DRC-2022-018844 - 0901a068810b8a83

TNENoYFUEIS
Dir, 611'4uut* Management
nrrd ltadiation Control
JUL f 9 ?il2?
Energy Fuels Resources (USA) Inc.
225Union Blvd. Suite 600
Lakewood, CO, US,80228
303 974 2t40
www.energ)'fuels.com
Re:
July 15,2022
Sent VIA EXPEDITED DELMRY
Mr. Doug Hansen
Director
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Transmittal of Groundwater Discharge Permit Renewal Application for the White Mesa Uranium Mill,
Blanding Utah Pursuant to Part tV.D of the March 8,2021Utah Groundwater Discharse Permit No.
ucw370004
Dear Mr. Hansen:
Enclosed are two copies of the Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Uranium Mill
Groundwater Discharge Permit ("GWDP") application for the White Mesa Mill in accordance with R317-6-
6.7 and the current GWDP revision dated March 8,202I, Part IV.D. This is. an updated application
(the "Application") to the Director for renewal of the Permit for another S-years under R313-6-6.7.
If you should have any questions regarding this submittal, please contact me at 303-3 89-4134.
Yours very truly,
Kathy Weinel
Director, Regulatory Compliance
CC: Scott Bakken
David Frydenlund
Logan Shumway
Garrin Palmer
tM
ENnnc{ FUELS RnsouncBs (USA) INC.
DRC-2022-018844
July 15, 2022
Sent VIA EXPEDITED DELIVERY
Mr. Doug Hansen
Director
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Re: Transmittal of Groundwater Discharge Permit Renewal Application for the White Mesa Uranium Mill,
Blanding Utah Pursuant to Part IV.D of the March 8, 2021 Utah Groundwater Discharge Permit No.
UGW370004
Dear Mr. Hansen:
Enclosed are two copies of the Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Uranium Mill
Groundwater Discharge Permit ("GWDP") application for the White Mesa Mill in accordance with R317-6-
6. 7 and the current GWDP revision dated March 8, 2021, Part IV.D. This is an updated application
(the "Application") to the Director for renewal of the Permit for another 5-years under R313-6-6. 7.
If you should have any questions regarding this submittal, please contact me at 303-389-4134.
Yours very truly,
~ ENERGj FUELS RESOURCES (USA) INC.
Kathy W einel
Director, Regulatory Compliance
CC: Scott Bakken
David Frydenlund
Logan Shumway
Garrin Palmer
White Mesa Mill
Renewal Application
State of Utah Groundwater Discharge
Permit No. UGW370004
Energy Fuels Resources (USA) Inc.
July 2022
1.0 INTRODUCTION
1.1 Background
1.2 Applicable Standards for Review and Approval of this Application
1.3 Background Groundwater Reports
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
2.2 Legal Location of the Facility (R317-6-6.3B)
2.3 Name and Type of Facility (R317-6-6.3.C)
1
1
1
5
18
18
19
19
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well, Drinking Water Source
Protection Zones, Topography, Springs, Water Bodies, Drainages, And Man-Made Structures Within A One-Mile
Radius Of The Discharge. (R317-6-6.3.D) 20
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317-6-6.3.E)
2.5.1 Groundwater Characteristics
2.5.1.1 Geologic Setting
2.5.1.2 Hydrogeologic Setting
2.5.1.3 Perched Zone Hydrogeology
2.5.1.4 Perched Groundwater Flow
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient Of The TMS
2.5.2 Groundwater Quality
2.5.2.1 Entrada/Navajo Aquifer
2.5.2.2 Perched Groundwater Zone
2.5.3 Springs and Seeps
2.5.4 Topography
2.5.5 Soils
2.5.6 Bedrock
2.5.7 Agricultural and Land Use Description of the Area
2.5.8 Well Logs
20
20
20
21
21
25
26
27
27
28
28
29
29
30
30
31
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of the Effluent or Leachate
to be Discharged (R317-6-6.3.F) 31
2.7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate Into or Adversely Affect
the Quality of any Other Waters of the State (R317-6-6.3.G) 32
2.7.1 General 32
2.7.2 Cells 1, 2 and 3 33
2.7.2.1 Design and Construction of Cells 1, 2 and 3
2.7.2.2 Improved Groundwater Monitoring
2.7.2.3 Operational Changes and Improved Operations Monitoring
2.7.2.4 Evaluation ofTailings Cell Cover System Design
2.7.3 Cell 4A
2.7.4 Cell 4B
33
34
35
35
36
39
2.7.5 Future Additional TMS Cells
2.7.6 Other Facilities and Protections
2. 7 .6.1 Feedstock Storage
2.7.6.2 Mill Site Reagent Storage
2.7.6.3 New Construction
2.7.6.4 Other
2.7.7 Surface Waters
2. 7 .8 Alternate Concentration Limits
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information of the Quality of the
41
42
42
42
42
43
43
43
Receiving Ground Water (R317-6-6.3.H) 43
2.8.1 Existing Wells at the Time of Original Permit Issuance 44
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit 44
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.I) 45
2.9.1 Groundwater Monitoring to Determine Groundwater Flow Direction and Gradient, Background Quality at
the Site, and the Quality of Groundwater at the Compliance Monitoring Point 45
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit 45
2.9.1.2 Issuance of the Permit 45
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit
2.9.1.4 Groundwater Flow Direction and Gradient
2.9.1.5 Background Quality at the Site
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point
46
47
48
so
2.9.2 Installation, Use and Maintenance of Monitoring Devices 50
2.9.2.1 Compliance Well Monitoring 50
2.9.2.2 Leak Detection System in Cell 4A and Cell 48 50
2.9.2.3 Other DMT Monitoring Requirements 51
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring Points 51
2.9.4 Monitoring of the Vadose Zone 52
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation, Including Post-
Operational Monitoring 52
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation 52
2.9.5.2 Post-Operational Monitoring 52
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where Applicable to Specified
Guidance 52
2.9.6.1 Monitoring Well Construction 52
2.9.6.2 Ground Water Sampling 57
2.9. 7 Description and Justification of Parameters to be Monitored 57
2.9.8 Quality Assurance and Control Provisions for Monitoring Data 58
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of Discharge Systems (R317-
6-6.3.J) 59
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-6-6.3.K)
2.11.1 General
2.11.2 Background Ground Water Quality in the Perched Aquifer
2.11.3 GWCL Determination for Field pH
2.11.4 Quality of Ground Water at the Compliance Monitoring Point
2.12 Compliance Sampling Plan (R317-6-6.3.L)
2.12.1 Tailings Cell Wastewater Quality Sampling Plan
2.12.2 White Mesa Seeps and Springs Sampling Plan
2.12.3 Monitoring of Deep Wells
11
59
59
60
66
69
69
69
70
71
2.13 Description of the Flooding Potential of the Discharge Site (R317-6-6.3.M)
2.13.1 Surface Water Characteristics
2.13.2 Flood Protection Measures
2.14 Contingency Plan (R317-6-6.3.N)
71
71
72
72
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting Failure of the System
(R317-6-6.3.0) 72
2.15.1 Existing Tailings Cell Operation 73
2.15.2 Existing Facility DMT Performance Standards 73
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3 73
2.15.2.2 Slimes Drain Monitoring 73
2.15.2.3 Maximum Tailings Waste Solids Elevation 76
2.15.2.4 Inspection of Feedstock Storage Area 76
2.15.2.5 Monitor and Maintain Inventory of Chemicals 77
2.15.3 BAT Performance Standards for Cell 4A 78
2.15.3.1 BAT Operations and Maintenance Plan 78
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance Plan 78
2.15.4 BAT Performance Standards for Cell 4B 79
2.15.4.1 BAT Operations and Maintenance Plan 79
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance Plan 79
2.15.5 Stormwater Management and Spill Control Requirements 80
2.15.6 Tailings and Slimes Drain Sampling 80
2.15.7 Additional Monitoring and Inspections Required Under the Mill License 81
2.15.7.1 Daily Inspections 81
2.15.7.2 Weekly Inspections 82
2.15.7.3 Monthly Reports 82
2.15.7.4 Quarterly Tailings Inspections 83
2.15.7.5 Annual Evaluations 83
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to Remedy any Violation
of Applicable Ground Water Quality Standards (R317-6-6.3.P) 84
2.16.1 Chloroform Investigation 84
2.16.2 Nitrate Investigation 87
2.17 Other Information Required by the Director (R317-6-6.3.Q) 91
2.17.1 Chemical Inventory Report 91
2.17.2 Southwest Hydrogeologic Investigation 92
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-6.3.R) 92
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent Ground Water
Contamination During the Closure and Post Closure Phases of Operation (R17-6-6.3.S) 93
2.19.1 Regulatory Requirements for Uranium Mills 93
2.19.1.1 Long Term Custodian 93
2.19.1.2 Responsibility For And Manner Of Clean Up 93
2.19.1.3 Surface 93
2.19.1.4 Groundwater 94
2.19.1.5 License Termination 94
2.19.2 Current Reclamation Plan 95
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan 96
2.19.4 Post-Operational Monitoring 97
lll
3.0 CONCLUSIONS
4.0 SIGNATURE AND CERTIFICATIONS
5.0 REFERENCES
IV
97
98
99
Figure No.
1 ....................... .
2 ....................... .
3 ....................... .
4 ....................... .
5 ....................... .
6 ....................... .
7 ....................... .
8 ....................... .
9 ....................... .
10 ....................... .
11 ....................... .
INDEX OF FIGURES
Description
White Mesa Mill Location Map
White Mesa Mill Land Map
Generalized Stratigraphy of White Mesa Mill
Kriged Top of Brushy Basin White Mesa Site
Kriged 4th Quarter, 2021 Water Levels
Showing Inferred Perched Water Flow Paths
Southwest of Tailings Management System
Seeps and Springs on USGS Topographic
Base White Mesa
4th Quarter, 2021 Depths to Perched Water in
Feet, White Mesa Site
4th Quarter, 2021 Perched Zone Saturated
Thickness in Feet White Mesa Site
Groundwater (Well and Spring) Sampling
Stations in the White Mesa Vicinity
White Mesa Mill Site Plan Showing
Locations of Perched Wells and Piezometers
Mill Site Layout
12......... ... .... .. . ..... Drainage Map of the Vicinity of the White
Mesa Mill
13 ......... .. . .. . . . . . . .... Streamflow Summary Blanding, UT Vicinity
V
Table No.
1.2-1 ............. .
1.2-2 ............. .
2.4-1 .............. .
2.5.2.1-1 ......... .
2.5.3-1 ........... .
2.5.3-2 ........... .
2.5.3-3 ........... .
2.5.3-4 ........... .
2.5.3-5 ........... .
2.9.1.3-1 ........ ..
2.11.2-1.. ........ .
2.13.1-1 ........... .
INDEX OF TABLES
Description
Chloroform Monitoring Wells (Depth and Purpose)
Nitrate Monitoring Wells (Depth and Purpose)
Groundwater Monitoring Wells (Depth and Purpose)
Water Quality of Entrana/Navajo Aquifer in the Mill Vicinity
Results of Quarterly Sampling Ruin Spring (2003-2004)
Results of Annual Sampling Ruin Spring (2009-2022)
Results of Annual Sampling Cottonwood Spring (2009-2022)
Results of Annual Sampling Westwater Seep (2009-2022)
Results of Annual Sampling Entrance Spring (2009-2022)
Groundwater Monitoring Constituents Listed in Table 2 of the
Permit
Plan & Time Schedule and Source Assessment Report Status
Drainage Areas of Mill Vicinity and Region
Vl
Appendix
A .................... .
B .................... .
INDEX OF APPENDICES
Description
Radioactive Materials License Amendment No.
4: March 31, 2007
White Mesa Mill Site Maps with Well
Locations
C..................... Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill,
Revision: 3, November 11, 2019
D......... .. . . . . .. . . . . Results of Soil Analysis at Mill Site
E..................... Tables: Chemical and Radiological
Characteristics of Tailings Solutions, Leak
Detection Systems and Slimes Drains
F. ........ ... ......... Cell 4A and 4B BAT Monitoring, Operations
and Maintenance Plan 07/11 Revision: Denison
2.3
G. ...... .. ...... ... .. . Stormwater Best Management Practices Plan,
Revision 2.1: April 2022
H... .. . . . .. . . . . . . . . . .. White Mesa Mill Discharge Minimization
Technology (DMT) Monitoring Plan, 1/2022,
Revision: EFRI 13.0
I....................... White Mesa Mill Tailings Management System,
3/2017, Revision: EFR 2.5
J. .. . . . . .. . . . . .. . . .. . .. . Cell 2 Slimes Drain Calculations and Figure
2009-2022
K............. .. ... .... White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP)
Date 2/15/2022 Revision 7.7
L..................... .. Tailings and Slimes Drain Sampling Program,
Revision 3.0, July 8, 2016
M.................... .... Contingency Plan, 12/11 Revision: DUSA-4
N ..................... .. White Mesa Mill Containerized Alternate
Feedstock Material Storage Procedure, PBL-
19, Revision: 3.0, March 1, 2017
0... . . . . . . . . . . . . . . . . . . . . . White Mesa Mill Chemical Inventory
vii
1.0 INTRODUCTION
1.1 Background
Energy Fuels Re ources (USA) Inc. ("EFRI") operate the White Mesa Uranium Mill (the
"Mill"), located approximately six miles south of Blanding, Utah, under State of Utah Ground
Water Discharge Permit No. UGW 370004 (the "Permit" or "GWDP"). The Permit was
originally issued by the Co-Executive Secretary of the Utah Water Quality Board on March 8,
2005, for 5 years, expiring on March 8, 2010, and was up for timely renewal in accordance with
Utah Administrative Code ("UAC") R317-6-6.7. A renewal application was submitted
September l 2009. At the reqL1e: t of the Director of the Utah Division of Radiation Control
("DRC ), EPRI ubmitted an updated ver ion of the September I, 2009 renewal application on
July 13 2012. EFRI ubrnitted an updated ver ion of the July 2012 renewal application on June
5, 2014 to address the Division of Waste Management and Radiation Control's ("DWMRC' ')
Request for Additional Information ("RAJ"). The Permit wa i ued January 19 2018.
In accordance with R317-6-6.7 and the current GWDP revision dated March 8, 2021, Part IV.D,
this is an updated application (the "Application") to the Director for renewal of the Permit for
another 5-years under R313-6-6.7.
The Mill is also subject to State of Utah Radioactive Materials License No. UT 1900479 (the
"Mill License"), which was issued by DWMRC on January 18, 2018 for 10-years. The current
amendment to the License (Amendment 10) was issued July 27 2021. The Mill is al o ubject
to State of Utah Air Quality Approval Order DAQE-ANOl 12050024-21 (the 'Air Approval
Order') which wa re-is ued on December 23 2021 and is not up for renewal at thi time. While
the Mill License is referred to in this Application from time to time in order to allow the Director
to better understand Mill operations and compliance with applicable regulatory requirements,
this is not an application for renewal of the Mill License or Air Approval Order.
Prior to July 1, 2012, the Director of the Utah Division of Radiation Control ("Director") was
referred to as the Executive Secretary of the Utah Radiation Control and Board Co-Executive
Secretary of the Utah Water Quality Board. Prior to 2015, the DWMRC was referred to as the
Utah DRC. Document referenced in this Application, published prior to these dates, may refer
to the previous titles and division names.
1.2 Applicable Standards for Review and Approval of this Application
In accordance with R317-6-6.4C, the Director may issue ( or renew) a ground water discharge
permit for an existing facility, such as the Mill, provided:
a) The applicant demonstrates that the applicable class total dissolved solids ("TDS")
limits, groundwater quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) The applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by
1
facilities that produce similar products or services with similar production process
technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
Thi Permit Application demonsn·ates how ex1 trng facilities continue to meet applicable
regulatory criteria and the monitoring u·ategie employed to prevent impairment of pre ent and
future beneficial u e. of the groundwater. EFRI conducts variou kinds of environmental
monitoring at the White Mesa Mill including but not limited to groundwater, surface water, soil,
sediment, tailings waste water, air, and vegetation. Specific groundwater monitoring activities
employed are summarized below.
EFRI's groundwater monitoring program is comprehensive in that it includes all of the 82
monitoring wells and three piezometers at the facility, as described below, although not every
location is sampled every quarter or for the complete list of GWDP con tituents. Samples are
taken and analyzed for a large number of groundwater contaminants including heavy metals,
nutrients, general chemistry analytes, radiologies, and volatile organic compounds ("VOCs").
Exceedences of standards found during this monitoring program have been addressed as
described throughout this GWDP Application.
Under the License, the Permit, and the Corrective Action Plans, EFRI has completed and is
monitoring the 85 groundwater monitoring locations (82 wells and three piezometers) described
below.
• 31 grollndwater wells monitored to detect any potential leaks from the Tailings
Management System ("TMS") and/or provide information regarding local geochemical
conditions at the Mill. Because the leak detection systems for Cells 1, 2, and 3 utilized
older, less sophisticated technology, DWMRC required nine new wells be installed
adjacent to the TMS in 2005. These wells are used as a first line of defense to detect any
potential TMS impacts. These supplemented the existing thirteen wells that were
installed prior to the 2005 issuance of the original permit (existing well MW-3 has since
been abandoned). Two additional general monitoring wells were included in the program
(MW-20 and MW-22). An additional three wells have been installed in association with
the construction of Cells 4A and 4B. Three wells have been added by EFRI in response to
requests from the Ute Mountain Ute Tribe ("UMUT") far cross-gradient to the TMS to
provide water level data and to provide additional information on site geology and
naturally occurring geochemical behaviors. One weJJ ha been in talled adjacent to MW-
24 for additional studies of regional geochemi try. Chloroform weJI TW4-24 ha been
added as a general monitoring well under the groundwater sampling program.
