h) The Cell 2 spillway. Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
-14)4403/17 Revision: EFR 2.45
Page 6 of 37
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)
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.
l) 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
\mmy\l Revision: EFR 2.45
Page 7 of 37
r) Observations regarding visible sediments (Celll and Cell 4B only).
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
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 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 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Revision: EFR 2.45
Page 8 of 37
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).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
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-l 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
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
14/4403/17 Revision: EFR 2.45
Page 9 of 37
(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) EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) 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 of the 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
44/4403/17 Revision: EFR 2.45
Page 10 of 37
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 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 Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, 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) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
(/) 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
d)Decontamination Pads
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+3*4603/17 Revision: EFR 2.45
Page 11 of 37
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
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.
ej_______Weekly photographs of Cells 1 and Cell 4B documenting observations regarding
sediments present and proof of saturation as necessary. Digital photographs will
be taken and will have at a minimum date and time electronically embedded.
Notations resardins the completion of the photographic documentation will be
made on the Weekly Tailings and DMT Inspection form in Attachment A.
ejf}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 of the 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-3)4603/17 Revision: EFR 2.45
Page 12 of 37
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.
d) Overspray Dust Minimization
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 attached to 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:
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4^4603/17 Revision: EFR 2.45
Page 13 of 37
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.
c) Construction Review
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).
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
\WtWmi Revision: EFR 2.45
Page 14 of 37
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.
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 of the 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 SecretaryDirector 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.
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual. Section 3.1
42*4603/17 Revision: EFR 2.45
Page 15 of 37
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 Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
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 of 0.77 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 Cell 4A is 40 acres, and in Cell 4B is 40
acres. The top of the flexible membrane liner (“FML”) for Cell 1 is 5,618.2 FMSL, for Cell 4A
is 5,598.5 FMSL and for Cell 4B 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 Cell 1 will be set at 5,615.4 FMSL. This will allow Cell 1 to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 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 Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).
6.3.3.Cell 3
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Vmwmi Revision: EFR 2.45
Page 16 of 37
The freeboard limit for Cell 3 is inapplicable, since Cell 3 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 Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell 4A will be attributed to Cell 4B. A spillway has been added to Cell 4A to allow overflow into
Cell 4B.
6.3.5. Cell 4B
The freeboard limit for Cell 4B 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 Cell 4B is as follows:
(a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell 4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume 38.1 acre-feet
Overflow from Cell 4A assuming no storage in Cell 3 or 4A 159.4 acre-feet
Sum of PMP volume and overflow volume 197.5 acre-feet
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres 4.9 feet
Wave run up factor 0.77 feet
Total required freeboard 5.7 feet
(all values in the above calculation have been rounded to the nearest one-tenth of a foot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation of the beach area in Cell 4B 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=0) (until the next November 1) will be
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-2/4403/17 Revision: EFR 2.45
Page 17 of 37
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 (“T0”) will be determined;
ii) The expected number of dry tons to be deposited into Cell 4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period (“Ao*”), will be determined;
iii) Aq* 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 Cell 4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus T0;
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 Cell 4B
for solids. That is, the reduced pool surface area for period t=0 (“RPAq”), after the
reduction, will be calculated to be:
(1 - (A0* x 1.5) / (2,094,000 - T0)) x 40 acres = RPA0
vii) The required freeboard for Cell 4B for the remainder of the period t=0 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 Cell 4B for
the remainder of period t=0 would then be the elevation of the FML for Cell 4B 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 (ARPA,.|)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-1).
The RPAt_i used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPAt.i is merely the RPA 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 RPA been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+2,4403/17 Revision: EFR 2.45
Page 18 of 37
account actual tonnages deposited in the cell as of the date of the calculation. The
ARPA,.i can be calculated using the following formula:
(1 - At-i / (2,094,000 - T,.,)) x ARPAt.2 = ARPA,.,
Where:
• A,_i is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;
• Tt.| is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t-1; and
• ARPAt.2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARPA,.2 is 40 acres;
ii) Once the ARPAt.i for the previous period (period t-1) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1 - (At* x 1.5) / (2,094,000 - T,)) x ARPA,., = RPA,
Where:
• A,* is the expected number of dry tons of tailings to be deposited into Cell 4B
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);
• T, is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t; and
• ARPA,., is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-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 period t 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 RPA,.
