DRC-2011-001114 - 0901a068801f30d3

January 10, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Re: State of Utah Ground Water Discharge Permit ("GWDP") No. UGW370004
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: 303 628·7798
Fax: [phone]
www.denisonmines.com
Transmittal of Revised Documents Addressing White Mesa Uranium Mill New Cell4B and Response
to Division of Radiation Control ("DRC") Letter of January 6, 2011 Regarding Comprehensive
Comments on Proposed Revised Plans
Dear Mr. Lundberg :
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Tailings Management System
and Discharge Minimization Technology Monitoring ("DMT") Plan, and the Best Available Technology
Operations and Maintenance ("BAT O&M") Plan for the White Mesa Mill which are currently pending UDEQ
approval. This letter also responds to DRC's letter of January 6, 2011 requesting additional changes to
previously submitted versions of these documents. Per DRC's letter, we understand that the Contingency
Plan will be addressed separately and changes will not be tied to approval for use of Cell 4B or the New
Decontamination Pad.
DRC received the October 11, 2010 letter requesting changes to previously submitted versions of the DMT
Plan BAT O&M Plan, and Contingency Plan. To address those comments and other changes necessary for
operation of Cell 4B, Denison submitted on November 12, 2010 red line and clean copy revisions of those
documents entitled DMT Plan Revision 11, BAT O&M Plan Revision 2.0 and Contingency Plan Revision 4.0.
DRC reviewed those submittals and requested additional changes to the DMT and BAT O&M Plans in the
letter of January 6, 2011. Denison has accepted all the changes submitted on November 12, 2010 to create
new black-line copies of the DMT and BAT O&M Plans, and has prepared the additional changes, in
response to DRC's January 6, 2011 letter, as redlined markups, entitled DMT Plan 11.1 and BAT O&M Plan
Revision 2.1, These revisions have been provided, respectively, as Attachments 1 and 2 to this letter.
For ease of review, both of the revised documents have also been provided as clean file versions with all
changes accepted. Denison requests that UDEQ review and approve the versions attached to this letter,
which consolidate into one set of documents all changes submitted by Denison since September 2008, for
which Denison is awaiting DRC approval.
N:\Cell 4B\January 2011 Submittals and Revisions for Cell 4B\01.1 0.11 Transmittal to ORC Plan Revisions for Cell4B.doc
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 2
We have also provided, below, specific responses to each request in UDEQ's January 6, 2011 letter. The
sections and numbering of the remainder of this letter follow the DRe January 6, 2011 letter. Each UDEQ
request is shown in italics, below, followed by Denison's response.
DEQ Comments and Responses
The Contingencv Plan (1112010 Revision: DUSA-4J
Please be aware that in order to expedite the Cell 48 review process, that DRC review of the Contingency
Plan will be addressed under separate cover, proceed independently, and not be tied to the use of the NDP
nor Cell 48. The following is noted for future reference:
A. In the subject November 12, 2010 letter, DUSA provides proposed red-line and clean versions
of the Contingency Plan version noted, which include aspects regarding Cell 48.
8. The third paragraph as well as Section 2 . a. 1 of a September2 ,2010 DUSA letter discusses
contingency plan comments in our May 10,2010 letter.
Denison Response: No response required.
The DMT Plan (11/2010 Revision: DUSA-11
1. We acknowledge a section of paragraph 3 . 1. e.i. D has been changed appropriately to read that, or •••
The depth to water from the top ... of any of the three (3) observation ports to the standing water
shall be no less than 6.2 feet. " It appears that incorporation of this item into an approved DMT
Plan would complete the issues regarding the NDP with respect to DMT Plan adjustments.
Denison Response: No response required.
2. The DMT Plan (as well as the O&M Plan), incorporating necessary items for Cell 48, must be approved
prior to DRC authorization of use for Ce1l48. Regarding freeboard requirements, the Plans proposed by
the subject DUSA November 12,2010 letter make the assumption that Cell 48 is currently authorized for
use, and it is not necessary to establish a freeboard for CeIl4,A. However, this is incorrect. This
approach DUSA has taken appears to necessitate one of the following:
a. That the last action prior to authorizing use of Cell 48 must be the approval of the DMT Plan (and
the O&M Plan), or
b, To obtain approval of the DMT and O&M Plans now, DUSA change the plans to establish the
freeboard for Cell 4A. to be one of the following, either:
(1). The fixed freeboard elevation for Cell 4A, established by the DRC freeboard
variance letter of November 20, 2008, or
(2). Change the current freeboard determination verbiage proposed in these Plans be more
robust. This would include that the freeboard for Cell 4A or Cell 48, as may be applicable, would
be established by the rigorous freeboard calculation method outlined in former proposed Plans,
but would be written such that if Cell 48 becomes approved, that the freeboard determination
method would no longer be needed for or apply to Cell 4A.
Please provide DRC your decision to us in this regard, together with any and all necessary
corresponding changes to the DMT Plan.
OENISOJ)J~
MINES
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 3
Denison Response: Denison has chosen option (a.) above and will request the approval of the DMT Plan and
the O&M Plan as the last action prior to the UDEQ authorization for the use of Cell 4B. As such, the changes
requested regarding the reintroduction of Freeboard limits for Cell 4A are not necessary.
3. The following changes in oMT Plan forms, related to tailings beach elevations, are needed due to the
need to measure beach elevations in tailings Cells 4A or 4B, as applicable ( per paragraph 2 above).
This issue was brought to your attention earlier in our letter dated October 11, 2010. The freeboard for
these ponds is determined from the use of such (see paragraph 6.3 and Appendix F of the OMT Plan):
a. On page 2B of 49 in Appendix A of the submitted clean copy of the Plan:
(1) The heading numbered as one, near the left margin on that page; must state "Pond and Beach
elevations ... ," the following earlier proposed oMT Plan versions also contained this provision;
(a). 12108 Revision: oenison-7,
(b). 05109 Revision: oenison-B, and
(c). 3110 Revision:oenison-9.
(2) In the corresponding page of the submitted red-line version (i.e. page 33 of 56), item number
one contains sections for Cell 4A. and Cell 48. An item (d) stating "Elevation of Beach Area with
the Highest Elevation (monthly), " must be added into the sections on this page for each of
these cells, as applicable with paragraph 2 above. (Earlier proposed OMT Plan versions
contain this item (d) for Cell 4A, in the versions given in paragraph 3.a. above).
b. Section 3.1. d. vii, paragraph C should be labeled as paragraph B. The title of this paragraph should be
"Cell 4A or 4B Beach Elevation, " as needed and applicable with paragraph 2 above. The body of that
paragraph should indicate that the beach elevation survey will be in Cell 4.A, or Cell 4B as applicable.
(If Cell 4B becomes approved for use, it then will be is no longer necessary to establish freeboard
elevation for Cell 4A).
Denison Response:
3.a.(1) The heading has been changed as requested.
3.a.(2) The requested text "Elevation of Beach Area with the Highest Elevation (monthly)," has been
added to Cell 4B only. As previously stated, Denison is requesting UDEQ approval of the DMT Plan as
the last action prior to the use of Cell 4B, and as such the requested change to the Cell 4A weekly
inspection is not necessary.
3.b. See response to 3.a.(2) above.
4. Please correct miscellaneous errors noted at the following locations on the subject submitted redline
oMT Plan copy:
a. The third paragraph of page 2, and in paragraph a) below it, the deletion and relocation of a
sentence is erroneous.
b. Last paragraph of page 3, the elevations listed for the lowest points on the flexible membrane liners
for Cells 4A and 4B conflict with the elevations listed in Appendix A (page 33 of the redline copy) for
Cells 4A. and 4B.
c. On page 11 heading III, (used for the Roberts Pond) should be a heading IV.
OENISOJ)~~
MINES
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 4
d. In Section 6.3, the fifth paragraph, the first number in the parenthetical phase appears it should be
40 rather than 45.72.
e. On page 28 of the clean copy, corresponding to p. 33 of the red-line copy, for Cell 4A the FML
bottom elevation line needs to be right justified.
f On page 33,paragraph number 2, the statement "Pump Timer set at 15 min on ... ," needs to be
deleted.
g. On page 36, the asterisk footnote shown refers to an elevation which appears to apply only to Cell
4A. The footnote needs to be adjusted somehow include the elevation that applies to Cell 4B as
well.
Denison Response: These changes have been made in the attached DMT Plan Revision 11 .1.
The Cell 4A & 4B O&M Plan, 1112010 Revision Denison 2.0, of the submitted red-line copy:
I. Figure 6B does not follow the same logic as Figure 6A I.e., the lowest FML elevation above the
sump level is not 1.5-feet above the sump bottom (for the 18-inch diameter collection pipe) as in
Figure 6A. Please explain and justify this difference.
II. On page II, in two separate paragraphs numbered I and 2, the second and the last sentence
respectively, contain a parenthetical phase that must be deleted or adjusted, as it is incorrect.
III. On page 14, in the third sentence the parenthetical phrase must be deleted or adjusted, as it is
incorrect.
IV. Also, on page 14, the second to last sentence from the bottom of the page, beginning with, "Each
pump is equipped with ... ," refers to distances of 2.25 feet and 9-inches. These distances appear to
not be applicable for the Cell 4B sump and respecting Figure 6B. Please revise this sentence and
or figure, to be correct for Cell 4B as well.
V. On page 15, the last sentence of the first paragraph on that page must specify what Figure it refers
to.
VI. Page 17, the third paragraph states," Condition 10.3 states that ... ," however, current License
Condition 10.3 does not state the verbiage quoted after that sentence. Please adjust this paragraph
with the proper references and verbiage, as applicable.
VII. Beginning on page 17, rewrite the section of the O&M Plan titled "Cell 4A Solution Freeboard
Calculation, " including the title of that section. This will need to be done according to OUSA's
application of the paragraph numbered 2, under the OMT Plan comment section of this letter.
VIII. Please correct miscellaneous errors noted at the following locations on the subject red-lined copy of
the Cell 4A and 4B BA T O&M Plan:
a. On page 6 , paragraph .2, add a sentence which describes that the non-woven geotextile
material is also overlain at the surface by a woven geotextile fabric, which is ballasted laterally
by sandbags on each side of the backbone gravel berm.
b. The above item also must be added to paragraph e.2 on page 3 and 4.
c. On page 6, paragraph e.3, also add a sentence which describes that the non-woven geotextile
material is also overlain at the surface by a woven geotextile fabric, which is ballasted by
sandbags.
d. The above item also must be added to paragraph e.3 on page 4.
e. Page 20, entry 11 on the Attachments list needs to be updated, and the sentence ended with
"OMT Monitoring Plan."
Denison Response:
OENISOJ)~~
MINES
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 5
I. Figure 6B is correct. The lowest FML above the sump level is 2.06 feet for Cell 4B.
II. The phrase has been deleted from both paragraphs as requested.
III. The phrase has been deleted as requested.
IV. The text has been corrected to reflect the actual conditions in Cell 4B as shown in Figure 6B,
which is correct.
V. Figure 5 was referenced in the previous version and no correction is required.
VI. The correct verbiage has been added.
VII. See response to 3.a.(2) above.
VIII. Items a through e have been corrected or amended as requested.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
~Chl~
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
"ENISOJ)~J
MINES
ATTACHMENT 1
PROPOSED REVISON 11.1 TO DMT PLAN
RED-LINED AND CLEAN VERSIONS
White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
.tQIIHU Revision: Denisonll.l
Page 2 of49
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.
Areas to be inspected include the following: CellI, 2, 3, 4A.and 4B, Dikes 1,2,3, 4A-S, 4A-W, 4B-
Sand 4B-W wind movement of tailings, effectiveness of dust minimization methods, spray
evaporation, Cell 2 spillway, Cell 3 spillway, Cell 3, 4A and 4B liquid pools and associated liquid
return equipment, cell leak detection systems, and the wildlife ponds.
Operational features of.the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings i(ll;pecLion:
a) Tailings slt.my and SX raffinatc transport systems from the Mill to the active
fellO¥/mg items roqt:Hfe ... istiRI iflsfleelieft al:lf~Rg !:flo aSHY tailfRgIj iRBl'JOotiOJr.
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: tailingssluny lines from CeD
La lhe acti ve tai lings cell' X raffinaLe lines lhal can discharge into Ccll I, Cell 3.
er--CeIl4A or Cc1l4B; the pond l'('ltUI'll line from the tailings area to the Mill' and
lines transporting pond solutions from one cell to another.
b) CellI.
c) Cell 2.
d) Cell 3.
e) Ce1l4A.
t) Ce1l4B.
g) Dike structures including dikes 1,2,3, 4A-S, 4A-W, 4B-S and 4B-W.
h) The Cell 2 spillway, Cell 3 spillway, Cell 3. tmd-CeIl4A and Cell4B 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.
