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HomeMy WebLinkAboutDRC-2015-003271 - 0901a06880545c36ENERGYFUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.cneryvfuels.com April 6, 2015 VIA EXPRESS DELIVERY Mr. Rusty Lundberg Director ofthe Utah Division of Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt Lake City, UT 84116-4850 Dear Mr, Lundberg: Re: Utah Ground Water Discharge Permit No. UGW3700004 White Mesa Uranium Mill - Discharge Minimization Technology Monitoring Plan ("DMT Pursuant to the Division of Radiation Control's ("DRC's") March 5, 2015 letter, regarding thc 4" Quarter 2014 DMT Performance Standards Monitoring Report, Energy Fuels Resources (USA) Inc. ("KFRI") is submitting a revised DMT Plan for DRC review. As requested in the DRC March 5, 2015 letter, references to Roberts Pond have been removed from the DMT Plan because Roberts Pond has been removed from service. The final excavation report for Roberts Pond was submitted to DRC under separate cover. A redline strikeout version and clean version of the DMT Plan are attached for your convenience. Please contact me if you have any additional questions or require any further information. Yours very tmly, Plan") ENKR<;Y FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: David C. Frydenlund Dan Hillsten Harold R. Roberts David K. Turk WHITE MESA MILL DISCHARGE MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN Revision 12.23 Mov 2014April 2015 Prepared by: Energy Fuels Resources (USA) Inc. 225 Union Boulevard, Suite 600 Lakewood, CO 80228 I White Mesa Mill - Discharge Minimization Technology Monitoring Plan VM4/1? Revision: EFRI 12 Page 2 ot 24 WHITE MESA MILL DISCHARGE MINIMIZATION TECHNOLOGY (DMT) MONITORING PLAN TABLE OF CONTENTS 1. INTRODUCTION 3 I.I. Background 3 2. DAILY TAILINGS INSPECTIONS 4 2.1. Daily Inspection -..j.— 4 v WEEKLY TAILINGS AND DMT INSPECTION 3 3.1. Weekly Tailing Inspection^ 5 Northing 9 Hasting 9 3.2. Weekly K'edMock Storage Area Inspections 12 4. ANNUAL EVALUATIONS 12 4.1. Freeboard Limits 12 4.2. Annual lx;ak Detection Fluid Samples 13 4.3. Annual Inspection of the Decontamination Pads 13 5 5.0 Inspection ofthe Ammonium Sulfate Cover Area 13 ft. OTHER INSPECTIONS 14 7. REPORTING REQUIREMENTS 14 7.1. DM1 Reports 14 ATTACHMENTS Attachment A Forms Attachment B Feedstock Storage Area Attachment C Tables I While Mesa Mill Discharge Minimi7aiion Technology Monitoring Plan VI44/J s Revision: HFRI 12.=2 Page 1 of 24 1. INTRODUCTION This DMT Monitoring Plan ("DMT Plan") sets out thc procedures to demonstrate compliance with Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F ofthe White Mesa Mill's (the "Mill's") Groundwater Discharge Permit ("GWDP") Number 370004. Additional procedures for monitoring the tailings cell systems as required under State of Utah Radioactive Matenals License No. UT1900479 (the "RME") are set out in the Tailings Management System procedure for the Mill, which comprises Chapter 3.1 ofthe Mill's Environmenlal Protection Manual. This DMT Plan and the Tailings Management System procedure when implemented in concen are designed as a comprehensive systematic program for constant surveillance and documentation of the integrity ofthe tailings impoundment system including dike stability, liner integrity, and transport | systems, as well as monitoring of wtttei levoU m Rol'H'n- Poml-amF th-.- feedstock storage areas al the Mill This DMT Plan is issued as a stand-alone document, while the Tailings Management System procedure is published and maintained in thc Mill's Environmental Protection Manual. I.I. Background The Tailings Management System procedure was originally developed as Chapter 3.1 ofthe Mill's Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a comprehensive systematic program for constant surveillance and documentation ofthe integrity of thc tailings impoundment system. Upon the Stale of Utah becoming an Agreement Slate for uranium mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and thc State of Utah GWDP. The GWDP required that EFRI develop thc initial DMT Plan in response to GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings Management System procedure set out as Chapter 3.1 of the Mill's Environmental Protection Manual wilh a number of new DMT requirements from the GWDP to form the initial DMT Plan. Thc initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements from the RML (i.e.. Chapter 3.1 ofthe Mill's Environmental Protection Manual) and the DMT requirements ofthe GWDP in a single document. However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable lo separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two separate documents. This DMT Plan continues lo be a stand-alone plan that contains the DMT requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS measurements as noted below. However, the portions of the initial DMT Plan that flowed from the RML and not from the GWDP have been separated from thc DMT Plan and have been returned to their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of ihe Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected and enforced under the requirements ofthe GWDP and this Tailings Management System procedure I While Me.su Mill - Dischaige Minimization Technology Monitoring Plan -W/Revision: bFRI I ?.= ."• Page I or 24 to be managed, inspected and enforced under the requirements ofthe RML. This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with the division ofthe requirements into two distinct documents as noted in their correspondence dated December 20, 2011. Pursuant to a written request from DRC. dated May 30, 2012, the RML requirements for thc inspections of the Cells 1. 2, and 3 Leak Detection Systems fLDSs") has been included in this DMT Plan. The inclusion of ihis RML. requirement into this DMT Plan is to address the DRC request for uniformity in monitoring and reporting requirements for Cells 1, 2, and 3 and to address anticipated GWDP modifications regarding the LDS monitoring in Cells 1. 2, and 3. 2. DAILY TAILINGS INSPECTIONS The following daily tailings inspections shall be performed: 2.1. Daily Inspection On a daily basis, including weekends, thc Cells 1. 2, 3. 4A. and 4B leak detection systems must be inspected either under the DMT Plan or the Tailings Managemenl System procedure. The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings inspections. The RSO may designate olhcr individuals with training, as described in Section 2.4 below, to perform these inspections. Observations made by the inspector will be recorded on Attachment A to this DM T Plan. The inspector will place a check by all inspection items that appear to he operating properly. Those items wheie 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 foim until the problem has been remedied. The date that corrective action was taken should be noted as well. Sec the Tailings Management System procedure for additional daily inspection requirements. a) Daily measurements in the leak detection system sumps of Cells 1. 2. 3. (as required by the RML) and Cells 4A, and 4B (as required by the GWDP) are recorded. For simplicity, the leak detection system measurements for all cells have been combined on the Daily Inspection Data Form included as Attachment A-1 to this DMT Plan regardless of the origin of thc requirement. The triggers for further action and thc associated actions when evaluating Cells I, 2. and 3. leak detection systems are discussed in the Tailings Management System procedure. Section 2.1 q). 