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HomeMy WebLinkAboutDRC-2015-001662 - 0901a0688050d783@) MWH BUILDING A BETTER WORLD Energy Fuels Resources (USA) Inc. WHITE MESA MILL Tailings Data Analysis Report October 2014 March 2015 DRC-2015-001662 3665 JFK Parkway Suite 206 Fort Collins, CO USA MWH Tailings Data Analysis Report TABLE OF CONTENTS 1.0 INTRODUCTION 1 1.1 Project Background 1 1.2 Historical Tailings Data 2 1.3 Objectives of Tailings Investigation 3 1.4 Objective of Tailings Data Analysis Report 3 2.0 TAILINGS INVESTIGATION 5 2.1 CPT Soundings 5 2.2 Direct Push Sampling 9 3.0 LABORATORY INVESTIGATION 11 4.0 TAILINGS CHARACTERIZATION 15 4.1 Tailings Classification 15 4.2 Pore Pressures 17 4.3 Tailings Density 18 4.4 Hydraulic Conductivity 20 4.5 Consolidation Properties 23 5.0 SUMMARY 25 6.0 REFERENCES 26 LIST OF TABLES Table 2-1 CPT Testing Summary Table 3-1 Geotechnical Laboratory Testing Schedule Table 3-2 Summary of Laboratory Testing Results Table 4-1 Estimated Elevation of Top of Saturated Tailings Table 4-2 Summary of In-Situ Tailings Density from Laboratory Testing and Estimated from CPT Soundings Table 4-3 RecommendedAveraqe Measured Tailings Density Values for Analysis Table 4-4 Summary of Laboratory Measured Vertical Hydraulic Conductivity Table 4-5 Summary of Estimated Horizontal Hydraulic Conductivity from CPT Data Table 4-6 Estimation of Hydraulic Conductivity for Sand Tailings Samples Table 4-7 Summary of Laboratory Measured Consolidation Parameters Table 4-8 Summary of Estimated Horizontal Coefficient of Consolidation from CPT Soundings Energy Fuels Resources (USA) Inc. MWH Americas, Inc. October 201 <1March 2015 MWH Tailings Data Analysis Report LIST OF FIGURES Figure 1-1 Regional Location Map Figure 2-1 CPT Sounding and Sampling Locations Figure 2-2 Thickness Contours of Interim Cover and Tailings Figure 4-1 Estimated Elevation of Top of Saturated Tailings, October 2013 Figure 4-2 Thickness of Saturated Tailings, October 2013 Figure 4-3 Tailings CPT Sounding and Sampling Location - Cross Section A Figure 4-4 Tailings CPT Sounding and Sampling Location - Cross Section B Figure 4-5 Tailings CPT Sounding and Sampling Location - Cross Section C Figure 4-6 Pore Pressure vs. Elevation from CPT Soundings. CPT-2W3 and CPT 2W3A LIST OF APPENDICES Appendix A Cone Penetration Testing Results Appendix B Subsurface Exploration Logs Appendix C Direct Push Sampling Photographs Appendix D Geotechnical Laboratory Test Results Appendix E Interpretation Graphs of CPT and Laboratory Data Energy Fuels Resources (USA) Inc. ii MWH Americas, Inc. October 201 AMarch 2015 © MWH Tailings Data Analysis Report 1.0 INTRODUCTION This report presents the results of the tailings investigation of Cells 2 and 3 at the White Mesa site. This report has been prepared for Energy Fuels Resources (USA), Inc. (EFRI) by MWH Americas, Inc. (MWH) for submittal to the Utah Division of Radiation Control (DRC). The objectives and background for this report and supporting data are summarized below. The DRC requested that EFRI collect site-specific tailings data to supplement existing data used for technical analyses in the White Mesa Reclamation Plan, Version 5.0 (Denison, 2011) and the Infiltration and Contaminant Transport Modeling (ICTM) Report (MWH, 2010). This request was part of DRC's February 2013 review comments (DRC, 2013a, b) on EFRI's August and September 2012 responses to DRC's Round 1 interrogatories for the White Mesa Reclamation Plan Rev. 5.0 and the ICTM Report (EFRI, 2012a, b). 1.1 Project Background The White Mesa Uranium Mill (Mill) is located in San Juan County in southeastern Utah, approximately 6 miles south of Blanding, Utah. The site is located on White Mesa, a flat area bounded on the east by Corral Canyon, to the west by Westwater Creek, and to the south by Cottonwood Canyon. A site location map is shown in Figure 1-1. The Mill is located at an elevation of 5,600 ft above mean sea level. EFRI facilities consist of a uranium processing mill and five lined tailings/process solution storage cells located within an approximately 686-acre restricted area. The tailings cells are located south ofthe Mill and comprise the following: • Cell 1-55 acres, used for the evaporation of process solutions • Cell 2-65 acres, used for storage of barren tailings sands (which has been filled with tailings sands and covered with a minimum of approximately 3 feet of interim cover across the cell) • Cell 3-70 acres, used for storage of barren tailings sands (which has been partially covered with a minimum of approximately 3 feet interim cover, and across the majority of the cell, except the center of the cell which is currently receiving mill waste in the center of the cell) • Cell 4A - 40 acres, used for storage of barren tailings sands and evaporation of process solutions • Cell 4B - 40 acres, currently being used for evaporation of process solutions The Mill was initially licensed by the United States Nuclear Regulatory Commission (NRC) in August 1979, and the tailings system was licensed in May 1980 under NRC Source Material License No. SUA-1358. After the State of Utah became an Agreement State for uranium mills in August 2004, the NRC license was replaced with the current State of Utah License (License) and the Ground Water Discharge Permit (GWDP). EFRI (formerly Denison Mines (USA) Corp.) submitted an application to DRC for License renewal on February 27, 2007 and for renewal of the GWDP on September 2, 2009. Updated GWDP renewal applications were submitted in 2012 and 2014. Among the documents submitted to DRC in support of the license and permit renewals, the most recent EFRI documents reviewed by DRC for the license renewal include the Reclamation Plan, Revision 5.0 (Denison, 2011) and the ICTM Report (MWH, 2010). The ICTM Report was originally submitted in support of the GWDP renewal. DRC provided interrogatories for these documents in March Energy Fuels Resources (USA) Inc. 1 MWH Americas, Inc. October 201'AMarch 2015 .© MWH Tailings Data Analysis Report 2012 (DRC, 2012a, b) in regards to the license renewal. EFRI provided responses to these interrogatories for the Reclamation Plan, Revision 5.0 in May and August 2012 (Denison, 2012a; EFRI, 2012a) and for the Revised ICTM Report in May and September 2012 (Denison, 2012b; EFRI, 2012b). DRC provided review comments on EFRI's responses in February 2013 (DRC, 2013a, b). On April 30, 2013, EFRI, DRC, MWH, and URS Corporation (URS) met at URS' office in Denver, CO to discuss specific issues identified in DRC's February 2013 review comments, including DRC's request for site-specific tailings data. EFRI proposed a tailings investigation to address the request for additional information and committed to provide DRC with a work plan for the investigation. The initial work plan for the proposed tailings investigation (MWH, 2013a) was provided to DRC on June 24, 2013. DRC provided comments on the work plan in a letter dated July 2, 2013 (DRC, 2013c). A revised work plan (MWH, 2013b) and responses to DRC comments (MWH, 2013c) were provided to DRC on August 1, 2013. DRC provided approval of the work plan verbally to EFRI on September 12, 2013 (documented in EFRI, 2013). Prior to starting the investigation, MWH provided a final update to the work plan to EFRI on October 10, 2013 (MWH, 2013d). The final update included the following procedural revisions: 1) improved sample handling and shipping procedures, 2) replacement of the recommended geotechnical laboratory with two alternative certified laboratories (due to the previously listed | laboratory no longer having a valid radioactive materials license), 3) added text to note thethat settlement had been checked prior to the investigation, and 4) updated schedule for the field investigation. At the request of DRC, EFRI submitted draft tailings investigation data on August 22, 2014 to DRC. DRC provided review comments on the draft data to EFRI on September 24. 