White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+QIIIGI Revision: Denison I I.,!
Page 3 of49
j) Spray evaporation pumps and lines.
k) Wind movement oftailings and dust minimization.
Wind movement oftailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas oftailings 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.
I) Observation offlow and operational status ofthe 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.
0) 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 (LOS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in the CellI and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell 4A or 4B leak detection system is not allowed to be more
than 1.0 foot above the lowest point on the bottom flexible membrane liner (Cell
4A FML elevation is 5555.14 amsl and with the addition of the 1.0 foot of
solution the solution elevation is 5556.14 feet amsl.!.. .fEor CeIl4A andCell4B the
FML elevation is 5557.50 amsl and with the addition ofthe 1.0 foot of solution
the solution elevation is 5558.5Q feet amsl fer CeH--4Jl). If any of these
observations are made, the Mill Manager should be notified immediately and the
leak detection system pump started. In addition, the requirement to notifY the
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+.QIIHU Revision: Denison 11.1
Page 5 of49
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 Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the M ill 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).
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 to determine
whether it is wet or dry. Ifmarked wet, the liquid levels need to be measured and
reported. In Cell 1 and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. The Cell 4A and 4B leak detection systems are
monitored on a continuous basis by use of a pressure transducer that feeds water
level information to an electronic data collector. The pressure transducer is
calibrated for fluid with a specific gravity of 1.0. The water levels are measured
every hour and the information is stored for later retrieval. The water levels are
measured to the nearest 0.10 inch. The data collector is currently programmed to
store 7 days of water level information. The number of days of stored data can be
increased beyond 7 days if needed. The water level data is downloaded to a
laptop computer on a weekly basis and incorporated into the Mill's
environmental monitoring data base, and into the files for weekly inspection
reports of the tailings cell leak detection systems
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+.Q IIHll Revision: Denison 11..1
Page 7 of49
FML in Cell 2, which, based on construction reports, is at a depth of 39 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 five feet
above the bottom ofthe slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 5 feetand is below the phreatic surface of
tailings Cell 2, about 20 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. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 ofthe GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Ce1l4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Cell 4B slimes drain will be
authorized once it is put into service and while it is active. 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 and Ce1l4A
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual. Section 3.1
+QIIHU Revision: Denison I 1,1
Page 8 of49
slimes drains are kept as low as reasonably achievable, and that the Cell 3, Cell 4A,
and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit."
c) Wind Movement a/Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken ifneeded.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 14A, and 4B and Roberts Pond are to be taken by
survey on a weekly basis, and the beach area in Cell 4A and 4B with the maximum
elevation is to be taken by survey on a monthly basis, as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 14A, and 4B, and Roberts
Pond are known points established by professional survey. For Cell 1 and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell I. The elevation ofthe metal disk (the "Reference Point
Elevation") for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3 Cell 4A, and Cell 4B, the Reference Point is a piece of
metal rebar located on the south dike of Cell 3. The elevation at the top ofthis
piece ofrebar (the Reference Point Elevation for Ce\14A and 4B) is at 5,607.83
FMSL. The Surveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 1 and
Roberts Pond, this is typically on the road on the Cell 1 south dike between Cell 1
and Roberts Pond, approximately 100 feet east of the Cell lIRoberts Pond
Reference Point. For Cell 4A and Cell 4B, this is typically on the road on the Cell
3 dike approximately 100 feet east ofthe Cell 3 Reference Point;
(iv)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell lIRoberts Pond Reference Point on the top of the rebar on
the Cell 4A and 4B Reference PoinL T~e_ ~~sis!~n! ~jl1 ~I!s_u~e_ tp~t_t~~ §~ry~y __ J _ --{ Formatted: Not Highlight
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+Q llIGl Revision: Denisonll~
Page 9 of49
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the
Reference Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell 1, Cell 4A, CeIl4B,
or Roberts Pond, or the area of the beach in Cell 4A or Cell 4B with the highest
elevation, as the case may be. These designated locations, and the methods to be
used by the Assistant to consistently use the same locations are as follows:
A. Pond Surface Measurements
L Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
II. Ce\14B
The Assistant will walk down the slope in the northwest corner of Cell 4B and
place the Survey Rod at the liquid level.
IlL Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell I. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northing Easting
Roberts Pond 323,041 2579,697
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Ce1l4B 320,690 2,576,200
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+----{ Formatted: Tab stops: 1.25", Left + Not at 1" 1
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+QI /I Gl Revision: Denison I 1..1.
Page 10 of49
Ga·
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Celt-4B Beach Elevation
The Assistant will place the Survey Rod at the point on the beach area of Cell 4B
that has the highest elevation. Ifit is not clear which area of the beach has the
highest elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(viii) The Assistant will hold the Survey Rod vertically with one end of the Survey
Rod just touching the pond surface. The Assistant will ensure that the Survey
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(ix)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+QIIlGl Revision: Denison 1 1..1
Page 12 of 49
j) Summary
basis. Any soil and debris will be removed from the Existing
Decontamination Pad immediately prior to inspection of the concrete
wash pad for cracking Observations will be made of the current
condition of the Existing Decontamination Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and 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.
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. Ifthe pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D;
b) a 4 ft. buffer is maintained at the periphery ofthe storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary ofthe storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
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White Mesa Mill-Standard Operating Procedures
Book II : Environmental Protection Manual, Section 3.1
+.QI/lGI Revision: Denison I 1..1
Page 13 of49
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer 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 inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction offlow. 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 Minimi=ation
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.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
,JQIIHU Revision: DenisonllJ.
Page 17 of49
is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSLL _____ n _______________________ ~ _ --{ Formatted: Not Highlight
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
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. Ce1l4A
The freeboard limit for Cell 4A is inapplicable since all ofthe PMP flood volume associated with
Ce1l4A will be attributed to Ce1l4B. A spillway has been added to Ce1l4A to allow overflow into
Ce1l4B.
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:
(aJ 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 Ce1l4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Cell 4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
38.1 acre-feet
159.4 acre-feet
197.5 acre-feet
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+.QIIHll Revision: Denison 11.1
Page 19 of49
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
5,594FMSL
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 (ARPAI.I)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-l).
The RPAt.! 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
been used for period t-l had the actual tonnages for year t-l been known at the outset
of period t-l 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
ARPAt.! can be calculated using the following formula:
(1 -~t.! / g,Q~4):1.0_0_-::. It:J2t x_ ~~ ~!:2_~ ~!.{!' ~H ________________________ --{ Formatted: Not Highlight
Where:
• ~t.! is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-I;
• Tt.t 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 ARP At-2 is 40 acres;
ii) Once the ARP At-! for the previous period (period t-I) has been calculated, the RP A
for the subject period (period t) can be calculated as follows:
(1 -(~t* x 1.5) / L2 OJ~.o_09 ~ .T.J2 ~ A~~t:J _=_~~~L ___________________ -_ --{ Formatted: Not Highlight
Where:
• ~t* is the expected number of dry tons of tailings to be deposited into Cell4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Tt is the actual number of dry tons oftailings solids historically deposited in
Cell4B prior to the beginning of period t; and
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White Mesa Mill-Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
+QIIl gl Revision: Denison 11.1
Page 21 of 49
the use ofthe facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September I
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity ofthe steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be
visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may
have occurred since the last inspection. If any abnormalities are identified, defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use of the
facility. All inspection findings and any repairs required shall be documented on the Annual
Decontamination Pad Inspection form. A record of the repairs will be maintained as a part of the
Annual Inspection records at the Mill site. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due
September 1 of each calendar year.
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 Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2, 3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, 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 Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer 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 pre parer in addition to the Radiation Safety Officer and the Mill
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White Mesa Mill-Standard Operating Procedures
Book 1 J: Environmental Protection Manual, Section 3 1
Manager.
8.2. DMT Reports
+QJIlGl Revision: Denison11..!
Page 22 of49
Quarterly reports ofDMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 ofthe GWDP
relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool and Beach Area Elevation
Monitoring), 3.2 (Weekly Inspection of Solution Levels in Roberts Pond) and 3.3
(Weekly Feedstock Storage Area Inspections);
b) On a quarterly basis, a summary ofthe weekly water level (depth) inspections for
the quarter for the presence offluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection ofthe New Decontamination Pad described
in Section 6.5(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year; and
e) An annual summary and graph for each calendar year ofthe depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
III. DIKES AND EMBANKMENTS
+QIIHU Revision: DenisonlI"l
Page 250[49
I
InsQection Items Conditions of Potential Dike I-I Dike 1-Dike 2 Dike 3 Dike Dike Dike Dike I
Concern lA 4A-S 4A-W 4B-S 4B-W
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
Crest Cracks, Subsidence, Severe
Erosion -
IV. FLOW RATES I
SluITY Line(s) Pond Return
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VI. DUST CONTROL
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
General Meteorological conditions:
Ce\l2
S-X Tails
______ yes
______ yes
Ce\l3
Spray System
____ ---'No
_____ No
Ce\l4A Ce\l4B
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
VII. DAILY LEAK DETECTION CHECK
Cell 1
Leak Checked
Detection
I I
Cell 2
Checked
-lQlIHU Revision: Denisonll,.!
Page 26 of49
Cell 3 Cell4A Ce1l4B
Checked Checked Checked
System ___ Wet ___ Dry ___ Wet ___ Dry __ Wet __ Dry __ Wet __ Dry ___ Wet ___ Dry
Checked
Initia1level Initial level Initial level Initial level Initial level
Final Final Final Final Final
level level level level level
Gal. pumped Gal. pumped Gal. pumped Gal. pumped ___ Gal, pumped --
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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While Mesa MiII-Siandard Operating Procedures
Book 11 : Environmemal Prolection Manual. Section 3.1
[MAP OF TAl LING S AREA)
-tQ11l91 Revision: Denison IIJ.
Page 27 of49
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+QI/IGI Revision: Denisonll.J.
Page 29 of49
3. Leak Detection Systems
Observation:
Celli Cell 2 Cell 3 Ce1l4A Ce1l4B
Is LDS wet or __ wet __ wet wet __ wet wet
dry? dry dry dry dry dry
If wet, Record Ftto Ftto ---Ft to ___ Ftto ---Ft to
liquid level: Liquid Liquid Liquid Liquid * Liquid *
If sufficient Volume Volume Volume Volume Volume
fluid is
present, record Flow Flow Flow Flow Flow
volume of Rate ---Rate ---Rate ___ Rate ___ Rate ---fluid pumped
and flow rate:
Was fluid ----..Yes __ no ----..Yes __ no ----..Yes __ no ----..Yes __ no ----..Yes __ no
sample
collected?
Observation:
New Decon Pad, New Decon Pad, Ne~ Decon Pad
Portal I Portal 2 Portal 3
Is LDS (Portal) __ wet __ dry __ wet __ dry __ wet __ dry
wet or dry?
If wet, Record Ftto ___ Ftto Ftto
liquid level: Liquid Liquid Liquid
Ifwet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented:, _____________________ _
6. RemM~: ______________________________ _
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
.j.QIIHU Revision: Denisonll.J.
Page 31 of49
MONTHL Y INSPECTION DATA
Inspector: ____________ _
Date: _________________________ _
1. Slurry Pipeline: _______________________________________________________ _
Pipe Thickness: ______ {To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Benn:
Stability Issues
Signs of Distress
Diversion Ditch 1 Diversion Ditch 2
~es __ no ~es __ no
~es __ no ~es __ no
~es __ no ~es __ no
~es __ no ~es __ no
Diversion Ditch 3
~es __ no
~es __ no
~es __ no
~es __ no
Diversion Benn 2
~es __ no
~es __ no
Comments:. __________________________________ ___
3. Summary of Activities Around Sedimentation Pond: _________________ __
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
APPENDIX B
+QlIlGl Revision: Denisonll~
Page 37 of 49
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualitying 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 specity 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 notity Corporate
Management. Ifdam failure occurs, notity your supervisor and the Mill Manager immediately. The
Mill Manager will then notity 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 for an example ofthe daily tailings
inspection form. The inspection form consists ofthree pages and 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
are to be monitored for leaks, and loose connections. The pipeline supports are to be
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+QIIlGl Revision: Denisonll,l
Page 38 of49
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
ofthe 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 3, 4A-S, 4A-W, 4B-S, and 4B-W, 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 ofthese conditions exist, the
inspection report should be marked accordingly.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Flow Rates:
-l-QllHll Revision: Denison I 1.1
Page 39 of49
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (OPM). 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 ofthe
mill. If possible, the inspection should include observation ofthe 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 preci pitation 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 the Shifter 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 ofthe inspection involves drawing, as accurately as possible, the following
items where applicable.