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 Wink" Mesa Mill - Discharge Minimization Technology Monitoring Plan ?<H-M/15 Revision: EFRI 1 2.A i Page 5 ol" 24 (FML) (Cell 4 A FML elevation is 5555.14 amsl and with the addition of the 1.0 fool of solution the solution elevation is 5556.14 feci amsl. For Cell 4B the FMI. elevation is 5557.50 amsl and with the addition ofthe 1.0 foot of solution the solution elevation is 5558.50 feet amsl). If any of these observations are made, the Mill Manager should he notified immediately and thc 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 be adhered to when thc solution level trigger for Cell 4A or 4B has been exceeded. 3. WEEKLY TAILINGS AND DMT INSPECTION 3.1. Weekly Tailings Inspections Weekly tailings inspections arc to be conducted by the RSO or his designee and include the following: a) Leak Detection Systems Each tailings cell's LDS shall be checked weekly (as well as daily) to determine whether it is wet or dry. If marked wet, the liquid levels need to be measured and reported. In Cells 1, 2, and 3 thc LDS is measured by use of a dual probe system that senses thc presence of solutions in the LDS (comparable to the systems in Cell 4A and Cell 4B) and indicates the presence of solution with a warning light. 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 dala collector. The pressure transducer is calibrated for fluid with a specific gravity of 1.0. Thc water levels are measured every hour and the information is stored for later retrieval. The water levels are measured to thc nearest 0.10 inch. Thc data collector is currently programmed to store 7 days of water level information. The number of days of stored data can be increased beyond 7 days if needed. For Cells 1. 2. and 3, the water level data is recorded on the Daily Tailings Inspection Form included as Attachment A-1 of this DMT Plan . For Cells 4A and 4B, the water level data is downloaded to a laptop computer periodically and incorporated into the Mill's environmental monitoring data storage. The data are reviewed during the weekly inspections ofthe tailings cell leak detection systems. If an LDS monitoring system becomes inoperable, alternate methods for LDS fluid measurements may be employed with Executive Secretary approval. If sufficient fluid is present in thc leak detection system of any cell, the fluid shall be pumped from the LDS, to the extent reasonably possible, and record the I White Mesa Mill - Discharge Minimi/anon Technology Moniionng Plan v'J+l/l s Revision: LFRf 12.r * Page 6 of 24 volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a disposal cell. For Cells 1. 2, and 3. if fluid is pumped from an LDS, thc procedures specified in the Tailings Management System procedure Section 3.1 a) shall be implemented. For Cells 1. 2. and 3, upon the initial pumping of fluid from an LDS, a tluid sample shall be collected and analyzed in accordance with paragraph 11.3C of the RML as described in the Tailings Management System procedure. For Cell 4A and 4B, under no circumstance shall fluid head in ihc leak detection system sump exceed a I-foot level above the lowest point in the lower flexible membrane liner. To determine the Maxtmum Allowable Daily LDS Flow Rates in the Cell 4A and 4B leak detection systems, the total volume of all fluids pumped from thc 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 Cell 4A or 26.145 gallons/day for Cell 4B. The maximum daily LDS flow volume will be compared against thc measured cell solution levels detailed on Table I A and IB (for Cells 4A and 4B, respectively) in Attachment C, to detennine the maximum daily allowable LDS flow volume for varying head conditions in Cell 4A 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) EFRI re-graded the interim fill on Cell 2 in otder to reduce the potential for the accumulation of storm water on the surface of Cell 2. As a result ofthe re-grading of the interim cover and the placement of an additional 62,000 cubic yards of fill material on Cell 2, the slimes drain access pipe was extended 6 97 feet. The extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97 feet from the bottom ofthe slimes drain. Thc measuring point on the extension pipe was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is 5618.73 fmsl. For the quarterly recovery lest described in section vi below, this extension has no effect on the data measurement procedures. Cell 2 has a pump placed inside of the slimes drain access pipe al the bottom of the slimes drain. As taken from actual measurements, the bottom of the slimes drain is 37.97 feet below a water level measuring point which is a notch on the side of the Cell 2 slimes drain access pipe . This means that the bottom of the slimes drain pool and ihe location of the pump arc one foot above the lowest point of the FML in Cell 2, which, based on construction reports, is at a depth of 38.97 feet below the water level measuring point on the slimes drain access pipe for Cell 2; j While Mesa Mill - Dischaige Minimi/anon Technology Monitoring Plan 13 Revision TZFRI 12.=^ Pago 7 of 24 (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 fool above the bottom of the slimes drain standpipe, and the float valve is located at three feet above the bottom of thc slimes drain standpipe. The average wastewater head in the Cell 2 slimes drain is therefore less lhan 3 feet and is below the phreatic surface of tailings Cell 2. about 27 feet below the water level measuring point on the slimes drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2 into the slimes drain collection system. Mill management considers lhat 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) AII head measurements must be made from the same measuring point (the notch at the north side ofthe access pipe 5618.73 fmsl), and made to the nearest 0.01 foot. The equation specified in the GWDP will be used to calculate the slimes drain recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the depth to wastewater in thc Cell 2 slimes drain access pipe (in feet) will be subtracted from the surveyed elevation ofthe measuring point. The calculation is as follows: 5618.73 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE (v) Effective July 11, 201 I, on a quarterly basis, the slimes drain pump will be turned off and the wastewater in the slimes drain access pipe will be allowed lo 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 walerlevel ofthe wastewater will be measured and recorded as a depth-in-pipe measurement on Quarterly Dala form, by measuring thc depth to water below the water level measuring point on thc slimes drain access pipe: (vi) No process liquids shall be allowed to be discharged into Cell 2; (vii) lf at any time the most recent average annual head in the Cell 2 slimes drain is found to have increased above Ihe average head for Ihe 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; (viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3, Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for ensuring that average head elevations in the Ceil 3, Cell 4A, and 4B slimes drains arc kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes drains are inspected and the results reported in accordance with the requirements of the permit. c) Tailings Wastewater Pool Elevation Monitoring | Solution elevation measurements in Cells 1. 