2014. EFRI submitted a Tailings Data Analysis Report on October 17, 2014. The report addressed DRC's September 24, 2014 data review comments. DRC provided review comments on the October 2014 report on January 22, 2015. This report includes revisions to the October 2014 Tailings Data Analysis Report to address DRC's January 2015 review comments. 1.2 Historical Tailings Data Previous geotechnical data collected on tailings at the White Mesa site was provided in Denison (2009). The testing was limited to testing on samples collected from ore grinding prior to mill operation and a few bulk tailings samples collected after operations commenced. CSM (1978) conducted gradation testing on 9 tailings samples from grinding tests. The results for percent passing the No. 200 sieve ranged from 30 to 47 percent. Chen and Associates (1987) conducted specific gravity, Atterberq limits, standard Proctor, and percent passing the No. 200 sieve tests on one bulk tailings sample. Western Colorado Testing (1999) performed testing on 6 tailings samples (2 samples from Cell 2 and 4 samples from Cell 3). Testing included specific gravity, Atterberg limits, standard Proctor, and percent passing the No. 200 sieve. The range of percent passing the No. 200 sieve for the 1987 and 1999 testing was 23 to 83 percent, with an average of 43 percent. This historic data will be considered for future technical analyses as a subset of the tailings data in this report. Water level data is available at the sump location in Cell 2. Surface water levels were measured for Cell 3. There is no additional water level instrumentation (i.e. piezometers) in the remaining areas ofthe cells. Water levels in the Cell 2 sump have been measured since January 2009, and have been decreasing by an average of 0.8 feet/year since the start of dewatering. The water level Energy Fuels Resources (USA) Inc. 2 MWH Americas, Inc. October 2014March 2015 MWH- Tailings Data Analysis Report elevation for the Cell 2 sump during time period ofthe tailings investigation (October 2013) was 5596.4 feet. This compares with the top of saturation levels in Cell 2 at CPT locations near the Cell 2 sump ranging from elevation 5603 to 5604 feet. Surface water levels were measured for Cell 3 from January 2001 through the spring of 2011. Additional mill waste has been added to Cell 3, but additional tailings process solutions have not been added since the beginning of 2009. Interim cover was placed over the majority of Cell 3. Surface water level elevations after 2009 ranged from 5600 to 5605 feet. Since dewatering in Cell 3 has not yet been started, 2010-2011 surface water level readings would be similar to the water level in the tailings during the tailings investigation. This is consistent with top of saturation levels in Cell 3 CPT testing ranging from approximate elevation 5600 to 5605 feet. 4.4*1.3 Objectives of Tailings Investigation The objectives of the tailings investigation (outlined in the October 2013 work plan) are listed below: • Address the DRC request for site-specific tailings data • Characterize the tailings to clarify the tailings stratigraphy and measure the physical properties associated with tailings consolidation, settlement, and pore water drainage • Conduct tailings characterization with Cone Penetration Test (CPT) soundings, direct push sampling, and geotechnical laboratory testing on selected representative tailings samples • Conduct the CPT soundings and sampling in areas of Cells 2 and 3 that are accessible for exploration, and in a manner that does not damage the underlying drainage and liner system in the cells The tailings objectives of the tailings investigation focused on obtaining information on the tailings from the CPT soundings and direct push sampling. Evaluation of the interim cover material was not included as part of the tailings investigation. The intent of the tailings investigation was to provide site-specific tailings data as reguested bv the DRC. The interim cover material has been evaluated extensively as documented in Denison (2011) and EFRI (2012a). The installation of monitoring instrumentation was also not included as part of this tailings investigation. 1.4 Objective of Tailings Data Analysis Report The objective of this report is to present the results ofthe tailings investigation. The October 2013 work plan listed the following items to be included in this report: • A site plan showing the CPT soundings and direct push sampling locations • Presentation of field results including raw data outputs from the CPT measurements (i.e. tip resistance, friction ratio, dynamic pore pressures, and pore pressure dissipation readings) > Presentation of laboratory testing results • Interpretation of results including correlation of CPT and direct push samples, estimation of water levels, and development of subsurface profiles Energy Fuels Resources (USA) Inc. I 3 MWH Americas, Inc. October 201 IMarch 2015 Tailings Data Analysis Report » A summary of estimated soil properties based upon CPT soundings using established correlations and direct push sampling information The results of this investigation will be used to update technical analyses to address DRC review comments on the Reclamation Plan Revision 5.0 and the revised ICTM Report. Although the data presented in this report will be used for these future technical analyses, it is not the intent of this report to provide specific recommendations on how tailings properties will be selected for each type of analysis. .© MWH Energy Fuels Resources (USA) Inc. 4 MWH Americas, Inc. October 2014March 2015 © MWH Tailings Data Analysis Report 2.0 TAILINGS INVESTIGATION The tailings investigation within Cells 2 and 3 was conducted between October 15 and 23, 2013 and included CPT soundings followed by direct push sampling to calibrate the CPT results and collect samples for geotechnical laboratory testing. The remaining cells (Cells 1, 4A and 4B) could not be accessed with the CPT rig. Cell 1 and 4B contain process solutions only. Cell 4A is partially filled with tailings and process solutions, with a small portion of the tailings beach | visjfeJerabove the process water level. In addition, there is a small area in the center of Cell 3 that could not be accessed with a CPT rig. This inaccessible area was receiving mill waste and was not covered with interim cover. The health and safety practices and procedures to minimize exposure of radioactive materials outlined in the work plan were followed during the tailings investigation. 2.1 CPT Soundings Seven CPT soundings at locations adjacent to selected settlement monuments in both Cell 2 and Cell 3 were proposed in the approved work plan (MWH, 2013b). Figure 2-1 shows locations where the CPT soundings were conducted for the field investigation. The locations shown on Figure 2-1 include the same locations proposed in the work plan, as well as locations added during the investigation. Two additional CPT soundings were conducted in Cell 2 between settlement monument 2W6-S and the Cell 2 sump location. These locations were added during the investigation at the request of EFRI to collect additional information on water levels near the sump. In addition, two CPT soundings, CPT-2W3A and CPT-2W4-CA, were added for Cell 2 adjacent to settlement monuments 2W3 and 2W4-C to conduct additional pore pressure dissipation tests at these locations. CPT-3-7S was proposed in the work plan, however debris was encountered and refusal occurred during the CPT probe advancement, as well as at an adjacent location where a second attempt was made (CPT-3-7SA). CPT-3-8S was added during the investigation to replace CPT-3-7S. ConeTec, Inc. (ConeTec) of Salt Lake City, Utah conducted the CPT soundings under supervision by MWH personnel. The CPT soundings were performed in accordance with ASTM D5778-12 and industry standard practices. A compression model electronic piezocone penetrometer, with a 15-cm2 tip and a 225-cm2 friction sleeve was used for the testing. ConeTec used a track-mounted CPT rig to advance the CPT probe into the tailings. The CPT probe was advanced into the subsurface vertically at a constant rate to