• 43 monitoring wells associated with characterizing the chloroform groundwater plume.
• Eight monitoring wells and three piezometers are a ociated with characterizing the
nitrate groundwater plume.
The monitoring results for each of the 31 groundwater wells that are sampled, are evaluated
against standards for 38 different constituents. Monitoring results for each of the 43 chloroform
wells and 11 nitrate sampling locations are evaluated for six different constituents and two
2
different constituents respectively. For all 85 monitoring locations, regardless of whether the
standards are met, the results are evaluated for trends in the data that may show a need for further
action.
Four indicator parameters ( chloride, uranium, fluoride, and sulfate) are used at the site to
determine if there has been any potential cell leakage. These constituents were chosen because
they are the most mobile and are expected to be seen first with any upward trend in consistent
concentrations. If a cell were leaking, it is expected that all four parameters would show
increasing trends within two years, based on Kd values and other transport characteristics for the
contaminants and site. In instances where the indicator parameters are affected by the co-located
nitrate and chloride plume or other location specific geochemical influences, alternative mass
balance assessments and studies are completed to assure protection levels are met.
During a DWMRC split sampling event in May, 1999, excess chloroform concentrations were
discovered in monitoring well MW-4, which is located along the eastern margin of the site.
Because these concentrations were above the Utah Ground Water Quality Standard of 70 µg/L,
the DWMRC initiated enforcement action against EFRI on August 23, 1999 by issuing a Ground
Water Corrective Action Order. The Order required completion of: 1) a contaminant
investigation report to define and delineate boundaries for the contaminant plume, and 2) a
groundwater corrective action plan to clean it up. Twenty new monitoring wells (since increased
to 34 wells) were installed at the site as part of the investigation. Table 1.2-1 lists the 43
chloroform monitoring wells.
The Director and EFRI determined that the laboratory wastewater sent to sewage leach fields,
and not potential impacts from the TMS, was the most likely source of the chloroform plume.
As with every groundwater corrective action, the corrective action plan is developed based on
assumptions about the source, and those assumptions are tested continuously with groundwater
monitoring as corrective action proceeds.
With DWMRC concurrence, EFRI began to pump chloroform contaminated groundwater in
April, 2003. Groundwater monitoring results show this initial remediation effort has been
effective based on reduction of contaminant concentrations. Reductions of the contaminant
concentrations indicates both that the pumping program is working and that there is no
continuous source for the contaminants, as would be the case if the TMS were leaking.
During a review of the EFRI April 30, 2008 New Wells Background Report and other EFRI
reports, Nitrate + Nitrite (as N) (hereafter Nitrate) concentrations were observed above the Utah
Ground Water Quality Standard (10 milligrams per liter ["mg/L"]) in five monitoring wells in
the mill site area.
After the Nitrate Plume was identified, the Executive Secretary and EFRI entered into a January
28, 2009 Stipulated Consent Agreement that required EFRI to complete a Contaminant
Investigation Report to determine the potential sources of the Nitrate contamination. Nineteen
additional wells were installed to determine the extent of the contamination; nine of these wells
have since been abandoned. An additional two wells were installed in 2021 to address nitrate
3
plume migration occurring upgradient of the TMS. Table 1.2-2 lists the current and former
nitrate wells installed as part of the nitrate corrective actions.
EFRI submitted two reports to DWMRC regarding the elevated Nitrate concentrations. The
reports identified the extent of the Nitrate plume but EFRI and DWMRC disagreed about what
the rep01ts indicated about the likely source of the plume. EFRI does not believe that the results
adequately demonstrated an on-site source, especially since a significant p01tion of the plume
originates upgradient from the Mill facilities, specifically upgradient of the TMS.
EFRI agreed to implement a corrective action plan to clean up the plume. EFRI completed and
submitted the Nitrate Corrective Action Plan to the DRC on May 7, 2012 (HGC 2012b). The
Corrective Action Plan was approved following a public comment period, and was incorporated
into a December 12, 2012 Stipulation and Consent Order, Docket Number UGW12-04. The
approval is subject to conditions, stipulated penalties and timelines outlined in the Stipulation
and Consent Order. The remediation plan requires EFRI to pump the groundwater and treat it
by evaporation and/or use as process water. Pumping under the remediation plan began in
January 2013.
Groundwater monitoring results show this initial remediation effort has been effective based on
reduction of the plume mass to date.
When the DWMRC began oversight of the Mill, it noted that groundwater monitoring had
showed elevated concentrations of metals, primarily uranium, in wells MW-3, MW-3A, MW-14,
MW-15, MW-22 on the Mill site. The DWMRC was concerned about whether the observations
meant that the TMS was potentialJy impacting groundwater. To address its concerns, the
DWMRC commissioned the Uoiver ity of Utah to investigate the elevated concentrations in July
2007. The University completed its study and published a report in May 2008 (the "2008
University Report").
After review of the 2008 University Report, the DWMRC determined that downgradient wells
with elevated total uranium concentrations (including well MW-22) were not being impacted by
potential TMS leakage. This conclusion was based on at least three lines of isotopic evidence:
1. Tritium Signature. Wells MW-3 (now abandoned), MW-3A, MW-14, MW-15, MW-22 had
tritium signatures in groundwater at or below the limit of detection of 0.3 Tritium Units
(2008 University Report p. 26). These values are more than an order of magnitude below
the corresponding surface water results found in either the TMS or the wildlife ponds. This
means that the groundwater in these five downgradient wells is older than water in the TMS,
and is of a different origin than the TMS fluids.
2. Stable Isotopes of Deuterium and Oxygen-18 in Water. The Deuterium and Oxygen-18
content of the groundwater matrix and TMS fluids were tested in all of the water sources
studied. The 2008 University Report results showed that wells MW-3 (now abandoned),
MW-3A, MW-14, MW-15, and MW-22, all downgradient wells with elevated uranium
concentrations, had Deuterium and Oxygen-18 signatures that were almost twice as negative
as any of the surface water results (2008 University Report, p. 42.). This shows that
4
groundwater in these downgradient wells had a different geochemical origin than the TMS
fluids.
3. Stable Isotopes on Dissolved Sulfate. The University Study evaluated two stable isotopes
found in sulfate minerals dissolved in the water samples, Oxygen-18 and Sulfur-34. The
evaluation showed that the sulfate solutes in groundwater from downgradient wells MW-3
(now abandoned), MW-3A, MW-14, MW-15, and MW-22 had a different isotopic signature
than the sulfate minerals dissolved in the TMS fluids. In the case of Oxygen-18 in sulfate,
the downgradient wells showed more negative values than the TMS fluids. For Sulfur-34,
the results were inversed, with groundwater showing more positive values than the negative
values seen in the TMS fluids (2008 University Report p. 46.). This shows that the sulfate
dissolved in the downgradient wells, with elevated uranium concentrations, has a different
origin than the TMS fluids.
In summary, the University Study concluded that wells with high concentrations of metals (MW-
3 [now abandoned], MW-14, MW-15, MW-18, and MW-22) bear very different isotopic
fingerprints than those of the surface water sites (e.g. wildlife ponds, and TMS) (2008 Univer ity
Report p. 58). Regarding uranium concentrations in well MW-22, the University Study stated
that " .. .it does not appear that the elevated uranium values are the result of leakage from tailings
cells .... " (2008 University Report p. 45).
The 2008 University Report further theorized that the cause of the increasing contaminant
concentrations on the site wa artificial recharge from wildlife pond constructed in 1995
de ·cribed in Part 1.5.1 of the 2008 Univer ity Report. Tiu recharge likely leached and
mobilized natural uranium and other con tituent as a re ult of new aturation of zones beneath
the site that had previously been unsaturated. The Mill ceased delivery of water to the wildlife
ponds in March 2012.
As indicated by these previous studies, the Mill meets the requirements set out in R317-6-6.4( c ).
This Application has been prepared under the direction, and bears the seal, of a professional
engineer qualified to practice engineering before the public in the state of Utah and
professionally registered as required under the Professional Engineers and Professional Land
Surveyors Licensing Act rules (UAC 156-22).
1.3 Background Groundwater Reports
In the December 1, 2004 Statement of Basis (the "2004 Statement of Basis") prepared by
DWMRC in connection with the original issuance of the Permit, three monitoring wells (MW-
14, MW-15, and MW-17) located downgradient of the Mill's TMS were found to have long-term
increasing concentration trends for uranium. These three wells had uranium concentrations
above the Utah Ground Water Quality Standard ("GWQS"), found in UAC R317-6-2 (see the
2004 Statement of Basis, pp. 6-7). These findings were of concern to the DWMRC becau e they
appeared to indicate that the TMS had possibly discharged fluids into the underlying hallow
aquifer.
To resolve this concern, the Director required EFRI to evaluate groundwater quality data from
5
the thirteen existing wells on site, and submit a Background Ground Water Quality Report for
Director approval. The exi ting well are tho, e wells which were installed prior to the issuance
of the original GWDP on March 8, 2005 and include: MW-! MW-2, MW-3 (now abandoned)
MW-5, MW-11, MW-12, MW-14, MW-15, MW-17 MW-18 MW-19 MW-26 (formerly called
TW4-15 and installed as part of the chloroform corrective action order), and MW-32 (formerly
called TW4-17 and installed as part of the chloroform corrective action order). It is important to
note that MW-4 was in talled prior to the issuance of the original permit; however, MW-4 is
monitored under the chloroform program and was not included in the Existing Background
Report. Groundwater Compliance Limits ( GWCLs') have not been establi. hed for thi · well,
and MW-4 i not a Point of Compliance ("POC') well Llnder the GWDP. One of the purposes of
the background report was to provide a critical evaluation of historic groundwater quality data
from the facility, and determine representative background quality conditions and reliable
GWCLs for the Permit.
As required, EFRI submitted the following reports:
• Revised Background Groundwater Quality Report: Existing Wells For Denison Mines
(USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, October 2007 (INTERA
2007a) prepared by INTERA, Inc. (the 'Existing Well Background Report"); and
• Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Ba ·kground Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Co,p. 's White Mesa Mill Site, an Juan County, Utah November
16, 2007 (INTERA 2007b), prepared by INTERA, Inc. (the "Regional Background
Report").
The Exi ting WelJ Background Report and the Regional Background Reporl included a detailed
quality assurance evaluaLion of all existing groundwater quaJity data collected pr.ior to the date of
is. uaoce for the thirteen existing wells, jn accordance with criteria e. tabli hed by DWMRC and
United States Environmental Protection Agency ("EPA') guidance. Thi resulted .in a database
suitable for statistical and other analyses. Ba ed on an analy i of this updated database the
Existing Well Background Report and Regional BackgrOLmd Report concluded that there had
been no impacts to groundwater from Mill activitie , ba ed on a number of factor including the
following:
• There were a number of exceedances of GWQSs in upgradient and far downgradient
wells at the site, which cannot be considered to have been impacted by Mill operation .
Exceedances of GWQSs in monitoring wells nearer to the site itself are therefore
consistent with natural background in the area.
• There were numerou case of both increasing and decreasing trends in constituents in
upgradient far downgradient and MiJJ ite wells, which provide evidence that there are
natural force at work that are impacting groundwater quality across the entire site.
• In almost all cases where there were increasing trends in constituents in wells at the site,
there were increasing trends in those constituents in upgradient wells.
6
See Section 2.11.2 below for a more detailed discussion of the Existing Well Background Report
and Regional Background Report and their conclusions.
The Permit also required nine new monitoring wells to be installed around TMS Cells 1 and 2,
followed by groundwater sampling and analysis, and later submittal of another Background
Ground Water Quality Report to determine reliable background conditions and groundwater
compliance limits for the new wells. The new wells are those wells, which were installed after
the issuance of the original GWDP on March 8, 2005 and include: MW-3A, MW-23, MW-24,
MW-25, MW-27, MW-28, MW-29, MW-30, and MW-31. In response to this requirement, EFRI
installed the nine new wells, and submitted to the Director a Revised Addendum: --Background
Groundwater Quality Report: New Wells For Denison Mines (USA) Corp. 's White Mesa Mill
Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc. (the "New Well
Background Report"), and together with the Existing Well Background Repmt and the Regional
Background Report, are referred to as the "Background Reports").
The New Well Background Report concluded that the sampling results for the new wells confirm
that the groundwater at the Mill site and in the region is highly variable naturally and has not
been impacted by Mill operations and that varying concentrations of constituents at the site are
consistent with natural background variation in the area. See Section 2.11.2 below for a more
detailed discussion of the New Well Background Report and its conclusions.
During the course of discussions with EFRI staff, and further DWMRC review, DWMRC
decided to supplement the analysis provided in the Background Reports by commissioning the
University of Utah to perform a geochemical and isotopic groundwater study at White Mesa.
This resulted in the University of Utah completing a study entitled Summary of work completed,
data results, interpretations and recommendations for the July 2007 Sampling Event at the
Denison Mines, USA, White Mesa Uranium Mill Near Blanding Utah, May 2008, prepared by T.
Grant Hurst and D. Kip Solomon, Department of Geophysics, University of Utah (the
"University of Utah Study"). The purpose of the University of Utah Study was to determine if
the increasing and elevated trace metal concentrations (such as uranium) found in the monitoring
wells at the Mill were due to potential leakage from the TMS. To investigate this potential
problem, the study examined groundwater flow, chemical composition, noble gas and isotopic
composition, and age of the on-site groundwater. Similar evaluations were also made on
samples of the TMS fluids and nearby surface water stored in the northern wildlife ponds at the
facility. Fieldwork for the University of Utah Study was conducted from July 17 -26 of 2007.
The conclusions in the University of Utah Study supported EFRI's conclusions in the
Background Reports.
As stated above, EFRI prepared Background Reports that evaluated all historic data for the
thirteen existing wells and nine new wells for the purposes of establishing background
groundwater quality at the site and developing GWCLs under the GWDP. Prior to review and
acceptance of the conclusions in these Background Reports, the GWCLs were set on an interim
basis in the GWDP. The interim limits were established as fractions of the state GWQSs for
drinking water, depending on the quality of water based on TDS in each monitoring well at the
site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
7
for the thirteen existing wells and the nine new wells based primarily on the conclusions and
analysis in the Background Reports. It should be noted however, that, becau e the GWCLs have
been set at the mean pJu second standard deviation, or the equivalent un-impacted groundwater
would normally be expected to exceed the GWCL. appioximately 2.5% of tbe time. Therefore,
exceedances are expected in approximately 2.5% of all sample re ults, and do not necessarily
represent impacts to groundwater from Mill operations.
In addition to the thirteen existing wells (12 remaining after the abandonment of MW-3) and the
nine new wells there are an additional 10 monitoring wells at the site which are included in the
routine groundwater monitoring program and sampled when ufficient water i present. Tho e
nine wells are: MW-20, MW-22, MW-35, MW-36, MW-37, MW-38 MW-39, MW-40 MW-
24A, and TW4-24.
The GWDP dated January 20, 2010 required the completion of eight consecutive quarters of
groundwater sampling and analysis of MW-20 and MW-22 and later submittal of anothes
Background Report to determine if wells MW-20 and MW-22 should be added a POC
monitoring wells. Data from MW-20 and MW-22 were analyzed in the pre-operational and
regional background addendum (JNTERA 2007a); however there was not a complete data set at
the time. Although wells MW-20 and MW-22 were installed in 1994, they were not sampled
regularly until the econd quarter of 2008. The eighth full round of sampling was completed
during the fir t quarter of 2010, and EFRI submitted to the Director the Background
Groundwater Quality Report for Wells MW-20 and MW-22 for Denison Mines (USA) Corp. 's
White Mesa Mill Site, San Juan County, Utah, June 1, 2010, prepared by INTERA, Inc. (the
"MW-20 and MW-22 Background Report"). DWMRC classified MW-20 and MW-22 as
general monitoring wells, and GWCLs have not been established for these wells. MW-20 and
MW-22 are sampled semi-annually.
Part I.H.6 of the GWDP dated June 21, 2010 required the in tallation of three hydraulically
downgradient wells adjacent to Tailings Cell 4B (MW-33, MW-34, and MW-35) prior to
placement of solids or fluids in Cell 4B. The purpo e of the, e monitoring wells was to provide
early detection of potential impacts to the shallow groundwater from Tailings Cell 4B. EFRI
installed MW-33, MW-34, and MW-35 as required. Of the, e three well. installed near tailing
Cell 4B, only MW-35 was hydraulically acceptable, with five feet or more of saturated thickness.
MW-35 was sampled quarterly since fourth quarter 2010 to collect eight statistically valid data
points for the completion of the Background Report and calculation of GWCLs. MW-33 and
MW-34 had insufficient water for sampling, with saturated thicknesses less than five feet. MW-
33 is completely dry, and no samples or depth to water measurements are collected from this
well. Quarterly depth to water is measured in MW-34, but no sampling or analysis is required.
Part I.H.4 of the February 15, 2011 GWDP required the installation of two wells hydraulically
downgradient of Tailings Cell 4B as replacements for MW-33 and MW-34. EFRI installed
MW-36 and MW-37 as required. MW-36 and MW-37 were sampled quarterly beginning in the
third quarter 2011 to collect eight statistically valid data points for the completion of the
Background Report and calculation of GWCLs.