4A. and 4B and Roberts Pond arc to be taken by White Mesa Mill - Discharge Minimization Technology Monitoring Plan */+44/ls Revision. F.FRI 12.^; Page X of 24 survey on a weekly basis. The beach area in Cell 4B with thc maximum elevation is to be taken by survey on a monthly basis when beaches are first observed, as follows: (i) The survey will be performed by the Mill's Radiation Safety Officer or designee (thc "Surveyor") with the assistance of another Mill worker (the "Assistant"); (ii) The survey will be performed using a survey instrument (the "Survey Instrument") accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments; (iii) The Reference Points for Cells 1, Cell 4A, and 4B, und Roberts Pond are known points established by professional survey. For Cell 1 and Robert;. Fond, the Reference Point is a wooden stake with a metal disk on it located on the southeast corner of Cell I. Thc elevation of thc metal disk (tlie "Reference Point Elevation") for Cell 1 tttH-i-Roberts Pond-is at 5,623.14 feel above mean sea level ("FMSL"). For Cell 4A and 4B, the Reference Point is a piece of stamped metal monument located next to the transformer on the south side of Cell 4A and 4B. Thc elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a location where both the applicable Reference Point and pond surface are visible. (iv) Oncc in location, the Surveyor will ensure that the Survey Instrument is level by centering thc bubble in the level gauge on thc Survey Instrument; (v) The Assistant will place the Survey Rod vertically on the Reference Point (on the metal disk on the Cell I/Roberta Pond Reference Point on the top ofthe rebar on thc Cell 4A and 4B Reference Point. The Assistant will ensure that thc Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established a level reading; (vi) The Surveyor will focus the cross hairs of the Survey Instrument on thc scale on thc Survey Rod, and record the number (the "Reference Point Reading"), which represents the number of feel thc Survey Instrument is reading above thc Reference Point; (vii) The Assistant will then move to a designated location where the Survey Rod can be placed on the surface ofthe main solution pond in the Cell I, Cell 4 A. or Cell 4B,ef Roberts Pond, .or the area ofthe beach in 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: For a newly-constructed cell, when the cell is first placed into operation, the solution level is typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation. For newly-constructed cells, measurement of solution level will commence within 30 days of authorization for use. Measurements will be conducted as described above in items d) (i) through d) (vii) of this Section consistent with current Mill health and safety procedures. The measurements will be completed using survey equipment and thc appropriate length survey rod (either 25' or 45'). A. Pond Surface Measurements While Mesa Mill - Discharge Minimization Technology Moniionng Plan -5/U 4/l.s Revision FFRI I2.i,\ Page 9 of 24 I. 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. Cell4B The Assistant will walk down the slope in the southeast corner of Cell 4B 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 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 A-fHWk-hrt-v IVt*H tMnK<.^l olVlhtf-Htllw^-y»FlW fH*»0|WrtfHl-t+(-R«-»<WW4>-<-M^f—RH? A-riMim*-1* 4F-{»I<K e the Survey K*xf agiiin-t ihut mttfk-rtf*! ht+ltl- •bt'-NHl > rt i_ -. .11 \ II ill* .vi'-' . 1 ¥*l i 1 til' I l<^llJ1Jatl'*» » li.iin.t ' I'll 1 y'.» vtrftrtrTtrty'."TVtttT ' tttr Trtltr fit" tl^fvttlttyr tinr tltjllrtt ^ui tifW. Based on the foregoing methods, the approximate coordinate locations for the measuring points for Roberts Pond and thc Cells are: Northing Easting Robert * Pond 3.570.697 Cell 322,196 2.579,277 Cell 4A 320.300 2.579,360 Cell 4B 320,690 2,576,200 These coordinate locations may vary somewhat depending on solution elevations in the Pond and Cells; B. Cell 4B Beach Elevation Beach elevations in Cell 4B will commence when beaches arc first observed. The Assistant will place the Survey Rod at thc point on the beach area of Cell 4B that has the highest elevation. If it is not clear which area of the beach has the highest elevation, then multiple points on the beach area will be surveyed until the Surveyor is satisfied that the point on the Cell 4B beach area with the highest While Mc»a Mil! - Discharge Minimization Technology Monitoring Plan 5 Revision: EFRI 12.i} Page 10 of 24 elevation has been surveyed If it is clear that all points on the Cell 4B heach area are below 5.593 FMSL, then the Sttrveyoi may rely on one survey point; (i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod jusl touching the pond surface. The Assistant will ensure lhat the Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established a level reading; (ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on thc Survey Rod. and record the number (the "Pond Surface Reading"), which represents the number of feel the Survey Instrument is reading above thc pond surface level. The Surveyor will calculate the elevation of thc pond surface as FSML by adding the Reference Point Reading for the Cell-•* 4*<4>eHVPHH.1, as ihe case may be, to the Reference Point Elevation for the Cell o? Roberts Pond and subtracting thc Pond Surface Reading for the Cell t-H- K-«4HfMvP+»«d, and will record the number accurate to 0.01 feet. d) Decontamination Pads (i) New Decontamination Pad The New Decontamination Pad is located in thc southeast corner of the ore pad, near the Mill's scale house. A. In order lo 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 ihc 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 thc primary containment into thc void between the primary and secondary containment. The depth to water in each portal will be measured weekly, by physically measuring thc depth lo water with an electrical sounding tape/device. All measurements must be made from the same measuring point and be made lo ihe 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 I While Mesa Mill - Discharge Minimization Technology Monitoring Plan s<i i S/l.i Revision- FI RI 12 Page 11 ol' 24 any standpipe, at any time. This will be determined by subtracting thc weekly depth to water measurement from the distance from thc measuring point in the standpipe to the dry concrete floor The deptli to water from the top (elevation 5589.8 feet amsl) of any ofthe three (3) observation ports to the standing water shall be no less than 6.2 feet. Depths less than 6.2 feel shall indicate more that 0.1 foot of standing water above thc concrete floor (elev. 5583.5 feel amsl), and shall indicate a leak in the primary containment. L. Any observation of fluid between the primary and secondary containments will be reported to the RSO. F. ln addition to inspection of the water levels in the siandpipes, 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 thc 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. (ii) Existing