obtain a continuous profile of the tailings at each location. Upon completion of the sounding, the CPT probe was retracted. The holes partially caved upon retraction, and were then backfilled using bentonite pellets from the ground surface aftdwith bentonite pellets, which were subsequently hydrated. The actual CPT probe depths for the soundings conducted were less than the maximum allowable probe depths provided in the approved work plan (MWH, 2013b) for all the locations except CPT-3-8S, CPT-2W6-S(2), and CPT-2W6-S(3). For these CPT locations added during | the field investigation, the maximum allowable probe depth wasdepths were estimated using the same procedure provided in the work plan and the depths were provided to field personnel prior to conducting the soundings. The intention of recommending a maximum allowable probe depth was to provide a buffer zone to minimize the potential for puncture of the tailings liner system in Cells 2 and 3 during the investigation. The total depth of each sounding is shown on Figure 2-1 and in Table 2-1. For comparison purposes, total thickness contours of interim cover and tailings are provided in Figure 2-2. The total thickness of interim cover and tailings at each CPT location, as well as each settlement monument, are also shown on Figure 2-2. The estimated thickness of interim cover and tailings at each CPT location is greater than the total Energy Fuels Resources (USA) Inc. 5 MWH Americas, Inc. October 201AMarch 2015 MWH Tailings Data Analysis Report depth of the CPT sounding at each location, indicating that no CPT probes came close to the liner. Cone tip resistance, sleeve friction, and dynamic pore pressures were measured at 2-inch intervals for each sounding location. Shear wave velocity measurements were performed for locations was measured at designated in Table 2-1 locations, and the weighted average velocity over the profile is listed in the summary table.Table 2-1. Pore pressure dissipation tests were conducted at select depths based on review of CPT sounding measurements and to assist with | estimating static phreatic levels or pore pressures. A total of 28 pore pressure dissipation tests were conducted, and the results are summarized in Table 2-1. The ConeTec field report with CPT data and field logs for the CPT soundings is provided as Appendix A. Field logs of CPT soundings were obtained electronically in real time during soundings. The log recorded an approximate location and depth (0.2 foot accuracy) of each sounding. The log includes tip and sleeve resistances, pore pressures, and other measured parameters. In addition, the logs contain interpretations of CPT measurements using published correlations (e.g. for soil behavior type). Energy Fuels Resources (USA) Inc. 6 MWH Americas, Inc. October 201 IMarch 2015 MWH Tailings Data Analysis Report Table 2-1 CPT Testing Summary Tailings Cell CPT Sounding Elevation (ft) Latitude/ Longitude CPT Depth (ft) PPD1 Testing PPD Depth (ft) Pore Pressure at PPD Depth (ft) Water Table Calculated from PPD Test (ft) Shear Wave Velocity2 (ft/s) Cell 2 CPT-2W2 CPT-2W3 CPT-2W3A CPT-2W4-C CPT-2W4-CA CPT-2W5-C CPT-2W6-S CPT-2W6-S(2) CPT-2W6-S(3) CPT-2W7-C CPT-2E1 5615.86 37.533317/ -109.512367 20.34 13.94 11.2 5615.72 37.533617/ -109.511300 21.65 18.54 18.4 21.65 24.1 3.12 5615.72 37.533617/ -109.511283 4.43 3.94 4.43 4.2 5616.24 37.533100/ -109.509967 26.57 17.39 12.1 5616.24 37.533100/ -109.509950 9.35 6.07 0.6 9.35 5.2 5615.86 37.532917/ -109.508467 30.18 12.63 11.0 5615.85 37.532183/ -109.507033 29.20 15.09 4.5 29.20 16.9 5614.93 37.532133/ -109.507417 25.59 19.85 7.8 5614.66 37.532050/ -109.507700 25.10 21.65 12.9 5619.60 37.532533/ -109.505300 28.05 15.09 8.5 5619.95 37.532800/ -109.503700 28.05 20.51 11.3 2.8 0.2 3.2 3.9 0.2 5.3 5.5 4.2 1.7 10.6 12.3 12.0 6.5 9.2 459 457 510 606 485 539 530 Notes 1. PPD = pore pressure dissipation 2. Shear wave velocities were measured for the CPT soundings indicated. The velocity values listed are the weighted average over the profile. Energy Fuels Resources (USA) Inc. MWH Americas, Inc. iMarch 2015 MWH Tailings Data Analysis Report Table 2-1 CPT Testing Summary (continued) Tailings Cell CPT Sounding Elevation (ft) Latitude/ Longitude PPD Testing CPT Depth (ft) PPD Depth (ft) Pore Pressure at PPD Depth (ft) Water Table Calculated from PPD Test (ft) Seismic Velocity (ft/s) Cell 3 CPT-3-1S CPT-3-2C CPT-3-3S CPT-3-4N CPT-3-6N CPT-3-7SJ CPT-3-7SA CPT3-8N CPT-3-8S 5612.56 37.530767/ -109.515350 17.88 12.80 8.2 4.6 5610.82 37.532400/ -109.513783 20.34 12.47 6.9 5.5 5609.63 37.530600/ -109.514433 23.79 18.86 14.9 4.0 5608.70 37.530600/ -109.514467 21.16 13.12 13.8 21.16 18.5 2.7 5607.44 37.531933/ -109.511650 18.54 8.86 5.6 3.2 18.54 15.3 3.2 5607.63 37.531330/ -109.508800 8.04 No PPD Test 5607.63 37.529600/ -109.508067 10.01 9.02 5608.37 37.529783/ -109.505833 15.26 10.01 3.94 5608.70 37.529050/ -109.504883 15.26 6.07 15.26 9.4 6.5 4.6 0.8 10.2 3.5 5.3 5.1 488 463 549 369 41! 51! 494 Notes 1. PPD = pore pressure dissipation 2. Shear wave velocities were measured for the CPT soundings indicated. The velocity values listed are the weighted average over the profile. 3. Refusal at 8 and 10 feet for CPT-3-7S and CPT-3-7SA, respectively. CPT-3-8S added to replace this location. Energy Fuels Resources (USA) Inc. 8 MWH Americas, Inc. October 201AMarch 2015 © MWH Tailings Data Analysis Report 2.2 Direct Push Sampling Direct push sampling was completed after the CPT soundings. ConeTec performed the direct push sampling under the direction of MWH personnel. It was proposed in theThe approved work plan to havelisted two direct push sampling locations per tailings cell (four total)), which were to be selected during the field program based on the results of the CPT soundings. Direct push sampling was actually conducted at the nine sampling locations shown on Figure 2-2. The locations were selected to span the range of material responses (e.g. pore pressures, soil behavior types) measured during CPT testing, as well as to provide sufficient tailings samples for laboratory testing. Samples depths were selected based on review ofthe CPT results. -In the work plan, approximately 30 6-inch long samples were to be collected based on the direct push sampling freguency and laboratory testing program. A total of 49 samples were collected. 46 samples were selected for testing, and 38 of the samples had lengths of 6 inches or greater. Piston-type samplers were used to collect relatively undisturbed samples without generating soil cuttings. The direct push samplers were deployed from the CPT rig. The samplers have 1.5- | inch inner diameters and are 24 or 36 inches in length. The soil sampler was initially pushed in a "closed" position to the desired sampling interval. The inner cone tip portion of the sampler was then retracted leaving a hollow sampler with an inner liner containing soil sample tubes (1.5 inches in diameter). The hollow sampler was then pushed in a locked "open" position to collect a soil sample. The filled sampler and push rods were then raised to the ground surface. Upon completion of direct push sampling, the sampler was retracted, retrieved to the ground surface. The holes partially caved upon retraction, and were then backfilled from the ground surface with bentonite pellets, which were subseguently hydrated. Each sample was assigned a designation based on the tailings cell number, site location, and the depth interval. The sample designation and date was recorded on the sample tube. Each sample tube had the end caps secured with wax. The original field logs recorded the depths of samples from the bottom of the sample run. The sample depths have been revised on the logs to represent depth from the top of the sample run. This revisions is documented in the notes. In addition, the sample designations provided to the laboratory have been revised in the laboratory report. A sampling loo was recorded for each direct push location. The loos are provided in Appendix B. Photographs of the collected samples are provided as Appendix C_Upon completion of direct puoh sampling, tho oamplor wao rotractod.