The freeboard limit for Cell 4B for period t would then be the elevation of the FML
for Cell 4B of 5594.0 FMSL less this 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 Cell 4B 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 Cell 4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
42A603/17 Revision: EFR 2.45
Page 19 of 37
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
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.
8.2. Weekly Cell 1 and Cell 4B Photographs
Weekly photographs taken in response to ERA 40 CFR Part 61 will be stored on the Mill network
and reported in the EPA Central Data Exchange at least monthly (as available). If the ERA Central
Data Exchange is unavailable, the photographs will be maintained at the Mill in an electronic format.
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-3/4403/17 Revision: EFR 2.45
Page 20 of 37
APPENDIX A
FORMS
White Mesa Mill - Standard Operating Procedures 12/1603/17 Revision: EFR 2.45
Book 11: Environmental Protection Manual, Section 3.1 Page 21 of 37
APPENDIX A-l
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
Inspection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
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 of Potential Concern Cel 1 Cell 2 Cell 3 Cel 4A Ce 1 4B
N S E W N S E W ^ S E W
Interior Cell Walls 1
Liner Observable Liner Damage 1
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
Presence of Sediments Sediments should be saturated YorN N/A N/A N/A YorN
Notes:
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
42A403/17 Revision: EFR 2.45
Page 22 of 37
III. DIKES A>D EMBANKMENTS
Inspection Items Conditions of Potential
Concern
Dike 1-1 Dike 1-
1A
Dike 2 Dike 3 Dike
4A-S
Dike
4A-E
Dike
4B-S
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
Crest Cracks, Subsidence, Severe
Erosion
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
IV. FLOW RATES
Slurry Line(s) Pond Return S-X Tails Spray System
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point ____________Yes _____________No
Observed Entire Discharge Line ____________Yes _____________No
VI. DUST CONTROL
Cell 2 Cell 3 Cell 4A Cell 4B
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
Slimes
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
42/4403/17 Revision: EFR 2.45
Page 23 of 37
General Meteorological conditions:.
VII. DAILY LEAK DETECTION CHECK
Daily Leak Detection Checks are recorded on the Daily Inspection Data form included
as Attachment A-l of the DMT Plan
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+3,4403/17 Revision: EFR 2.45
Page 24 of 37
Kmii
Ta
i
l
i
n
g
s
Da
i
l
y
In
s
p
e
c
t
i
o
n
Re
p
o
r
t

Ta
i
l
i
n
g
s
Sl
u
n
y
Di
s
c
h
a
r
g
e
Lo
c
a
t
i
o
n
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+3/4403/17 Revision: EFR 2.45
Page 25 of 37
APPENDIX A-2
WHITE MESA MILL
WEEKLY TAILINGS INSPECTION
Date:_________________ Inspectors:
I. 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 43.4r-Depth to Liquid Pre­
pump =
Post-pump head is 43.41 ’ -Depth to Liquid Post­
pump =
2. Existing Decontamination Pad (concrete):________________
3. _Tailings Area Inspection (Note dispersal of blowing tailings):
3t4. Sediments visible in: Cell 1: Y Or N Cell 4B: Y Or N If yes, are they saturated? Y Or N If no.
note corrective actions
4-75J2ontrol Methods Implemented:.
5t6. Remarks:.
4t7. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
42/4403/17 Revision: EFR 2.45
Page 26 of 37
APPENDIX A-3
MONTHLY INSPECTION DATA
Inspector:
Date:___
1. Slurry Pipeline:
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing ves no ves no ves no
Erosion ves no yes no ves no
Undesirable ves no ves no ves no
Vegetation
Obstruction of Flow ves no ves no ves no
Diversion Berm:
Stability Issues _____yesno
Signs of Distress _____yesno
Comments:.