Decontamination Pad The Existing Decontamination Pad is located between the northwest corner of the Mill's maintenance shop and thc ore feeding grizzly. Weekly inspection requirements for the Existing Decontamination Pad are discussed in the Tailings Management System Procedure. e) Summary ln 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 fonn. An example ofthe Weekly Tailings and DMT Inspection form is provided in Appendix A to the Tailings Management System and as Attachment A to this DMT Plan. I White Mesa Mill - Discharge Minimization Technology Monitoring Plan ^444/1 s Revision' KFRI 12.2} Page 12 of 24 Weekly lwsf^MH^-ot-Solu4**m-l-.e-Ve-h w4tt»hei»S Pmtd Ofi-^-we<»k4y-l;>tisrisTst>UitH-Mi-e4eJrTtHi+Hs tfitvtitk^Ho«-Rv4>^i+s-Ptwh:rriH-at:tw svMnit 4i^-Se*HoH t -4) ttl*ovv—Tlie-W't^4<4y-^*^itlh-HMe^Mfh4<^>|>etls-P»MKl «v-itt>^kMl-«>fi -the Wt^h-4^ttUfti^rr1Htf-i /**\f>rY 4-H HtKH-HK- Bil^eO-t*H hW-H) H-'ill > (iv^ff-Vt+HBH-rr lllf FMI.lH fbe-P*>*it4 SoHfHte-R'em4+n^-int»rt-l+>'-4<i4vefiv4J^>tf-i^^^KV4Hirt<efy^iA--WH-:4it>'. aK've^fn^tVr^f-fWfH t-m the fvmt^v FML-r-lf-thr |H»ntl-s< ^i4«onelewui<^aH4ie-4^KfS^i4itee4<e^ f11fiHireitr-t-lie• fHHIU• w+| f be-f e*^ «H.tet4-«*T f*e+f tg 11 r y7 | 2. Weekly Feedstock Storage Area Inspections Weekly feedstock storage area inspections will be performed by thc Radiation Safety Department to confirm that: a) the bulk feedstock materials are stored and maintained within the defined area described in the GWDP, as indicated on the map attached hereto as Attachment B; b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material in order lo assure that the materials do nol encroach upon the boundary ofthe storage area; and c) all alternate feedstock located outside the defined Feedstock Area are maintained within water light containers. The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection Report, a copy of which is contained in Attachment A. Any variance in stored materials from this requirement or observed leaking alternate feedstock drums or othcr containers will be brought to the attention of Mill Management and rectified within 15 days. 4. ANNUAL EVALUATIONS The following annual evaluations shall be performed: I 4T+: freeboard-Limits 4T4-4^ Ketens Pond 4-'he-4fi?eb<-w*t4i wH-to^l^vert"v4A->mFi^-tt4ii{i 11 tl tun vu nwf H-elevaHfHH>f->.62 4.() ^t*ho*e-mt?«»-s<Hi level, as specified in the GWDP. I While Mesa Mill - Discharge Minimization Technology Monitoring Plan ><•! 1? Revision III-RI 12^3 Page 13 ol' 24 | 4T2-T4. 1. Annual Leak Detection Fluid Samples Pursuant to Part I,E. 10(c) of thc GWDP, a sample will be collected from the Cells 4A and 4B leak detection systems annually as pail of the Tailings Cell Wastewater Quality Monitoring. Sampling procedures are described in the Tailings Sampling and Analysis Plan. | 4.3.4.2. Annual Inspection of the Decontamination Pads a) New Decontamination Pad During thc second quarter of each year, the New Decontamination Pad will be taken out of service and inspected to ensure thc integrity of the wash pad's exposed concrete surface. If any abnormalities arc identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width) or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming the use 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 2IU| 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 thc integrity of the steel tank. Once the water and any sediment present is removed from the steel tank containment, the walls and bottom ofthe tank will be visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred since thc last inspection. If any abnormalities arc identified, defects or damage will be reported lo Mill management and repairs will be made prior to resuming the use ofthe 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 I of each calendar year. 5. 5.0 Inspection of the Ammonium Sulfate Cover Area After installation and approval ofthe As-Built plans by DRC, the Ammonium Sulfate Cover Area will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will be conducted during the second quarter of each year. The results of quarterly and annual inspections will be reported in thc quarterly DMT Reports. Quarterly and annual inspections will be completed as described below and will be documented on the inspection form included as Attachment A-5. The Ammonium Sul fate Cover Area will be inspected to ensure the integrity of the exposed concrete and asphalt surfaces. If any abnormalities arc identified, i.e. cracks in the concrete or asphalt with greater than 1/8 inch separation (width) or any significant deterioration or damage of thc concrete I While Mesa Mill Dischaige Minimization 'technology Monitoring Plan ^m-'ii Revision EPRI \ 2-l] Pdge 14 oi 24 pad or asphalt surfaces, repairs will he made within 7 calendar days of the inspection. All inspection findings and any repairs required shall be documented on thc Decontamination Pad/Ammonium Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs completed shall be summarized in the 2iul Quarter DMT Monitoring Report due September 1 of each calendar year. The first inspection ofthe Ammonium Sulfate Cover Area will be conducted during the second quarter in the year following installation/completion of the pad. 6. OTHER INSPECTIONS All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as specified in this DMT Plan. See also the Tailings Management System procedure included in the EPM for additional inspection requirements. However, additional inspections should be conducted after any significant storm or significant natural or man-made event occurs. 7. REPORTING REQUIREMENTS In addition to the forms included m this DMT Plan, the following additional reports shall also be prepared: 7.1. DMT Reports Quarterly reports of DMT monitoring activities, which will include the following information, will be provided to the Executive Secretary on the schedule provided in Table 5 ofthe GWDP: a) On a quarterly basis, all required information required by Part I.E.2 of the GWDP relating to the inspections described in Section 3.1 (a) (lxak Detection Systems Monitoring). Section 3.1(b) (Slimes Drain Water Level Monitoring). 3.1 (c) (Tailings Wastewater Pool Elevation Monitoring), 3.1(d) (Tailings Wastewater Pool and Beach Area Elevation Monitoring). 