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White Mesa Mill -Standard Operating Procedures
Book I I: Environmental Protection Manual, Section 3. I
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
+QII1Gl Revision: DenisonllJ.
Page 40 of49
S. 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 for the tailings area is IS mph and 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.
S. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation 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
Form, Appendix C. This form should be signed and dated only after a thorough review ofthe
tailings information previously presented. The form will then be signed by the Radiation
White Mesa Mill -Standard Operating Procedures
Book 1 \: Environmental Protection Manual, Section 3.1
Safety Officer and filed.
+QI/lGl Revision: Denison I 1,1
Page 41 of49
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While Mesa Mill -tMdard Operating Procedures
Dook II: Environmental Protection Mnnual, Section 3.1
APPENDlXC
CERTIFICATION FORM
Date: __________ _
Name: ________________ ___
~lIHU Revision: Denison I U .
Page 42 of49
I have read the documenllitled 'Tailings Management yslcm, White Mesa Mill Tailings
Inspector Training and have received on-sile instruction at the tailings system. Thi instruction
included documentation of daily tailings in pections, analysis of potential problems (dike
failures, unusual l1ows), notification procedures and saf'ety.
ignature
I eerlify thallhe above-named person is qualifi.ed to perl'orm the daily inspection of the tailings
ystcm at Lhe While Mesa Mill.
Radiation afely Personnel! Tailings System
upervisor
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
APPENDIXE
TABLES
+Q IIIGI Revision: Denison I I....!.
Page 44 of49
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+QI/IGl Revision: Denisonll.J.
Page 45 of49
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day)
Table lB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+1l I/IGl Revision: Denisonll.J.
Page 46 of49
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White Mesa Mill-Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
+.QI/IGl Revision: Denisonll..l
Page 48 of49
*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 Ce1l4B would be calculated
as follows:
1. Prior to March 1,2012
Prior to March 1,2012, the maximum elevation ofthe beach area in Ce1l4B is less than or
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 offreeboard would be 197.5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave run up factor for Ce1l4B 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
fi'om 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 of225,000 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 offreeboard would be 197.5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave run up factor for Ce1l4B 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 l3.66
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, 20l3.
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White Mesa MiII-Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
-lQIIHll Revision: Denisonl 1J.
Page 49 of49
4. November I, 2013 to November 1. 2014
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(1 -275,000 / (2,094,000 -1,000,000 -225,000) x 31.77 acres = 2l.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 offreeboard would be 197.5 acre feet divided by
10.75 acres equals 18.37 feet. When the wave run up factor for Ce1l4B 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.
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
01111 Revision: Denison 1 1.1
Page 1 of49
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
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 four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4 below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A). The Daily Inspection Data form contains an inspection checklist,
which includes a tailings cells map, and spaces to record observations, especially those of immediate
N:\Ce1l4B\January 2011 Submittals and Revisions for CeU4B\DMT Plan Ol.lO.II\Tailings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 -
clean.doc
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 2 of49
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.
Areas to be inspected include the following: CellI, 2,3, 4A and4B, Dikes 1,2,3, 4A-S, 4A-W, 4B-
Sand 4B-W wind movement of tailings, effectiveness of dust minimization methods, spray
evaporation, Cell 2 spillway, Cell 3 spillway, Cell 3, 4A and 4B liquid pools and associated liquid
return equipment, cell leak detection systems, and the wildlife ponds.
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 CellI, Cell 3,
Ce1l4A or Ce1l4B; the pond return line from the tailings area to the Mill; and,
lines transporting pond solutions from one cell to another.
b) CellI.
c) Cell 2.
d) Cell 3.
e) Ce1l4A.
f) Ce1l4B.
g) Dike structures including dikes 1,2,3, 4A-S, 4A-W, 4B-S and 4B-W.
h) The Cell 2 spillway, Cell 3 spillway, Cell 3, Ce1l4A and Ce1l4B 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.
N:\CeIl4BVanuary 2011 Submittals and Revisions for CeIl4B\DMT Plan OI.lO.II\Tailings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1-
clean.doc
White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
j) Spray evaporation pumps and lines.
01 III Revision: Denison ILl
Page 3 of49
k) Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
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.
1) Observation of flow and operational status ofthe 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.
0) 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 (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in the CellI and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell4A or 4B leak detection system is not allowed to be more
than 1.0 foot above the lowest point on the bottom flexible membrane liner (Cell
4A FML elevation is 5555.14 amsl and with the addition of the 1.0 foot of
solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 ofthe Groundwater Discharge Permit must
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be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, 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 II.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.
r) An estimate ofthe 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.
Items (a), (m), (n), and (0) 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
obvioussafety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record ofthese patrols need be made, but the inspectors will notify the Radiation Safety Officer
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
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White Mesa Mill -Standard Operating Procedures
Book ll: Environmental Protection Manual, Section 3.1
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
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Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencIes.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
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 to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell 1 and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. The Cell 4A and 4B leak detection systems are
monitored on a continuous basis by use of a pressure transducer that feeds water
level information to an electronic data collector. The pressure transducer is
calibrated for fluid with a specific gravity of 1.0. The water levels are measured
every hour and the information is stored for later retrieval. The water levels are
measured to the nearest 0.10 inch. The data collector is currently programmed to
store 7 days of water level information. The number of days of stored data can be
increased beyond 7 days if needed. The water level data is downloaded to a
laptop computer on a weekly basis and incorporated into the Mill's
environmental monitoring data base, and into the files for weekly inspection
reports of the tailings cell leak detection systems
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01 III Revision: Denison 11.1
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If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
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.
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 Radioactive Materials
License.
For Cell4A and 4B, under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in the
lower flexible membrane liner. To determine the Maximum Allowable Daily
LDS Flow Rates in the Ce1l4A and 4B leak detection systems, the total
volume of all fluids pumped from the LDS on a weekly basis shall be
recovered from the data collector, and that information will be used to
calculate an average volume pumped per day. Under no circumstances shall
the daily LDS flow volume exceed 24,160 gallons/day for Ce1l4A or
26, 145gallons/day for Ce1l4B. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table 1A and
IB (for Cells 4A and 4B, respectively) in Appendix E, to determine the
maximum daily allowable LDS flow volume for varying head conditions in
Cell4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) 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
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. 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
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FML in Cell 2, which, based on construction reports, is at a depth of 39 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 five feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 5 feet and is below the phreatic surface of
tailings Cell 2, about 20 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. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Ce1l4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Ce1l4B slimes drain will be
authorized once it is put into service and while it is active. 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 and Ce1l4A
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slimes drains are kept as low as reasonably achievable, and that the Cell 3, Cell4A,
and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit."
c) Wind Movement a/Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 14A, and 4B and Roberts Pond are to be taken by
survey on a weekly basis, and the beach area in Cell 4A and 4B with the maximum
elevation is to be taken by survey on a monthly basis, as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 14A, and 4B, and Roberts
Pond are known points established by professional survey. For CellI and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast comer of Cell 1. The elevation of the metal disk (the "Reference Point
Elevation") for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3 CeIl4A, and CeIl4B, the Reference Point is a piece of
metal rebar located on the south dike of Cell 3. The elevation at the top of this
piece ofrebar (the Reference Point Elevation for Cell4A and 4B) is at 5,607.83
FMSL. The Surveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 1 and
Roberts Pond, this is typically on the road on the Cell 1 south dike between Cell 1
and Roberts Pond, approximately 100 feet east of the CellI/Roberts Pond
Reference Point. For Cell4A and Cell4B, this is typically on the road on the Cell
3 dike approximately 100 feet east of the Cell 3 Reference Point;
(iv)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the CellI/Roberts Pond Reference Point on the top of the rebar on
the Cell4A and 4B Reference Point. The Assistant will ensure that the Survey
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
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(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the
Reference Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the CellI, CeIl4A, CeIl4B,
or Roberts Pond, or the area ofthe beach in Cell 4A or Cell 4B with the highest
elevation, as the case may be. These designated locations, and the methods to be
used by the Assistant to consistently use the same locations are as follows:
A. Pond Surface Measurements
I. Cell4A
The Assistant will walk down the slope in the northeast comer of Cell 4A and
place the Survey Rod at the liquid level.
II. Cell4B
The Assistant will walk down the slope in the northwest comer of Cell4B and
place the Survey Rod at the liquid level.
III. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
IV Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northing Easting
Roberts Pond 323,041 2,579,697
CellI 322,196 2,579,277
Ce1l4A 320,300 2,579,360
Ce1l4B 320,690 2,576,200
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B.
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Cell 4 B Beach Elevation
The Assistant will place the Survey Rod at the point on the beach area ofCe1l4B
that has the highest elevation. If it is not clear which area of the beach has the
highest elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Ce1l4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(viii) The Assistant will hold the Survey Rod vertically with one end of the Survey
Rod just touching the pond surface. The Assistant will ensure that the Survey
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(ix)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the pnmary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
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between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RSO).
F In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(U) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer ofthe
Mill's maintenance shop and the ore feeding grizzly.
A. The Existing Decontamination Pad will be inspected on a weekly
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j) Summary
basis. Any soil and debris will be removed from the Existing
Decontamination Pad immediately prior to inspection ofthe concrete
wash pad for cracking Observations will be made of the current
condition of the Existing Decontamination Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form. Ifthere are any cracks greater than 118 inch
separation (width), the RSO must be contacted. The RSO will have
the responsibility to cease activities and have the cracks repaired.
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results ofthe weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary ofthe storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
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The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHL Y TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer 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 inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
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.
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e) Remarks
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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.
j) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
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d) Summary
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The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
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
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs ofthe tailings area will be taken. The training ofindividuals will be
reviewed as a part of the Annual Technical Evaluation.
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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:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake City, Utah 84116-3156
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 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report ofthe
tailings management system.
6.3. Freeboard Limits
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the 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 Cell4A 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 Celli is 52.9 acres, in Cell4A is 40 acres, and in Ce1l4B is 40
acres. The top of the flexible membrane liner ("FML") for Celli is 5,618.2 FMSL, for Cell4A
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
is 5,598.5 FMSL and for Cell4B is 5600.4 FMSL.
o III 1 Revision: Denison 11.1
Page 17 of49
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. Celli
The freeboard limit for Cell 1 will be set at 5,615.4 FMSL. This will allow CellI 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 Cell4A (and/or any future tailings cells).
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. Cell4A
The freeboard limit for Cell4A is inapplicable since all of the PMP flood volume associated with
Cell4A will be attributed to Ce1l4B. A spillway has been added to Ce1l4A to allow overflow into
CeIl4B.
6.3.5. Cell4B
The freeboard limit for Cell4B will be set assuming that the total PMP volume for Cells 2, 3, 4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell 4B is as follows:
(aJ When the Pool Surface Area is 40 Acres
When the pool surface area in Cell4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Cell4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
38.1 acre-feet
159.4 acre-feet
197.5 acre-feet
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres
Wave run up factor
Total required freeboard
01/11 Revision: DenisonIl.l
Page 18 of49
4.9 feet
0.77 feet
5.7 feet
(all values in the above calculation have been rounded to the nearest one-tenth of afoot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation ofthe beach area in Cell4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevation of the beach area in Cell 4B first exceeds 5,594 FMSL, then the
freeboard limit for the remainder of the ensuing year (period t=O) (until the next November 1) will be
calculated when that elevation is first exceeded (the "Initial Calculation Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
4B prior to the Initial Calculation Date ("To") will be determined;
ii) The expected number of dry tons to be deposited into Cell4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("L1o*"), will be determined;
iii) L10* 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 4A will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder ofthe ensuing year will be
assumed to be directly proportional to the reduction in the available space in Ce1l4A
for solids. That is, the reduced pool surface area for period t=O ("RP Ao"), after the
reduction, will be calculated to be:
(1-(L10* x 1.5) 1(2,094,000 -To» x 40 acres = RPAo
vii) The required freeboard for Cell 4A for the remainder of the period t=O can be
calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the
quotient of 197.5 acre feet divided by the RP Ao. The freeboard limit for Cell4B for
the remainder of period t=O would then be the elevation of the FML for Ce1l4B of
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denisonl1.1
Page 19 of49
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculation is set out in Appendix F.
(d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5,594 FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARP At-I)
to reflect actual tonnages deposited in Cell4B for the previous period (period t-1).