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+2/4603/17 Revision: EFR 2.45
Page 27 of 37
4. Overspray Dust Minimization:
Overspray system functioning properly: _______yesno
Overspray carried more than 50 feet from the cell: _____yesno
If “yes”, was system immediately shut off? _____yesno
Comments:_______________________________________________
5. Remarks:
6. Settlement Monitors:
Attach the Settlement monitor monthly survey data (spreadsheet). Note any unusual observations
below.
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections:
9. Monthly LDS Pump Checks in Cells 4A and 4B:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-2/4403/17 Revision: EFR 2.45
Page 28 of 37
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 Cell 4A Cell 4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
42/4603/17 Revision: EFR 2.45
Page 29 of 37
APPENDIX B
TAILINGS INSPECTOR TRAINING
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 of Dam 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-2/1403/17 Revision: EFR 2.45
Page 30 of 37
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.
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4-2/4403/17 Revision: EFR 2.45
Page 31 of 37
4. Flow Rates:
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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
43A403/17 Revision: EFR 2.45
Page 32 of 37
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
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 Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell 4A 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 lifejacket 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 of Wildlife:
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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
44)4403/17 Revision: EFR 2.45
Page 33 of 37
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the RSO and
filed.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+3/4403/17 Revision: EFR 2.45
Page 34 of 37
APPENDIX C
CERTIFICATION FORM
Date:
Name:
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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+3,4603/17 Revision: EFR 2.45
Page 35 of 37
APPENDIX D
Example of Freeboard Calculations
For Cell 4B
Assumptions and Factors:
o Total PMP volume to be stored in Cell 4B - 159.4 acre feet
o Wave runup factor for Cell 4B - 0.77 feet
o Total capacity of Cell 4B - 2,094,000 dry tons
o Elevation of FML of Cell 4B - 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
Tailings Solids
Disposition into
Cell4B
Determined at
the beginning of
the period (dry
tons)*
Expected Tailings
Solids Disposition into
Cell 4B at the
beginning of the
period, multiplied by
150% Safety Factor
(dry tons)
Actual Tailings Solids
Disposition into Cell 4B
determined at end of
the period (dry tons)*
March 1, 2012 to
November 1, 2012
150,000 225,000 225,000
November 1, 2012 to
November 1, 2013
300,000 450,000 275,000
November 1, 2013 to
November 1, 2014
200,000 300,000 250,000
*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 Cell 4B would be calculated
as follows:
1. Prior to March 1, 2012
Prior to March 1, 2012, the maximum elevation of the beach area in Cell 4B is less than or
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
12/1603/17 Revision: EFR 2.45
Page 36 of 37
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1, 2012 to November 1, 2012
The pool surface area would be reduced to the following amount
(1 - 225,000/ (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 Cell 4B of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell 4B 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 to 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 of 225,000 dry tons was the same as
the modeled tonnage of 225,000 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/ (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 Cell 4B of 0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
4B 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:
| White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
43/4603/17 Revision: EFR 2.45
Page 37 of 37
(1 - 275,000/ (2,094,000 - 1,000,000 - 225,000) x 31.77 acres = 21.72 acres.
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/ (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 Cell 4B of 0.77 feet is added
to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell
4B 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.