—The holes partially caved upon retraction, and were then backfilled using bentonite pellets from tho ground surface and hydrated. The primary objective ofthe direct push sampling was to provide site-specific correlation of CPT results. Samples collected were shipped via UPS to S&ME, Inc. (S8cME) in Knoxville, Tennessee. Handling and shipping of samples was conducted in accordance with EFRI standard procedures for the Mill.White Mesa standard procedures. Samples were wrapped in multiple layers of bubble wrap and placed in a vertical axial orientation (i.e. upright) in 5-gallon buckets. Packing materials were added to the buckets to limit the potential for shifting of the samples while in transit to the laboratory. This was consistent with the sample handling procedure in the work plan. Due to the radioactive classification of the tailings samples, no other shipment method (such as shipment by air) was possible. Geotechnical laboratory testing was conducted on selected samples and the results are summarized in Section 3. A sampling log wao recorded for each diroct puoh location. The logc arc provided in Appendix B. Photographs of samples collected are provided as Appendix C. Energy Fuels Resources (USA) Inc. 9 MWH Americas, Inc. October 201 AMarch 2015 MWH Tailings Data Analysis Report Energy Fuels Resources (USA) Inc. 10 MWH Americas, Inc. October 2014March 2015 Q MWH Tailings Data Analysis Report 3.0 LABORATORY INVESTIGATION Geotechnical laboratory testing was conducted on selected samples collected during the tailings investigation. Laboratory testing was conducted by S&ME in Knoxville, Tennessee. S&ME has a currentwas selected for the testing at that time because: (1) they had an active radioactive materials license for geotechnical testing of radioactive soil samples, materials with low levels of radionuclides, and (2) had the capabilities to provide the reguired geotechnical tests. S&ME was listed as a potential geotechnical laboratory for the tailings samples in the f4na4 version of the work plan provided to EFRI on October 4-0^2013 work plan. This laboratory, as well as CB&I Federal Services, LLC, were added to the work plan to replace Advanced Terra Testing, Inc. as potential testing laboratories after Advanced Terra Testing, Inc. informed MWH that their radioactive materials license was currently in the process of being renewed and would not be valid at the time of the investigation. -At the time of the field investigation, further discussions with CB&I Federal Services indicated they would not be able to provide consolidation testing for the project and were removed from consideration. Samples were shipped to S&ME in mid-November 2013 after their receipt and review of the radiological survey data on the adjacent tailings samples collected by EFRI during the October 2013 field investigation. Review of the radiological survey data is a reguirement for S&ME's radioactive materials license. Initial geotechnical testing consisted of index testing for use in classifying the tailings. Samples were then selected for permeability and consolidation testing based on tailings classification. Laboratory testing was conducted over several months, due to the limited number of available consolidation and permeability test cells. Laboratory tests included natural water content, in-situ dry density, grain-size analysis (sieve and hydrometer), Atterberg limits, specific gravity, hydraulic conductivity, and consolidation | testing:—The number and type of tests are, as summarized in Table 3-1. The actual testing schedule is similar to the anticipated testing schedule in the approved work plan. The actual testing schedule was updated from the schedule listed in the approved work plan based on review of actual samples collected. The tested samples were selected to seancharacterize the range of tailings materials encountered and to provide a site-specific correlation of CPT sounding results. All laboratory testing was conducted according to applicable ASTM standards. A detailed summary of the results (Table D-1) and the S&ME laboratory testing report are provided in Appendix D. The test results are summarized in Table 3-2 by tailings type (i.e. sand, sand-slime, and slime). Evaluation of tailings type is discussed in Section 4.1. Energy Fuels Resources (USA) Inc. 11 MWH Americas, Inc. October 201 AMarch 2015 © MWH Tailings Data Analysis Report Table 3-1 Geotechnical Laboratory Testing Schedule Geotechnical Laboratory Test No. of Tests ASTM Standard Natural Moisture Content and Density 34 ASTM D2216 and D2937 Particle Size (sieve and hydrometer) ASTM D422 Particle Size (sieve and No. 200 wash) 11 ASTM D6913 Particle Size (No. 200 wash) ASTM D6913 Specific Gravity ASTM D854 Atterberg Limits 13 ASTM D4318 Permeability Test ASTM D5084 Consolidation Test ASTM D2435 Previous tailings laboratory testing data (Chen and Associates. 1987; Western Colorado Testing, 1999) were within the range of laboratory testing results for the October 2013 tailings investigation. The average percent passing the No. 200 sieve from the limited amount of previous testing is 43 percent. The average percent passing the No. 200 sieve from the October 2013 investigation is 50 percent. The collected tailings sample diameters (1.4 inches) were within the expected sample diameter range listed in the work plan (1.0 to 1.5 inches). For the consolidation testing, this sample diameter is smaller than the minimum diameter recommended per ASTM D2435 (2.0 inches). However, some studies indicate that a reduction in diameter from 2.4 to 1.2 or 1.4 inches for fine-grained soils has an insignificant impact on measured consolidation parameters (Kongkitkul et al, 2014; Shogaki, 2006). In addition, the measured consolidation parameters for the tailings samples tested were within the expected range for uranium tailings as discussed in Section 4.5. It is likely that gypsum is present in the tailings at White Mesa, based on the ore geology and the acid leach process used in the mill. However, the laboratory testing procedures were not modified to account for gypsum. This is consistent with tailings characterization testing conducted at other uranium tailings facilities under Uranium Mill Tailings Remedial Action (UMTRA) work for the U.S. Department of Energy (DOE). If The hydroscopic nature of gypsum is present in the tailings, testing results can result in erroneously high measured water contents using standard test methods. ASTM D2216 suggests drying soil samples containing gypsum at a lower oven temperature (60 degrees Celsius) than using the standard oven temperature (110 degrees Celsius). For a recent example, uranium tailings samples collected from the Church Rock Uranium Mill site were tested for moisturewater content using both oven temperatures. Water contents measured at 60 degrees Celsius were about 0.5 to 3.0 percent lower than water contents measured at 110 degrees Celsius (MWH, 2014). The resulting specific gravity showed an insignificant (less than 0.01 percent) difference between samples tested using the lower oven temperature versus the standard oven temperature (MWH, 2014). Since the acid leach process at the Church Rock Mill site was similar to the White Mesa Mill, similar variations in water content and specific gravity would be measured on the White Mesa tailings between the two oven temperatures. Energy Fuels Resources (USA) Inc. 12 MWH Americas, Inc. October 201 AMarch 2015 MWH Tailings Data Analysis Report Saturated tailings thicknesses were estimated using CPT testing results, and natural moisture contents were onlv measured as a check for estimating the saturated tailings thicknesses. It is not expected that natural moisture contents will not be used in any future technical analyses for the Reclamation Plan and ICTM Report. Testing results for particle size distribution (using the hydrometer) and for the No. 200 sieve wash can show higher values of natural moisture content and fines content using standard testing methods than sample preparation and testing procedures modified to account for gypsum. Saturated tailings thicknesses woro estimated using CPT testing results, and natural moisture contents wore measured as a check for estimating the saturated tailings thicknesses. Use of higher natural moisture contents for this evaluation would result in conservatively high saturated tailings thicknesses. In addition, tho results of this evaluation would not change if the natural moisture contents woro reduced.