The RP At-I used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPAt_1 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 RP A been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARPAt_1 can be calculated using the following formula:
(l-llt-I / (2,094,000 - Tt-I)) X ARPAt_2 = ARPAt_1
Where:
• llt-I is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;
• Tt-I is the actual number of dry tons oftailings solids historically deposited in
Cell4B prior to the beginning of period t-1; and
• ARP At-2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARP At-2 is 40 acres;
ii) Once the ARP At-I for the previous period (period t-1) has been calculated, the RP A
for the subject period (period t) can be calculated as follows:
(1 -(llt* x 1.5) / (2,094,000 - Tt)) x ARPAt_1 = RPAt
Where:
• llt * is the expected number of dry tons of tailings to be deposited into Cell 4 B
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);
• Tt is the actual number of dry tons of tailings solids historically deposited in
Cell4B prior to the beginning of period t; and
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01111 Revision: Denisonll.l
Page 20 of49
• ARP At-l is the Adjusted Reduced Pool Area for period t-l, which is the pool
surface area for the previous period (period t-l) 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 Cell4B of 0.77 feet plus the quotient of197.5 acre feet divided by the RPAt•
The freeboard limit for Cell4A for period t would then be the elevation ofthe 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 F.
(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 Ce1l4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
6.3.6. Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5 ,624.0 feet above mean sea
level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3. C. The results of the analysis will be reviewed to determine the origin of the
solution.
6.5. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01111 Revision: Denison 11.1
Page 21 of49
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be
visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may
have occurred since the last inspection. If any abnormalities are identified, defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use of the
facility. All inspection findings and any repairs required shall be documented on the Annual
Decontamination Pad Inspection form. A record of the repairs will be maintained as a part of the
Annual Inspection records at the Mill site. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due
September 1 of each calendar year.
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 Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2, 3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, 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 Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer 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
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Manager.
8.2. DMT Reports
01111 Revision: Denisonll.1
Page 22 of49
Quarterly reports ofDMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part I.F.2 ofthe GWDP
relating to the inspections described in Section 3.1 (b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool and Beach Area Elevation
Monitoring), 3.2 (Weekly Inspection of Solution Levels in Roberts Pond) and 3.3
(Weekly Feedstock Storage Area Inspections);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 6.5(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b), the inspection [mdings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year; and
e) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
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While Mesa Mill -Standard Opcrating Procedures
Book II: Environmental Protection Manu al, Section 3.1
APPENDIX A
FORMS
01 /11 Revision: Denison I 1.1
Page 23 of49
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01111 Revision: Denisonl1.1
Page 24 of49
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM I
Insoection Items Conditions of Potential Concern CellI
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 I
Inspection Items Conditions of Potential Concern CellI
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
Liner Observable Liner Damage
Cell 2
Cell 2
Inspector: ______ _
Date; ----------Accompanied by: ___ _
Time: ---------
Cell 3 Cell4A Cell4B
Cell 3 Cell4A Cell4B
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
III. DIKES AND EMBANKMENTS
Insl2ection Items Conditions of Potential
Concern
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
Crest Cracks, Subsidence, Severe
Erosion
IV. FLOWRATES
SluITV Line(s)
GPM
Dike I-I
I
01111 Revision: Denisonl1.l
Page 25 of49
Dike 1-Dike 2 Dike 3
lA
Dike
4A-S
Pond Return S-X Tails
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VI. DUST CONTROL
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
General Meteorological conditions:
Cell 2
______ yes
Yes ------
Cell 3
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Dike Dike Dike
4A-W 4B-S 4B-W
Spray System
______ No
No -------'
Cell4A Cell4B
I
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
VII. DAILY LEAK DETECTION CHECK
CellI
J l
Ce112
Leak Checked Checked
Detection
System Wet Dry Wet Dry
Checked
Initial level Initial level
Final Final
level level
Gal. pumped Gal. pumped
01/11 Revision: Denisonll.l
Page 26 of49
Cell 3 Ce114A
Checked Checked
Wet Dry Wet Dry
Initial level Initial level
Final Final
level level
Gal. pumped Gal. pumped
Cell4B
Checked
Wet Dry
Initial level
Final
level
Gal. pumped
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
[MAP OF TAILINGS AREA]
01111 Revision: Denisonll.l
Page 27 of49
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01111 Revision: Denison 11.1
Page 28 of49
Date: '--------
1. Pond and Beach
elevations (msl, ft)
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: ____________ _
CellI: (a) Pond Solution Elevation
(b) FML Bottom Elevation 5597 __ _
(c) Depth of Water above FML «a)-(b» _____ _
Ce1l4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14
(c)Depth of Water above FML «a)-(b» _____ _
Ce1l4B: (a)Pond Solution Elevation
Roberts
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML «a)-(b» ____ _
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation ___ 5612.3_
(c)Depth of Water above FML «a)-(b» _____ _
2. 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 38 '-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump= __ _
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
Observation:
CellI Cell 2 Cell 3
01111 Revision: Denisonll.l
Page 29 of49
Ce1l4A Cell4B
Is LDS wet or wet wet wet wet wet
dry? dry dry dry dry dry
If wet, Record Ftto Ft to Ftto Ftto Ftto
liquid level: Liquid Liquid Liquid Liquid * Liquid *
If sufficient Volume Volume Volume Volume Volume
fluid is
present, record Flow Flow Flow Flow Flow
volume of Rate Rate Rate Rate Rate
fluid pumped
and flow rate:
Was fluid --yes __ no --yes __ no --yes __ no --yes __ no --yes __ no
sample
collected?
Observation:
New Decon Pad, New Decon Pad, New Decon Pad
Portal I Portal 2 Portal 3
Is LDS (Portal) __ wet __ dry __ wet __ dry __ wet __ dry
wet or dry?
If wet, Record Ftto Ftto Ftto
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented: _____________________ _
6. Remarks: -------------------------------------------------------------
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, SectiQn 3. 1
01111 Revision: Denisonll.1
Pagf) 30 of49
7. Contaminated Waste Dump: ______________________ _
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Ce1l4A and 5558.50 for Cell 4B)? no __ yes
If Ce1l4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
01111 Revision: Denisonll.1
Page 31 of49
MONTHLY INSPECTION DATA
Inspector: __________________________ _
Date: ____________________________ __
1. Slurry Pipeline:
Pipe Thickness: _____ CTo be measured only during periods when the Mill is operating)
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 Diversion Ditch 2
-------.Yes __ no -------.Yes __ no
-------.Yes __ no -------.Yes __ no
-------.Yes __ no -------.Yes __ no
-------.Yes __ no -------.Yes __ no
Diversion Ditch 3 Diversion Berm 2
-------.Yes __ no
-------.Yes __ no
-------.Yes __ no
-------.Yes __ no
-------.Yes __ no
-------.Yes __ no
Comments: ______________________________________________________________________ _
3. Summary of Activities Around Sedimentation Pond: ________________________________ _
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White Mesa Mill-Standard Operating Procedures
Book I I: Environmental Protection Manual, Section 3. I
4. Overspray Dust Minimization:
Overspray system functioning properly: __ ~yes ___ no
o I III Revision: Denison I 1.I
Page 32 of49
Overspray carried more than 50 feet from the cell: ~es no
If"yes", was system immediately shut off? ~es __ no
Comments: ________________________________ _
5. Remarks: _______________________________ _
6. Settlement Monitors
Cell 2 WI: Cell 2W3-S: ____ _ Cell 3-1N: ____ _
Cell 2 W2: CeIl2EI-N: ____ _ CeI13-1C: ------Cell 2 W3: Cell 2E1-1S: ____ _ CeIl3-1S: ____ _
Cell 2 W4: Cell 2EI-2S: ____ _ Cell 3-2N: ____ _
Cell 2W7-C: -----Cell 2 East: Cell 2W5-N: ___ _
Cell 2 W7N: ____ _ Cell 2 W7S: ____ _ CeIl 2 W6N:
Cell 2 W6C: ____ _ Cell 2 W6S: ____ _ Cell 2 W4N: ___ _
Cell 4A-Toe: -----Cell 2 W4S: ____ _ CeIl 2 W5C: ___ _
Cell 3-2C: ____ _ Cell 3-2S: ____ _ CeIl 2 W5S: ____ _
7. Summary of Daily, Weekly and Quarterly Inspections: ______________ _
8. Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading):
9. Monthly Slimes Drain Static Head Measurement for Cell 3 (Depth-in-Pipe Water level) (after
Cell 3 is closed):
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White Mesa MilJ -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3. I
APPENDIX A (CONT.)
0111 1 Revision: Denisonll.l
Page 33 of49
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector: __________________________ _
Date: --------------------------------
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activities: --------------------------------------------
4. Summary: ____________________________________________________ ___
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
01111 Revision: Denisonl1.1
Page 34 of49
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through ____ Date of lnspection :, _______ _
Inspector: ___________ _
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no: ___ _
comments: -------------------------------------
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no: __ _
comments (e.g., conditions of containers): _________________ _
Are all sumps and low lying areas free of standing solutions?
Yes: No: ----If"No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No: ---Comments: ------------------------------------
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While Mesa MiII -Standard Operating Procedures
l300k I I: Environmental Protection Manual, Section 3. I
Other comments:
o til I Revision: Denison ILl
Page 35 or 49
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
01111 Revision: Denison 1 1.1
Page 36 of49
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection: _______ _
Inspector: ___________ _
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation? _Yes _No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? __ Yes __ No
Findings:
Repair Work Required:
Note For the annual inspection ofthe both the Existing and New Decontamination Pads, the
annual inspection findings, any repairs required, and repairs completed, along with a summary of
the weekly inspections, shall be discussed in the 2nd Quarter report, due September 1 of each
calendar year
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXB
01111 Revision: DenisonIl.l
Page 37 of49
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 for an example of the daily tailings
inspection form. The inspection form consists of three pages and 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
are to be monitored for leaks, and loose connections. The pipeline supports are to be
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
01111 Revision: Denisonll.l
Page 38 of49
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
ofthe 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 3, 4A-S, 4A-W, 4B-S, and 4B-W, should be
inspected closely for mice holes and more importantly for prairie dog holes, as the prairie
dogs are likely to burrow in deep, possibly to the liner. If any of these conditions exist, the
inspection report should be marked accordingly.
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3. I
4. Flow Rates:
Ol/ll Revision: DenisonIl.1
Page 39 of49
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. Ifpossible, 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 oftailings.
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 the Shifter 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.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
01 /11 Revision: Denisonl1.1
Page 40 of49
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 for the tailings area is 15 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation 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
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 Radiation
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Safety Officer and filed.
011ll Revision: Denisonl1.1
Page 41 of49
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White Mesa Mill -Standard Operating Procedures
Book II : Environmental Protection Manual, Section 3.1
Al'PENDlXC
CERTIFICATION FORM
Date: ~~~~~~~~~_
Name: _~~~~~~~~~~
01/11 Revision: Denison 11 .1
Page 42 of49
I have read the document titled "Tailings Management System, White Mesa Mill Tai lings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of dai ly tai lings 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 dai ly inspection of the tail.ings
system at the Whi te Mesa Mill.
Radiation Safety Personnel! Tailings System
Supervi sor
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White Mesa Mill -tandard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
01111 Revision: Denison ILl
Page 43 of49
APPENDIXD
FEEDSTOCK STORAGE AREA
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White Mesa Mill -Siandard Operating Procedures
Ilook I I: Environmental Prolcclion Manual, Section 3.1
APP EN DIX E
TABLES
01 /11 Revision: Dcnison l l.l
Page 44 of49
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah
01111 Revision: Denison 11.1
Page 45 of49
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day)
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4 B White mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
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White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
01 III Revision: Denison 11.1
Page 46 of49
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Assumptions and Factors:
APPENDIXF
Example of Freeboard Calculations
For Ce1l4B
01111 Revision: Denisonl1.1
Page 47 of49
o Total PMP volume to be stored in Cell4A -159.4 acre feet
o Wave runup factor for Cell4A -0.77 feet
o Total capacity of Cell 4B -2,094,000 dry tons
o Elevation ofFML ofCell4B -5,600.35 FMSL
o Maximum pool surface area of Cell 4A -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 fust exceeds 5,594, FMSL -March 1,2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Actual Tailings
Tailings Solids Tailings Solids
Disposition into Solids Disposition into
Cell 4B Disposition Cell 4B
Determined at into Cell determined at
the beginning of 4B at the end of the
the period (dry beginning period (dry
tons)* of the tons)*
period,
multiplied
by 150%
Safety
Factor
(dry_tonsl
March 1, 2012 150,000 225,000 225,000
to November 1,
2012
November 1, 300,000 450,000 275,000
2012 to
November 1,
2013
November 1, 200,000 300,000 250,000
2013 to
November 1,
2014
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01111 Revision: Denisonl1.1
Page 48 of49
*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 Ce1l4B would be calculated
as follows:
1. Prior to March 1, 2012
Prior to March 1,2012, the maximum elevation of the beach area in Ce1l4B is less than or
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 Ce1l4B of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Ce1l4B 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 of225,000 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 Ce1l4B 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.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. November 1, 2013 to November 1, 2014
The pool surface area would be reduced to the following amount:
01111 Revision: Denisonl1.1
Page 49 of49
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(1 -275,0001 (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:
(1-300,0001 (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 Ce1l4B 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.