CLEAN
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
Revision 2.5
March 2017
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill - Standard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual. Section 3.1 Page 2 of 37
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......................................................................................................................15
6.3.1. Cell 1....................................................................................................................................15
6.3.2. Cell 2...................................................................................................................................15
6.3.3. Cell 3...................................................................................................................................16
6.3.4. Cell 4A................................................................................................................................16
6.3.5. Cell 4B................................................................................................................................16
7. OTHER INSPECTIONS.................................................................................................................19
8. REPORTING REQUIREMENTS.................................................................................................19
8.1. Monthly Tailings Reports........................................................................................................19
8.2. Weekly Cell 1 and Cell 4B Photographs...............................................................................19
APPENDICES
Appendix A Forms
Appendix B Tailings Inspector Training
Appendix C Certification Form
Appendix D Example Freeboard Calculations for Cell 4B
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 3 of 37
1. INTRODUCTION
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, and inspection of the 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 Energy Fuels Resources (USA) Inc. (“EFRI”)
develop the initial DMT Plan in response to GWDP requirements. In developing the initial DMT
Plan, EFRI combined the existing Tailings Management System procedure set out as Chapter 3.1 of
the Mill’s Environmental Protection Manual with a number of new DMT requirements from the
GWDP to form the initial DMT Plan. The initial DMT Plan and subsequent revisions (through
revision 11.5) maintained the requirements from the RML (i.e., Chapter 3.1 of the Mill’s
Environmental Protection Manual) and the DMT requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. 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
enforced under the requirements of the GWDP and this Tailings Management System procedure to
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 4 of 37
be managed, inspected and enforced under the requirements of the RML.
In addition, EFRI has incorporated in this plan the requirements for operating mill tailings specified
by the Environmental Protection Agency (“EPA”) in 40 CFR Part 61, Revisions to National
Emissions Standards for Radon Emissions From Operating Mill Tailings.
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”) 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 1, 2, and 3 and to address
anticipated GWDP modifications regarding the EDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the evaporation cells (Cell 1 and Cell
4B) and the tailings cells (Cells 2, 3, 4A,) 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 1,2, and 3 will be
recorded on the Daily Inspection Data form included as Attachment A-l 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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 5 of 37
Areas to be inspected include the following: Cell 1, 2, 3,4A and 4B, the liners of Cells 1, 2, and 3,
Dikes 4A-S, 4A-E, and 4B-S, wind movement of tailings, effectiveness of dust minimization
methods, spray evaporation, Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A 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, Cell
4A or Cell 4B; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
b) Cell 1.
c)Cell 2.
d) Cell 3.
e)Cell 4A.
f)Cell 4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S.
h) The Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 6 of 37
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)
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.
l) 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 Director.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 7 of 37
r) Observations regarding visible sediments (Celll and Cell 4B only).
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
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 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 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual. Section 3.1
03/17 Revision: EFR 2.5
Page 8 of 37
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).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
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-l 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
White Mesa Mill - Standard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual, Section 3.1 Page 9 of 37
system which aids in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) 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 of the 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 10 of 37
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 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 Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, 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) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
(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
d)Decontamination Pads
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 11 of 37
exposed surfaces of the pad. Any abnormalities relating to the pad and
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) Weekly Photographs for EPA Subpart W
Weekly photographs of Cells 1 and Cell 4B documenting observations regarding
sediments present and proof of saturation as necessary. Digital photographs will
be taken and will have at a minimum date and time electronically embedded.
Notations regarding the completion of the photographic documentation will be
made on the Weekly Tailings and DMT Inspection form in Attachment A.
f) 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 of the 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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 12 of 37
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.
d) Overspray Dust Minimization
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 attached to 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:
While Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 13 of 37
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.
c) Construction Review
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).
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 14 of 37
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.
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 of the 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
Director 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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual. Section 3.1
03/17 Revision: EFR 2.5
Page 15 of 37
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
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
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 of 0.77 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 Cell 4A is 40 acres, and in Cell 4B is 40
acres. The top of the flexible membrane liner (“FML”) for Cell 1 is 5,618.2 FMSL, for Cell 4A
is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill’s tailings cells will be set as follows:
The freeboard limit for Cell 1 will be set at 5,615.4 FMSL. This will allow Cell 1 to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 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.
0.90 feet.
6.3.1.Cell 1
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 Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 16 of 37
6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell 3 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 Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell 4A will be attributed to Cell 4B. A spillway has been added to Cell 4A to allow overflow into
Cell 4B.