—Natural moisture contents will not be used in any future technical analyses for the Reclamation Plan and ICTM Report. The measured percent fines for the tailings samples were used with the CPT test results to classify the tailings (see Section 4.1). The tailings were classified using the method from Larson and Mitchell (1986) based on measured laboratory and CPT data for uranium tailings from numerous sites. The measured laboratory data used for the Larson and Mitchell (1986) study did not account for | gypsum in the tailingsT (Ned Larson, personal communication, February 9, 2015). Therefore, the tailings classification for the White Mesa tailings would not change if the hydrometer testing were modified to account for gypsum. The measured percent fines of the tailings will be used for liquefaction analyses, but is not planned to be used for any other technical analyses for the Reclamation Plan and ICTM Report. A reduction in the percent fines to account for gypsum in the tailings would not significantly affect the tailings liquefaction analysis results. DRC (2014) reguested review of the results of the percent passing the No. 200 test using ASTM D1140 prior to using ASTM D422 for the 11 samples tested with both procedures. The results showed a higher percent passing the No. 200 sieve with the subseguent sieve analysis (ASTM D422). This is expected with additional interaction with the deflocculant and mechanical shaking for the sieve analysis. An average increase of 5 percent for percent passing the No. 200 sieve was measured between the initial No., 200 wash test (ASTM D1140) and the subseguent sieve analysis (ASTM D422). The standard deflocculant (sodium hexametaphosphate) at the standard ASTM recommended concentration (4 percent) was used for the recommended ASTM standard duration (2 to 16 hours). Because no additional or different deflocculant was added to account for the presence of gypsum, gypsum in the solution would flocculate resulting in a higher measured percentage of larger particles for the initial No. 200 wash. The subseguent testing using ASTM D422 would allow for breakdown of the a portion of the remaining gypsum during shaking. The test results from the subseguent sieve analysis (ASTM D422) were reported for the percent passing No. 200 sieve results and were used for tailings classification. Energy Fuels Resources (USA) Inc. 13 MWH Americas, Inc. October 201 AMarch 2015 © MWH Tailings Data Analysis Report Table 3-2 Summary of Laboratory Testing Results3 Tailings Type % Finer than No. 200 Sieve Natural Water Content (%) In-Situ Dry Density (pcf) Atterberg Limits (%)° LL PL PI Specific Gravity Hydraulic Conductivity (cm/s) Consolidation Properties' cv 9 (cm/s) Sand 18 (11.2-29.2) 27 (25.5-29.2) 97 (93.5-98.3) Not Tested Not Tested Not Tested Not Tested Sand- Slime 47 (34.2-58.1; 35 (13.2-71.6) 88 (56.2-114.4) 34 (26 - 54) 23 (19-30) 10 (6-24) 2.80 (2.77-2.84) 9.0E-076 (1.6E-07-3.3E-06) 0.32 (0.11 -0.66) 0.001 (0.0005 • 0.002) Slime 71 (60.2 - 97.0) 41 (29.3-63.8) 78 (61.0-94.6) 41 (31-68) 26 (23 - 36) 16 (7-32) 2.86° (2.85-2.86) 1.3E-06ae (1.7E-07-9.8E-06) 0.28d (0.27-0.28) 0.002a (0.0005 - 0.003) Notes: a. Average laboratory values shown in table with ranges shown in parentheses b. Sand tailings (0 - 30% fines); Sand-slime tailings (30 - 60% fines); Slime tailings (60 - 100% fines) (adjusted from ranges defined in Larson and Mitchell, 1986) c. NP = non-plastic; LL = liquid limit (%); PL = plastic limit (%); PI = plasticity index (%) d. Two samples tested. e. Geometric mean f. Cc = compression index; cv = coefficient of consolidation g. cv value estimated from linear portion of consolidation curve cm/s = cubic meters per second, pcf = pounds per cubic foot Energy Fuels Resources (USA) Inc. 14 MWH Americas, Inc. October 2014March 2015 O MWH Tailings Data Analysis Report 4.0 TAILINGS CHARACTERIZATION CPT field data and laboratory testing results were used to characterize the tailings at the White Mesa site. Material properties estimated based on this data will be used in technical analyses to address DRC review comments on the Reclamation Plan Revision 5.0 and the revised ICTM Report. Appendix E includes figures used to assist with interpreting the CPT and laboratory data. 4.1 Tailings Classification A number of criteria have been used for classifying soil types from CPT measurements, including the method by Lunne, Robertson, and Powell (1997). This method is -based on soil behavior type zones, and is used by the CPT contractor, ConeTec. The soil behavior types used by Lunne, Robertson, and Powell (1997) include a range of types including sensitive fine- grained material, organic material, gravelly sand, sand, silty sand, sandy silt, clayey silt, silty clay, clay, and overconsolided or cemented material. The criteria used to categorize the tailings for this investigation were based upon criteria used by the DOE for interpreting CPT tests | specifically in uranium tailings (Larson and Mitchell, 1986). As noted in Larson and Mitchell (1986), classification of tailings using soil behavior type zones similar to the method by Lunne, Robertson, and Powell (1997) result in a higher level of uncertainty than the classification method presented in Larson and Mitchell (1986). Therefore, the DOE criteria, and not the soil behavior types method was used to classify the tailings. Soil behavior type in the CPT results report (Appendix A) was not used for tailings classification. The DOE criteria as outlined in Larson and Mitchell (1986) divide uranium tailings into the three general categories based upon the percentage of material finer than the No. 200 sieve (% fines) by weight as follows: • Sand Tailings (0 to 30 percent passing the No. 200 sieve) • Sand-Slime Tailings (30 to 70 percent passing the No. 200 sieve) • Slime Tailings (70 to 100 percent passing the No. 200 sieve) The use of other index parameters, such as Atterberg limits and density, are not included in defining these categories. The DOE criteria provide a correlation between CPT results, specifically the cone tip resistance and the side-friction/tip-resistance ratio, and these three tailings classifications. This correlation from Larson and Mitchell (1986) is shown on Figure E.1-1 in Appendix E. This correlation is based on 87 tailings samples analyzed for 5 uranium mill tailings sites. CPT data from the White Mesa tailings investigation are shown on the graph for locations where laboratory data is also available. The data points are designated as sand, sand-slime, or slime tailings based on their respective laboratory—measured percent passing the No. 200 sieve resultsr (on 20 samples). The measured percent passing the No. 200 sieve value is shown adjacent to each data point. As shown in Figure.1-1, the figure, thetailings classifications based on percent passing the No. 200 sieve do not fit with the general CPT result categories in Larson and Mitchell (1986). The samples classified as sand tailings based on percent fines fall within the sand-slime tailings | range of the graph (neglectingcategory, except for the one outlier sample fesu4t)rwith 29% Energy Fuels Resources (USA) Inc. 15 MWH Americas, Inc. October 201AMarch 2015 MWH • Tailings Data Analysis Report passing the No. 200 sieve which falls on the sand-slime/slime cutoff line. The samples classified as sand-slime tailings based on percent fines fall within both the sand-slime and slime tailings fanoescateqories on the graph. The samples classified as slime tailings based on percent fines fall within the slime tailings rangecategory