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ATTACHMENT 2
PROPOSED REVISON 2.1 TO BAT OPERATIONS AND MANAGEMENT PLAN
RED-LINED AND CLEAN VERSIONS
~01/2011 Revision Denison 2.1Q
Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25, 2007. The construction
authorization provided that Ce1l4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part LF.3 of the
Groundwater Discharge Permit No. UGW370004 ("GWDP") and fulfill the
requirements of Parts 1.0.6, 1.E.8, and I.F.9 of the GWDP.
Construction ofCell4B was authorized by DRC on June 21, 2010. The construction
authorization provided that Cell 4B shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the GWDP and
fulfill the requirements of Parts 1.0.12, I.E.12, and I.F.9 ofthe GWDP
Cell Design
Tailings Ce1l4A consists of the following major elements:
a) Dikes -consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a IS-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to 1 V. The west dike has an interior slope of 2H to
1 V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 21 I-feet at the west dike.
b) Foundation -including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90%. Floor of
Cell 4A has an average slope of 1 % that grades from the northeast to the
southwest comers.
c) Tailings Capacity -the floor and inside slopes of Cell 4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of impermeable 60
N'\Ccl! 4!3\J nuary 2011 Submil!als !lnd Rcvi ions for CcIl4BIQ&M Plnn QI.IO.I1ICcI14A nnd 48 0 M PIAn Rev 2-'
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PlaA ClelHl 2Q IQ JIQ3 .aee
Page I
~ Revision [}cni$Oll 2.19
mil high density polyethylene (HOPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
atlhe top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Ce ll4A floor
area. In Olher locations, the primary FML will be in conlact with the
slimes drain collection system (discussed below).
NWcll 4/ru'!!!!I'Y 2011 Submjllllaind ItCYlsjo!!S ror Ccll 1PWM PI. 01 10 11\9;11 410 IOd 111 Q M Ply Sa2 !
• RWhnc.4QUI;'C.1I 4iWole" ... h., ''''''''ilH I1114 lhIYisillM I"« CAli 48\OAM 111_ 1I,II.IIJIC.1I4A .... mO M
PluCI_ ~OIOIIOUu
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Ce1l4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.Gl
2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an I8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML -consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System -including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ill Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. The non-woven geotextile
material is overlain at the surface by a woven geotextile fabric. which is
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-Redline.doc~H>\ibmiIl&lH~ien5-ferGe
PieR CleaR 2QHlIIQ].aee
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Cell4A BAT Monitoring, Operations and Maintenance Plan \112010 Revision Denison
2·g1
ballasted laterally bv sandbags Oil each side of the backbone of the benn.
In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as
the "backbone" to the slimes drain system and runs from the far northeast
corner downhill to the far southwest corner of Cell 4A where it joins the
slimes drain access pipe.
3) Slimes Drain Access Pipe -consisting of an I8-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and nonwoven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven. geotexti le fabric, wh ich is ballasted by sandbags.A reducer
connects the horizontal I8-inch pipe with the 4-inch SDC pipe. At some
future time, a pump will be set in this I8-inch pipe and used to remove
tailings wastewaters for purposes of de-watering the tailings cell.
f) Dike Splash Pads - A minimum of eight (8) 20-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads consist of an extra layer of 60 mil
HDPE membrane that is placed down the inside slope of Cell 4A, from the top
of the dike and down the inside slope. The pads extend to a point 5-feet
beyond the toe of the slope to protect the liner bottom during initial startup of
the Cell. The exact location of the splash pads is detailed on the As-Built
Plans and Specifications.
g) Rub Protection Sheets -In addition to the splash pads described in f) above,
rub sheets are installed beneath all piping entering or exiting Cell 4A that is
not located directly on the splash pads.
h) Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. A second
spillway has been constructed in the southwest corner of Cell 4A to allow
emergency runoff from Cell 4A into Cell 48. All stormwater runoff and
tailings wastewaters not retained in Cells 3 and 4A, will be managed and
contained in Cell 4B, including the Probable Maximum Precipitation and
flood event.
Tailings Ce1l4B consists of the following major elements:
a) Dike -consisting of a newly-constructed dike on the south side of the cell
with a I5-foot wide road at the top (minimum) to support an access road.
The grading plan for the Cell 4B excavation includes interior slopes of 2H
to 1 V. The exterior slope of the southern dike will have the typical slopes
of 3H to 1 V. Limited portions of the Cell 4B interior sideslopes in the
northwest corner and southeast corner of the cell (where the slimes drain
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Ce1l4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
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and leak detection sump will be located) will also have a slope of 3H to
1 V. The base width of the southern dike varies from approximately 100
feet at the western end to approximately 190 feet at the eastern end of the
dike, with no exterior embankment present on any other side of the cell.
b) Foundation -including subgrade soils over bedrock materials. Foundation
preparation included 6-inch over excavation of rock and placement and
compaction of imported soils to a maximum dry density of 90% at a
moisture content between +3% and -3% of optimum moisture content, as
determined by ASTM D-1557. The floor of Cell 4B has an average slope
of I % that grades from the northwest corner to the southeast corner.
c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass
about 45 acres and the cell will have a water surface area of 40 acres and a
maximum capacity of about 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of 60 mil high
density polyethylene (HDPE) membrane that extends across both the
entire cell floor and the inside side-slopes, and is anchored in a trench at
the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4B floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4B, and
drains to a leak detection sump in the southeast corner. Access to the leak
detection sump is via aft ~2-foot inside diameter (ID) PVC pipe
placed down the inside slope, located between the primary and secondary
FML liners. At its base this pipe will be surrounded with a gravel filter set
in the leak detection sump, having dimensions of 10 feet by 10 feet by 2
feet deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML -consisting of a 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends
across the entire Cell 4B floor, up the inside side-slopes and is also
anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4B, the Permittee shall demonstrate that the
GCL ha_~. achieved a moisture content of at least 50% by weight.
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
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e) Slimes Drain Collection System -including a two-part system of strip
drains and perforated collection pipes both installed immediately above
the primary FML, as follows:
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4B that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southeasterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ill Schedule 40 perforated PVC slimes drain
collection (SOC) pipe found at the down gradient end of the strip drain
lines. This pipe is in tum overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In tum, the gravel is overlain
by a layer of non-woven geotextile to serve as an additional filter material.
The non-woven geotextile material is overlain at the surface by a woven
geotextile fabric. which is ballasted by sandbags. This perforated
collection pipe serves as the "backbone" to the slimes drain system and
runs from the far northwest corner downhill to the far southeast comer of
Cell 4B where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe -consisting of an IS-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4B at the southeast comer,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and non:woven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted laterally by sandbags on each
side of the backbone of the berm. A reducer connects the horizontal IS-
inch pipe with the 4-inch SDC pipe. At some future time, a pump will be
set in this IS-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
f) Cell 48 North and East Dike Splash Pads -Nine 20-foot-wide splash pads
will be constructed on the north and east dikes to protect the primary FML
from abrasion and scouring by tailings slurry. These pads will consist of
an extra layer of textured, 60 mil HDPE membrane that will be installed in
the anchor trench and placed down the inside slope of Cell 48, from the
top of the dike, under the inlet pipe, and down the inside slope to a point at
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Cell4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
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least 5 feet onto the Cell 4B floor beyond the toe of the slope.
g) Rub Protection Sheets -In addition to the splash pads described in f)
above, rub sheets are installed beneath all piping entering or exiting Cell
4B that is not located directly on the splash pads.
h) Emergency Spillway - a concrete lined spillway constructed near the
southern corner of the east dike to allow emergency runoff from Cell 4A
into Cell 4B. This spillway will be limited to a 6-inch reinforced concrete
slab, with a welded-wire fabric installed within its midsection, set atop a
cushion geotextiJe placed directly over the primary FML in a 4-foot deep
trapezoidal channel. A 100 foot wide, 60 mil HDPE geomembrane splash
pad will be installed beneath the emergency spillway. No other spillway
or overflow structure will be constructed at Cell 4B. All storm water
runoff and tailings wastewaters not retained in Cells 2, 3 and 4A, will be
managed and contained in Cell 4B, including the Probable Maximum
Precipitation and flood event.
Cell Operation
Solution Discharge to Cell 4A
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3, or transferred from Cell 2
tailings dewatering operations. The solution will be pumped to Cell 4A through 6
inch or 8 inch diameter HDPE pipelines. The initial solution discharge will be in
the southwest comer of the Cell. The solution will be discharged in the bottom
of the Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and CeIl4A, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.
Solution Discharge to Cell 4B
Cell 4B will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3 or Cell 4A, or transferred
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Ce1l4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.01
from Cell 2 dewatering operations. The solution will be pumped to Cell 4B
through 6 inch or 8 inch diameter HDPE pipelines. The initial solution discharge
will be in the southeast comer of the Cell. The discharge pipe will be routed
down the Splash Pad provided in the southeast comer of the Cell at the spillway
to protect the primary FML. The solution will be discharged in the bottom of the
Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and Cell 4B, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.
Initial Solids Discharge into Cell 4A
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No.8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 4A, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure lAo Figure
2A illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2A. Because of the
depth of Cell 4A, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
Initial Solids Discharge into Cell 4B
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Cell4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2·()1
Once Cell 4B is needed for storage for tailings solids the slurry discharge from
No.8 CCO thickener will be pumped to the cell through 6 inch or 8 inch diameter
HOPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 4B, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1 B. Figure
2B illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2B. Because of the
depth of Cell 4B, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
Equipment Access to Cell 4A and Ce1l4B
Access will be restricted to the interior portion of the cells due to the potential to
damage the flexible membrane liners. Only low pressure rubber tired all terrain
vehicles or foot traffic will be allowed on the flexible membrane liners. Personnel
are also cautioned on the potential damage to the flexible membrane liners
through the use and handling of hand tools and maintenance materials.
Reclaim Water System at Cell 4A
A pump barge and solution recovery system is operating in the southwest comer
of the cell to pump solution from the cell for water balance purposes or for re-use
in the Mill process. Figure 3A illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Reclaim Water System at Cell 4B
A pump barge and solution recovery system will be installed in the southeast
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Cell4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.Ql
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3B illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharge to Ce1l4A
Figure 4A illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4A. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
Interim Solids Discharge to Cell 4B
Figure 4B illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4B. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
Liner Maintenance and QAlQC for Cell 4A
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised Construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
Liner Maintenance and QA/QC for Cell 4B
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Construction Quality Assurance Plan
for the Construction of the Cell 4B Lining System, October 2009, by
Geosyntec Consultants.
BAT Performance Standards for Tailings Cell 4A and 4B
DUSA will operate and maintain Tailings Cell 4A and 4B so as to prevent release of
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Cell4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.G!
wastewater to groundwater and the environment in accordance with this BAT Monitoring
Operations and Maintenance Plan, pursuant to Part I.H.8 of the GWDP. These
performance standards shall include:
1) Leak Detection System Pumping and Monitoring Equipment -the
leak detection system pumping and monitoring equipment in each cell
includes a submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system in each
cell at no more than 1 foot above the lowest level of the secondary flexible
membrane, not including the sump (i.e. lie mele !:haft 3 feet eee,'e ike
BOttOfB of the Sl:lfBfJ). A second leak detection pump with pressure
transducer, flow meter, and manufacturer recommended spare parts for the
pump controller and water level data collector is maintained in the Mill
warehouse to ensure that the pump and controller can be replaced and
operational within 24 hours of detection of a failure of the pumping
system. The root cause of the equipment failure will be documented in a
report to Mill management with recommendations for prevention of a re-
occurrence.
2) Maximum Allowable Head -the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane in each cell
by the use of procedures and equipment specified in the White Mesa
Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan, 10/10 Revision: Denison-tO.2,
or the currently approved DMT Plan. Under no circumstance shall fluid
head in the leak detection system sump exceed a I-foot level above the
lowest point in the lower flexible membrane liner, not including the
sump (Le. Re lIIore tBlIfI 3 feet aBeo.'e the aoUem efttie Sl:lH'Ip).
3) Maximum Allowable Daily LDS Flow Rates -the Permittee shall
measure the volume of all fluids pumped from each LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell
4B. The maximum daily LDS flow volume will be compared against the
measured cell solution levels detailed on the attached Table lA or IB for
Cells 4A or 4B, respectively, to determine the maximum daily allowable
LDS flow volume for varying head conditions in the cell.