The Background Report for wells MW-35, MW-36, and MW-37 was submitted to the Director
on May 1, 2014. The findings of the Background Analysis for wells MW-35, MW-36, and MW-
8
37 support previous conclusions that the groundwater at the Mill is not being affected by any
potential TMS seepage. The Director incorporated MW-35, MW-36 and MW-37 in a subsequent
revision of the GWDP and these wells are sampled as required.
Three wells have been added by EFRI in response to requests from the UMUT far cross-gradient
to the TMS to provide water level data and to provide additional information on site geology and
naturally occurring geochemical behaviors. DWMRC stated in the Public Participation
Summary ("PPS") for the January 18, 2018 GWDP renewal that "There is no regulatory or
technical basis to require additional monitoring wells between Cell 4A and MW-22. Monitoring
wells currently exist directly downgradient and cross gradient from Cell 4A which would
identify potential TMS impacts before anything would appear in MW-22 and at this time no
tailings cell leakage has been observed. In regards to the requested three new monitoring wells
made by the UMUT in other comments, although the Division e s no technical or regulatory
basis to include monitoring wells in the location between Tailing, Cell 4A and MW-22, EFRI
has agreed to address the UMUT concern and voluntarily install three monitoring wells in the
area between monitoring wells MW-17 and MW -22."
The three wells, MW-38, MW-39 and MW-40, were installed in February 2018. The
Background Report for wells MW-38, MW-39, and MW-40 was submitted to the Director on
June 7, 2021 after sufficient data had been collected to complete the statistical evaluation. The
findings of the Background Analysis for wells MW-38, MW-39, and MW-40 support previous
conclusions that the groundwater at the Mill is not being impacted by any potential TMS
seepage. The Director approved the background report for MW-38, MW-39, and MW-40 by
letter dated June 16, 2021. MW-38, MW-39, and MW-40 will be incorporated into a subsequent
revision of the GWDP. Until such time as these wells are incorporated into the GWDP, they are
sampled on a quarterly basis.
Part I.G.2 of the Permit provide that out-of-compliance ·tatu exi t when the concentration of a
constituent in two con ecutive sample from a compliance monitoring po.int exceeds a GWCL in
Table 2 of the Permit. A part of the a se ment of exceedance. of previ.ou GWCLs, increasing
trends in several constituents in MW-24 and other wells were observed as noted in the reports
listed below.
In response to the previously identified exceedances and increasing trends, in 2020 EFRI
voluntarily completed a study of MW-24A (collocated with MW-24) to determine what
geochemical and hydrogeological influence. are pre ent which may be impacting monitoring
data collected at these two wells and potentially other wells aero. the Mill ite. The MW-24A
study and report (EFRI, 2021c) included several additional field data collection and analytical
.activities based on the conclusions of other Mill reports including but not limited to:
• 2008. Background Groundwater Quality Report: New Wells for Denison Mines (USA)
Corp. 's Mill Site. April 30, 2008. Prepared by INTERA.
• 2012. Source Assessment Report White Mesa Uranium Mill. October 10, 2012. Prepared
by INTERA ("2012 SAR").
• 2012. pH Report White Mesa Uranium Mill. November 9, 2012. Prepared by Intera
("pH Report").
9
• 2012. Investigation of Pyrite in the Perched Zone White Mesa Uranium Mill. Prepared
by HGC ("Pyrite Report ).
• 2016. Source Assessment Report for MW-18 and MW-24 White Mesa Uranium Mill. June
24, 2016. Prepared by INTERA ("2016 SAR").
• 2019. Source Assessment Report for MW-11 and MW-24 White Mesa Uranium Mill. June
27, 2019. Prepared by INTERA ("2019 SAR")
The result of the analytical and test data collected during tbe MW-24A tudy demonstrated that
natural proce e unrelated to dispo al of materials in the TMS can account for the behavior of
all trace metaJ · of concern, as weU as fluoride in groundwater at MW-24 and MW-24A. Bottle-
roll test results indicated that naturally-occurring trace metal can be mobilized at concentrations
imilar to or greater than in groundwater even without a large pH decrea e, uggesting that
agitation alone, 'uch as would occur during routine purging and ·ampling of low penneability
well uch a MW-24A, could re ult in metal mobilization.
The perched groundwater y tern ho ted by the Burro Canyon Formation and Dakota Sandstone
does not approach teady tate over mu b of the monitored area. A large part of the site perched
water y tern i · in a transient state and affected by long-term chru1ge in water level due to past
and current activitie unrelated to the di 'PO al of materials to the TMS. Ba ed on the result of
the MW-24A tudy EFRI ha voluntarily agreed to implement a Phase 2 study to determine what
geochemical and hydrogeological influences are present that may be affecting monitoring data
collected at other wells acros the Mill site. Thi voluntary tudy will commence in mid to late
2022.
As a result of the planned additional . tudies EFRI received a deferment of the Background
Groundwater Quality Report for MW-24A required by the March 8, 2021 GWDP because the
Background Report for MW-24A i · premature at thi time. The deferment until will last until
after the completion of the additional tudie · discussed above.
Monitoring well MW-41 will be installed during the planned additional studies associated with
MW-24/MW-24A.
1.4 Documents Referenced in This Application
The following documents are referenced in this Application.
a) The following Permits, Licenses, Statement of Basis, Plans and Related Reports:
(i) State of Utah GWDP No. UGW370004 dated March 8, 2021 and previoll ver ions
of the Permit dated January 10, 2010, March 8, 2010, June 21, 2010, February 15,
2011, July 14, 2011, August 24, 2012 January 19, 2018, and Mrud1 19, 2019.
(ii) State of Utah License No. UT 1900479, Amendment 10 dated July 27, 2021;
(iii) Statement of Basis For a Uranium Milling Facility at White Mesa, South of
Blanding, Utah, Owned and Operated by International Uranium (USA)
10
Corporation, December 1, 2004, prepared by the State of Utah Division of
Radiation Control;
(iv) Statement of Basis Radioactive Materials License No. UT 1900479 and
Groundwater Discharge Permit No. UGW 370004, January 2018
(v) Final Statement of Basis and Groundwater Permit, UGW370004, January 2019
(vi) Modification of Groundwater Permit No UGW370004 Statement of Basis, March
2020
(vii) Reclamation Plan White Mesa Mill Blanding, Utah, Revision 5.1, February 8, 2018
(the "Reclamation Plan"); and
(i) UMETCO Minerals Corporation: White Mesa Mill Drainage Report for Submittal
to NRC, January 1990;
b) The following Background Groundwater Quality Reports and Related Studies:
(i) Revised Background Groundwater Quality Report: Existing Wells For Denison
Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, October 2007
(INTERA 2007a), prepared by INTERA, Inc.;
(ii) Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Ba kground Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah,
November 16, 2007 (INTERA 2007b), prepared by INTERA, Inc.;
(iii) Revised Addendum: --Background Groundwater Quality Report: New Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, April
30, 2008, prepared by INTERA, Inc.; and
(iv) Summary of work completed, data results, interpretations and recommendations
for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa
Uranium Mill Near Blanding Utah, May 2008, prepared by T. Grant Hurst and D.
Kip Solomon, Department of Geophysics, University of Utah;
(v) Background Groundwater Quality Report for Wells MW-20 and MW-22 for
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, June
1, 2010, prepared by INTERA, Inc. (the "MW-20 and MW-22 Background
Report");
(vi) Background Groundwater Quality Report for Monitoring Wells MW-35, MW-36
and MW-37 White Me a Mill Blanding, Utah, May 1, 2014 (INTERA 2014c)
prepru:ed by INTERA, Inc. (the 'MW-35, MW-36, and MW-37 Background
Report".
11
(vii) Background Groundwater Quality Report for Monitoring Wells MW-38, MW-39
and MW-40 White Mesa Mill Blanding, Utah June 7, 2021, prepared by INTERA,
Inc. (the "MW-38, MW-39, and MW-40 Background Report".
c) The following environmental reports and analyses:
(i) Environmental Report, White Mesa Uranium Project San Juan County, Utah,
January 30, 1978, prepared by Dames & Moore (the "1978 ER"); and
(ii) Final Environmental Statement related to operation of White Mesa Uranium
Project Energy Fuels Nuclear, Inc., May 1979, Docket No. 40-8681, prepared by
the United States Nuclear Regulatory Commission (the "FES");
d) The following engineering, geological and hydrogeological reports:
(i) Umetco Groundwater Study, White Mesa Facilitie , Blanding, Utah, 1993,
prepared by Umetco Minerals Corporation (the operator of the Mill at the time)
and Peel Environmental Services;
(ii) Hydrogeological Evaluation of White Mesa Uranium Mill, July 1994, prepared by
Titan Environmental Corporation (the "1994 Titan Report");
(iii) Evaluation of Potential for Tailings Cell Discharge -White Mesa Mill, November
23, 1998, prepared by Knight-Pie ·old LLC;
(iv) Investigation of Elevated chloroform concentrations in Perched Groundwater at
the White Mesa Uranium Mill Near Blanding, Utah, 2001, prepared by Hydro Geo
Chem, Inc.;
(v) Letter Report dated August 29, 2002, prepared by Hydro Geo Chem, Inc.;
(vi) Hydrogeology White Mesa Uranium Mill Site Near Blanding, Utah, June 6, 2012,
prepared by Hydro Geo Chem, Inc.;
e) The following plans and specifications relating to construction and operation of the
Mill's TMS:
(i) Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
(ii) Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by
D' Appolonia Consulting Engineers, Inc.;
12
(iii) Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia
Consulting Engineers, Inc.;
(iv) Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc. (the
operator of the Mill at the time);
(v) Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation (the operator of the Mill at the time);
(vi) Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by International Uranium (USA)
Corporation (the operator of the Mill at the time);
(vii) Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants;
(viii) Cell 4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah,
July 2008, prepared by Geosyntec consultants;
(ix) Cell 4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007,
prepared by Geosyntec Consultants; and
(x) Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants.
f) The following documents relating to the chloroform investigation at the site:
(i) Stipulation and Consent Order Docket Number UGW20-01-SCO September 14,
2015;
(ii) Groundwater Corre ·tive Action Plan ("GCAP") for the Energy Fuels Resources
(USA) Inc. Chloroform Plume at the White Mesa Uranium Recovery Facility Near
Blanding, Utah, September 14, 2015.
(iii) Corrective Action Comprehensive Monitoring Evaluation ("CACME") report for
chloroform in perched groundwater at the White Mesa Uranium Mill (the 'Mill")
located near Blanding, Utah, March 16, 2016, prepared by Hydro Geo Chem, Inc.;
(iv) Corrective Action Comprehensive Monitoring Evaluation ("CACME") report for
chloroform in perched groundwater at the White Mesa Uranium Mill (the "Mill")
located near Blanding, Utah, March 31, 2018, prepared by Hydro Geo Chem, Inc.;
13
(v) Corrective Action Comprehensive Monitoring Evaluation ("CACME") report for
chloroform in perched groundwater at the White Mesa Uranium Mill (the "Mill")
located near Blanding, Utah, March 31, 2020, prepared by Hydro Geo Chem, Inc.;
(vi) Corrective Action Comprehensive Monitoring Evaluation ("CACME") report for
chloroform in perched groundwater at the White Mesa Uranium Mill (the "Mill")
located near Blanding, Utah, March 31, 2022, prepared by Hydro Geo Chem, Inc.;
g) The following documents relating to the pH and other Out of Compliance
investigations at the site:
(i) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the First, Second, Third and Fourth Quarters of 2010 and First
Quarter 2011, June 13, 2011;
(ii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Second Quarter of 2011, September 7, 2011;
(iii) Plan and Time Schedule for Assessment of pH Under Groundwater Discharge
Permit UGW370004, April 13, 2012 (2012a) prepared by Hydro Geo Chem, Inc.;
(iv) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of 2012, December 13, 2012;
(v) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for
Constituents in the Fourth Quarter of 2012, March 15, 2013;
(vi) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the First Quarter of 2013, August 28, 2013;
(vii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the Second Quarter of 2013, September 20, 2013;
(viii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of 2013, December 5, 2013;
(ix) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of 2014, December 4, 2014;
14
(x)
(xi)
(xii)
(xiii)
(xiv)
(xv)
(xvi)
(xvii)
(xviii)
(xix)
(xx)
(xxi)
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the First Quarter of 2015, May 19, 2015;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Second Quarter of 2015, September 10, 2015;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of 2015, December 3, 2015;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the Fourth Quarter of 2015, March 3, 2016;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the Fourth Quarter of 2016, March 10, 2017;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Fourth Quarter of 2017, March 2, 2018;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Second Quarter of 2018, August 28, 2018;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of 2018, December 5, 2018;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part I.G.2 for
Constituents in the Fourth Quarter of 2018, February 21, 2019;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the First Quarter of 2019, May 13, 2019;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Fourth Quarter of 2019, February 27, 2020;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
15
(xxii)
(xxiii)
(xxiv)
(xxv)
(xxvi)
(xxvii)
(xxviii)
(xxix)
(xxx)
(xxxi)
(xxxii)
(xxxiii)
(xxxiv)
and Time Schedule Under part l.G.4 (d) for Violations of Part I.G.2 for
Constituents in the First Quarter of 2020, May 21, 2020;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Third Quarter of 2020, November 18, 2020;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Fourth Quarter of 2020, January 25, 2021;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part l.G.4 (d) for Violations of Part l.G.2 for
Constituents in the First Quarter of 2021, May 11, 2021;
White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part I.G.4 (d) for Violations of Part l.G.2 for
Constituents in the Second Quarter of 2021, August 25, 2021;
Source Assessment Report, White Mesa Uranium Mill, Blanding Utah, October
10, 2012 prepared by INTERA, Inc;
pH Report White Mesa Uranium Mill, Blanding Utah, November 9, 2012
prepared by INTERA, Inc;
Investigation of Pyrite in the Perched Zone, White Mesa Uranium Mill, Blanding
Utah, December 7, 2012 (HGC 2012c) prepared by Hydro Geo Chem, Inc.;
Source Assessment Report for TDS in MW-29, White Mesa Uranium Mill,
Blanding Utah, May 7, 2013 (INTERA 2013a) prepared by INTERA, Inc;
Source Assessment Report for Selenium in MW-31, White Mesa Uranium Mill,
Blanding Utah, August 30, 2013 (INTERA 2013b) prepared by INTERA, Inc;
Source Assessment Report for Tetrahydrofuran in MW-OJ, White Mesa Uranium
Mill, Blanding Utah, December 17, 2013 (INTERA 2013c); prepared by
INTERA, Inc.
Source Assessment Report for Gross Alpha in MW-32, White Mesa Uranium Mill,
Blanding Utah, January 13, 2014 (INTERA 2014a) prepared by INTERA, Inc;
Source Assessment Report for Sulfate in MW-OJ and TDS in MW-03A, White
Mesa Uranium Mill, Blanding Utah, March 19, 2014 (INTERA 2014b) prepared
by INTERA, Inc;
Source Assessment Report for Selenium, Sulfate, TDS and pH in MW-31, White
16
Mesa Uranium Mill, Blanding Utah, December 9, 2015 prepared by INTERA,
Inc;
(xxxv) Source Assessment Report for Sulfate in MW-18 and Fluoride, Cadmium
Thallium and pH in MW-24, White Mesa Uranium Mill, Blanding Utah, June 24,
2016 prepared by INTERA, Inc;
(xxxvi) Source Assessment Report for Selenium, Sulfate, and Uranium in MW-31, White
Mesa Uranium Mill, Blanding Utah, August 20, 2017 prepared by INTERA, Inc;
(xxxvii) Source Assessment Report for Fluoride in MW-14, White Mesa Uranium Mill,
Blanding Utah, June 25 , 2018 prepared by INTERA, Inc;
(xxxviii) Source Assessment Report for Uranium, Selenium and pH in MW-30, White Mesa
Uranium Mill, Blanding Utah, January 16, 2019 (INTERA 2019a) prepared by
INTERA, Inc;
(xxxix) Source Assessment Report for Manganese in MW-11, andfluoride, pH, cadmium,
beryllium, nickel, and thallium in MW-24 White Mesa Uranium Mill, Blanding
Utah,, June 27, 2019 (INTERA 2019b) prepared by INTERA, Inc;
(xl) Source Assessment Report for Cadmium in MW-25, White Mesa Uranium Mill,
Blanding Utah, September 23, 2019 (INTERA 2019c) prepared by INTERA, Inc;
(xii) Source Assessment Report for TDS and Sulfate, in MW-31, White Mesa Uranium
Mill, Blanding Utah, June 24, 2020 prepared by INTERA, Inc;
(xiii) Source Assessment Report for Selenium and Uranium in MW-28, White Mesa
Uranium Mill, Blanding Utah, October 19, 2020 prepared by EFRI;
(xliii) Source Assessment Report for Uranium in MW-31, White Mesa Uranium Mill,
Blanding Utah, April 29, 2021 (EFRI 2021a) prepared by EFRI;
(xliv) Source Assessment Report for Uranium in MW-29, White Mesa Uranium Mill,
Blanding Utah, September 7, 2021 (EFRI 2021b) prepared by EFRI;
(xlv) Source Assessment Report for Uranium and Selenium in MW-30, White Mesa
Uranium Mill, Blanding Utah, January 28, 2022 prepared by EFRI;
h) The following documents relating to the nitrate investigations at the site:
(i) Stipulated Consent Agreement Docket No. UGW12-03 between Denison Mines
(USA) Corp. and the Director of the Division of Radiation Control, July 12, 2012.
(ii) Revised Tolling Agreement, Revision 3, between DUSA and the Director,
Revision 2, dated August 21, 2011.