3.21 Weekly Inspection ot Solution Levels mR-oherv- Pond), 3.3 3 2(W'eekly Feedstock Storage Area inspections) 5.0 (Inspection ofthe Ammonium Sulfate Cover Area [for 8 quarters including any repairs required, and repairs completed]): b) On a quarterly basis, a summary of thc 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 thc quarter; c) With respect to the annual inspection ofthe New Decontamination Pad described in Section 4.3(a), the inspection findings, any repairs required, and repairs completed shall be summarized in thc 2nd Quarter report, due September 1 of each calendar year; I While Mesa Mill - Discharge Minimization Technology Monitoring Plan 5/4-44/15 Revision: EFRI 12.53. Page 15 ol' 24 d) With respect to the annual inspection of the Existing Decontamination Pad described m Section 4.3(b), the inspection findings, any repairs required, and repairs completed shall be summarized in the 2mt Quarter report, due September 1 of each calendar year; e) With respect to thc annual inspection (after the completion of 8 quarterly inspections) ofthe Ammonium Sulfate Cover Area described in Section 5.0, the inspection findings, any repairs required, and repairs completed shall be summarized in thc 2nJ Quarter report, due September 1 of each calendar year; and f) An annual summary and graph for each calendar year of the depth to wastewater in thc Cell 2 slimes drain must be included in the fourth quarter report. After the fti^L vet»r-. rHh4 lvwwtti^H»-^)<MvttOT«rtet4wefH*;t'* *-htilWiK4u+ie4v>ib-th<? tmi+eni WMf tm»in4i4y- vatuev-rtHd a gr-tphte *>wfMH-*>fHrv tHe-fHevM«u*-yertt. I Whuc Mesa Mill - Discharge Minimization Technology Monitoring Plan Revision' liFRl I2.,M Page I b of 24 ATTACHMENT A FORMS I Whuc Mesa Mill - Discharge Minimization Technology Monitoring Plan >/+4-4/l 5 Revision: EFR) 12.51 Page 17 of" 24 ATTACHMENT A-1 DAILY INSPECTION DATA Inspector. Date;i Accompanied by: Time. Any Item not "OK" must be documented. A check mark = OK, X = Action Required VII. DAILY LEAK DETECTION CHECK Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B Leak Detection System Checked Checked Wet Drv Checked Checked _Wei Dry _Wet Dry Checked Wet Dry Checked Wet Drv Initial level. Final level. Initial level. Final level Initial level. Final level Initial level. Final level Initial level. Final level Gal, pumped. Gal, pumped. Gal, pumped. Gal. pumped_ Gal. pumped_ Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tai! System (Appendix A-1) ings Management I While Mesa Mill - Discharge Minimization Technology Monitoring Plan 15 Revision- FFRI \ 2.il Page IS ol" 24 Date: ATTACHMENT A-2 WEEKLY TAILINGS INSPECTION Inspectors' I Pond and Beach elevations (msl, ft) Cell I: (a) Pond Solution Elevation (b) FML Bottom Elevation (c) Depth or Water above FML ((a)-(b)). Cell 4A: (a)Pond Solution Elevation (b)FML Bottom Elevation 5597. 5555.14 (c)Deplh of Water above FML ((a)-(b)) Cell 4B: (a)Pond Solution Elevation (b)F'ML Bottom Elevation 5557.50 (e)Depth of Water above FML ((a)-(b)) (d)Elevalion of Beach Area with Highest Elevation (monthly) Robert;- inJ-St+hrt htfi-hkivtiuon (c)Deplh ot Water til*»ve FML ((»> (t>)> 56 i 2.3. 2. Leak Detection Svstems Observation: New Decon Pad. Portal 1 New Decon Pad. Portal 2 New Decon Pad Portal 3 Is LDS (Portal) wet or drv'? wet_ _dry _wet dry wet dry If wet. Record liquid level: .Ft to Liquid _Ft to Liquid .Ft to Liquid If wet, Report to RSO * Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes II" Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately. 3. New Decontamination Pad (concrete): I While Mesa Mill - Discharge Minimization Technology Monitoring Plan Si+44/15 Revision: HFR1 12.23 Page 19 of 24 ATTACHMENT A-3 ORE STORACE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week ol through Date of Inspection. Inspector: _ Weather conditions for ihe week' Blowing dust conditions for thc 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 matenals 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: I White Mesa Mill - Discharge Minimi /.at ion Technology Monitoring Plan 5/1 '1 i/15 Revision: f-FRI 12.^3 Page 20 of 24 Ore Pad Storm waier Transfer Line: Is the transfer line visible? Yes: No: Comments: | Is there l-tv^any evidence of breakage, spillage or leakage? Yes: No: Comments: Othet comments: While Mesa Mill - Discharge Minimization Technology Monitoring Plan ^+-*4/_^ Revision: RPR I 12 2} Page 21 of 24 ATTACHMENT A-4 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 thc pad surface? Yes No Findings; Repair Work Required: Existing Decontamination Pad: Were (here any observed problems with the steel tank? Yes No Findings: Repair Work Required: Note: For the annual inspection ofthe Existing and New Decontamination, the annual inspection findings, any repairs required, and repairs completed, along with a summary ofthe weekly inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September 1 of each calendar yean White Mesa Mill - Discharge Minimization Technology Monitoring Plan .5-444/!/. Revision- EFRI 12 2j Page 22 of 24 ATTACHMENT A-5 AMMONIUM SULFATE COVER AREA INSPECTION Ammonium Sulfate Concrete Pad: Are there any cracks on the concrete pad surface greater than 1/8 inch of separation? _ Yes No Is there any significant deterioration or damage of the pad surface? Yes No Findings: Repair Work Required: Ammonium Sulfate Asphalt Cover: Are there any cracks on asphalt surface greater than 1/8 inch of separation .' _Yes No Is there any significant deterioration or damage of the asphalt surface? Yes No Findings: Repair Work Required: Note: For the quarterly inspection of thc Ammonium Sulfate Cover Area, the quarterly inspection findings, any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For the annual inspection of the Ammonium Sulfate Cover Area, thc annual inspection findings, any repairs required, and repairs completed, along with a summary ofthe weekly inspections of the Decontamination Pads, shall be discussed in the 2>v> Quarter report, due September 1 of each calendar year. While Mesa Mill - Discharge Minimization Technology Monitoring Plan ^4-44/] s Revision lil-'RI 12.3 Page 2 ? of 24 ATTACHMENT B FEEDSTOCK STORAGE AREA / r ~» *7 <r - / /* Or_r>\vy s/ / CO 3 r no II 3 N WHITE MCTA mi T—r-5 t I While Mesa Mill - Discharge Minimi/ation Technology Moniloring Plan :4*!-*-!!_ Revision: EFRI 12 i i Page 24 ot" 24 ATTACHMENT C TABLES Table IA Calculated Action leakage Rates for Various head Conditions Cell 4A While Mesa Mil! Blanding, Utah Head above Liner System (feel) 10 15 20 25 30 35 37 Calculated Action leakage Rate ( gallons / acre / day ) 222.04 314.01 384.58 '444.08 496.50 543.88 587.46 604.01 Table IB Calculated Action leakage Rates for Various head Conditions Cell 4B While Mesa Mill Blanding, Utah Head above Liner Syslem (feet) 10 15 20 30 35 37 Calculated Action leakage Rate ( gallons / acre / day ) 211.40 317.00 369.90 422.70 475.60 528.40 570.00 581.20 WHITE MESA MILL DISCHARGE MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN Revision 12.3 April 2015 Prepared by: Energy Fuels Resources (USA) Inc. 225 Union Boulevard, Suite 600 Lakewood, CO 80228 While Mesa Mill Discharge Minimizaiion Technology Monilonng Plan 4/15 Revision- KFR1 12.3 Page 2 of 23 WHITE MESA MILL DISCHARGE MINIMIZATION TECHNOLOGY (DMT) MONITORING PLAN TABLE OF CONTENTS 1. INTRODUCTION 3 I.I. Background 3 2. DAILY TAILINGS INSPECTIONS 4 2.1. Daily Inspection 4 3. WEEKLY TAILINGS AND DMT INSPECTION 5 3.1. Weekly Tailings Inspections 5 Northing 9 Easting 9 3.2. Weekly Feedstock Storage Area Inspections 12 4. ANNUAL EVALUATIONS 12 4.1. Annual Leak Detection Fluid Samples 12 4.2. Annual Inspection ofthe Decontamination Pads 12 5. 