4) 3-foot Minimum Vertical Freeboard Criteria -the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell 4A and Cell 4B. Said measurements
shall be made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring -immediately after the
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Cel14A BAT Monitoring, Operations and Maintenance Plan \112010 Revision Denison
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Permittee initiates pumping conditions in the Tailings Cell 4A or Cell
4B slimes drain system, monthly recovery head tests and fluid level
measurements will be made in accordance with a plan approved by the
DRC Executive Secretary. The slimes drain system pumping and
monitoring equipment, includes a submersible pump, pump controller,
water level indicator (head monitoring), and flow meter with volume
totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements of solution elevation in Cell 4A and Cell 4B are to be taken by
survey on a weekly basis, and measurements of the beach area in Cell4A and Cell
4B with the highest elevation are to be taken by survey on a monthly basis, by the
use of the procedures and equipment specified in the latest approved edition ofthe
DMTPlan.
Leak Detection System
The Leak Detection System in Cell 4A and Cell 4B is monitored on a
continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The water levels are measured
every hour and the information is stored for later retrieval. The water
levels are measured to the nearest 0.10 inch. The data collector is
currently programmed to store 7 days of water level information. The
number of days of stored data can be increased beyond 7 days if needed.
The water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill's environmental monitoring data base,
and into the files for weekly inspection reports of the tailings cell leak
detection systems. Within 24 hours after collection of the weekly water
level data, the information will be evaluated to ensure that: 1) the water
level in the Cell 4A and Cell 4B leak detection sumps did not exceed the
allowable level (5556.14 feet amsl in the Cell 4A LDS sump and 5558.5
feet amsl in the Cell4B sump), and 2) the average daily flow rate from the
LDS did not exceed the maximum daily allowable flow rate at any time
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Ce1l4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.()!
during the reporting period. For Cell 4A and Cell 4B, under no
circumstance shall fluid head in the leak detection system sump exceed a
I-foot level above the lowest point in the lower flexible membrane liner,
not including the sump~aa 3 feet above ilie bortoffi ef the
SttHtpj. To determine the Maximum Allowable Daily LDS Flow Rates in
the Cell 4A and Cell 4B leak detection system, the total volume of all
fluids pumped from the LDS of each cell on a weekly basis shall be
recovered from the data collector, and that information will be used to
calculate an average volume pumped per day for each cell. Under no
circumstances shall the daily LDS flow volume exceed 24,160 gallons/day
from Cell 4A or 26,145 gallons/day from Cell 4B. The maximum daily
LDS flow volume will be compared against the measured cell solution
levels detailed on the attached Tables lA and lB, to determine the
maximum daily allowable LDS flow volume for varying head conditions
in Cell 4A and Cell 4B. Any abnormal or out of compliance water levels
must be immediately reported to Mill management. The data collector on
each cell is also equipped with an audible alarm that sounds if the water
level in the leak detection sump exceeds the allowable level (5556.14 feet
amsl in the Cell4A LDS sump and 5558.5 feet amsl in the Cell 4B sump).
The current water level is displayed at all times on each data collector and
available for recording on the daily inspection form. Each leak detection
system is also equipped with a leak detection pump, EPS Model # 25S05-
3 stainless steel, or equal. Each pump is capable of pumping in excess of
25 gallons per minute at a total dynamic head of 50 feet. Each pump has a
1.5 inch diameter discharge, and operates on 460 volt 3 phase power.
Each pump is equipped with a pressure sensing transducer to start the
pump once the level of solution in the leak detection sump is
approximately 2.25 feet (elevation 5555.89 in the Cell 4A LOS sump and
5557.69 feet amsl in the Cell 4B sump) above the lowest level of the leak
detection sump (9 inches above the lowest point on the lower flexible
membrane liner for Cell 4A and 3 inches for Cell 4B), to ensure the
allowable 1.0 foot (5556.14 feet amsl in the Cell 4A LOS sump and
5558.5 feet amsl in the Cell4B sump) above the lowest point on the lower
flexible membrane liner is not exceeded). The attached Figures 6A and
6B (Cell 4A and 4B, respectively), Leak Detection Sump Operating
Elevations, illustrates the relationship between the sump elevation, the
lowest point on the lower flexible membrane liner and the pump-on
solution elevation for the leak detection pump. The pump also has manual
start and stop controls. The pump will operate until the solution is drawn
down to the lowest level possible, expected to be approximately 4 inches
above the lowest level of the sump (approximate elevation 5554.0 and
5555.77 ft amsl for Cells 4A and 4B, respectively). The pump discharge
is equipped with a 1.5 inch flow meter, EPS Paddle Wheel Flowsensor, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The flow rate and total gallons are recorded by the
Inspector on the weekly inspection form. The leak detection pump is
N'\CcI! 4B\Januarv 201 I Sybmitl4!s and Revisions [or Cell 4B\Q&M PI n () I 10. I I\CoII 4A ond 4B a M Plan Rev 2. I
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
H l
installed in the horizontal section of the 18 inch, perforated section of the
PVC collection pipe. The distance from the top flange face, at the
collection pipe invert, to the centerline of the 22.5 degree elbow is 133.4
feet in Cell 4A and 135.6 feet in Cell 4B, and the vertical height is
approximately 45 feet in Cell 4A and approximately 42.5 feet in Cell 4B.
The pump is installed at least 2 feet beyond the centerline of the elbow.
The bottom of the pump will be installed in the leak detection sump at
least 135.4 feet in Cell 4A and l37.6 feet in Cell 4B or more from the top
of the flange invert. A pressure transducer installed within the pump
continuously measures the solution head and is programmed to start and
stop the pump within the ranges specified above. The attached Figure 5,
illustrates the general configuration of the pump installation.
A spare leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller on either cell can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of are-occurrence.
Slimes Drain System
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe of each cell and a near
as possible to the bottom of the slimes drain sump. The bottom of the
slimes drain sump in Cell 4A and Cell 4B are 38 and 35.9 feet below a
water level measuring point, respectively, at the centerline of the slimes
drain access pipe, near the ground surface level. Each pump discharge
will be equipped with a 2 inch flow meter, E/H Model #33, or equal, that
reads the pump discharge in gallons per minute, and records total gallons
pumped. The flow rate and total gallons will be recorded by the Inspector
on the weekly inspection form.
Cii) The slimes drain pumps will be on adjustable probes that allow the pumps
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A and Cell 4B slimes drain pumps will be checked weekly to
observe that they are operating and that the level probes are set properly,
which is noted on the Weekly Tailings Inspection Form. If at any time
either pump is observed to be not working properly, it will be repaired or
replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A and Cell 4B slimes drain access riser
pipes shall be monitored and recorded weekly to determine maximum and
minimum fluid head before and after a pumping cycle, respectively. All
head measurements must be made from the same measuring point, to the
N'\Ce!l 4B\1nnuarv 2011 Submit!81~qnd Rcvi~ions for CcIl4mO&M Plan 01.10 I IICcll4A and4B 0 M Plen Rev 2 I
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Page 14
Ce1l4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2·Ql
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, each slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pumps for each cell will not be operated until Mill management
has determined that no additional process solutions will be discharged to that cell,
and the cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell 2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Ce1l4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-1, Cell 2, Cell 3, CeIl4A,
and Cell 4B are regulated by condition 10.3 of the White Mesa Mill l1e.(2) Materials
License.
Condition 10.3 states that "The FreellElImJ limit fer Celllsltsil be S61S.4 feet sbove
meso sell leYel;-&IHHIJe fnebosf'd limit feF Cell 41. 8~1 4B 5hel~
iD-&eee-RJollee "'ith the flroee9ures set eut ill tbe latest edition of the Wbite-Mess
Mill Tailings M8A&gem:e:ot-System snd l)isehftrge MittimiMtioll Technology (DMT)
~Ait9Fiflg Plftll 'lllIiefi.-is inchlded os s seetion of the Mill's Environmental
N;\Ccl] 1B\Jnnunrv 20) I Submitmls and Revisions for <&1\4BIQ&M PIM 01.10. I I\Cell 4A od 4·B Q M Plan Rev 2 I
-Redline.dooN;l,(;;eIl-4B\Novembe~llul~ IlREI RedsiollS for Cell 4BIO&M-Pl&n 1 1.1 l.IQ\CellAA 8nd-4~
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Page 15
Cel14A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2·Ql
Pretemao MeRuel. Said eeleulotieHs SMillie submitted as paFt ef t:he Attaua!
Teeh&ieal E-.'ohmti&n RepeR. Sltid FepeFt shall be submitted fer Elleeuti'le
SeeFetary optJf'6val fie later th1lH NO'leHlber lS ef eoeh )'eor.Freeboard limits.
stonnwaler and wastewater management for the railings cells shall be detennined as
follows:
A. The freeboard limit for CellI shall be set annually in accordance
with the procedures set out in Section 3.0 to Appendix E of the
previously approved NRC license application. including the
January 10, 1990 Drainage Report. Discharge of any surface water
or wastewater from Cell I is expressly prohibited.!!
B. The freeboard limit for Cells 3. 4A and 4B shall be recalculated
annually in accordance with the procedures established by the
Executive Secretary. Said calculations for freeboard limits shall be
submitted as part of the Annual Technical Evaluation Report
CATER), as described in Condition 12.3 below [of the licesnse and
not included herein].
C. The clischarge of any surface water. stormwater. or wastewater
from Cells 3. 4A. and 48 shall only be through an Executive
Secretary authorized spiOway structure. [Applicable NRC
Amendment:161 [Applicable UORC Amendment: 31 [Applicable
UDRC Amendment:4] ,
The freeboard limits set out in Section 6.3 of the DMT Plan are intended to capture the
Local 6-hour Probable Maximum Precipitation (PMP) event, which was detennined in
the January 10, 1990 Drainage Report for the White Mesa site to be 10 inches.
Based on the PMP storm event, the freeboard requirement for Cell 1 is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3, 4A, or 4B.
Cells 2 and 3 have no freeboard limit because those Cells are full or near full oftailings
solids. Cell 4A has no freeboard limit because it is assumed that all precipitation falling
on Cell 4A will overflow to Cell 4B. All precipitation falling on Cell 2, 3, and 4A and
the adjacent drainage areas must be contained in Cell 4B. The flood volume from the
PMP event over the Cell 2, 3, and Cell4A pond areas, plus the adjacent drainage areas,
which must be contained in Cell 48, is 159.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3 .25 acres, times the PMP of 10 inches). For the
purposes of establishing the freeboard in Cell 4B, it is assumed Cell 4A has no freeboard
limit and all of the flood volume from the PMP event will be contained in Ce1l4B. The
flood volume from the PMP event over the Ce1l4B area is 38.l acre-feet of water (40
acres, plus the adjacent drainage area of 5.7 acres, times the PMP of 10 inches). This
would result in a total flood volume of 197.5 acre-feet, including the 123.4 acre-feet of
solution from Cells 2 and 3 and 36 acre-feet of solution from Cells 2, 3, and 4A that must
N;\Co1l 4B\Januarv ZOI I Submittalsaod Revisions Cor Cc!l 4B\Q&M Plan 0 I. 10. I I\Cc!l 4A and 4B 0 M Plan Rev 2.1
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Page 16
Formatted: Outline numbered + Level: 6 +
Numbering Style: A, B, C, ... + Start at: 1 +
Alignment: Left + Aligned at: 1.15" + Tab
after: 1.5" + Indent at: 1.5"
Cell4A BAT Monitoring. Operations UJld Maintenance Plan J 1120JORevision Denison
2.01
be contained in Cell 48. The procedure for calculating the freeboard limit for Cell4B is
set oUl in the DMT Plan.
The Groundwater Quality Discharge Permit. 0.UGW370004, for the White Mesa Mill
requires thatlhe minimum freeboard be no less than 3.0 feet for Cells I, 4A, and 4B bul
based on License condition 10.3 and the procedure set out in the DMT Plan, the
fi'eeboard limits for Cells I, 4A and 48 will be at leasl three feet.
Figure 7, Hydraulic Pro'file Schematic, shows the relationship between the Cells and the
relative elevations of the solution pools and the spillway elevations.
The required freeboard for Cells 4A and 48 will be recalculated annually.