17
(iii) Revised Phase 1 (A through C) Work Plan and Schedule for Phase 1 A -C
Investigation, May 11, 2011, prepared by INTERA, Inc;
(iv) Revised Phase 2 through 5 Work Plan and Schedule, June 3, 2011, prepared by
INTERA, Inc;
(v) Revised Phase 2 QAP and Work Plan, Revision 2.0, July 12, 2011;
(vi) Nitrate Corrective Action Plan, May 7, 2012 (HGC 2012b), prepared by Hydro
Geo Chem, Inc.;
(vii) Nitrate Contamination investigation Report, December 30, 2009, prepared by
INTERA, Inc.;
(viii) Stipulation and Consent Order Docket No. UGW12-04 between DUSA and the
Director, December 12, 2012;
(ix) Nitrate CACME UDEQ Docket UGW12-04, December 11, 2017 prepared by
Hydro Geo Chem, Inc., Inc.; and
(x) Phase Ill Nitrate Corrective Action Planning Document and Recommended Phase
Ill Corrective Action Docket UGW12-04, White Mesa Mill, December 13, 2018
prepared by Hydro Geo Chem, Inc.
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
The Applicant and Mill Operator is Energy Fuels Resources (USA) Inc. EFRI is the current
holder of the Permit. The Mill is owned by EFRI' s affiliate, EFR White Mesa LLC
("EFRWM").
The address for both EFRI and EFRWM is:
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Telephone: [phone] Fax: [phone]
Contacts at EFRI, all located at the aforementioned office:
David C. Frydenlund
Chief Financial Officer, General Counsel and Corporate Secretary
Direct telephone: [phone]
[e-mail]
18
Scott Bakken
Vice President, Regulatory Affairs
Direct telephone: [phone]
[e-mail]
Kathy Weinel
Director, Regulatory Compliance
Direct telephone: [phone]
[e-mail]
2.2 Legal Location of the Facility (R317-6-6.3B)
The Mill is regionally located in central San Juan County, Utah, approximately 6 miles (9.5 km)
south of the city of Blanding. The Mill can be reached by taking a private road for
approximately 0.5 miles west of Utah State Highway 191. See Figure 1.
Within San Juan County, the Mill is located on fee land and mill site claims, covering
approximately 5,415 acres, encompassing all or part of Sections 21, 22, 27, 28, 29, 32, and 33 of
T37S, R22E, and Sections 4, 5, 6, 8, 9, and 16 of T38S, R22E, Salt Lake Base and Meridian
("SLBM"). See Figure 2.
All operations authorized by the Mill License are conducted within the existing site boundary.
The milling facility currently occupies approximately 50 acres, and the TMS encompass another
250 acres. See Figure 2.
2.3 Name and Type of Facility (R317-6-6.3.C)
The name of the facility is the White Mesa Uranium Mill. The facility is a uranium milling and
TMS facility, which operates under a Radioactive Materials License issued by the Director of the
DWMRC under UAC R313-24. The Mill produces uranium in the form of U30s from
conventional ores and alternate feed materials. Alternate feed materials are uranium bearing
materials other than conventionally mined ores. The Mill also produces vanadium, in the form
of vanadium pentoxide ("V20s"), ammonia metavanadate ("AMY") and vanadium pregnant
liquor ("VPL"), from certain conventional ores. The Mill has produced other metals from certain
alternate feed materials (specifically tantalum and niobium as authorized under NRC License
amendment 4, included as Attachment A). In addition, the Mill also processes uranium-bearing
natural ores for the production of uranium and a Rare Earth Element ("REE") carbonate.
Construction of the Mill was completed and first operations commenced in May 1980. The Mill
does not have a set operating life, and can operate indefinitely, subject to available TMS capacity
and license and permit renewals. EFRI has submitted a GWDP and RML amendment
application to construct, operate and (when operations are complete) reclaim proposed Cells 5A
and 5B. The amendment request is currently in progress by DWMRC. Upon completion of the
DWMRC review, the RML will be subject to a Public Comment period. The construction of
Cells 5A and 5B is an essential element of future operations at the Mill as their construction is
necessary in order to continue providing sufficient impoundment surface area for the evaporation
of Mill process water, and to provide additional tailings capacity which is necessary to
19
accommodate the tailings volume associated with routine processing operations. At this time,
EFRI does not anticipate the construction of Cells 5A and SB immediately upon the Director's
approval of the License and GWDP amendments; however, authorization is being sought in
advance to allow the Mill to respond to future needs. The conceptual and permitted total
capacity is for the quantity of Mill tailings produced from a 15-year operating period at a rate of
2,000 tons per day, operating 340 days per year. Since it commenced operations in 1980, the
Mill has operated on a campaign basis, processing conventional ores and alternate feed materials
as they become available and as economic conditions warrant.
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well, Drinking
Water Source Protection Zones, Topography, Springs, Water Bodies, Drainages, And Man-Made
Structures Within A One-Mile Radius Of The Discharge. (R317-6-6.3.D)
There are five deep wells within a one mile radius of the Mill, two of which supply the Mill
facility. There are no Drinking Water Source Protection Zones or ordinances within this radius.
Routine groundwater monitoring wells have been established for monitoring under the Permit.
These monitoring wells are depicted on Figure 10 and in Appendix B to this Application. The
depth and purpose of each of these wells is as shown in Tables 1.2-1, 1.2-2, and 2.4-1.
See Section 2. 9 .1.3 below for a detailed description of the Mill's groundwater monitoring
program.
The surface topography and man-made structures are shown on Figures presented in Appendix
B. See Sections 2.5.4 and 2.5.7 below for a more detailed discussion on local topography and
land use. In addition, see the biennial land use reports from 2018, 2020 and 2022 for details
regarding land use (EFRI 2018, 2020, 2022). The Mill area has several dry drainages, and the
only nearby natural water bodies within one mile are Westwater Creek, Corral Creek and
Cottonwood Creek. In addition to these are Ruin Spring and several other springs and seeps
located within a 1.5 mile radius of the Mill. See Sections 2.5.3 and 2.13 below for discussions
relating to seeps and springs in the vicinity of the site and to surface water and drainages,
respectively.
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317-6-6.3.E)
2.5.1 Groundwater Characteristics
This Section is based primarily on the Report entitled: Hydrogeology of the White Mesa
Uranium Mill, Blanding Utah July 13, 2022, prepared by Hydro Geo Chem, Inc. ("HGC") (the
"2022 HGC Report" referred to as HGC, 2022). Other reports are referenced as needed.
2.5.1.1 Geologic Setting
The Mill is located within the Blanding Basin of the Colorado Plateau physiographic province.
Typical of large portions of the Colorado Plateau province, the rocks underlying the site are
relatively undeformed. The average elevation of the site is approximately 5,600 ft (1,707 m)
above mean sea level ("amsl").
The site is underlain by unconsolidated alluvium and indurated sedimentary rocks consisting
primarily of sandstone and shale. The indurated rocks are relatively flat lying with dips generally
20
less than 3°. The alluvial materials consist mostly of aeolian silts and fine-grained aeolian sands
with a thickness varying from negligible to as much as 25 to 30 feet across the site. In some
portions of the site the alluvium is underlain by a few feet to as much as 30 feet of Mancos
Shale. In other areas, the Mancos Shale is absent. The alluvium and Mancos (where present) are
underlain by the Dakota Sandstone and Burro Canyon Formation, which are sandstones having a
combined total thickness ranging from approximately 55 to 140 feet (17 to 43 m). Beneath the
Burro Canyon Formation lies the Morrison Formation, consisting, in descending order, of the
Brushy Basin Member, the Westwater Canyon Member, the Recapture Member, and the Salt
Wash Member. The Brushy Basin and Recapture Members of the Morrison Formation, classified
as shales, are very fine-grained and have a very low permeability. The Brushy Basin Member is
primarily composed of bentonitic mudstone, siltstone, and claystone. The Westwater Canyon and
Salt Wash Members are primarily sandstones but are expected to have a low average vertical
permeability due to the presence of interbedded shales. See Figure 3 for a generalized
stratigraphic column for the region.
Beneath the Morrison Formation lies the Summerville Formation, an argillaceous sandstone with
interbedded shales, and the Entrada Sandstone. Beneath the Entrada lies the Navajo Sandstone.
The Navajo and Entrada Sandstones constitute the primary aquifer in the area of the site. The
Entrada and Navajo Sandstones are separated from the Burro Canyon Formation by
approximately 1,000 to 1,100 feet (305 to 335 m) of materials having a low average vertical
permeability. Groundwater within this system is under artesian pressure in the vicinity of the site,
is of generally good quality, and is used as a secondary source of water at the site.
2.5.1.2 Hydrogeologic Setting
The site is located within a region that has a dry to arid continental climate, with average annual
precipitation of approximately 13.3 inches, and an average annual lake evaporation rate of
approximately 47.6 inches. Recharge to the principal aquifers (such as the Navajo/Entrada)
occurs primarily along the mountain fronts (for example, the Henry, Abaja, and La Sal
Mountains), and along the flanks of folds such as Comb Ridge Monocline.
Although the water quality and productivity of the Navajo/Entrada aquifer are generally good,
the depth of the aquifer (approximately 1,200 feet below land surface [ft bls]) makes access
difficult. The Navajo/Entrada aquifer is capable of yielding significant quantities of water to
wells (hundreds of gallons per minute [gpm]). Water in on-site wells completed within the
Navajo/Entrada rises approximately 800 feet above the base of the overlying Summerville
Formation.
The shallowest groundwater beneath the site consists of perched water hosted primarily by the
Burro Canyon Formation. Perched water is used on a limited basis to the north (upgradient) of
the site because it is much shallower and more easily accessible than the deep Navajo/Entrada
aquifer.
2.5.1.3 Perched Zone Hydrogeology
Perched groundwater originates mainly from precipitation and local recharge sources such as
unlined reservoirs (Kirby, 2008) and is supported within the Burro Canyon Formation by the
underlying, fine-grained Brushy Basin Member. Perched groundwater at the site is generally of
21
poor quality due to high TDS in the range of approximately 1,100 to 7,900 mg/L. Its relatively
poor quality is one reason that perched water is used primarily for stock watering and irrigation
in areas upgradient (north) of the site. Figure 4 is a contour map showing the approximate
elevation of the contact of the Burro Canyon Formation with the Brushy Basin Member, which
essentially forms the base of the perched water zone at the site. Based on Figure 4, the Burro
Canyon Formation/Brushy Basin Member contact generally dips to the south/southwest beneath
the site.
Figure 5 is a perched groundwater elevation contour map for the fourth quarter, 2021. Based on
the contoured water levels, groundwater within the perched zone flows generally south to
southwest beneath the site. Beneath the TMS, perched groundwater flow is generally to the
southwest.
Perched groundwater discharges from outcrops of the Burro Canyon Formation in seeps and
springs along Westwater Creek Canyon and Cottonwood Canyon (to the west-southwest of the
mill site and TMS) and along Corral Canyon (to the east and northeast of the mill site and TMS).
Known discharge points include the seeps and springs shown in Figure 5 except Cottonwood
Seep. As discussed in (HGC, 2014; 2018a; and 2022), Cottonwood Seep is located more than
1,500 feet west of White Mesa in an area where the Dakota Sandstone and Burro Canyon
Formation (which hosts the perched water system) are absent due to erosion, and at an elevation
approximately 230 feet below the base of the perched zone defined by the contact between the
Burro Canyon Formation and the underlying Brushy Basin Member. Cottonwood Seep occurs
near the contact between the slope-forming Brushy Basin Member and the underlying Westwater
Canyon (sandstone) Member.
Contact elevations shown in Figure 4 are based on perched monitoring well drilling and
geophysical logs and surveyed land surface elevations, and the surveyed elevations of Westwater
Seep and Ruin Spring. The elevations of Westwater Seep and Ruin Spring are included in the
kriged contours because they occur at the contact between the Burro Canyon Formation and the
underlying Brushy Basin Member.
Groundwater elevations shown in Figure 5 include the surveyed elevations of all seeps and
springs except Cottonwood Seep. As discussed above, no evidence exists to connect Cottonwood
Seep to the perched water system. Although Cottonwood Seep may potentially receive some
contribution from perched water, its occurrence near the contact between the Brushy Basin
Member and the underlying Westwater Canyon Member indicates that its elevation is not
representative of the perched water system.
The permeabilities of the Dakota Sandstone and Burro Canyon Formation at the site are
generally low. No significant joints or fractures within the Dakota Sandstone or Burro Canyon
Formation have been documented in any wells or borings installed across the site (Knight
Piesold, 1998). Any fractures observed in cores collected from site borings are typically
cemented, showing no open space.
Porosities and water contents of the Dakota Sandstone have been measured in samples collected
during installation of former well MW-16 and well MW-17 (Figure 5). MW-16 was located
immediately downgradient of TMS Cell 3 (beneath Cell 4B); and MW-17 is located south of
22
TMS Cell 4A at a location primarily cross-gradient with respect to perched water flow.
Porosities of the Dakota Sandstone range from 13.4% to 26%, averaging 20%, and water
saturations range from 3.7% to 27.2%, averaging 13.5%. The average volumetric water content
is approximately 3%. The hydraulic conductivity of the Dakota Sandstone based on packer tests
in borings installed at the site prior to 1994 ranges from 2. 71 x 1 o-6 centimeters per second
("crn/s") to 9.12 x 10-4 crn/s, with a geometric average of 3.89 x 10-5 emfs (TIT AN, 1994).
The average porosity of the Burro Canyon Formation is similar to that of the Dakota Sandstone.
Based on samples collected from the Burro Canyon Formation at former well MW-16 porosity
ranges from 2% to 29.1 %, averaging 18.3%, and water saturations of unsaturated materials range
from 0.6% to 77.2%, averaging 23.4% (TITAN, 1994). These porosities are similar to those
reported by MWH (MWH, 2010) for archived samples from borings MW-23 and MW-30.
Extensive hydrogeologic characterization of the saturated Burro Canyon Formation has occurred
through hydraulic testing of perched monitoring wells and borings at the site. Hydraulic testing
of MW-series wells located upgradient, cross-gradient, downgradient, and within the millsite and
TMS, TW4-series wells located cross-gradient to upgradient of the millsite and TMS, TWN-
series wells located primarily upgradient of the millsite and TMS, and DR-series piezometers,
located downgradient of the TMS, indicate that the hydraulic conductivity of the perched zone
ranges from approximately 2 x 10-8 to 0.01 crn/s.
TIT AN (1994 ), reported that the hydraulic conductivity of the Burro Canyon Formation ranges
from 1.9 x 10-7 to 1.6 x 10 -3 emfs, with a geometric mean of 1.01 x 10-5 emfs, based on the
results of 12 pumping/recovery tests performed in monitoring wells and 30 packer tests
performed in borings prior to 1994. The range reported by TITAN (1994) is within the hydraulic
conductivity range of approximately 2 x 10-8 to 0.01 emfs reported by HGC (HGC, 2014; 2018a;
and 2022).
In general the highest permeabilities and well yields are in the area of the site immediately
northeast and east (upgradient to cross gradient) of the TMS. A relatively continuous, higher
permeability zone (associated with poorly indurated coarser-grained materials in the general area
of the chloroform plume) has been inferred to exist in this portion of the site. Analysis of
drawdown data collected from this zone during long-term pumping of MW-4, MW-26
(TW 4-15), and TW 4-19 (Figure 5) yielded estimates of hydraulic conductivity ranging from
approximately 4 x 10-5 to 1 x 10-3 emfs (HGC, 2014; 2018a; and 2022). The decrease in perched
zone permeability south to southwest of this area (south of TW4-4), based on tests at TW4-6,
TW4-26, TW4-27, TW4-29 through TW4-31, and TW4-33 and TW4-34, indicates that this
higher permeability zone "pinches out".
Relatively high conductivities measured at MW-11, located on the southeastern margin of the
downgradient edge of TMS Cell 3, and at MW-14, located on the downgradient edge of TMS
Cell 4A, of 1.4 x 10-3 crn/s and 7.5 x 10-4 crn/s, respectively, may indicate that this higher
permeability zone extends beneath the southeastern portion of the TMS. However, based on
hydraulic tests south and southwest of these wells, this zone of higher permeability does not
appear to exist within the saturated zone downgradient (south-southwest) of the TMS.
Furthermore, as discussed in HGC (2018b), although the hydraulic conductivity is relatively high
23
at both MW-11 and MW-14, the higher permeability materials penetrated by these wells do not
appear to connect.
Slug tests performed at groups of wells and piezometers located northeast (upgradient) of, in the
immediate vicinity of, and southwest (downgradient) of the TMS indicate generally lower
permeabilities compared with the area of the chloroform plume. The following results are based
on analysis of automatically logged slug test data using the KGS solution available in
AQTESOL V (HydroSOL VE, 2000).
Te ting of TWN-edes wells instaUed in the northeast portio11 of the site a part of nitrate
inve tigation activitie yielded a hydraulic conductivity range of approximately 3.6 x 10-7 to 0.01
cm/ with a geometric average f approximately 6 x I 0-5 cm/s. lnclL1ding more recently in talled
well TWN-20 and TWN-21 (HGC, 2021) yields a geometric average hydraulic conductivity of
approximately 5 x 10-5 cm/s. The value of 0.01 cm/s estimated for TWN-16 is the highest
mea, med at the site, and the value of 3.6 x 10-7 cm/s estimated for TWN-7 is one of the lowest
measured at the site.