on the graph. Correlation with the laboratory results for percent fines and the Larson and Mitchell (1986) graph indicate that better site-specific correlation would be obtained if the material definitions based on percent fines were modified and the curves adjusted so that the sand/ and sand-slime tailings are combined and the sand-slime/slime cutoff is shifted. This adjustment is consistent with ASTM D5778 for CPT of soils, which recommends the collection of samples from adjacent borings to CPT soundings be used to provide site specific correlations to CPT data. The recommended modifications to the classifications for the White Mesa tailings are listed below and Figure E.1-2 shows the data points classified using this criteria on the adjusted graph. • Sand Tailings (0 to 30 percent passing the No. 200 sieve) • Sand-Slime Tailings (30 to 60 percent passing the No. 200 sieve) • Slime Tailings (60 to 100 percent passing the No. 200 sieve) Figure E.1-3 and Figure E.1-4 show all the CPT data (cone resistance versus friction ratio) for Cells 2 and 3, respectively, along with the adjusted graph for denoting the division between sand/ and sand-slime-and/ slime tailings. Using these figures, approximately 2025 percent of the tailings are categorized as slime tailings and the remainder isare categorized as sand and sand-slime tailings for both Cell 2 and Cell 3. Figure E.1-5 through Figure E.1-20 show the CPT data (cone resistance versus friction ratio) for each CPT location and the recommended sand/ and sand-slime—and/ slime tailings division. These figures indicate a range of approximately 5 to 5Q%60 percent tailings slimes feffrom the CPT soundings in both Cell 2 and Cell 3. Using the tailings classification provided in Figure E.1-2, the tailings profiles were developed for each CPT location and are shown in Figures E.1-21 through Figure E.1-37. A layer of interim cover is shown at the top of each profile. The CPT soundings show evidence of this interim cover, which has higher tip resistance than the underlying tailings. A minimum of 3 feet of interim cover has already been placed in covered areas and this is consistent with the estimated thickness shown on the profiles. Profiles showing the tailings layers classified based on laboratory testing are shown for locations where direct push sampling was conducted. The tailings samples were classified according to the percent passing the No. 200 sieve as sand tailings (0 to 30 percent fines), sand-slime tailings (30 to 60 percent fines), and slimes (60 to 100 percent fines). Figure 4-3 through Figure 4-5 show sections through Cells 2 and 3 and include tailings profiles developed from the CPT results. Review of these figures, as well as the boring logs and laboratory results indicate there is significant interbedding and minimal segregation of tailings within each cell. This is expected, since the tailings discharge points in Cells 2 and 3 were located throughout the cells and not just along the perimeter. The tailings in Cells 2 and 3 also appear to be similar in particle size distribution and other geotechnical characteristics. The tailings within Cells 2 and 3 were processed from similar ores and using the same crushing, grinding and processing procedures. The tailings within Cells 2 and 3 are expected to be relatively uniform based on tailings deposition history and tailings processing procedures. Energy Fuels Resources (USA) Inc. 16 MWH Americas, Inc. October 201AMarch 2015 © MWH Tailings Data Analysis Report 4.2 Pore Pressures Both CPT pore pressure dissipation tests and dynamic pore pressure measurements were evaluated to estimate the top of the saturated tailings zone. Equilibrium pore pressures measured during pore pressure dissipation tests often yield values that are higher than actual steady-state pore pressure at the specific location and depth. Figure E.2-1 through Figure E.2- | 16 show pore pressure versus elevation for-results from the CPT soundings. Dynamic pore pressures and the results from the pore pressure dissipation tests are shown on the figures. The estimated elevation of the top of the saturated tailings shown on the figures was selected as the depth where continuous elevated dynamic pore pressures were encountered. Hydrostatic pore pressures with depth are shown on the figures and were used to assist with estimating the too of the saturated tailings bv evaluating the trend of pore pressures below this depth. The estimated elevations of the top of the saturated tailings at the CPT locations are listed in Table 4-1 and shown in Figure 4-1. Figure 4-2 shows the estimated saturated tailings thicknesses. Dynamic pore pressures typically represent the upper bound of the actual equilibrium pore pressures since they are the sum of the equilibrium pore pressure and excess pore pressures due to shearing. The pore pressures due to shearing are usually positive unless the tailings are | heavily overconsolidatedT (i.e. overconsolidation ratio, OCR, greater than 4). There are some thin zones within the saturated tailings where dynamic pore pressures are less than hydrostatic pressures, indicating potential heavily overconsolidated lensesrzones. Overall, the dynamic pore pressure results indicate the tailings are primarily normally consolidated to slightly overconsolidated. Laboratory results for tailings samples tested for consolidation show all samples have OCRs less than 4. It should be noted that the values for preconsolidation pressure listed in the laboratory reports were incorrectly determined and should not be used. Using the traditional Casagrande method to estimate preconsolidation pressures, OCRs range from less to 1 to approximately 3, which indicates the tailings are not dilative. There are also some lenses of elevated pore pressures at shallow depths, but these are considered perched zones in the interim cover and/or tailings due to seasonal fluctuations, infiltration influences. No data is available, but considering the climate at the White Mesa site, it is likely these perched zones are seasonal versus perennial in naturoMydrostatic poro prossuroo with dopth aro ohown on tho figuroc and woro uood to oooiot with ootimating tho top of tho ooturatod tailingo by ovaluating tho trond of poro prossuroo bolow this dopth. Tho ootimatod olovationo of tho top of tho saturated tailingo at tho CPT locations aro liotod in Tablo 1 1 and shown in Figuro 1 1. Figuro 1 2 shows tho ostimatod saturatod tailingo thicknoosoo. Figure 4-6 is provided as an example of how the elevation of the top of saturated tailings was estimated for a CPT location. Figure 4-6 presents the dynamic and static pore pressures measured for CPT-2W3 and CPT-2W3A. As shown in the figure, upper bound and lower bound hydrostatic pore pressures were estimated based on 5 pore pressure dissipation tests. The upper bound hydrostatic line (with a water level at the ground surface elevation) does not represent field conditions. The ground surface in Cell 2 was visually dry during the tailings investigation. In addition, thick zones within the tailings with negative pore pressures is not expected. The lower bound hydrostatic line corresponds fairly well with the trend of the dynamic pore pressures with depth. This lower bound line, along with the trend in dynamic pore pressures, were used to estimate the selected elevation of the top of saturated tailings. As shown in Figure 4-1, the top of saturated tailings elevation is lower for locations closer to the Cell 2 sump, indicating migration of water towards the sump in Cell 2. For Cell 3, the top of saturated tailings elevations range from approximately 5603 to 5606 feet. Dewatering has not yot started inThe Cell 3; therefore, it is expected that the tailings would have a relatively Energy Fuels Resources (USA) Inc. I 17 MWH Americas, Inc. October 201 AMarch 2015 © MWH Tailings Data Analysis Report consistent top of saturated tailings elevation since dewatering has not been started. EFRI measured water level elevations in the Cell 3 sump through the spring of 2011. The water