N'\ccU 413\JanuDJY 2011 Subminols lind Revisions rQr Cell 4BIQ&M Plan 0 1.10.11\CcU 4A and 4B 0 M PI n Rev 2 J
-Rcdlinc,dQcW:~1 4&\NoYemllef-SublllitlAl!Hl~ns-f~I-48\Q&M Phm 11.11.IQlCeJl ~ ... alJli.4B..G.-M
~1l201011Q3,dee
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.()1
Attachments
1) Figures 1A and lB, Initial Filling Plan, Geosyntec Consultants
2) Figure 2A and 2B, Initial Filling Plan, Details and Sections, Geosyntec
Consultants
3) Figure 3A and 3B, Initial Filling Plan, Solution and Slurry Pipeline Routes,
Geosyntec Consultants
4) Figure 4A and 4B, Interim Filling Plan, Geosyntec Consultants
5) Figure 5, Leak Detection System Sumps for Cell 4A and 4B, Geosyntec
Consultants
6) Figure 6A and 6B, Leak Detection Sump Operating Elevations, Geosyntec
Consultants
7) Figure 7, Hydraulic Profile Schematic
8) Cell 4A and Cell 4B Freeboard Calculations
9) Table lA, Calculated Action leakage Rates for Various Head Conditions,
Cell 4A, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
10) Table 1B, Calculated Action leakage Rates for Various Head Conditions,
Cell 4B, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
+---"\ Formatted: Tab stops: 4.99", Left
11) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan", 19/HI Re'oIisieA: DUSA 19, , eF
eurreBtly IlJ3Pfe'JeEl .... ersiaR afthe DMT
N;\Ccll mlJRHWyY 20' 1 Submjltals gnd Revisions for Cd' 4B\O&M Plan 0' 1O.11\Ce1l4A and 4B 0 M Plan Rev 2.1
-Redline.doc~!;'.Cell 4B\)l~I&l5-oRd R-e"iSiQA~ Iilr Cell 4B\Q&.H Plan Il.11.10\Gell 4"" BAd 49 0 H
Phm ClelHl21lHll Hl3.dee
Page 18
Geosyntec Consultants Table 1A
Calculated Action Leakage Rates for Various Head Conditions
Cel14A, White Mesa Mill
Blanding, Utah
Head Above Liner Calculated Action Leakage Rate
System (feet) (gallons/aue/day)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
Geosyntec Consultants Table 16
Calculated Action leakage Rates for Various Head Conditions
Cell 46, White Mesa Mill
Blanding, Utah
Head Above Liner System Calculated Action Leakage Rate
(feet) (gallons/acre/day)
5 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
3S 570.0
37 581.2
01 /2011 Revision Denison 2.1
Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("ORC) on June 25, 2007. The construction
authorization provided that Cell 4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the
Groundwater Discharge Permit No. UGW370004 ("GWDP") and fulfill the
requirements of Parts I.D.6, I.E.8, and I.F.9 of the GWDP.
Construction ofCe1l4B was authorized by DRC on June 21, 2010. The construction
authorization provided that Cell 4 B shall not be in operation until after a BA T
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the GWDP and
fulfill the requirements of Parts I.D.12, I.E. 12, and I.F.9 of the GWDP
Cell Design
Tailings Ce1l4A consists of the following major elements:
a) Dikes -consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a IS-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to 1 V. The west dike has an interior slope of 2H to
1 V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation -including sub grade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90%. Floor of
Cell 4A has an average slope of 1 % that grades from the northeast to the
southwest corners.
c) Tailings Capacity -the floor and inside slopes of Cell 4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
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the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Ce1l4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
N:\Ccll 4B\.Ianllary 20 II llbmittnls ru1d Revi ions for Ce ll 4B\O&M Plan 01.1 O.II\Cell 4A and 480 M Plan Rcv 2.1
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Ce1l4A BAT Monitoring, Operations and Maintenance Plan 1112010 Revision Denison
2.1
2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an I8-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML -consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay
liner (GCL) composed of O.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System -including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
I) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. The non-woven geotextile
material is overlain at the surface by a woven geotextile fabric, which is
ballasted laterally by sandbags on each side of the backbone of the berm.
N:\Ce1l4B\January 2011 Submittals and Revisions for Ce1l4B\O&M Plan 01.10.ll\Ce1l4A and 4B 0 M Plan Rev 2.1
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Ce1l4A BAT Monitoring, Operations and Maintenance Plan 11/2010 Revision Denison
2.1
In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as
the "backbone" to the slimes drain system and runs from the far northeast
corner downhill to the far southwest corner of Cell 4A where it joins the
slimes drain access pipe.
3) Slimes Drain Access Pipe -consisting of an I8-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and nonwoven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted by sandbags.A reducer
connects the horizontal I8-inch pipe with the 4-inch SDC pipe. At some
future time, a pump will be set in this 18-inch pipe and used to remove
tailings wastewaters for purposes of de-watering the tailings cell.
f) Dike Splash Pads - A minimum of eight (8) 20-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads consist of an extra layer of 60 mil
HDPE membrane that is placed down the inside slope of Cell 4A, from the top
of the dike and down the inside slope. The pads extend to a point 5-feet
beyond the toe of the slope to protect the liner bottom during initial startup of
the Cell. The exact location of the splash pads is detailed on the As-Built
Plans and Specifications.
g) Rub Protection Sheets -In addition to the splash pads described in f) above,
rub sheets are installed beneath all piping entering or exiting Cell 4A that is
not located directly on the splash pads.
h) Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. A second
spillway has been constructed in the southwest corner of Cell 4A to allow
emergency runoff from Cell 4A into Cell 4B. All stormwater runoff and
tailings wastewaters not retained in Cells 3 and 4A, will be managed and
contained in Cell 4B, including the Probable Maximum Precipitation and
flood event.
Tailings Cell4B consists of the following major elements:
a) Dike -consisting of a newly-constructed dike on the south side of the cell
with a IS-foot wide road at the top (minimum) to support an access road.
The grading plan for the Cell 4B excavation includes interior slopes of 2H
to IV. The exterior slope of the southern dike will have the typical slopes
of 3H to IV. Limited portions of the Cell 4B interior sideslopes in the
northwest corner and southeast corner of the cell (where the slimes drain
and leak detection sump will be located) will also have a slope of 3H to
N :\Ce1l4B\January 2011 Submittals and Revisions for Ce1l4B\O&M Plan 01.10.II\Ce1l4A and 4B 0 M Plan Rev 2.1
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 11120 I 0 Revision Denison
2.1
1 V. The base width of the southern dike varies from approximately 100
feet at the western end to approximately 190 feet at the eastern end of the
dike, with no exterior embankment present on any other side of the cell.
b) Foundation -including subgrade soils over bedrock materials. Foundation
preparation included 6-inch over excavation of rock and placement and
compaction of imported soils to a maximum dry density of 90% at a
moisture content between +3% and -3% of optimum moisture content, as
determined by ASTM D-1557. The floor of Cell 4B has an average slope
of 1 % that grades from the northwest corner to the southeast comer.
c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass
about 45 acres and the cell will have a water surface area of 40 acres and a
maximum capacity of about 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) -consisting of 60 mil high
density polyethylene (HDPE) membrane that extends across both the
entire cell floor and the inside side-slopes, and is anchored in a trench at
the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4B floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
2) Leak Detection System -includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4B, and
drains to a leak detection sump in the southeast corner. Access to the leak
detection sump is via a 2-foot inside diameter (ID) PVC pipe placed down
the inside slope, located between the primary and secondary FML liners.
At its base this pipe will be surrounded with a gravel filter set in the leak
detection sump, having dimensions of 10 feet by 10 feet by 2 feet deep. In
turn, the gravel filter layer will be enclosed in an envelope of geotextile
fabric. The purpose of both the gravel and geotextile fabric is to serve as a
filter.
3) Secondary FML -consisting of a 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends
across the entire Cell 4B floor, up the inside side-slopes and is also
anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay
liner (GCL) composed of O.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4B, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight.
e) Slimes Drain Collection System -including a two-part system of strip
drains and perforated collection pipes both installed immediately above
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Cell 4A BAT Monitoring, Operations and Maintenance Plan
the primary FML, as follows:
1112010 Revision Denison
2.1
1) Horizontal Strip Drain System -is installed in a herringbone pattern
across the floor of Cell 4B that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southeasterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with ftlter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System -includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
by a layer of non-woven geotextile to serve as an additional filter material.
The non-woven geotextile material is overlain at the surface by a woven
geotextile fabric, which is ballasted by sandbags. This perforated
collection pipe serves as the "backbone" to the slimes drain system and
runs from the far northwest corner downhill to the far southeast corner of
Ce1l4B where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe -consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4B at the southeast corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and non-woven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted laterally by sandbags on each
side of the backbone of the berm. A reducer connects the horizontal 18-
inch pipe with the 4-inch SDC pipe. At some future time, a pump will be
set in this 18-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
f) Ce1l4B North and East Dike Splash Pads -Nine 20-foot-wide splash pads
will be constructed on the north and east dikes to protect the primary FML
from abrasion and scouring by tailings slurry. These pads will consist of
an extra layer of textured, 60 mil HDPE membrane that will be installed in
the anchor trench and placed down the inside slope of Cell 4B, from the
top of the dike, under the inlet pipe, and down the inside slope to a point at
least 5 feet onto the Cell4B floor beyond the toe of the slope.
g) Rub Protection Sheets -In addition to the splash pads described in f)
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above, rub sheets are installed beneath all piping entering or exiting Cell
4B that is not located directly on the splash pads.
h) Emergency Spillway - a concrete lined spillway constructed near the
southern corner of the east dike to allow emergency runoff from Cell 4A
into Cell 4B. This spillway will be limited to a 6-inch reinforced concrete
slab, with a welded-wire fabric installed within its midsection, set atop a
cushion geotextile placed directly over the primary FML in a 4-foot deep
trapezoidal channel. A 100 foot wide, 60 mil HDPE geomembrane splash
pad will be installed beneath the emergency spillway. No other spillway
or overflow structure will be constructed at Cell 4B. All stormwater
runoff and tailings wastewaters not retained in Cells 2, 3 and 4A, will be
managed and contained in Cell 4B, including the Probable Maximum
Precipitation and flood event.
Cell Operation
Solution Discharge to Cell 4A
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3, or transferred from Cell 2
tailings dewatering operations. The solution will be pumped to Cell4A through 6
inch or 8 inch diameter HDPE pipelines. The initial solution discharge will be in
the southwest corner of the Cell. The solution will be discharged in the bottom
of the Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and Ce1l4A, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.
Solution Discharge to Ce1l4B
Cell 4B will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3 or Cell 4A, or transferred
from Cell 2 dewatering operations. The solution will be pumped to Cell 4B
through 6 inch or 8 inch diameter HDPE pipelines. The initial solution discharge
will be in the southeast corner of the Cell. The discharge pipe will be routed
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down the Splash Pad provided in the southeast corner of the Cell at the spillway
to protect the primary FML. The solution will be discharged in the bottom of the
Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and Cell4B, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.
Initial Solids Discharge into Cell 4A
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No.8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Ce1l4A, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure IA. Figure
2A illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2A. Because of the
depth of Cell 4A, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
Initial Solids Discharge into Ce1l4B
Once Cell 4B is needed for storage for tailings solids the slurry discharge from
No.8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell4B, with discharge valves and drop pipes extending down the Splash Pads to
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the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure lB. Figure
2B illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6" or 8" stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2B. Because of the
depth of Cell 4B, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.
Equipment Access to Ce1l4A and Ce1l4B
Access will be restricted to the interior portion of the cells due to the potential to
damage the flexible membrane liners. Only low pressure rubber tired all terrain
vehicles or foot traffic will be allowed on the flexible membrane liners. Personnel
are also cautioned on the potential damage to the flexible membrane liners
through the use and handling of hand tools and maintenance materials.
Reclaim Water System at Ce1l4A
A pump barge and solution recovery system is operating in the southwest comer
of the cell to pump solution from the cell for water balance purposes or for re-use
in the Mill process. Figure 3A illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Reclaim Water System at Cell4B
A pump barge and solution recovery system will be installed in the southeast
comer of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3B illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
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the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharge to Cell 4A
Figure 4A illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4A. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
Interim Solids Discharge to Cell4B
Figure 4B illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4B. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.
Liner Maintenance and QAlQC for Cell 4A
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised Construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
Liner Maintenance and QA/QC for Ce1l4B
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Construction Quality Assurance Plan
for the Construction of the Cell 4B Lining System, October 2009, by
Geosyntec Consultants.