Testing of MW-series wells MW-23 through MW-32 installed between and at the margins of the
TMS in 2005 (and using the higher estimate for MW-23) yielded a hydraulic conductivity range
of approximately 2 x 10-7 to 1 x 10-4 cm/ with a geometric average of approximately 2 x 10-
cm/s. The geometric average hydraulic conductivity of all te ted MW-erie well · (including far
up-gradient; far cross-gradient; and far downgradient well ; and u ing the higher e timate for
MW-23) is less than 3 x 10-5 cm/s.
Hydraulic test conducted at DR-erie piezometers installed as part of the southwest area
investigation dowogradient of the TMS yielded hydraurc conductivitie ranging from
approximately 2 x 10·8 to 4 x 104 cm/ with a geometric average of 9.6 x 10-6 cm/·. The low
permeabilitie and shallow hydralllic gradi nts downgradjent of the TMS result in average
perched groundwater pore velocity e timate that are among the lowest on site (approximately
0.26 feet per year (ft/yr) to 0.91 ft/yr).
The extensive hydraulic testing of perched zone wells at the site indicates that perched zone
permeabilitie are generally Jow with the exception of the apparently relatively isolated zone of
higher permeability a s ciated with the chloroform plume ea t to norlhea t (cro -gradient to
upgradie1 t) of the TMS (Figure 5). The geometric average hydraulic conductivity
(approximately 1 x 10-5 cm/ ) of the DR-eries piezometer · which cover an area nearly half the
size of the total monitored area at White Mesa (excluding MW-22), is nearly identical to the
geometric average hydraulic conductivity of 1.01 x 10-cm/ reported by TITAN (1994), and is
within the range of 5 to 10 feet per year (ft/yr) [approximately 5 x 10-6 emfs to 1 x 10-5 cm/ ]
reported by Dames and Moore (1978) [the 1978 ER] for tbe ( aturated) perched zone during the
initial site investigation.
Becau e of the generally low permeability of the perched zone beneath the site, well yield me
typically low (les than 0.5 gpm), although su tainable yields of as much as 4 gpm (for example,
at TW4-19 hown in Figure 5) have been (at least temporarily) possible in wells intercepting the
relatively large saturated thicknesses within the higher pe1111eability zone located east to
northeast (cross-gradient to upgradient) of the TMS at the ite. However, even site wells that
24
yielded as much as 4 gpm during the first few months of pumping eventually saw yields drop to
about 1 gpm or less. As of the fourth quarter of 2021, total sustainable pumping from the 16
wells comprising the chloroform and nitrate pumping systems was just under 6 gpm.
Sufficient productivity from the perched zone can generally be obtained only in areas where the
saturated thickness is greater, which is one reason that 1) some perched zone wells completed
near the northern wildlife ponds are relatively productive and 2) the perched zone has been used
on a limited basis as a water supply to the north (upgradient) of the site. Due to the continuing
decay of the perched groundwater mounds associated with former wildlife pond usage, and
consequent reductions in saturated thicknesses, productivities of on-site wells are expected to
continue to decline.
2.5.1.4 Perched Groundwater Flow
Perched groundwater flow at the site has historically been to the south/southwest. Figure 5
groundwater elevations indicate that beneath and south of the TMS, in the west central portion of
the site, perched water flow is south-southwest to southwest. Flow on the western margin of
White Mesa is generally south, approximately parallel to the mesa rim (where the Burro Canyon
Formation [and perched zone] is terminated by erosion). On the eastern side of the site, perched
water flow is also generally southerly. Near the formerly used northern wildlife ponds, flow
direction ranges locally from southwesterly (west of the ponds) to southeasterly (east of the
ponds). A residual groundwater mound associated with well TWN-3 (located west of the
northern wildlife pond) likely results from low permeability and possibly enhanced recharge in
the vicinity due to graded areas of the Mill site having relatively flat topography and relatively
slow runoff. Although the water level at TWN-3 remains relatively elevated, the formerly
elevated water level at TWN-2 has declined due to pumping.
Cones of depression result from pumping of chloroform wells MW-4, MW-26, TW4-1, TW4-2,
TW4-4, TW4-ll, TW4-19, TW4-21, TW4-37, TW4-39, TW4-40 and TW4-41; and nitrate wells
TWN-02, TW4-22, TW4-24, and TW4-25 (Figure 10). These wells are pumped to reduce
chloroform and nitrate mass in the perched zone east and northeast of the TMS. The cones of
depression resulting from pumping of these wells are evident in the water level contours shown
on Figure 5.
In general, perched groundwater elevations have not changed significantly at most of the site
monitoring wells since installation, except in the vicinity of the wildlife ponds and the pumping
wells. For example, relatively large increases in water levels occurred between 1994 and 2002 at
MW-4 and MW-19, located in the east and northeast portions of the site, respectively. These
water level increases in the northeastern and eastern portions of the site were the result of
seepage from formerly used wildlife ponds located near piezometers PIEZ-1 through PIEZ-5
shown in Figure 5, which were installed in 2001 for the purpose of investigating these changes.
The mounding associated with the formerly used wildlife ponds and the resulting general
increase in water levels in the northeastern portion of the site caused local steepening of
groundwater gradients over portions of the site. Conversely, pumping of chloroform wells MW-
4, MW-26, TW4-1, TW4-2, TW4-4, TW4-ll, TW4-19, TW4-21, TW4-37, TW4-39, TW4-40
and TW4-41; and nitrate wells TWN-02, TW4-22, TW4-24, and TW4-25; has depressed the
perched water table locally and reduced average hydraulic gradients to the south and southwest
25
of these wells. In addition, at the request of DWMRC, water has not been delivered to the
northern wildlife ponds since March, 2012. The perched water mound associated with recharge
from the formerly used ponds is diminishing and is expected to continue to diminish, thereby
reducing saturated thicknesses, as well as hydraulic gradients downgradient of the ponds, in
particular to the south and southwest.
As discussed above, perched water discharges in springs and seeps along Westwater Creek
Canyon and Cottonwood Canyon to the west-southwest of the site, and along Corral Canyon to
the east of the site. The known discharge points located directly downgradient of the TMS are
Westwater Seep and Ruin Spring. These features are located more than 2,000 feet west-
southwest and more than 9,000 feet south-southwest of the TMS as shown in Figure 5.
DR-8, located approximately 4,000 feet southwest of the TMS, is located near the mesa rim
above Cottonwood Seep along a line between the TMS and Cottonwood Seep. There is no
evidence to connect Cottonwood Seep to the perched water system as it is separated from the
perched water by approximately 230 feet of low permeability shale and mud tone . However
under hypothetical condition ' that Cottonwood Seep receives ome contribution from perched
water perched water passing beneath the TMS would pre umably pac;s by DR-8 before
continuing on an unidentified potential pathway toward Cottonwood Seep ('potential path'
shown in Figure 5).
Figure 5 shows perched water pathlines southwest of the TMS based on fourth quarter, 2021
perched water level data. Paths 1 and 3 repre ent the shortest pathlines to di ·charge point.
Westwater Seep and Ruin Spring, respectively. Path 2 i the shorte 't pathline to DR-8, located
near the edge of the mesa above Cottonwood Seep. A · noted above, a potential pathJjne i drawn
from DR-8 to Cottonwood Seep. Although there is no evidence to connect Cottonwood Seep to
the perched water system, this potential pathline is represented to allow for the possibility of an
as yet unidentified connection. Westwater Seep is downgradient of TMS Cell 1 and the western
po1tions of Cells 2, 3, and 4B. DR-8 is downgradient of TMS Cells 2, 3 and 4B. Ruin Spring is
downgradient of Cell 4A, and the eastern portions of Cells 2, 3, and 4B.
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient Of The TMS
The perched zone hydrogeology southwest ( downgradient) of the TMS is imilar to other areas
of the site except that the saturated thicknesse:s are generally smaller, portions of the perched
zone are dry, and hydraulic gradients and hydraulic conductivities are relatively low. The
combination of shallow hydraulic gradients, relatively low permeabilities, and small saturated
thicknesses, results in rates of perched water movement that are among the lowest on-site.
In the immediate vicinity of the TMS, perched water was encountered at depths of approximately
58 to 114 ft below the top of casing ("btoc") as of the fourth quarter of 2021 (Figure 7). Beneath
TMS Cell 3, depth, to water ranged from approximately 69 feet btoc near the northea t
(upgradient) corner of the ceJI to approximately L 14 feet btoc at the southwest (down gradient)
corner of the cell. Assuming an average depth of the ba e of TMS Cell 3 of 25 feet below grade
this corresponds to perched water depths of approximately 44 to 89 feet below the base of the
cell; the average depth to water is approximately 67 feet beneath the base of the cell.
26
Beneath TMS Cells 4A and 4B, depths to water ranged from approximately 81 feet btoc near the
northeast (upgradient) corner of Cell 4A to approximately 114 feet btoc along the western
margin of Cell 4B. Assuming an average depth of the base of TMS Cells 4A and 4B of 25 feet
below grade, this corresponds to perched water depths of approximately 56 to 89 feet below the
base of the cells; the average depth to water is approximately 79 feet beneath the base of the
cells.
The saturated thickness of the perched zone in the immediate vicinity of the TMS as of the fourth
quarter of 2021 ranges from approximately 74 feet to negligible (Figure 8). Beneath TMS Cell 3,
the saturated thickness varies from approximately 58 feet in the eastern portion of the cell to
approximately 8 feet in the western portion of the cell. Beneath TMS Cells 4A and 4B, the
saturated thickness varies from approximately 47 feet along the north dike of Cell 4A to
negligible in the southwestern portion of Cell 4B, where a dry zone, defined by MW-33 and
former (historically dry) well MW-16, is present.
Saturated thicknesses in the southwest area of the site are affected by the ridge-like high in the
Burro Canyon Formation/Brushy Basin Member contact (see Figure 4). As shown in Figures 5
and 8, dry to low saturated thickness conditions are associated with this paleoridge.
South-southwest of the TMS, the saturated thickness ranges from negligible at MW-21
(historically dry) to approximately 25 feet at DR-9. Small saturated thicknesses (less than or
about equal to 3 feet) near DR-6, DR-7, and DR-10 (west and southwest of Cell 4B) result from
the paleoridge. The average saturated thickness based on measurements at MW-37, DR-13, MW-
3, MW-20, and DR-21, which lay close to a line between the southeast portion of TMS Cell 4B
and Ruin Spring, is approximately 11 feet. The average saturated thickness based on
measurements at MW-35, DR-7, and DR-6, which are the points closest to a line between the
southeast portion of TMS Cell 3 and Westwater Seep, is approximately 6 feet.
Perched zone hydraulic gradients currently range from a maximum of approximately 0.098 feet
per foot (ft/ft) east of Cell 2 (within and in the vicinity of the chloroform plume, between TW4-2
and TW4-3) to approximately 0.0021 ft/ft in the northeast corner of the site (between TWN-19
and TWN-16). Hydraulic gradients in the southwest portion of the site are typically close to 0.01
ft/ft, but the gradient is less than 0.005 ft/ft west/southwest of TMS Cell 4B, between Cell 4B
and DR-8. The overall average site hydraulic gradient, between TWN-19 in the extreme
northeast to Ruin Spring in the extreme southwest, is approximately 0.011 ft/ft. The hydraulic
gradient between the west dike of TMS Cell 3 and Westwater Seep is approximately 0.0136 ft/ft,
and between the south dike of TMS Cell 4B and Ruin Spring, approximately 0.0116 ft/ft
2.5.2 Groundwater Quality
2.5.2.1 Entrada/Navajo Aquifer
The Entrada and Navajo Sandstones are prolific aquifers beneath and in the vicinity of the site.
Water supply wells at the site are screened in both of these units, and therefore, for the purposes
of this discussion, they will be treated as a single aquifer. Water in the Entrada/Navajo Aquifer
is under artesian pressure, rising 800 to 900 ft above the top of the Entrada's contact with the
overlying Summervillle Formation; static water levels are 390 to 500 ft below ground surface.
27
Within the region, this aquifer is capable of yielding domestic quality water at rat of 150 to 225
gpm, and for that reason, it serves as a secondary source of water for the Mill. Additionally, two
domestic water supply wells drawing from the Entrada/Navajo Aquifer are located 4.5 miles
southeast of the Mill site on the Ute Mountain Ute Reservation. Although the water quality and
productivity of the Navajo/Entrada aquifer are generally good, the depth of the aquifer (>1,000 ft
bls) makes access difficult.
Table 2.5.2.1-1 i a tabulation of groundwater quality of the Navajo Sand tone aqu ifer a
reported in the FES and sub equeat ampling. TDS range from 244 to 1, J 10 mg/liter in three
ample taken over a period from January 27, 1977, to May 4 1977. High iron (0.057 mg/liter)
concenn·atjons are found in the Navajo Sandstone. Because the Navajo Sandstone aquifer is
isolated from the perched groundwater zone by approximately 1,000 to 1,100 ft of materials
having a Jow average vertical permeability, . ampling of the Navajo Sandstone is not required
un der the Mill's previou NRC Po.int of Compliance monitoring program or under the Permit.
However, samples were taken at two other deep aquifer wells (#2 and #5) on site (See Figure 9
for the locations of these wells), on June 1, 1999 and June 8, 1999, respectively, and the results
are included in Table 2.5.2.1-1.
2.5.2.2 Perched Groundwater Zone
Perched groundwater in the Dakota/Burro Canyon Formation is u ed on a limited basis to the
north (upgradient) of the ite becau e it is more easily acces ible. The quality of the Burro
Canyon perched water beneath and downgrad.ient from the ite i poor and extremely variable.
The concentrations of TDS measured in water sampled from upgradient and downgradjent well
range between approximately 1. l 00 to 7 900 mg/L. Sulfate concentrations measured in three
upgradient well. varied between 670 and 1,740 mg/1 (Titan, 1994). The perched groundwater
therefore i u ed primarily for stock watering and irrigation. The aturated thiclcne of the
perched water zone generally increase to the north of the site. See Section 2.11.2 below for a
more detailed discussion of background ground water quality in the perched zone.
2.5.3 Springs and Seeps
As discussed in Section 2.5.1.4, perched groundwater at the Mill site discharges in springs and
seeps along Westwater Creek Canyon and C ttonwood Canyon to the west-southwest of Lhe ite,
and along Corral Canyon to the east of the site where the Burro Canyon Formation outcrop ·.
Water samples have been collected and analyzed from ~-prings and seep in the Mill. vicinjty a
part of the baseline field investigations reported in the 1978 ER (See Table 2.6-6 in the I 978
ER).
During the period 2003-2004, EFRI implemented a sampling program for seeps and springs in
the vicinity of the Mill which had been sampled in 1978, prior to the Mill's construction. Four
locations were designated for sampling, as shown on Figure 9. These are Ruin Spring (G3R),
Cottonwood Seep (G4R), west of Westwater Creek (G5R) and Corral Canyon (GlR). During
the 2-year study period only two of the four locations could be sampled, Ruin Spring and
Cottonwood Canyon. The other two locations, Corral Creek and the location west of Westwater
Creek were not flowing (seeping), and samples could not be collected. With regard to the
28
Cottonwood seep, while water was present, the volume was not sufficient to complete all
determinations, and only organic analyses were conducted. Analysis of the Cottonwood Seep
water samples did not detect any organics.
Samples at Ruin Spring were analyzed for major ions, physical properties, metals, radionuclides,
volatile and semi-volatile organic compounds, herbicides and pesticides, and synthetic organic
compounds. With the exception of one chloromethane detection, all organic determinations were
at less than detectable concentrations. The detection of chloromethane is not uncommon in
groundwater and can be due to natural sources. The results of sampling for the other parameters
tested are shown in Table 2.5.3-1. The results of the 2003/2004 sampling did not indicate the
presence of mill derived groundwater constituents and are representative of background
conditions.
As required by Part I.E.6 of the Permit, the Mill has implemented a Sampling Plan for Seeps and
Springs. Per Part I.E.6 of the Permit, sampling of seeps and springs in required annually. A copy
of the currently approved Sampling Plan for Seeps and Springs Revision 3, dated November 11,
2019, is included as Appendix C to this Application. A summary of sampling results from the
2009 through 2022 sampling events, performed under the approved Sampling Plans for Seeps
and Springs, is provided in Table 2.5.3-2 through Table 2.5.3-5.
2.5.4 Topography
The Mill site is located on a gently sloping mesa that, from the air, appears similar to a
peninsula, as it is surrounded by steep canyons and washes and is connected to the Abajo
Mountains to the north by a narrow neck of land. On the mesa, the topography is relatively flat,
sloping at less than one (1) percent to the south and nearly horizontal from east to west. See also
Figure 6.
2.5.5 Soils
The majority (99%) of the soil at the Mill site consists of the Blanding soil series (1978 ER,
Section 2.10.1.1 ). The remaining 1 % of the site is in the Mellenthin soil series. Because the
Mellenthin soil occurs only on the eastern-central edge of the site (1978 ER, Plate 2.10-1), the
FES (Section 2.8) concluded that it should not be affected by Mill construction and operation.
The Mill and TMS are located on Blanding silt loam, a deep soil formed from wind-blown
deposits of fine sands and silts. Although soil textures are predominantly silt loam, silty-clay-
loam textures are found at some point in most profiles (See Appendix D to this Application -
Results of Soil Analysis at Mill Site). This soil generally has a 4 to 5 inch reddish-brown, silt-
loam A horizon and a reddish-brown, silt-loam to silty-clay-loam B horizon. The B horizon
extends downward about 12 to 16 inches where the soil then becomes calcareous silt-loam or
silty-clay-loam, signifying the C horizon. The C horizon and the underlying parent material are
also reddish-brown in color.