level elevations measured during 2010 through 2011 ranged from 5600 to 5605 feet, and were similar to the top of saturated tailings elevation estimated from the recent tailings investigation. Additional mill waste has been added to Cell 3, but additional process solutions have not been added; therefore it is reasonable to assume that the past water level readings are similar to the top ofthe saturated tailings elevations estimated from the field investigation. Table 4-1 Estimated Elevation of Top of Saturated Tailings Tailings Cell CPT Sounding CPT Sounding Ground Surface Elevation (ft) Estimated Depth to Top of Saturated Tailings (ft) Estimated Elevation at Top of Saturated Tailings (ft) CPT-2W2 5615.86 C PT-2 W3/C PT-2W3A 5615.72 CPT-2W4-C/CPT-2W4-CA 5616.24 CPT-2W5-C 5615.86 Cell 2 CPT-2W6-S 5615.85 CPT-2W6-S(2) 5614.93 CPT-2W6-S(3) 5614.66 CPT-2W7-C 5619.60 CPT-2E1 5619.95 3.9 4.3 8.9 10.0 11.5 11.0 11.5 9.2 11.2 5611.96 5611.42 5607.34 5605.86 5604.35 5603.93 5603.16 5610.40 5608.75 CPT-3-1S 5612.56 CPT-3-2C 5610.82 CPT-3-3S 5609.63 Cell 3 CPT-3-4N 5608.70 CPT-3-6N 5607.44 CPT3-8N 5608.37 CPT-3-8S 5608.70 5.6 3.8 3.8 4.2 3.5 5.2 5603.86 5605.22 5605.83 5604.90 5603.24 5604.87 5603.50 4.3 Tailings Density | Density testing was porformedTailings densities were measured on sand, sand-slime and slime tailings samples collected from the direct push sampling. The testing results were presented in | Table 3-2 and are summarized below in Table 4-2. Figure E.23-1 and Figure E.23-2 show laboratory-measured total and dry density values versus depth, respectively. The data points are designated as sand, sand-slime, or slime tailings based on the modified criteria provided in Section 4.1. The range of measured densities is also shown on the figures. The figures indicate that there is not a relationship for density with depth. Density values for sand tailings samples are typically higher than for slime tailings samples. Density values for sand-slime tailings vary across the total range of measured values for all tailings types. Figure E.23-3 through Figure E.23-10 show laboratory measured total and dry density versus depth for each CPT location where samples were collected to measure in-situ densities. These figures also indicate that there is not a clear increase in density of tailings with depth. Energy Fuels Resources (USA) Inc. 18 MWH Americas, Inc. October 201 AMarch 2015 MWH Tailings Data Analysis Report Energy Fuels Resources (USA) Inc. MWH Americas, Inc. 19 October 2011 March 2015 © MWH Tailings Data Analysis Report Table 4-2 Summary of In-Situ Tailings Density from Laboratory Testing Tailings Type3 Sand Sand-Slime Slime Average In-Situ Dry Densityb (pcf) 97 (93.5-98.3) 88 (56.2-114.4) 78 (61.0-83.6) 86 In-Situ Total Density" (pcf) 123 (120.8- 124.9) 114 (96.4- 129.5) 108 (98.4-122.7) 112 Notes: a. Sand tailings (0 - 30% fines); Sand-slime tailings (30 - 60% fines); Slime tailings (60 - 100% fines) (adjusted from Larson and Mitchell, 1986) b. Average laboratory values with ranges shown in parentheses, pcf = pounds per cubic foot Total density was estimated from CPT data using 1) the relationship provided in Robertson and Cabal (2012) for a correlation with friction ratio and cone resistance, and 2) the relationship provided in Lunne et al. (1997) for a correlation with the CPT soil behavior type index. The dry density was calculated using the total unit weight and the average measured specific gravity of 2.82 for locations where the tailings are expected to be saturated. Comparisons of laboratory measured dry density versus estimated dry density values from the CPT data using Robertson and Cabal (2012) and Lunne et al. (1997) are shown on Figure E.2-11 and Figure E.2-12, respectively. The results indicate that neither relationship provides a good correlation with measured data at the same depths. Laboratory measured dry density values were also plotted versus CPT measured values for cone resistance and friction ratio in Figure E.2-13 and Figure E.2-14, respectively. These figures indicate that there is not a direct relationship between CPT cone resistance or friction ratio with in-situ dry densities for this data. Since a reliable correlation between the CPT data and in-situ density was not developed, the average measured tailings densities listed in Table 4-3 should be used with materials classified according to Figure E.1-2. Table 4-3 RecomtnemtedAveraqe Measured Tailinc Tailings Type Sand/Sand-Slime Slime Dry Density (pcf) 90 78 s Density Values for-Afia4ys4S Total Density (pcf) 116 108 pcf = pounds per cubic foot 4.4 Hydraulic Conductivity Hydraulic conductivity testing was performed for sand-slime and slime tailings samples collected from the direct push sampling. The testing results were presented in Table 3-2 and are summarized below in Table 4-4. The testing was performed using effective confining pressures ranging from 5 to 12 psi. The confining pressure used for each test was selected based on the estimated overburden pressure for the sample. The geometric mean vertical hydraulic conductivities ofthe sand-slime and slime tailings are similar at approximately 1 x 10"6 cm/s. Energy Fuels Resources (USA) Inc. MWH Americas, Inc. 20 October 2014March 2015 MWH Tailings Data Analysis Report Energy Fuels Resources (USA) Inc. MWH Americas, Inc. 21 October 201AMarch 2015 MWH Tailings Data Analysis Report Table 4-4 Summary of Laboratory Measured Vertical Hydraulic Conductivity Tailings Type Sand-Slime Slime Vertical Hydraulic Conductivity8 (cm/s) 9.0E-07 (1.6E-07-3.3E-06) 1.3E-06 (1.7E-07-9.8E-06) Note: Geometric mean with range of values shown in parentheses, cm/s = cubic meterscentimeters per second The horizontal hydraulic conductivities of the sand-slime and slime tailings were estimated using CPT data and the relationship provided in Robertson and Cabal (2012), based on CPT soil behavior. The results are shown in Table 4-5 for the depths where vertical hydraulic conductivities were measured. The estimated geometric mean horizontal hydraulic conductivities for the sand-slime and slime tailings are similar, with values of 6.84 x 10~6 and 3r56.6 x 10"6 cm/s, respectively. The calculated anisotropy ratio (hydraulic conductivity to vertical hydraulic conductivity) of the sand-slime and slime tailings is on the order of 2 toabout 3 and 5. respectively, excluding the result of 6847 for CPT-2W6-S(3). Table 4-5 Summary of Estimated Horizontal Hydraulic Conductivity from CPT Data Tailings Type Location and Depth Estimated Horizontal Hydraulic Conductivity (cm/s) Laboratory Measured Vertical Hydraulic Conductivity (cm/s) Calculated Hydraulic Conductivity Anisotropy Ratio (horizontal/vertical) CPT-2W2at7.5-8' 3.8E-06 1 4E-06 Sand-Slime CPT-2W3 at 7 - 8r§7.8' 7T4€9JDE- 06 3.3E-06 23 CPT-2W6-S(3) at 4S- 4§^14.5- 15' 44E- O57.6E-06 1.6E-07 §847 Geometric mean 6.SE4E-06 9.0E-07 37 Slime CPT-2W6-S(2) at 43- 43^12.3-12.8' 4£E- O73.2E-06 1.7E-07 319 CPT 2W6 S(3)-6N at 4§- 4§r^5.3-5.8' O51.3E-07 9.8E-06 31 Geometric mean 3rSE6.6E- 06 1.3E-06 35 cm/s = cubic meterscentimeters per second The sand tailings samples did not have sufficient cohesion to be used for specimens for hydraulic conductivity testing. Hydraulic conductivity was estimated using 1) CPT data and the relationship shown in Robertson and Cabal (2012), and 2) measured grain-size analyses and the empirical relationships from Fair-Hatch and Harlman (McWhorter and Sunada, 1977). The results are shown in Table 4-6. Assuming a horizontal to vertical conductivity ratio of approximately 1, the results indicate an isotropic hydraulic conductivity of approximately 43 x 10" 5 to 35 x 10"5 cm/s for the sand tailings. Tho pormoability toot rooulto for tho Whito Mooa sand, oand olimo, and olimo tailingo aro oonoistont with othor publiohod uranium tailingo tost rosults (Koohion and Ragor, 1086). Energy Fuels Resources (USA) Inc. 22 MWH Americas, Inc. October 20MMarch 2015 © MWH Tailings Data Analysis Report Table 4-6 Estimation of Hydraulic Conductivity for Sand Tailings Samples Tailings Cell Sampling Location Sample Depth Interval (ft) % Passing No. 200 Sieve Estimated Hydraulic Conductivity using Fair-Hatch and Harlman relationships (cm/s) Estimated Horizontal Hydraulic Conductivity using CPT data and relationship from Robertson and Cabal (2012) (cm/s) Cell 2 CPT-2E1 43H 7- 17.4' 29.2 1.5.E-05 1.8E 055.6E-06 Cell 3 6.5-7 13.0 4.9.E-05 2-£E-3.3E-04 CPT-3-4N 8.5-9 19.6 2.5.E-05 4^E-8.5E-05 11 - 11.5 11.2 4.8.E-05 2.2E-079E-Q5 Geometric mean 3.1E-05 44E4.6E-05 cm/s : scentimeters per second The permeability test results for the White Mesa sand, sand-slime, and slime tailings are consistent with other published uranium tailings test results (Keshian and Rager. 