5.0 Inspection of the Ammonium Sulfate Cover Area 13 6. OTHER INSPECTIONS 13 7. REPORTING REQUIREMENTS 13 7.1. DMT Reports 14 ATTACHMENTS Attachment A Forms Attachment B Feedstock Storage Area Attachment C Tables While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision EPRI 12.3 Page 3 of 23 1. INTRODUCTION This DMT Monitoring Plan ( "DMT Plan") sets out the procedures to demonstrate compliance with Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.Fof the White Mesa Mill's (the "Mill's") Groundwater Discharge Permit ("GWDP") Number 370004. Additional procedures for monitoring the tailings cell systems as required under State of Utah Radioactive Materials License No. UT 1900479 (thc "RML") are set out in the Tailings Management System procedure for the Mill, which comprises Chapter 3.1 of the Mill's Environmental Protection Manual. This DMT Plan and the Tailings Management System procedure when implemented in concert are designed as a comprehensive systematic program for constant surveillance and documentation of the integrity ofthe tailings impoundment system including dike stability, liner integrity, and transport systems, as well as monitoring of the feedstock storage areas at the Mill. This DMT Plan is issued as a stand-alone document, while the Tailings Management System procedure is published and maintained in the Mill's Environmental Protection Manual. 1.1. Background The Tailings Management System procedure was originally developed as Chapter 3.1 of tlie Mill's Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a comprehensive systematic program for constant surveillance and documentation of the integrity of the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium mills in 2004. the Mill's Source Material License was replaced by the State of Utah RML and the State of Utah GWDP. The GWDP required that EFRI develop thc initial DMT Plan in response to GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings Management System procedure set out as Chapter 3.1 of the Mill's Environmental Protection Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan. The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements from the RML (i.e., Chapter 3.1 ofthe Mill's Environmental Protection Manual) and the DMT requirements of the GWDP in a single document. However, after several years of implementing thc DMT Plan, EFRI concluded that it is preferable to separate the RML portions of the DMT Plan from thc GWDP portions of the DMT Plan, into two separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT requirements from the GWDP except for thc daily recording of the Cells 1, 2, and 3 LDS measurements as noted below. However, the portions ofthe initial DMT Plan that flowed from the RML and not from the GWDP have been separated from the DMT Plan and have been returned to their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of the Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected and enforced under the requirements of the GWDP and this Tailings Management System procedure to be managed, inspected and enforced under the requirements of the RML. While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12 3 Page 4 of 23 This division of ihc requirements was discussed with DRC on October 26, 2011. DRC agreed with the division of the requirements into two distinct documents as noted in their correspondence dated December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, thc RML requirements for the inspections ofthe Cells 1,2. and 3 Leak Detection Systems ("LDSs") has been included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address the DRC request for uniformity in monitoring and reporting requirements for Cells 1,2, and 3 and to address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3. 2. DAILY TAILINGS INSPECTIONS The following daily tailings inspections shall be performed: 2.1. Daily Inspection On a daily basis, including weekends, the Cells 1,2,3,4A, and 4B leak detection systems must be inspected either under the DMT Plan or the Tailings Management System procedure. The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings inspections. The RSO may designate other individuals with training, as described in Section 2.4 below, to perform these inspections. Observations made by the inspector will be recorded on Attachment A to this DMT Plan. Thc 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 thc problem. This observation of concern should be noted on the form until the problem has been remedied. Thc date that corrective action was taken should be noted as well. Sec thc Tailings Management System procedure for additional daily inspection requirements. a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as required by the RML) and Cells 4A, and 4B (as required by the GWDP) are recorded. For simplicity, the leak detection system measurements for all cells have been combined on ihe Daily Inspection Data Form included as Attachment A-1 to this DMT Plan regardless of ihc origin of the requirement. The triggers for further action and the associated actions when evaluating Cells 1, 2, and 3, leak detection systems are discussed in the Tailings Management System procedure, Section 2. Iq). Thc solution level in Cell 4A or 4B leak detection system is not allowed to be more than 1.0 foot above the lowest point on the bottom flexible membrane liner (FML) (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 While Mesa Mill - Discharge Minimization Technolog) Monitoring Plan 4/15 Revision: EFRI 12.3 Page 5 ol 23 elevation is 5557.50 amsl and with the addition ofthe 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 thc leak detection system pump started. In addition, thc requirement to notify the Executive Secretary in accordance with Parts I D.6 and I.G.3 of thc Groundwater Discharge Permit must be adhered to when the solution level trigger for Cell 4A or 4B has been exceeded. 3. WEEKLY TAILINGS AND DMT INSPECTION 3.1. Weekly Tailings Inspections Weekly tailings inspections are to be conducted by the RSO oi his designee and include the following: a) Leak Detection Systems Each tailings cell's LDS shall be checked weekly (as well as daily) lo determine whether it is wet or dry. If marked wet, the liquid levels need to be measured and reported. In Cells 1, 2. and 3 thc LDS is measured by use of a dual probe system that senses the presence of solutions in the LDS (comparable to the systems in Cell 4A and Cell 4B) and indicates the presence of solution with a warning light. Thc Cell 4A and 4B leak detection systems are monitored on a continuous basis by use of a pressure transducer lhat feeds water level information to an electronic data collector. Thc pressure transducer is calibrated for fluid with a specific gravity of 1.0. Thc water levels are measured every hour and the information is stored for later retrieval. The water levels arc measured to ihe nearest 0.10 inch. The data collector is currently programmed to store 7 days of watei level information. The number of days of stored dala can be increased beyond 7 days if needed. For Cells I, 2, and 3. the water level data is recorded on thc Daily Tailings Inspection Form included as Attachment A-1 of this DMT Plan . Foi Cells 4A and 4B. the water level dala is downloaded to a laptop computer periodically and incoiporated into the Mill's environmental monitoring data storage. The data are reviewed during thc weekly inspections of the tailings cell leak detection systems. If an LDS monitoring system becomes inoperable, alternate methods for LDS fluid measurements may be employed with Executive Secretary approval. If sufficient fluid is present in the leak detection system of any cell, the fluid shall be pumped from thc 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. White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/1.S Revision- EFRI 12 3 Page 6 of 23 For Ceils 1, 2, and 3, if fluid is pumped from an