BAT Performance Standards for Tailings Cell 4A and 4B
DUSA will operate and maintain Tailings Ce1l4A and 4B so as to prevent release of
wastewater to groundwater and the environment in accordance with this BAT Monitoring
Operations and Maintenance Plan, pursuant to Part I.H.8 of the GWDP. These
performance standards shall include:
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1) Leak Detection System Pumping and Monitoring Equipment -the
leak detection system pumping and monitoring equipment in each cell
includes a submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system in each
cell at no more than 1 foot above the lowest level of the secondary flexible
membrane, not including the sump. A second leak detection pump with
pressure transducer, flow meter, and manufacturer recommended spare
parts for the pump controller and water level data collector is maintained
in the Mill warehouse to ensure that the pump and controller can be
replaced and operational within 24 hours of detection of a failure of the
pumping system. The root cause of the equipment failure will be
documented in a report to Mill management with recommendations for
prevention of are-occurrence.
2) Maximum Allowable Head -the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane in each cell
by the use of procedures and equipment specified in the White Mesa
Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan, 10/10 Revision: Denison-l0.2,
or the currently approved DMT Plan. Under no circumstance shall fluid
head in the leak detection system sump exceed a 1-foot level above the
lowest point in the lower flexible membrane liner, not including the
sump.
3) Maximum Allowable Daily LDS Flow Rates -the Permittee shall
measure the volume of all fluids pumped from each LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Ce1l4A or 26,145 gallons/day for Cell
4B. The maximum daily LDS flow volume will be compared against the
measured cell solution levels detailed on the attached Table 1A or 1B for
Cells 4A or 4B, respectively, to determine the maximum daily allowable
LDS flow volume for varying head conditions in the cell.
4) 3-foot Minimum Vertical Freeboard Criteria -the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Ce1l4A and Ce1l4B. Said measurements
shall be made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring -immediately after the
Permittee initiates pumping conditions in the Tailings Cell4A or Cell
4B slimes drain system, monthly recovery head tests and fluid level
measurements will be made in accordance with a plan approved by the
DRC Executive Secretary. The slimes drain system pumping and
monitoring equipment, includes a submersible pump, pump controller,
water level indicator (head monitoring), and flow meter with volume
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totalizer.
Routine Maintenance and Monitoring
11/2010 Revision Denison
2.1
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
Measurements of solution elevation in Ce1l4A and Ce1l4B are to be taken by
survey on a weekly basis, and measurements of the beach area in Ce1l4A and Cell
4B with the highest elevation are to be taken by survey on a monthly basis, by the
use of the procedures and equipment specified in the latest approved edition of the
DMT Plan.
Leak Detection System
The Leak Detection System in Cell 4A and Cell 4B is monitored on a
continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The water levels are measured
every hour and the information is stored for later retrieval. The water
levels are measured to the nearest 0.10 inch. The data collector is
currently programmed to store 7 days of water level information. The
number of days of stored data can be increased beyond 7 days if needed.
The water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill's environmental monitoring data base,
and into the files for weekly inspection reports of the tailings cell leak
detection systems. Within 24 hours after collection of the weekly water
level data, the information will be evaluated to ensure that: 1) the water
level in the Cell 4A and Cell 4B leak detection sumps did not exceed the
allowable level (5556.14 feet amsl in the Cell 4A LDS sump and 5558.5
feet amsl in the Cell4B sump), and 2) the average daily flow rate from the
LDS did not exceed the maximum daily allowable flow rate at any time
during the reporting period. For Cell 4A and Cell 4B, under no
circumstance shall fluid head in the leak detection system sump exceed a
I-foot level above the lowest point in the lower flexible membrane liner,
not including the sump. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and Cell 4B leak detection system, the
total volume of all fluids pumped from the LDS of each cell on a weekly
basis shall be recovered from the data collector, and that information will
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be used to calculate an average volume pumped per day for each cell.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day from Cell 4A or 26,145 gallons/day from Cell 4B. The
maximum daily LDS flow volume will be compared against the measured
cell solution levels detailed on the attached Tables lA and 1B, to
determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4A and Cell 4B. Any abnormal or out of
compliance water levels must be immediately reported to Mill
management. The data collector on each cell is also equipped with an
audible alarm that sounds if the water level in the leak detection sump
exceeds the allowable level (5556.14 feet amsl in the Cell 4A LDS sump
and 5558.5 feet amsl in the Cell 4B sump). The current water level is
displayed at all times on each data collector and available for recording on
the daily inspection form. Each leak detection system is also equipped
with a leak detection pump, EPS Model # 25S05-3 stainless steel, or
equal. Each pump is capable of pumping in excess of 25 gallons per
minute at a total dynamic head of 50 feet. Each pump has a 1.5 inch
diameter discharge, and operates on 460 volt 3 phase power. Each pump
is equipped with a pressure sensing transducer to start the pump once the
level of solution in the leak detection sump is approximately 2.25 feet
(elevation 5555.89 in the Cell 4A LDS sump and 5557.69 feet amsl in the
Cell4B sump) above the lowest level of the leak detection sump (9 inches
above the lowest point on the lower flexible membrane liner for Cell 4A
and 3 inches for Cell 4B), to ensure the allowable 1.0 foot (5556.14 feet
amsl in the Cell4A LDS sump and 5558.5 feet amsl in the Cell 4B sump)
above the lowest point on the lower flexible membrane liner is not
exceeded). The attached Figures 6A and 6B (Cell 4A and 4B,
respectively), Leak Detection Sump Operating Elevations, illustrates the
relationship between the sump elevation, the lowest point on the lower
flexible membrane liner and the pump-on solution elevation for the leak
detection pump. The pump also has manual start and stop controls. The
pump will operate until the solution is drawn down to the lowest level
possible, expected to be approximately 4 inches above the lowest level of
the sump (approximate elevation 5554.0 and 5555.77 ft amsl for Cells 4A
and 4B, respectively). The pump discharge is equipped with a 1.5 inch
flow meter, EPS Paddle Wheel Flowsensor, or equal, that reads the pump
discharge in gallons per minute, and records total gallons pumped. The
flow rate and total gallons are recorded by the Inspector on the weekly
inspection form. The leak detection pump is installed in the horizontal
section of the 18 inch, perforated section of the PVC collection pipe. The
distance from the top flange face, at the collection pipe invert, to the
centerline of the 22.5 degree elbow is 133.4 feet in Cell 4A and 135.6 feet
in Cell 4B, and the vertical height is approximately 45 feet in Ce1l4A and
approximately 42.5 feet in Cell 4B. The pump is installed at least 2 feet
beyond the centerline of the elbow. The bottom of the pump will be
installed in the leak detection sump at least 135.4 feet in Cell 4A and
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137.6 feet in Cell4B or more from the top of the flange invert. A pressure
transducer installed within the pump continuously measures the solution
head and is programmed to start and stop the pump within the ranges
specified above. The attached Figure 5, illustrates the general
configuration of the pump installation.
A spare leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller on either cell can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of are-occurrence.
Slimes Drain System
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe of each cell and a near
as possible to the bottom of the slimes drain sump. The bottom of the
slimes drain sump in Cell 4A and Cell 4B are 38 and 35.9 feet below a
water level measuring point, respectively, at the centerline of the slimes
drain access pipe, near the ground surface level. Each pump discharge
will be equipped with a 2 inch flow meter, EIH Model #33, or equal, that
reads the pump discharge in gallons per minute, and records total gallons
pumped. The flow rate and total gallons will be recorded by the Inspector
on the weekly inspection form.
(ii) The slimes drain pumps will be on adjustable probes that allow the pumps
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A and Cell 4B slimes drain pumps will be checked weekly to
observe that they are operating and that the level probes are set properly,
which is noted on the Weekly Tailings Inspection Form. If at any time
either pump is observed to be not working properly, it will be repaired or
replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A and Cell 4B slimes drain access riser
pipes shall be monitored and recorded weekly to determine maximum and
minimum fluid head before and after a pumping cycle, respectively. All
head measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, each slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
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point on the slimes drain access pipe;
11120 I 0 Revision Denison
2.1
The slimes drain pumps for each cell will not be operated until Mill management
has determined that no additional process solutions will be discharged to that cell,
and the cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell 2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer andlor Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in CellI, Cell 2, Cell 3, Ce1l4A, and
Ce1l4B are regulated by condition 10.3 of the White Mesa Mill lle.(2) Materials
License.
Condition 10.3 states that "Freeboard limits, stormwater and wastewater management for
the tailings cells shall be determined as follows:
A. The freeboard limit for Cell 1 shall be set annually in accordance
with the procedures set out in Section 3.0 to Appendix E of the
previously approved NRC license application, including the
January 10, 1990 Drainage Report. Discharge of any surface water
or wastewater from Cell 1 is expressly prohibited.
B. The freeboard limit for Cells 3, 4A and 4B shall be recalculated
annually in accordance with the procedures established by the
Executive Secretary. Said calculations for freeboard limits shall be
submitted as part of the Annual Technical Evaluation Report
(ATER), as described in Condition 12.3 below [of the licesnse and
not included herein].
C. The discharge of any surface water, stormwater, or wastewater
from Cells 3, 4A, and 4B shall only be through an Executive
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Secretary authorized spillway structure. [Applicable NRC
Amendment:16] [Applicable UDRC Amendment: 3] [Applicable
UDRC Amendment:4]"
The freeboard limits set out in Section 6.3 of the DMT Plan are intended to capture the
Local 6-hour Probable Maximum Precipitation (PMP) event, which was determined in
the January 10, 1990 Drainage Report for the White Mesa site to be 10 inches.
Based on the PMP storm event, the freeboard requirement for Cell 1 is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3, 4A, or 4B.
Cells 2 and 3 have no freeboard limit because those Cells are full or near full of tailings
solids. Ce1l4A has no freeboard limit because it is assumed that all precipitation falling
on Ce1l4A will overflow to Ce1l4B. All precipitation falling on Cell 2, 3, and 4A and
the adjacent drainage areas must be contained in Ce1l4B. The flood volume from the
PMP event over the Cell 2, 3, and Cell4A pond areas, plus the adjacent drainage areas,
which must be contained in Ce1l4B, is 159.4 acre-feet of water.
The flood volume from the PMP event over the Cell4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). For the
purposes of establishing the freeboard in Ce1l4B, it is assumed Ce1l4A has no freeboard
limit and all of the flood volume from the PMP event will be contained in Ce1l4B. The
flood volume from the PMP event over the Cell 4B area is 38.1 acre-feet of water (40
acres, plus the adjacent drainage area of 5.7 acres, times the PMP of 10 inches). This
would result in a total flood volume of 197.5 acre-feet, including the 123.4 acre-feet of
solution from Cells 2 and 3 and 36 acre-feet of solution from Cells 2, 3, and 4A that must
be contained in Ce1l4B. The procedure for calculating the freeboard limit for Cell4B is
set out in the DMT Plan.
The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for Cells 1, 4A, and 4B but
based on License condition 10.3 and the procedure set out in the DMT Plan, the
freeboard limits for Cells 1, 4A, and 4B will be at least three feet.
Figure 7, Hydraulic Profile Schematic, shows the relationship between the Cells, and the
relative elevations of the solution pools and the spillway elevations.
The required freeboard for Cells 4A and 4B will be recalculated annually.
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Attachments
11120 lO Revision Denison
2.1
1) Figures lA and IB, Initial Filling Plan, Geosyntec Consultants
2) Figure 2A and 2B, Initial Filling Plan, Details and Sections, Geosyntec
Consultants
3) Figure 3A and 3B, Initial Filling Plan, Solution and Slurry Pipeline Routes,
Geosyntec Consultants
4) Figure 4A and 4B, Interim Filling Plan, Geosyntec Consultants
5) Figure 5, Leak Detection System Sumps for Cell 4A and 4B, Geosyntec
Consultants
6) Figure 6A and 6B, Leak Detection Sump Operating Elevations, Geosyntec
Consultants
7) Figure 7, Hydraulic Profile Schematic
8) Ce1l4A and Ce1l4B Freeboard Calculations
9) Table 1 A, Calculated Action leakage Rates for Various Head Conditions,
Ce1l4A, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
10) Table 1B, Calculated Action leakage Rates for Various Head Conditions,
Ce1l4B, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
11) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan.
N:\Ce1l4BVanuary 2011 Submittals and Revisions for Ce1l4B\O&M Plan 01.lO.11\CeIl4A and 4B 0 M Plan Rev 2.1
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Geosyntec Consultants Table 1A
Calculated Action Leakage Rates for Various Head Conditions
CeIl4A, White Mesa Mill
BTanding, Utah
Head Above Liner CaJculated Action Leakage Rate
System (feet) (gallons/acre/day)
S 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
Geosyntec Consultants Table lB
Calculated Action leakage Rates for Various Head Conditions
Cell 4B, White Mesa Mill
Blanding. Utah
Head Above Liner System Calculated Action Leakage Rate
(feet) (ganons/acre/dav)
5 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
35 570.0
37 581.2