6.3.5. Cell 4B
The freeboard limit for Cell 4B 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 Cell 4B is as follows:
(a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell 4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume 38.1 acre-feet
Overflow from Cell 4A assuming no storage in Cell 3 or 4A 159.4 acre-feet
Sum of PMP volume and overflow volume 197.5 acre-feet
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres 4.9 feet
Wave run up factor 0.77 feet
Total required freeboard 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 of the beach area in Cell 4B 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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 17 of 37
(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=0) (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 Cell 4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period (“Aq*”), will be determined;
iii) A0* 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 Cell 4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus T0;
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 Cell 4B
for solids. That is, the reduced pool surface area for period t=0 (“RPAq”), after the
reduction, will be calculated to be:
(1 - (A0* x 1.5) / (2,094,000 - T0)) x 40 acres = RPA0
vii) The required freeboard for Cell 4B for the remainder of the period t=0 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 Cell 4B for
the remainder of period t=0 would then be the elevation of the FML for Cell 4B 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 (ARPAt_i)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-1).
The RPA,.| used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPAt.| is merely the RPA that would have
White Mesa Mill - Standard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual, Section 3.1 Page 18 of 37
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 RPA 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
ARPA,_i can be calculated using the following formula:
(1 - At., / (2,094,000 - T,.,)) x ARPAt.2= ARPA,.,
Where:
• At. i is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;
• Tm is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t-1; and
• ARPA,.2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARPAt.2is 40 acres;
ii) Once the ARPA,.| for the previous period (period t-1) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1 - (A,* x 1.5) / (2,094,000 - T,)) x ARPA,., = RPA,
Where:
• A,* is the expected number of dry tons of tailings to be deposited into Cell 4B
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);
• T, is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t; and
• ARPA,_| is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-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 period t 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 RPA,.
The freeboard limit for Cell 4B for period t would then be the elevation of the FML
for Cell 4B of 5594.0 FMSL less this 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 Cell 4B and a new tailings cell then, if an approved freeboard
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 19 of 37
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 Cell 4B 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
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.
8.2. Weekly Cell 1 and Cell 4B Photographs
Weekly photographs taken in response to EPA 40 CFR Part 61 will be stored on the Mill network
and reported in the EPA Central Data Exchange at least monthly (as available). If the EPA Central
Data Exchange is unavailable, the photographs will be maintained at the Mill in an electronic format.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A
03/17 Revision: EFR 2.5
Page 20 of 37
FORMS
White Mesa Mill - Standard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual, Section 3.1 Page 21 of 37
APPENDIX A-l
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
Inspection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Slurry Pipeline Leaks, Damage, Blockage, Shatp 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
Insoection Items Conditions of Potential Concern Ce 1 1 Cell 2 Cell 3 C:ell 4A Ce 14B
N S E W N S E W Nj S E W
Interior Cell Walls T
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
Presence of Sediments Sediments should be saturated YorN N/A N/A N/A YorN
Notes:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 22 of 37
III. DIKES A>D EMBANKMENTS
Inspection Items Conditions of Potential
Concern
Dike 1-1 Dike 1-
1A
Dike 2 Dike 3 Dike
4A-S
Dike
4A-E
Dike
4B-S
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
Crest Cracks, Subsidence, Severe
Erosion
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
IV. FLOW]RATES
Slurrv Linefs) Pond Return S-X Tails Sorav System
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point ____________Yes _____________No
Observed Entire Discharge Line ____________Yes _____________No
VI. DUST CONTROL
Cell 2 Cell 3 Cell 4A Cell 4B
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
Slimes
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 23 of 37
General Meteorological conditions:.