LDS, the procedures specified in the Tailings Management System procedure Section 3.1 a) shall be implemented. For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid sample shall be collected and analyzed in accordance with paragraph 11.3C ofthe RML as described in thc Tailings Management System procedure. For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection system sump exceed a 1-foot level above the lowest point in the lower flexible membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates in the Cell 4A and 4B leak detection systems, thc 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 Cell 4A or 26,145 gallons/day for Cell 4B. The maximum daily LDS flow volume will be compared against thc measured cell solution levels detailed on Table 1A and 1B (for Cells 4A and 4B, respectively) in Attachment C, to determine the maximum daily allowable LDS flow volume for varying head conditions in Cell 4A and 4B. h) Slimes Drain Water Level Monitoring (i) Cell 3 is neaily full and will commence closure when filled. Cell 2 is partially reclaimed with thc surface covered by platform fill. Fach cell has a slimes drain system which aids in dewatering the slimes and sands placed in the cell; (ii) EFRI re-graded thc interim fill on Cell 2 in order to reduce the potential for the accumulation of storm water on the surface of Cell 2. As a result of the rc-grading of the interim cover and the placement of an additional 62,000 cubic yards of fill material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97 feet from the bottom ofthe slimes drain. The measuring point on the extension pipe was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is 5618.73 fmsl. For the quarterly recovery test described in section vi below, this extension has no effect on the data measurement procedures. Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the slimes drain. As taken from actual measurements, the bottom ofthe slimes drain is 37.97 feet below a water level measuring point which is a notch on the side of the Cell 2 slimes drain access pipe.. This means that the bottom of the slimes drain pool and the location of the pump arc one foot above the lowest point of the FML in Cell 2, which, based on construction reports, is at a depth of 38.97 feet below thc 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 While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision- LPRl 12 3 Page 7 ot23 mechanism the pump is activated. Pumping then occurs until the water level reaches the lower probe which turns the pump off. Thc lower probe is located one foot above the bottom of the slimes drain standpipe, and the float valve is located at thiee feet above the bottom of the slimes drain standpipe. The average wastewater head in the Cell 2 slimes drain is therefore less than 3 feet and is below thc phreatic surface of tailings Cell 2, about 27 feet below the water level measuring point on the slimes drain access pipe. As a result, there is a continuous flow of wastew ater 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) AII head measurements must be made from the same measuring point (the notch at the north side of the access pipe 5618.73 fmsl), and made to the nearest 0.01 foot. The equation specified in the GWDP will be used to calculate thc slimes drain recovery elevation (SDRE). To calculate thc SDRE contemplated by the GWDP, the depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted from the surveyed elevation of the measuring point. The calculation is as follows: 5618.73 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE (v) Effective July 11, 2011, on a quarterly basis, the slimes drain pump will be turned off and the wastewater in the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once the water level has stabilized (based on no change in water level for three (3) successive readings taken no less than one (1) hour apart) the water level of the wastewater will be measured and recorded as a depth-in-pipe measurement on Quarterly Data form, by measuring thc depth to water below thc water level measuring point on the slimes drain access pipe; (vi) No process liquids shall be allowed to be discharged into Cell 2; (vii) lf 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 T.G.3 of the GWDP, including the requirement to provide notification to the Executive Secretary orally within 24 hours followed by written notification; (viii) Because Cell 3, Cell 4A, and 4B arc currently active, no pumping from thc Cell 3. Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes drains are inspected and the results reported in accordance with the requirements of the permit. c) Tailings Wastewater Pool Elevation Monitoring Solution elevation measurements in Cells l,4A,and4B are to be taken by survey on a weekly basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a monthly basis when beaches arc first observed, as follows: White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12.3 Page 8 of 23 (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, togelher with a survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments; (iii) The Reference Points for Cells 1, Cell 4A, and 4B, are known points established by professional survey. For Cell 1, the Reference Point is a wooden stake with a metal disk on it located on the southeast corner of Cell 1. Thc elevation of the metal disk (the "Reference Point Elevation") for Cell 1 is at 5,623.14 feet above mean sea level ("FMSL"). For Cell 4A and 4B, the Reference Point is a piece of stamped metal monument located next to the transformer on the south side of Cell 4A and 4B The elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a location where both the applicable Reference Point and pond surface are visible. (iv) Once in location, the Surveyor will ensure lhat the Survey Instrument is level by centering thc bubble in the level gauge on the Survey Instrument; (v) Thc Assistant will place thc Survey Rod vertically on thc Reference Point (on the metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and 4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established a level reading; (vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the Survey Rod, and record the number (the "Reference Point Reading"), which represents the number of feet the Survey Instrument is reading above the Reference Point; (vii) The Assistant will then move to a designated location where the Survey Rod can be placed on the surface of the main solution pond in the Cell 1, Cel I 4 A, or Cell 4B, or the area of the beach in Cell 4B with thc 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: For a newly-constructed cell, when the cell is first placed into operation, the solution level is typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation. For newly-constructed cells, measurement of solution level will commence within 30 days of authorization for use. Measurements will be conducted as described above in items d) (i) through d) (vii) of this Section consistent with current Mill health and safety procedures. The measurements will be completed using survey equipment and the appropriate length survey rod (cither 25' or 45'). White Mesa Milt - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12.3 Page 13 ol 23 b) Existing Decontamination Pad During thc 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 ofthe tank will be visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred since thc last inspection. If any abnormalities are identified, defects or damage will be reported to Mill management and repairs will be made prior lo resuming the use ofthe 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. Thc inspection findings, any repairs required and repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Repon due September 1 of each calendar year. 5. 