1986). The specific hydraulic conductivity values to use for analyses will be dependent upon the type of analyses and how the tailings will be modeled. It is expected that the hydraulic conductivities used for the tailings for future analyses will be lower than the estimated hydraulic conductivities used in previous analyses. 4.5 Consolidation Properties Results of laboratory consolidation testing on samples obtained from the direct push sampling were used to estimate consolidation parameters including the compression index (Cc) and the vertical coefficient of consolidation (cv). Cc provides an indication of the amount of compression that can be expected under a change in loading, with higher values of Cc indicating greater compression and larger settlements. The parameter cv provides an indication of the consolidation rate with vertical pore water pressure dissipation, with higher cv values indicating more rapid consolidation. Consolidation tests were performed on sand-slime and slime tailings samples. The sand tailings samples did not have sufficient cohesion to be used for consolidation testing. The consolidation testing results for the samples tested were presented in Table 3-2 and are summarized below in Table 4-7. The results for consolidation parameters are similar for sand-slime and slime tailings, with an average Cc value of approximately 0.3 and an average cv value of approximately 0.001 to 0.002 cm2/s. Table 4-7 Summary of Laboratory Measured Consolidation Parameters Tailings Type Sand- Slime Slime cv (cm/s) 0.32 (0.11-0.66) 0.001 (0.0005-0.002) 0.28 (0.27-0.28) 0.002 (0.0005-0.003) cm Is = square cubic meterscentimeters per second Energy Fuels Resources (USA) Inc. 23 MWH Americas, Inc. October 201 AM arch 2015 © MWH Tailings Data Analysis Report The measured Cc and cv values for the sand-slime and slime tailings samples are consistent with published test results for other uranium tailings samples (Keshian and Rager, 1986). Values of Cc from the consolidation testing were compared with Atterberg limits and in-situ density test results in Figure E.4-1 and Figure E.4-2, respectively. Figure E.4-1 indicates there is not a relationship between Atterberg limits and Cc values for the samples tested. Figure E.4- 2 indicates a relationship of increasing Cc values with decreasing in-situ dry densities with a value of Cc of 0.3 representative of the majority of the samples. Figure E.4-3 shows the consolidation test results for each sample tested and this graph also indicates a relationship of increasing Cc values with decreasing in-situ dry densities. The results of CPT pore pressure dissipation tests can be used to estimate the horizontal coefficient of consolidation for sands using the leading theoretical solution by Teh and Houlsby (1991) with the rigidity index estimated based on plasticity index (PI) from relationship presented in Keaveny & Mitchell (1986). The horizontal coefficient of consolidation (ch) provides an indication as to the rate of consolidation when pore water is dissipated horizontally, with higher ch values indicating more rapid consolidation. The results are summarized in Table 4-8. Only locations where laboratory samples were collected and tested at the same depth were evaluated. The results indicate ch values ranging from 0.3 to 0.8 cm2/s. These results are unreasonably high and cannot be explained solely by anisotropy. It is recommended that laboratory measured Cy values be used in future technical analyses and that Cy values not be calculated from estimated Ch values based on the CPT soundings. Table 4-8 Summary of Estimated Horizontal Coefficient of Consolidation from CPT Soundings Tailings Cell Cell 2 Cell 3 Sampling Location CPT-2W2 CPT-3-4N CPT-3-6N Tailings Type Sand-Slime Sand Sand Slime Slime PPD Depth (ft) 13.94 13.12 8.86 18.54 cm Is = square • scentimeters per second Estimated (cm2/s) 0.62 0.51 0.34 0.84 Energy Fuels Resources (USA) Inc. 24 MWH Americas, Inc. October 2014March 2015 MWH Tailings Data Analysis Report 5.0 SUMMARY The tailings investigation was conducted to address DRC's request for site-specific tailings information^, and followed the October 2013 work plan reviewed and approved by DRC. The results of this investigation will be used to update technical analyses to address DRC review comments on the Reclamation Plan Revision 5.0 and the revised ICTM Report. The tailings characteristic parameters presented in this document are based on the methods presented and our experience with similar materials. Any analyses conducted using these parameters will consider the conditions and assumptions under which the values were developed. The results of the tailings investigation indicate the tailings within Cells 2 and 3 are relatively uniform with minimal segregation of tailings within each cell. The tailings within Cells 2 and 3 are similar in particle size distribution and other geotechnical characteristics. Therefore, it is reasonable to assume the test results from the investigation are representative for both cells. A correlation between tailings classification and CPT results (i.e., cone resistance and friction ratio) was discussed in Section 4.1 and shown in Figure E.1-3 and Figure E.1-4 for Cell 2 and Cell 3, respectively. These figures classify the tailings as sand/sand-slime tailings or slime tailings based on CPT results. This criteria was developed based on calibration of laboratory data with CPT results. It is recommended that the materials identified in the CPT soundings be classified according to this criteria as sand/sand-slime tailings or slime tailings, and that the laboratory values representing these tailings classifications be used for future technical analyses. Energy Fuels Resources (USA) Inc. 25 MWH Americas, Inc. October 201 AMarch 2015 MWH Tailings Data Analysis Report 6.0 REFERENCES Chen and Associates, Inc., 1987. Physical Soil Data, White Mesa Project, Blandinq Utah, Report prepared for Energy Fuels Nuclear, Inc. Colorado School of Mines Research Institute (CSM), 1978. Grinding Reports - DSM Screen Undersize. 5 June, 1978.Denison Mines USA Corp. (Denison), 2009. Reclamation Plan, White Mesa Mill, Blanding Utah, Revision 4.0, November. Denison Mines (USA) Corp. (Denison), 2011. Reclamation Plan White Mesa Mill, Blanding, Utah, Version 5.0. September. Denison Mines (USA) Corp. (Dension) 2012a. Responses to Interrogatories - Round 1 for Reclamation Plan, Revision 5.0, March 2012. May 31. Denison Mines (USA) Corp. (Dension) 2012b. Responses to Interrogatories - Round 1 for the Revised Infiltration and Contaminant Transport Modeling Report, March 2010. May 31. Energy Fuels Resources (USA) Inc. (EFRI), 2012a. Responses to Interrogatories - Round 1 for Reclamation Plan, Revision 5.0, March 2012. August 15. Energy Fuels Resources (USA) Inc. (EFRI), 2012b. Responses to Interrogatories - Round 1 for the Revised Infiltration and Contaminant Transport Modeling Report, March 2010. September 10. Energy Fuels Resources (USA) Inc. (EFRI), 2013. Email from Jo Ann Tishler (EFRI) to John Hultquist (DRC) confirming comments from John Hultquist on September 12, 2013 that the responses to DRC comments on the Tailings Characterization Work Plan were satisfactory to DRC, that DRC had no further comments on the revised plan, and that MWH could proceed with the field investigation. September 12. 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