The A and B horizon both are non-calcareous with an average pH of about 8.0, whereas the C
horizon is calcareous with an average pH of about 8.5. Subsoil sodium levels range up to 12% in
some areas, which is close to the upper limit of acceptability for use in reclamation work (1978
29
ER, Sect. 2.10.1.1). Other elements, such as boron and selenium, are well below potentially
hazardous levels. Potassium and phosphorus values are high in this soil (1978 ER, Table 2.10-2)
and are generally adequate for plant growth. Nitrogen, however, is low (1978 ER, Sect. 2.10.1.1)
and may have to be provided for successful revegetation during final reclamation.
With well-drained soils, relatively flat topography (see Section 2.5.4), and limited annual
precipitation (see Section 2.5.1.2), the site generally has a low potential for water erosion.
However, the flows resulting from thunderstorm activity are nearly instantaneous and, without
the Mill's design controls, could result in substantial erosion. When these soils are barren, they
are considered to have a high potential for wind erosion. Although the soil is suitable for crops,
the low percentage of available moisture (6 to 9%) is a limiting factor for plant growth;
therefore, light irrigation may be required to establish native vegetation during reclamation.
2.5.6 Bedrock
Subsurface conditions at the Mill site area were investigated as part of the 1978 ER by drilling,
sampling, and logging a total of 28 borings which ranged in depth from 6.5 to 132.4 ft. Of these
borings, 23 were augured to bedrock to enable soil sampling and estimation of the thickness of
the soil cover. The remaining 5 borings were drilled through bedrock to below the perched water
table, with continuous in situ permeability testing where possible and selective coring in
bedrock. The soils encountered in the borings were classified, and a complete log for each
boring was maintained. See Appendix A of Appendix H of the 1978 ER.
Borings in the footprint of the existing TMS reported calcareous, red-brown sands and silts from
the surface to a depth of 15 ft, averaging over 7 ft. Borings in the general area of the Mill site and
the TMS reported calcareous, red-brown sands and silts from the surface to a depth of 14 ft,
averaging over 9 ft. Downgradient of the TMS, calcareous sands and silts extend to a depth of
17 ft of the surface. The calcareous silts and sands of the near-surface soils grade to weathered
claystones or weathered sandstones, inter-layered with weathered claystone and iron staining. At
depth, the weathered claystone or weathered clayey sandstone grade into sandstone with inter-
layered bands of claystone, gravel, and conglomerate. Some conglomerates are cemented with a
calcareous matrix.
2.5.7 Agricultural and Land Use Description of the Area
Approximately 60% of San Juan County is federally owned land administered by the U.S.
Bureau of Land Management (41%), the National Park Service (10%), and the U.S. Forest
Service (9% ). Primary land uses include livestock grazing, wildlife range, recreation, and
exploration for minerals, oil, and gas. Approximately 23% of the county is Native American
land owned either by the Navajo Nation or the Ute Mountain Ute Tribe. Approximately 8% of
the county is state-owned land, 8% privately-owned land and 1 % Indian Trust land. The area
within 5 miles of the Mill site is predominantly range land owned by residents of Blanding. The
Mill site itself, including TMS, encompasses approximately 300 acres.
A more detailed discussion of land use at the Mill site, in surrounding areas, and in southeastern
Utah, is presented in the FES (Section 2.5). Results of archeological studies conducted at the site
and in the surrounding areas as part of the 1978 ER are also documented in the FES (Section
2.5.2.3).
30
2.5.8 Well Logs
Well/boring logs for wells MW-1 (general monitoring well), MW-2, MW-3, MW-4 (not a
compliance well under the Permit), MW-5 MVv-11, MW-12, MW-14, MW-15, MW-16 (not a
compliance well under the Pe1mit and abandoned during the con truction of Tailing Ce!J 4B),
MW-17, MW-18 (general. monitoring well) and MW-19 (general monitoring welJ), are included
as Appendix A to the 1994 Titan Report. A copy of the 1994 Titan Report was previou ly
submitted under separate cover.
Lithologic and core logs for wells MW-3A, MW-23, MW-24, MW-25, MW-27, MW-28, MW-
29, MW-30 and MW-31 are included as Appendix A to the Report: Perched Monitoring Well
Installation and Testing at the White Mesa Uranium Mill April Through June 2005, August 3,
2005, prepared by Hydro Geo Chem, Inc. A copy of that Report was previously submitted under
separate cover.
Lithologic and core logs for well MW-26 (previously named TW4-15) and well MW-32
(previously named TW4-17) are included a Appendix A to the Letter Report dated August 29,
2002, prepared by Hydro Geo Chern, Inc. and addressed to Harold Roberts.
Lithologic and core logs for well MW-33, MW-34 and well MW-35 are included a Appendix A
to the Installation and Hydraulic Testing of Perched Monitoring Wells MW-33, MW-34 and
MW-35 at the White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chem,
Inc. October 11, 2010. A copy of that Rep01t was previously submitted under separate cover.
Lithologic and core logs for well MW-36 and weU MW-37 are included a Appendix A to the
Installation and Hydraulic Testing of Perched Monitoring Wells MW-36 and MW-37 at the
White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chem, In c. June 28,
2011. A copy of that Report was previously submitted under separate cover.
Lithologic and core logs for well MW-38 MW-39 and well MW-40 are included as Appendix A
to the Installation and Hydraulic Testing of Perched Monitoring Wells MW-38, MW-39 and MW-
40 at the White Mesa Uranium Mill Near Blandin Utah, prepared by Hydro Geo Chem, Inc.
June 12, 2018. A copy of that Report was previously submitted under separate cover.
The Lithologic and core log for well MW-24A are included as Appendix A to the Installation
and Hydraulic Testing of Perched Monitoring Wells MW-36 and MW-37 at the White Mesa
Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chem, Inc. January 29, 2020. A
copy of that Report was previously submitted under separate cover.
2.6 The Type, Source, and Cl1emical Physical, Radiological, and Toxic Characteristics of the
Effluent or Leachate to be Discharged (R317-6-6.3.F)
The Mill is designed not to discharge to groundwater or surface waters. Instead, the Mill
utilizes the TMS for disposal or evaporation of Mill effluents as indicated below:
• Cell 1: dedicated to evaporation of Mill solutions;
• Cell 2: contains Mill tailings, has an interim cover and is closed to future tailings
disposal;
31
• Cell 3: contains Mill tailings and is in the final stages of filling;
• Cell 4A: receives Mill tailings and is used for evaporation of Mill solutions; and
• Cell 48: authorized to receive Mill tailings but currently is used only for evaporation of
Mill solutions.
See Sections 2. 7 .2 through 2. 7.4 below for a more detailed discussion of the Mill's TMS.
The projected chemical and radiological characteristics of tailings solutions were assessed by
Energy Fuels Nuclear, Inc., a predecessor operator of the Mill, and NRC in 1979 and 1980,
respectively. In addition, early samples were assessed by D' Appolonia Engineering as the Mill
started operations to further evaluate and project the character of the solutions. Samples of
tailings after the Mill was fully operational were collected by NRC (1987), EFRI/UDEQ
(2003), and EFRI (2007 -2013). Samples collected in 2003 were obtained under the oversight
of DWMRC personnel. The Samples collected in 2007 and 2008 were obtained by EFRI on a
voluntary basis as the then proposed Tailings and Slimes Drain Sampling Plan (the "Tailings
Sampling Plan") had not been approved by the Director at that time. The 2009 samples were
collected on August 6, 2009 under the Tailings Sampling Plan that was approved at that time.
Subsequent annual sampling has been performed annually under an approved Tailings
Sampling Plan. A copy of the currently approved Tailings Sampling Plan is included as
Appendix L.
The chemical and radiological characteristics of the solutions held in the TMS, based on the
sample results described above, are provided in the tables included in Appendix E, which list
the concentration of parameters measured in accordance with the Permit.
There is no active discharge from the TMS; therefore, an estimation of the flow rate ("gpd") is
not applicable in this instance. However, when operating at full capacity, the Mill discharges
approximately 2000 tons per day of dry tailings and approximately 600 gpm of solutions to the
Mill's TMS.
2.7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate Into or
Adversely Affect the Quality of any Other Waters of the State (R317-6-6.3.G)
2.7.1 General
The Mill has been designed as a facility that does not discharge to groundwater or surface water.
All tailings and other Mill wastes are disposed of permanently into the Mill's TMS. Excess
waters are disposed of in the tailings or evaporation cells, where they are subject to evaporation,
or re-processed through the Mill circuit. See Section 2.6.
The Mill was also designed and constructed to prevent runon or runoff of storm water by a)
diverting runoff from precipitation on the Mill site to the TMS; and b) diverting mnoff from
surrounding areas away from the Mill site.
The Permit therefore does not authorize any discharges to groundwater or surface water, but is
intended to protect against potential inadvertent or unintentional discharges, such as through
potential failure of the Mill's TMS.
32
The Mill's TMS is currently comprised of five cells (Cells 1, 2, 3 4A, and 4B). Currently, Cells
3 and 4A are active tailings cells. Cells 1 and 4B are nonconventional impoundments used for
evaporation only. Cell 4B is authorized to receive Mill tailings but currently is used only for
evaporation of Mill olutions. Diagram. hawing the Mill facility layout, including the existing
TMS structures are included as Figures 10 and 11 to this Application.
The following sections de cribe the primary Discharge Minimization Technology ("DMT") and
Best Available Technology(' BAT ) features of the Mill, which demonstrate that the wastes and
tailings at the Mill can be controlled so that they do not migrate into or adversely affect the
quality of any waters of the State including groundwater and surface water.
2.7.2 Cells 1, 2 and 3
2. 7.2.1 Design and Construction of Cells 1, 2 and 3
Construction of Cell 2 was completed on May 3, 1980, construction of Cell 1 was completed on
June 29, 1981, and construction of Cell 3 was completed on September 15, 1982.
Each of Cells 1, 2 and 3 are constructed below grade. Each has a single 30 mil PVC flexible
membrane liner ("FML") constructed of olvent welded seams on a prepared sub base. A
protective soil cover layer was constructed immediately over the FML with a Lhickne of 12-
inches on the cell floor and 18-inches on the interior . ide lope. The criterion for placement of
the FML in Cells 1, 2 and 3 was a smooth ub base with no rock prolrudjng that could
potentially damage the FML. The cells were excavated by ripping the in-place Dakota
Sandstone with a large dozer. Where the rock could not be efficiently ripped, explosives were
used to loosen the rock. The cell bottom was then graded to the final design contours and rolled
with a smooth drum vibrating roller. The smooth drum roller effectively crushed the loose
sandstone, filling in small holes, and allowed for a smooth surface suitable for liner placement.
Due to the excavation method (ripping and blasting) there were some areas that required little or
no fill to meet final grade , while other area required pl acement of additional crushed sand tone
to meet the final grade. Tbe cell bottom wa ·ometime. re-worked everaJ time to accomplish
the desired result. The majority of the cell bottom is covered with a layer (1 to 6 inches) of
cru hed sandstone wl1ile the liner in ome area is placed directly on a smooth ro.lled surface of
Dakota Sandstone with onJy a thin veneer of re-compa ted and tone. In places where the
urface wa rough or contained maU hole , washed concrete and was used to fill or mootb the
imperfections, and the area was then rolled one last time before FML placement. Areas of
crushed sandstone filled sub base versus areas with little or no crushed sandstone base were not
documented during construction. Areas filled or smoothed with washed concrete sand is likely
less than 0.1 % of the cell bottoms. Beneath thi · underlay, native , andstone and other foundation
materials were graded to drain to a single low point .near the up, tream toe of the ot1th cro · -
valley dike. Inside this layer, is an east-west oriented pipe to gather fluid at the up t:ream toe of
the cross-valley dike. The crushed sandstone Layer draining to the pipe at the up t.ream toe of the
dike of the cell was intended to be a leak detection sy tern for each cell. However becau e the
de ·ign of these leak detection systems does rnot meet current BAT tandards, they are not
recognized as leak detection systems in the Permit.
33
Each of Cells 2 and 3 also has a slimes drain collection system immediately above the FML,
comprised of a nominal 12-inch thick protective blanket layer of soil or comparable material, on
top of which is a network of PVC perforated pipe laterals on a grid spacing interval of about 50-
feet. These pipe laterals gravity drain to a perforated PVC collector pipe which also drains
toward the south dike and is accessed from the ground surface via a non-perforated access pipe.
At cell closure, leachate head inside the pipe network will be removed via a submersible pump
installed inside the access pipe
See Part I.D. l of the Permit for a more detailed description of the design of Cells 1, 2 and 3.
After review of the existing design and construction and consultation with the State of Utah
Division of Water Quality, the Director determined, in connection with the issuance of the
Permit in 2005, that the DMT required under the groundwater quality protection rules (UAC
R317-6-6.4(c)(3)) for Cells 1, 2 and 3 that pre-dated those rules will be defined by the current or
existing cell construction, with modifications that were included in the Permit (see page 25 of the
2004 Statement of Basis). These modifications focus on changes in monitoring requirements,
and on improvements to facility closure. The goal of these improvements is to ensure that
potential wastewater losses are minimized and local groundwater quality is protected. The
modifications are described in Sections 2.7.2.2, 2.7.2.3 and 2.7.2.4 below.
2. 7.2.2 Improved Groundwater Monitoring
Improvements were made to the Mill's groundwater monitoring network at the time of issuance
of the original Permit, to meet the following goals:
a) Early Detection
As previously stated, 31 groundwater wells are monitored to detect any potential leaks from the
TMS. Because the leak detection systems for Cells 1, 2, and 3 utilized older, less sophisticated
technology, DWMRC required nine new wells be installed adjacent to the TMS in 2005. These
wells are used as a first line of defense to detect any potential TMS impacts. These supplemented
the existing thirteen wells that were installed prior to the 2005 issuance of the original permit.
Of the thirteen wells (MW-01, MW-02, MW-03 [subsequently abandoned], MW-05, MW-11,
MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-26, and MW-32) installed prior to
2005, seven of the wells are on the dikes of the cells or immediately adjacent to the cells, three
are upgradient, one has been abandoned and replaced and one is downgradient and one is cross
gradient. Of the nine wells installed as a result of the 2005 Permit, seven monitoring wells
(MW-23, MW-24, MW-25, MW-28, MW-29, MW-30 and MW-31) were added immediately
adjacent to or on the dikes of the existing cells. MW-03A and MW-27 are downgradient and
upgradient of the TMS respectively. DWMRC also required three new monitoring wells (MW-
35, MW-36 and MW-37) on the dikes of Cell 4B prior to that its use. The three wells on the
dikes of Cell 4B supplement the existing wells (MW-14 and MW-15) on the southern dike of
Cell 4A.
As can be seen from the well network, the site groundwater is extensively monitored and the
program is adequate to provide early detection of any potential TMS impacts.
34
b) Discrete Monitoring
In order to individually monitor each cell in the TMS and to be able to pinpoint the source of any
potential groundwater contamination that may be detected, there are 14 wells on the dikes or
immediately adjacent to the cells.
The monitoring program implemented at the site provides a comprehensive monitoring network
to determine any potential leakage from Cells 1, 2 and 3. See Figure 4 and Figure 10 for a map
showing the locations of the compliance monitoring wells for the site.
2.7.2.3 Operational Changes and Improved Operations Monitoring
The Permit required changes to disposal cell operation in order to increase efforts to minimize
potential seepage losses, and thereby improve protection of local groundwater quality. Examples
of these changes are:
c) Maximum Waste and Wastewater Pool Elevation
Part I.D.3 of the Permit requires that EFRI continue to ensure that impounded wastes and
wastewaters for all of the Mill's TMS are held within an FML.
d) Slimes Drain Maximum Allowable Head
Part I.D.3(b) of the Permit require that the Mill provide constant pumping efforts to minimize
the accumulation of leachate over the FML in Cell 2, and upon commencement of dewatering
activities, in Cell 3, and thereby minimize potential FML leakage to the foundation and
groundwater. See the discussion in Section 2.15 .2.2 below.
2. 7.2.4 Evaluation of Tailings Cell Cover System Design
EFRI submitted an Infiltration and Contaminant Transport Modeling Report ("ICTM Report"),
White Mesa Mill Site Blanding, Utah, N vember 2007, prepared by MWH Americas, Inc. EFRI
submitted a revised Infiltration and Contaminant Transport Modeling Report, White Mesa Mill
Site, Blanding, Utah, March 2010 ("revised ICTM Report") in response to DWMRC comments.
The March 2010 report is currently being reviewed in conjunction with the Reclamation Plan,
Revision 5.0. DWMRC provided interrogatories for the revised ICTM Report in March 2012.
EFRI provided responses to these interrogatories in May and September 2012. DRC provided
review comments on EFRI's May and September 2012 responses in February 2013.
The 2010 modeling was updated to address the Director's March 2012 and February 2013
comments on the ICTM Report and to incorporate supplemental field investigations conducted in
2010 and 2012 for cover borrow material and in 2013 for in situ tailings. The updated infiltration
modeling results were presented in EFRI's submitted responses to the Director's March 2012 and
February 2013 review comments in August 2012 and August 2015.
On November 11, 2015, the Director held a conference call with EFRI and recommended
submittal of an agreement outlining a plan to complete reclamation of Cell 2. This plan would
35
consist of completing placement of the cover design presented in Revision 5.0 of the
Reclamation Plan on Cell 2 and demonstrating acceptable cover performance via a performance
monitoring program.
On August 11, 2016, EFRI submitted Reclamation Plan, Revision 5 .1, with an Updated Tailings
Cover Design Report and incorporated comments received from the Director. On December 5,
2016, EFRI submitted the final version of Reclamation Plan, Revision 5.1, which incorporated
additional comments received from the Director.