5.0 Inspection of the Ammonium Sulfate Cover Area After installation and approval ofthe As-Built plans by DRC. the Ammonium Sulfate Cover Area will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will be conducted during thc second quarter of each year. The results of quarterly and annual inspections will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed as described below and will be documented on the inspection form included as Attachment A-5. Thc Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with greater than 1/8 inch separation (.width) or any significant deterioration or damage of the concrete pad or asphalt surfaces, repairs will be made within 7 calendar days ofthe inspection. All inspection findings and any repairs required shall be documented on thc Decontamination Pad/Ammonium Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs completed shall be summarized in the 2ncl Quarter DMT Monitoring Report due September 1 of each calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during the second quarter in the year following installation/completion ofthe pad. 6. OTHER INSPECTIONS All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as specified in this DMT Plan. See also the 'failings Management System procedure included m the EPM for additional inspection requirements. However, additional inspections should be conducted after any significant storm or significant natural or man-made event occurs. 7. REPORTING REQUIREMENTS In addition to thc forms included in this DMT Plan, the following additional reports shall also be prepared: While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: Hl-Rl 12.3 Page 15 ol 23 ATTACHMENT A FORMS White Mesa Mill - Discharge Minimization Technoloe> Monitoring Plan 4/15 Revision: EFRI 12.3 Pace 16 of 23 ATTACHMENT A-1 DAILY INSPECTION DATA Ins|>eclor._ Date: Accompanied by:_ Time. Any Item not "OK" must be documented A check mark = OK, X = Action Required VII. DAILY LEAK DETECTION CHECK Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B Leak Detection System Checked Checked Checked Checked .Wet Dry Wet Dr\ _Wel Drv Checked „Wet Drv Checked Wet Drv Initial level. Final le\el Initial level. Final level Initial level. Final level Initial level. Final level Initial level. Final le\el Gal, pumped. Gal, pumped. Gal, pumped. Gal, pumped. Gal, pumped. Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management System (Appendix A-1) While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision- EFRI 12.3 Page 17 of 23 ATTACHMENT A-2 WEEKLY TAILINGS INSPECTION Date Inspectors: I Pond and Beach Cell 1. (a) Pond Solution Elevation elevations (msl, ft) (b) FML Bottom Elevation 5597 (e) Depth of Water above PML ((a)-(b)) Cell 4A: (a)Pond Solution Elevation (b) FML Bottom Elevation 5555.14_ (c) Dcpth of Water above FML ((a)-tb)) Cell 4B: (a)Pond Solution Elevation (b) FML Bottom Elevation 5557.50 (c) Dcpth of Water above FML ((a)-(b)) (d) Elevalion of Beach Area with Highest Elevation (monthly) 2. Leak Detection Systems Observation: New Decon Pad. Portal I New Decon Pad. Portal 2 New Decon Pad Poital 3 Is LDS (Portal) wet or wet _dry wet _dry .wet dry If wet. Record liquid level: _Ft to Liquid _Ft to Liquid .Ft to Liquid If wet, Report to RSO Does Level exceed 12 inches ahove tlie lowest point on the bottom flexible membrane liner (solution elevation of 5556 14 ainsl for Cell 4A and 5558.50 for Cell 4B)'] no yes If Cell 4A leak detection system level exceeds 12 inches above thc lowest point on thc bottom flexible membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately. 3. New Decontamination Pad (concrete): While Mesa Mill - Discharge Minimization Technology Monitoring Plan 1/15 Revision' EFRI 12.3 Page 18 of 23 ATTACHMENT A-3 ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week of through Date of Inspection: Inspector: Weather conditions for the week: Blowing dust conditions for the week: Conective actions needed or taken for the week: Are all bulk feedstock matenals stored in the area indicated on the attached diagram: yes: no. comments: Are all alternate feedstock matenals located outside the area indicated on the attached diagram maintained within water-light containers: yes: no: comments (e 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: While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision- EFRI 12.3 Page 20 of 23 ATTACHMENT A-4 ANNUAL DECONTAMINATION PAD INSPECTION Date of Inspection: Inspector: New Decontamination Pad: Are there any c racks 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 lank? Yes No Findings: Repair Work Required: Note: For the annual inspection ofthe Existing and New Decontamination, thc annual inspection findings, any repairs required, and repairs completed, along with a summary ofthe weekly inspections ofthe Decontamination Pads, shall be discussed in the 2,u1 Quarter report, due September 1 of each calendar year. White Mesa Mill - Discharge Minimiiaiion Technology Monitoring Plan 4/15 Revision F.FRI 12.3 Page 21 of 23 ATTACHMENT A-5 AMMONIUM SULFATE COVER AREA INSPECTION Ammonium Sulfate Concrete Pad: Are there any cracks on the concrete pad surface greater than 1/8 inch of separation'' _ Yes No Is there any significant deterioration or damage of the pad surface'/ Ves . No Findings. Repair Work Required: Ammonium Sulfate Asphalt Cover: Are there any cracks on asphalt surf ace greater than 1/S inch of separation'.' _Yes No Is there any significant deterioration or damage of the asphalt surlace? Yes No Findings: Repair Work Required: Note. For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings, any repairs required, and repairs completed, shall he discussed in the associated quarterly DMT Report. For thc annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs required, and repairs completed, along with a summary of the weekly inspections ofthe Decontamination Pads, shall be discussed in the 2nd Quarter report, due September 1 of each calendar year. Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision. EFRI 12.3 Page 22 of 23 ATTACHMENT B FEEDSTOCK STORAGE AREA il \ V - D c5 5 1 if rH r : ;b£______ b»_5 N WHITE MCM t While Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12 3 Page 23 of 23 ATTACHMENT C TABLES Table IA Calculated Action leakage Rates for Various head Conditions Cell 4A White Mesa Mill Blanding. Utah Head above Liner System (feet) 10 15 20 25 30 35 37 Calculated Action leakage Rate ( gallons / acre / day ) 222.04 314.01 384.58 444.08 496.50 543.88 587.46 604.01 Table IB Calculated Action leakage Rates for Various head Conditions Cell4B White Mesa Mill Blanding, Utah Head above Liner System (feet) 15 20 25 30 35 37 Calculated Action leakage Rate ( gallons / acre / day ) 211.40 317.00 369.90 422.70 475.60 528.40 570.00 581.20