VII. DAILY LEAK DETECTION CHECK
Daily Leak Detection Checks are recorded on the Daily Inspection Data form included
as Attachment A-l of the DMT Plan
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
Da
t
e
:
_
_
_
_
In
s
p
e
c
t
o
r
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 24 of 37
Ta
i
l
i
n
g
s
Da
i
l
y
In
s
p
e
c
t
i
o
n
Re
p
o
r
t

Ta
i
l
i
n
g
s
Sl
i
m
y

Di
s
c
h
a
r
g
e
Lo
c
a
t
i
o
n
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 25 of 37
APPENDIX A-2
WHITE MESA MILL
WEEKLY TAILINGS INSPECTION
Date:_________________ Inspectors:
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 43.41’-Depth to Liquid Pre­
pump =
Post-pump head is 43.41’ -Depth to Liquid Post­
pump -
2. Existing Decontamination Pad (concrete):________________
3. Tailings Area Inspection (Note dispersal of blowing tailings):
4. Sediments visible in: Celll: YOrN Cell 4B: Y Or N If yes, are they saturated? YOrN
5. If no, note corrective actions:
6. Control Methods Implemented:
7. Remarks:
8. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 26 of 37
APPENDIX A-3
MONTHLY 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 of Distress
Diversion Ditch 1
ves no
ves no
ves no
ves no
ves no
yesno
Diversion Ditch 2
ves no
ves no
ves no
ves no
Diversion Ditch 3
ves no
ves no
ves no
ves no
Diversion Berm 2
Comments:
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 27 of 37
4. Overspray Dust Minimization:
Overspray system functioning properly: _______yesno
Overspray carried more than 50 feet from the cell: _____yesno
If “yes”, was system immediately shut off? _____yesno
Comments:__________________________________________________
5. Remarks:
6. Settlement Monitors:
Attach the Settlement monitor monthly survey data (spreadsheet). Note any unusual observations
below.
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections:
9. Monthly LDS Pump Checks in Cells 4A and 4B:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 28 of 37
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:
Cell 3 Cell 4A Cell 4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 29 of 37
APPENDIX B
TAILINGS INSPECTOR TRAINING
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 of Dam 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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 30 of 37
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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 31 of 37
4. Flow Rates:
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.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 32 of 37
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
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 Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell 4A 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 lifejacket 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 of Wildlife:
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
White Mesa Mill - Standard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual. Section 3.1 Page 33 of 37
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the RSO and
filed.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 34 of 37
APPENDIX C
CERTIFICATION FORM
Date:
Name:
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
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 35 of 37
APPENDIX D
Example of Freeboard Calculations
For Cell 4B
Assumptions and Factors:
o Total PMP volume to be stored in Cell 4B - 159.4 acre feet
o Wave runup factor for Cell 4B - 0.77 feet
o Total capacity of Cell 4B - 2,094,000 dry tons
o Elevation of FML of Cell 4B - 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
Tailings Solids
Disposition into
Cell4B
Determined at
the beginning of
the period (dry
tons)*
Expected Tailings
Solids Disposition into
Cell 4B at the
beginning of the
period, multiplied by
150% Safety Factor
(dry tons)
Actual Tailings Solids
Disposition into Cell 4B
determined at end of
the period (dry tons)*
March 1,2012 to
November 1, 2012
150,000 225,000 225,000
November 1, 2012 to
November 1, 2013
300,000 450,000 275,000
November 1, 2013 to
November 1, 2014
200,000 300,000 250,000
*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 Cell 4B would be calculated
as follows:
1. Prior to March L 2012
Prior to March 1, 2012, the maximum elevation of the beach area in Cell 4B is less than or
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 36 of 37
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1, 2012 to November 1, 2012
The pool surface area would be reduced to the following amount
(1 - 225,000/ (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 Cell 4B of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell 4B 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 to 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 of 225,000 dry tons was the same as
the modeled tonnage of 225,000 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/(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 Cell 4B of 0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
4B 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:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 37 of 37
(1 - 275,000/ (2,094,000 - 1,000,000 - 225,000) x 31.77 acres = 21.72 acres.
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/ (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 Cell 4B of 0.77 feet is added
to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell
4B 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.