EFRI and the Director executed a Stipulation and Consent Agreement ("SCA") on February 23,
2017 (DWMRC, 2017) defining the commitments and timeframes for completing placement of
reclamation cover on Cell 2 and performance assessment of the cover system, in accordance with
the Reclamation Plan Revision 5.1. EFRI updated the Reclamation Plan on February 8, 2018 to
Revision 5. lB and submitted to the Director, but the guidelines, monitoring, and reporting
requirements for the test sections did not change.
Per the 2017 SCA, the Director will approve Reclamation Plan 5.1 upon completion of a public
notice and comment period, and in conjunction with and conditional upon the execution and
delivery of the SCA by EFRI and the Director.
See Section 2.19 below for a more detailed discussion of post-closure requirements for the Mill.
2.7.3 Cell 4A
Construction of Cell 4A was completed on or about November 1989. Cell 4A was used for a
short period of time after its construction for the disposal of raffinates from the Mill's vanadium
circuit. No tailings waste or wastewater had been disposed of in Cell 4A since the early 1990s.
This lack of waste disposal, and exposure of the FML to the elements, caused Cell 4A to fall into
disrepair over the years.
Although the original design of Cell 4A was an improvement over the design of Cells 1, 2 and 3
(it had a one-foot thick clay liner under a 40 ml high density polyethylene ("HDPE") FML, with
a more elaborate leak detection system), it was constructed in 1989 and did not meet today's
BAT standards.
Cell 4A was re-lined in 2007-2008 and was re-authorized for use in November 2008. With the
reconstruction of Cell 4A, BAT was required, as mandated by Part I.D.4 of the Permit and as
stipulated by the Utah Ground Water Quality Regulations at UAC R317-6-6.4(A). With BAT
for Cell 4A, there are also new performance standards that require daily leak detection system
monitoring, weekly wastewater level monitoring, and slimes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Section 2.15.3 below for a more
detailed discussion relating to the BAT performance standards and monitoring requirements for
Cell 4A.
Tailings Cell 4A Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part I.D.5 of the Permit and consist of
36
the following:
a) Dikes -consisting of existing earthen embankment. of compacted . oil, con tructed by
a previous Mill operator between J 989-1990, and composed of four dikes each
including a 15-foot wide road at the top (minimum). On the north ea t, and soL1th
margin the e dike have lopes of 3H to JV. The west dike has a slope f 2H to L V.
Width of the e dike varies. Each has a minimum crest width of at least 15 feet to
upport an acce s road. Base width also varie. from 89-feet on the east dike (with no
exterior embankment), to 211-feet at the we t dike.
b) Foundation -including existing subgrade oils over bedrock materials. Foundation
preparation inclL1ded excavation and removal of contaminated soils, compaction of
imported oils to a maximum dry den ity of 90%. The floor of Cell 4A has an average
Jope of J ~ that grade from the northeast to the southwest corners.
c) Tailings Capacity -the floor and in ide lopes of Cell 4A encompa s about 40 acres
and hav 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:
(i) Primary FML -consisting of an impermeable 60 mil 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 is in direct
physical contact with the tailings material over most of the Cell 4A floor area. In
other location ·, the primary FML is in contact with the slimes drain collection
ystern (di cu ed below).
(ii) Leak Detection Sy tern -includes a permeable HDPE geonet fabric that extends
acros 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 ump is via
an 18-inch inside diameter (ID) HDPE pipe placed down the inside slope, located
between the primary and secondary FML. At its base this pipe is surrounded with
a gravel filter set in the leak detection sump, having dirnen ions of 10 feet by 10
feet by 2 feet deep. In turn, the gravel filter layer is enclo ed in an envelope of
geotextile fabric. The purpo. e of both the gravel and geotextile fabric is to serve
as a filter.
(iii) Secondary FML -consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. This FML also extend aero s the
entire Cell 4A floor, up the inside side-Jope and i also anchored in a trench at
the top of all fow-dikes.
(iv) Geo ynthetic C]ay Liner -consisting of a manufactured geosynthetic clay liner
(' GCL") compo ed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
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 drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated, two-part gee-composite drain material
37
(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.
(ii) 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,
sun-ounded 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. 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.
(iii) Slimes Drain Access Pipe -consisting of an 18-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 woven geotextile that
serves as a cushion to protect the primary FML. 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.
t) North Dike Splash Pads -three 20-foot wide splash pads have been constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings slurry.
These pads consist of an extra layer of 60 mil HOPE membrane that has been installed
in the anchor trench and placed down the inside slope of Cell 4A, from the top of the
dike, under the inlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope.
g) Emergency Spillway -a concrete lined spillway has been constructed near the
southwestern corner of the west dike to allow emergency runoff from Cell 4A to Cell
4B. At this time, 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.
h) BAT Performance Standards for Tailings Cell 4A -EFRI shall operate and maintain
Tailings Cell 4A so as to prevent release of wastewater to groundwater and the
environment in accordance with an Operations and Maintenance Plan, as cun-ently
approved by the Director, pursuant to Part I.H.19. At a minimum these performance
standards shall include:
(i) Maximum Allowable Daily Head-on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer.
38
See Part I.D.5 of the Permit for a more detailed discussion of the design of Cell 4A. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix F to this Application.
2. 7 .4 Cell 4B
Construction of Cell 4B was completed in November 2010.
Tailings Cell 4B Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part I.D.12 of the Permit and consist of
the following:
a) Dikes -consisting of newly constructed dikes on the south and west side of the cell,
each including a 20-foot wide road at the top (minimum). The exterior slopes of the
southern and western dikes have slopes of 3H to 1 V. The interior dikes have slopes of
2H to 1 V. Limited portions of the Cell 4B interior sidelopes in the northwest corner
and southeast corner of the cell (where the slimes drain and leak detection sump are
located) have a slope of 3H to 1 V. Width of these dikes varies. The base width of the
southern dike varies from approximately 92 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 existing 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%. The floor of Cell 4B has an average
slope of 1 % that grades from the northwest to the southeast corner.
c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass about 40 acres
and the cell has a maximum capacity 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:
(i) Primary FML -consisting of an impermeable 60 mil 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 is in direct
physical contact with the tailings material over most of the Cell 4B floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) 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
an 18-inch inside diameter ("ID") HDPE pipe placed down the inside slope,
located between the primary and secondary FML. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 15 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
39
(iii) Secondary FML -consisting of an impermeable 60-rnil HDPE membrane found
immediately below the leak detection geonet. This 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.
(iv) 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.
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 4B that drains 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.
(ii) 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. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southeast corner of Cell 4A where it joins the slimes drain
access pipe.
(iii) 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 woven geotextile that serves as
a cushion to protect the primary FML. 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) North and East Dike Splash Pads -nine 20-foot wide splash pads have been
constructed on the north and east dikes 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 has been 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 5-feet beyond the toe of the slope.
40
g) Emergency Spillway -a concrete lined spillway has been constructed near the
southeastern corner of the east dike to allow emergency runoff from Cell 4A into Cell
4B. This spillway is limited to a 6-inch reinforced concrete slab, with a welded wire
fabric installed within its midsection, set directly atop a cushion geotextile placed
directly over the primary FML in a 4-foot deep trapezoidal channel. A 100-foot wide,
60-mil HDPE membrane splash pad is installed beneath the emergency spillway. No
other spillway or overflow structure will be constructed at Cell 4B unless and until the
construction of Cells 5A and 5B. At this time, 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.
h) BAT Performance Standards for Tailings Cell 4B -EFRI shall operate and maintain
Tailings Cell 4B so as to prevent release of wastewater to groundwater and the
environment in accordance with the currently-approved Cell 4B BAT, Monitoring,
Operations and Maintenance Plan. At a minimum these performance standards shall
include:
(i) Maximum Allowable Daily Head-on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer,
(iv) Maximum Daily Wastewater Level -to ensure compliance with the minimum
freeboard requirements for Cell 4B, and prevent discharge of wastewaters via
overtopping.
See Part I.D.12 of the Permit for a more detailed discussion of the design of Cell 4B. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix F to this Application.
2.7.5 Future Additional TMS Cells
Future additional TMS cells at the Mill will require Director approval prior to construction and
operation. Future TMS cells at the Mill will be required to satisfy BAT standards at the time of
construction.
EFRI has submitted a GWDP and RML amendment application to construct, operate and (when
operations are complete) reclaim proposed new tailings impoundment Cells 5A and 5B at the
Mill. The License amendment request was previously submitted under separate cover. Review
of the application is currently in progress by DWMRC. Upon completion of the DWMRC
review, the RML will be subject to a Public Comment period. The construction of Cells 5A and
SB is an essential element of future operations at the Mill as their construction is necessary in
order to continue providing sufficient impoundment surface area for the evaporation of Mill
process water, and to provide additional tailings capacity which is necessary to accommodate the
tailings volume associated with routine processing operations. At this time, Energy Fuels does
not anticipate the construction of Cells 5A and 5B immediately upon the Director's approval of
the License and GWDP amendments; however, authorization is being sought in advance to allow
the Mill to respond to future needs.
41
2.7.6 Other Facilities and Protections
2.7.6.J Feedstock Storage
In order to constrain and minimize potential generation of contaminated stormwater or leachates,
Part I.D. J L of the Permit require the MilJ to continue it. existing practice of limiting open air
to.rage of feed tock material to the hi torical torage area found along the eastern margin of the
M.ill ite (as defined by the urvey coordinates found in Permit Table 4). The intent of Section I.
D. L 1, (based on the SOB for the 2009 GWDP), is to require that feedstock storage outside of the
area pecified in Tab.le 4 shall meet the following requirements:
a) Feedstock materials shall be stored at all times in water-tight containers or water-tight
container overpacks, and aisle ways will be provided at all times to allow visual
inspection of each and every feedstock container and container overpack, or
b) Feed tock container hall be stored on a hardened su1face to prevent p.il.lage onto
ub LIIface soil and that conform · with the foJiowing minimum pby ical requirement :
1) A torage area composed of a hardened engineered mface of a phaJt or concrete and
2)A torage area de igned con tructed, and operated in accordance with engineering
plan and pecification approved in advance by the Director. AJJ ucb engineering
plan or pecifications ubmitted shall demon trate compliance with Part I.D.4,
3)A torage area that provide containment berms to control stormwater run-on and run-
off, and
4)Stormwater drainage works approved in advance by the Director, or
5)0ther storage facilities and means approved in advance by the Director.
2. 7.6.2 Mill Site Reagent Storage
Part I.D.3(±) of the Permit requires the Mill to demonstrate that it has adequate provisions for
spill response, cleanup, and reporting for reagent storage facilities. The ·e provisions are detailed
in the Stormwater Best Management Practice Plan which is designed to prevent potential
reagent tank pill or leak. that could release contaminant to site soi]s or groundwater and to
provide proper spill prevention and control. Content of this plan are stipulated in Part I .D. JO of
the Permil, and . ub.mitta1 and approval of the plan is required. For exi t.ing facilities at the Mill
secondary containment is required, although such containment may be earthen ]ined. For new
facilities con tructed at the Mill, or reconstruction of exi ·ting facilities, Part I.D.3(±) requires a
higher standard of secondary containment that would prevent contact of any potential spill with
the ground surface.
A copy of the Mill's Stormwater Best Management Practices Plan, Revision 2.1: April 2022 is
attached a· Appendix G to this Application.
2. 7.6.3 New Construction
Part I.D.4 of the Permit requires any construction, modification, or operation of new waste or
wastewater disposal, treatment, or storage facilities shall require submittal of engineering design
plans and specifications, and prior Director review and approval. All engineering plans or
specifications submitted shall demonstrate compliance with all BAT requirements stipulated by
42
the Utah Ground Water Quality Protection Regulations (U AC R317-6). Upon Director approval
the Permit may be re-opened and modified to include any necessary requirements.
2.7.6.4 Other
The White Mesa Mill Discharge Minimization Technology Monitoring Plan, 01/22 Revision:
EFRI 13.0 (the "DMT Plan"), and the White Mesa Mill Tailings Management System, 03/17
Revision: EFR 2.5 (the "Tailings Management Plan"), are attached as Appendix H and Appendix
I to this Application, respectively. These plans provide a systematic program for constant
surveillance and documentation of the integrity of the TMS, including monitoring the leak
detection systems. The DMT Plan requires daily, weekly, quarterly, monthly and annual
inspections and evaluations and monthly reporting to Mill management. See Section 2.15.2
below for a more detailed discussion of the requirements of the DMT Plan.
2.7.7 Surface Waters
The Mill has been designed as a facility that does not discharge to surface waters. Tailings and
other Mill wastes are disposed of permanently into the Mill's TMS. Further, as mentioned
above, the Mill was designed and constructed to prevent run on or runoff of storm water by a)
diverting runoff from precipitation on the Mill site to the TMS; and b) diverting runoff from
surrounding areas away from the Mill site. As a result, there is no pathway for liquid effluents
from Mill operations to impact surface waters.
Under the Mill License, the Mill is required to periodically sample local surface waters to
determine if Mill activities may have impacted those waters. The primary pathway would be
from air particulates generated during Mill operations that may have landed on or near surface
waters, or that may have accumulated in drainage areas that could feed into surface waters.
Sampling results show no trends or other impacts of Mill operations on local surface waters. See
the Mill's Semi-Annual Effluent Reports, copies of which have previously been provided to the
Director.
2. 7 .8 Alternate Concentration Limits
Therefore, no alternate concentration limits are currently applicable to the site.
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information of the
Quality of the Receiving Ground Water (R317-6-6.3.H)
Groundwater classification was assigned by the Director in the Permit on a well-by-well basis
after review of groundwater quality characteristics for the perched aquifer at the Mill site. A
well-by-well approach was selected by the Director in order to acknowledge the spatial
variability of groundwater quality at the Mill, and afford the most protection to those portions of
the perched aquifer that exhibited the highest quality groundwater. These groundwater
classifications are set out in Part I.A and Table 1 of the Permit.
The primary element used by the Director in determining the groundwater classification of each
monitoring well at the site, is the TDS content of the groundwater, as outlined in UAC 317-6-3.
Groundwater quality data collected by the Mill show the shallow aquifer at the Mill has a highly
43
variable TDS content, wilh TDS average ranging from about 1100 to about 7700 mg/L. Another
key element in determination of groundwater class is the presence of naturally occurring
contaminants in concentration lbat exceed their respective GWQS. In such cases, the Director
has cause to downgrade aquifer classification from Class II to Class III (see UAC R317-6-3.6).
Using all available TDS data and background data, for the POC and general monitoring wells the
Director determined that four of those wells exhibit Class II drinking water quality groundwater.
The remaining wells at the site exhibited Class III or limited use groundwater. Well MW-24A
has not been classified at this time.
2.8.1 Existing Wells at the Time of Original Permit Issuance
The Director required EFRI to evaluate groundwater quality data front the thirteen existing wells
(MW-03 has since been abandoned) on site, and submit a Background Ground Water Quality
Report for Director approval. One of the purpo e of that report was to provide a critical
evaluation of historic groundwater quality data from the facility, and determine representalive
background quality conditions and reliable GWCLs for the Permit.
EFRI (then Denison) prepared the Existing Well Background Report that evaluated all historic
data for the tllirteen exi ting wells for Lhe purposes of establishing background groundwater
quality at the ite and developing GWCL under the GWDP. Prior to review and acceptance of
the conclusion ·in the Exi ting Well Background Report, the GWCLs were set on an interim
basis in the GWDP. The interim limits were e tablished as fractions of the state GWQSs for
drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflected background groundwater quality
for the thirteen existing wells, based primarily on the analysis performed in the Existing Wells
Background Report. It should be noted, however, that, because the GWCLs have been set at the
mean plus two tandard deviations, or Lhe equivalent, un-impacted groundwater would normally
be expected to exceed the GWCL approximately 2.5% of the time. Therefore, exceedances are
expected in approximately 2.5% of all ample results, and do not nece sarily represent impacts to
groundwater from Mill operations.
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit
Because the Permit called for installation of nine new monitoring wells around the TMS,
background groundwater quality had to be determi11ed for those monitoring point . To this end,
the Permit requjred the Mill to collect at least eight quarter of groundwater quality data and
submit the New Well Background Report for Director approval to e. tablisb background
groundwater quality for those wells.
EFRI (then Deni on) prepared the New WelJ Background Report that evaluated all hj toric data
for the nine new welJ for the purpose of e tablishing background groundwater quality at the
·ite and developing GWCL under the GWDP. Prior to review and acceptance of Lhe conclu. ion
in the New Well Background Report, the GWCLs were set on an interim basis in the GWDP.
The interim limits were established as fractions of the state GWQSs for drinking water,
depending on the quality of water in each monitoring well at the site.
44
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the aine new well ba ed primaril y on the analysis performed in the New Well Background
Report. It should be noted, however, Lhat, becau e th e GWCLs have been set at the mean plus
second tandard deviation, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Theref: re, exceedances are
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.I)
The groundwater monitoring plan is set out in the Permit. All groundwater monitoring at the site
is in the perched aquifer. The following sections summarize the key components of the Mill's
sampling and analysis plan.
2.9.1 Groundwater Monitoring to Determine Groundwater Flow Direction and Gradient,
Background Quality at the Site, and the Quality of Groundwater at the Compliance Monitoring
Point
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit
At the time of renewal of the Mill license by NRC in March, 1997 and up until issuance of the
Permit in March 2005, the Mill implemented a ground.water detection monit cing program, in
accordance with 10 CFR Part 40, Appendix A and the pro vi. ions of the NRC Mill Licen ·e
condition 11.3A. The detection monitoring program wa implemented in accordance with the
report entitled, Points of Compliance, White Mesa Uranium Mill, prepared by Titan
Environmental Corporation, submitted by letter to the NRC dated October 5, 1994. Under that
program, the Mill sampled monitoring wells MW-5, MW-11, MW-12, MW-14, MW-15 and
MW-17, on a quarterly basis. Samples were analyzed for chloride, potassium, nickel and
uranium, and the results of such sampling were included in the Mill's Semi -Annual Effluent
Monitoring Reports that were filed with the NRC up until August 2004 and with the DWMRC
subsequent thereto.
Between 1979 and 1997, the Mill monitored up to 20 constituents in up to 13 wells. That
program was changed to the Points of Compliance Program in 1997 because NRC had concluded
that:
• The Mill and TMS had produced no impacts to the perched zone or deep aquifer; and
• The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
2.9.1.2 Issuance of the Permit
On March 8, 2005, the Director issued the Permit, which includes a groundwater monitoring
program that superseded and replaced the groundwater monitoring requirements set out in the
NRC Mill License Condition 11.3A. Condition 11.3A has since been removed from the Mill
License. Groundwater monitoring under the Permit commenced in March 2005, the results of
which are included in the Mill's Quarterly Groundwater Monitoring Reports that are filed with
45
the Director.
On September 1, 2009, EFRI fiJed a Groundwater Di charge Permit Renewal Application. At
the reque t of the Director of the Utah Divi ion of Radiation Control, EFRI submitted an updated
ver. ion of the September 1, 2009 renewal application on July 13, 2012. At the request of the
Director of the Utah Division of Radiation Control, EFRI submitted an updated version of the
July 2012 renewal application on June 5, 2014. In accordance with R317-6-6.7 and the current
GWDP dated March 8, 2021, Part IV.D, this is an updated application to the Director for renewal
of the Permit for another 5-years under R313-6-6. 7.
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit
The current groundwater monitoring program at the Mill is used to determine groundwater flow
direction, gradient, and quality at the compliance monitoring points. This program consists of
monitoring at point of compliance monitoring wells: MW-2, MW-3A, MW-5, MW-11, MW-12,
MW-14,MW-15,MW-17,MW-23,MW-24,MW-25,MW-26,MW-27,MW-28,MW-29,MW-
30, MW-31, MW-32, MW-35, MW-36, and MW-37. Groundwater flow, direction and quality
are monitored at six general monitoring wells: MW-1, MW-18, MW-19, MW-20, MW-22 and
TW4-24 and at three well added by EFRI in respon e to reque t from the UMUT far cros -
graclient to the TMS to provide water level data and to provide adclitional information on ite
geology and naturally occmring geochemical behavior . One well ha been installed adjacenl to
MW-24 (MW-24A) for additional studie · of regional geochemistry. The l cati011 of these welJ '
are indicated on Figure 10.
Depth to water is measured quarterly in all of the well listed above as well as MW-34. Due to
limited water in MW-34, it is not ampJed for POC compliance. MW-33 is completely dry and
is not sampled for POC compliance.
Part I.E. l.( d) of the Permit requires that each point of compliance well as well as general
monitoring wells must be sampled for the constituents listed in Table 2.9.1.3-1.
Further, Part I.E.l.(d)l) of the Permit, requires that, in addition to pH, the following field
parameters must also be monitored:
• Depth to groundwater
• Temperature
• Specific conductance
• Redox potential ("Eh")
• Dissolved Oxygen ("DO")
and that, in addition to chloride and sulfate, the following general inorganics must also be
monitored:
• Carbonate, bicarbonate, sodium, potassium, magnesium, calcium, and total anions and
cations.
46
Sample frequency depends on the speed of groundwater flow in the vicinity of each well. Parts
I.E.1 (b) and ( c) provide that quarterly monitoring is required for all wells where local
groundwater average linear velocity has been found by the Director to be equal to or greater than
10 feet/year, and semi-annual monitoring is required where the local groundwater average linear
velocity has been found by the Director to be less than 10 feet/year.
Based on these criteria, quarterly monitoring is required at MW-11, MW-14, MW-25, MW-26
and MW-30, MW-31, and MW-36. Quarterly monitoring is required for MW-38, MW-39 and
MW-40 until such time as they are added to the GWDP and the frequency is modified based on
the flow velocity discussed above as necessary. Semi-annual monitoring is required at MW-1,
MW-2, MW-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-20, MW-22, MW-
23, MW-27, MW-28, MW-29, MW-32, MW-35 and MW-37. MW-24 and MW-24A, which
would normally be monitored on a semi-annual frequency, are monitored quarterly due to their
inclusion in additional geochemical studies. An additional well (MW-41) is planned for the area
downgradient of MW-24/MW-24A and upgradient of MW-2 as part of the additional studies
associated with MW-24A.
Geochemical and indicator parameter analysis during the initial SAR in October of 2012
concluded that upgradient monitoring wells MW-1, MW-18, and MW-19 have not been
impacted by Mill activities. These upgradient monitoring wells are sampled semi-annually but
are not subject to GWCLs. In addition, MW-20 MW-22, and TW4-24 are monitored on a semi-
annual basis as "General Monitoring Wells," but they are not subject to GWCLs.
2.9.1.4 Groundwater Flow Direction and Gradient
Part I.E.3 of the Permit requires that, on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.1 and described in Section 2.9.1.3 above, the Mill
shall measure depth to groundwater in the following wells and/or piezometers:
a) The point of compliance wells identified in Table 2 and l .E.1 of the Permit, as
described in Section 2.9.1.3 above.
b) Piezometers P-1, P-2, P-3A, P-4 and P-5.
c) Head Monitoring Well-MW-34.
d) General monitoring wells -Upgradient MW-1, MW-18, and MW-19; Lateral well
TW4-24; and Downgradient wells MW-20, MW-22.
e) Contaminant investigation wells -any well required by the Director as a part of a
contaminant investigation or groundwater corrective action (at this time this includes
the chloroform and nitrate investigation wells).
f) Any other wells or piezometers required by the Director.
While it is not a requirement of the GWDP, EFRI also measures depth to water in the DR
piezometers which were installed during the Southwest Hydrogeologic Investigation. The Mill
uses these measurements to prepare groundwater isocontour maps each quarter that show the
groundwater flow direction and gradient. The isocontour map for the fourth quarter of 2021 is
attached as Figure 5.
47
2.9.1.5 Background Quality at the Site
A significant amount of hi toric groundwater quality data had been colle ted by EFRI and
previou operators of the Mill for ome well at the faciUty. In some case the e data extend
back more than 42 years to September 1979. A brief ummary of the variou tudies that had
been performed prior to the original issuance of the Permit i · . et Olll in Section 2.0 of the
Regional Background Report.
However, at the time of original is ·uance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data qtiality, and quality as urance
issues. Such an examination needed to include such things as ju tification of any zero
concentration values reported, adequacy of minimum detection limits provided (particularly with
re pect to the c rre. ponding GWQS) adequacy of laboratory and analytical method u ed
con ·i tency of laboratory unit or reporting, internal con istency between :pecific and composite
types of analysi (e.g., major ion. and TDS) identification and ju tification of concentration
outlier and .implications of concentration trends (both temporal and spatial).
As discussed in Section 2.9 .6.1 below, the Director also noted several groundwater quality issues
that needed to be re olved prior to a determination of background groundwater quality at the . ite.
These were: 1) a number of con tituent exceeded their re pective GWQS (including nitrate in
one well and mangane e, elenium and uranium in several well ); 2) long term trend in uranium
in downgradient wells MW-14, MW-15 and MW-17; and 3) a spatial high of uranium in those
three downgradient well . See pages 5-8 of the 2004 Statement of Basis for a more detailed
discussion of these points.
As a result of the foregoing, the Director required that the Background Reports be prepared to
address and resolve these issues.
Further becau e background groundwater quality at the Mill site had not yet been approved at
the time of original Permit i uance, the Di1·ector was not able to determine if any contaminant is
naturally occurring and therefore detectable or undetectable for purpo e of electing GWCL · in
each well. Con equently the Director initia!Jy assigned GWCLs a · if they were 'undetectable'
(i.e. a sum.ing that all natural background concentrations were le s than a fraction of the
respective GWQS).
As di cussed in Section L.3 above and 2.1 J.2 below, EFRI submitted the Background Reports to
the DiJector. Both the Exi ting Well Background Report and the New Well Background Report
provided GWCLs for all of the con tituents in the exi ting weJI · and new weJls respectively,
based on a tatistical intra-well approach. The Director has approved the Background Reports.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells (MW-3 has since been abandoned) and the nine new wells based
primarily on the analy i performed in the Background Report . It should be noted however,
that becau e the GWCLs had been et at the mean plu econd standard deviation, or the
equivalent, un-impacted groundwater would normally be expected to exceed the GWCL
approximately 2.5% of the time. Therefore, exceedances are expected in approximately 2.5% of
all ample re uJts and do not neces arily repre ent impacts to groundwater from Mill operations.
48
The GWDP dated January 20, 2010 required the completion of eight con, ecutive quarter of
groundwater sampling and analy i, of MW-20 and MW-22 and later ubmittal of another
Background Report to determine if well MW-20 and MW-22 should be added as POC
monitoring wells. Data from MW-20 and MW-22 were analyzed in the pre-operational and
regional background addendum (INTERA 2007a)· however there wa not a complete data set at
the time. Although well MW-20 and MW-22 were in taHed in 1994 they were not . ampled
regularly until the second quarter of 2008. The eighth fuU round of sampling was completed
during the fir t quarter of 2010, and EFRT ubmitted to the Director the Background
Groundwmer Quality Report for Wells MW-20 and MW-22 for Denison Mines ( USA) Co1p. 's
White Mesa Mill Site San Juan County, Utah, June l 2010, prepared by INTERA Inc. (the
"MW-20 and MW-22 Background Report"). DWMRC classified MW-20 and MW-22 as
general monitoring wells, and GWCLs have not been established for these wells. MW-20 and
MW-22 are sampled semi-annually.
Part I.H.6 of the GWDP dated June 21, 2010 required the installation of three hydraulically
downgradient well adjacent to Taijjog Cell 4B (MW-33 MW-34, and MW-35) prior to
placement of olid or fluids in Cell 4B. The purpose of the e monitoring weU . was to provide
early detection of potential impacts to the hallow groundwater from Tailing · Cel.I 4B. EFRl
in talled MW-33, MW-34. and MW-35 a required. Of the e three wells installed near tailing
Cell 4B only MW-35 wa hydraulically acceptable, with five feet or more of saturated thickness.
MW-35 was ·ampJed quarterly ince fourth quarter 2010 to collect eight statistically valid data
points for the completion of the Background Report and calculation of GWCLs. MW-33 and
MW-34 had in ufficient water for sampling, with saturated thicknesses less than five feet. MW-
33 is completely dry, and no samples or depth to water measurements are collected from this
well. Quarterly depth to water is measured in MW-34, but no sampling or analysis is required.
Part I.H.4 of the February J 5, 2011 GWDP required the installation of two wells hydraulically
downgradient of Tailing Cell 4B as replacements for MW-33 and MW-34. EFRI installed
MW-36 and MW-37 as required. MW-36 and MW-37 were sampled quarterly beginning in the
third quarter 2011 to collect eight statistically valid data points for the completion of the
Background Report and calculation of GWCLs.
The Background Report for well MW-35, MW-36, and MW-37 was submitted to the Director
on May 1, 2014. The findings of the Background Analysis for well MW-35, MW-36, and MW-
37 upport previous conclusions that the groundwater at the Mill i not being affected by any
potential TMS seepage. The Director incorporated MW-35, MW-36 and MW-37 in a subsequent
revision of the GWDP and these weUs are ampled as required.
Three wells have been added by EFRI in response to reque ts from tbe UMUT far cross-gradient
to the TMS to provide water level data and to provide additional information on site geology and
naturally occurring geochemical behavior . DWMRC stated in the Public Participation
Summary ("PPS ) for the January 18 2018 GWDP renewal that "There i no regulatory or
technical. ba i to require additional monitoring well between CeJJ 4A and MW-22. Monitoring
weJI currently exi t directly downgradient and cross gradient from CelJ 4A which would
identify potential TMS impacts before anything would appear in MW-22 and at thi. time no
tailing cell leakage ha been observed. In regard · to the requested three new monitoring well
made by the UMUT in other comments although the Division ee no technical or r gulatory
49
basis to include monitoring wells in the location between Tailings Cell 4A and MW-22, EFRI
has agreed to address the UMUT concern and voluntarily install three monitoring wells in the
area between monitoring wells MW-17 and MW-22."
The three wells, MW-38, MW-39 and MW-40, were installed in February 2018. The
Background Report for wells MW-38, MW-39, and MW-40 was submitted to the Director on
June 7, 2021 after sufficient data had been collected to complete the statistical evaluation. The
findings of the Background Analysis for wells MW-38, MW-39, and MW-40 support previous
conclusions that the groundwater at the Mill is not being impacted by any potential TMS
seepage. The Director approved the background report for MW-38, MW-39, and MW-40 by
letter dated June 16, 2021. MW-38, MW-39, and MW-40 will be incorporated into a subsequent
revision of the GWDP. Until such time as these wells are incorporated into the GWDP, they are
sampled on a quarterly basis.
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point
There are over 42 years of data for some constituents in some wells at the site, but not for all
constituents. However, with the exception of tin, which was added as a monitoring constituent in
2007, all currently required monitoring constituents have been sampled in the wells that were in
existence on the date of the original issuance of the Permit commencing with the first quarter of
2005 . Further, all constituents in any new compliance monitoring wells have been sampled upon
installation of those wells, commencing either in the second or third quarters of 2005 for the
wells installed as a result of the 2005 Permit and in any wells installed subsequent to the 2005
Permit.
The analytical results from this sampling are reported quarterly in Groundwater Monitoring
Reports, which are filed with the Director pursuant to Part I.F.1 of the Permit.
2.9.2 Installation, Use and Maintenance of Monitoring Devices
Compliance monitoring at the Mill site is accomplished in three ways: the compliance well
monitoring program; the leak detection monitoring system in Cells 4A and 4B; and various DMT
monitoring requirements. Each of these are discussed below.
2.9.2.1 Compliance Well Monitoring
Compliance for TMS Cells 1, 2 and 3 and the remainder of the Mill site, other than Cells 4A and
4B, is accomplished by quarterly or semi-annual sampling of the network of compliance
monitoring wells at the site. See Figure 10 for a map that shows the compliance monitoring well
locations, and Section 2.9 .1.3 for a description of the monitoring program.
2.9.2.2 Leak Detection System in Cell 4A and Cell 4B
BAT was required, as mandated in Part I.D.4 of the Permit and as stipulated by UAC R317-6-
6.4(a) for the reconstruction of Cell 4A and the construction of Cell 4B. Because TMS Cells 1, 2
and 3 were constructed prior to the GWDP BAT requirements, and after review of the existing
design and construction, the Director determined that DMT rather than BAT is required for Cells
1, 2 and 3 (see the discussion in Section 2.7.2 above).
50
BAT for Cell 4A and Cell 4B included the construction of a modern leak detection system. See
Sections 2.7.3 and 2.7.4 above for a description of the key design elements of Cell 4A and Cell
4B respectively, including their leak detection systems. With BAT for Cell 4A and Cell 4B,
there are new performance standards in the Permit that require daily leak detection system
monitoring, weekly wastewate1· level monitoring, and Limes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Sections 2.15.3 and 2.15.4 below for a
more detailed discussion of the BAT monitoring requirements for Cell 4A and Cell 4B
respectively.
Because Cell 4A and Cell 4B have modern leak detection systems, that meet BAT standards and
are monitored daily, the leak detection systems in Cell 4A and Cell 4B can be considered to be a
point of compliance monitoring devices.
2.9.2.3 Other DMT Monitoring Requirements
In addition to the foregoing, the additional DMT performance standard monitoring discussed in
detail in Section 2.15 below is required to be performed under the Permit
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring
Points
The compliance monitoring area at the site is the area covered by the groundwater compliance
monitoring wells. Figure 10 shows the current locations of the compliance groundwater
monitoring wells at the site.
At the time of original Permit issuance, the Director reviewed the then recent water table contour
maps of the perched aquifer. Those maps identified a significant western component to
groundwater flow at the Mill site, which the Director concluded appeared to be the result of
wildlife pond seepage and groundwater mounding ( ee page 23 of the 2004 Statement of Ba i ).
As a consequence, new groundwater monitoring well were required, particularly along the
western margin of the TMS, in addition to the monitoring well already in existence at that time.
The Director also concluded that new wells were also needed for DMT purposes and to provide
discrete monitoring of each tailings cell. This resulted in the addition of the following
compliance monitoring wells to the then existing monitoring well network: MW-23, MW-24,
MW-25, MW-26 (which was then existing chloroform investigation well TW4-15), MW-27,
MW-28, MW-29, MW-30, MW-31 MW-32 (which was then existing chloroform investigation
well TW4-17), MW-35, MW-36, and MW-37. As previously stated MW-33 and MW-34 were
installed but are not currently sampled due to limited water and saturated thickness. MW-1, MW-
18, MW-19, MW-20, MW-22, and TW4-24 are not POC wells but are general monitoring wells
and are sampled semi-annually for information purposes only. MW-38, MW-39 and MW-40
have been added by EFRI in response to requests from the UMUT far cross-gradient to the TMS
to provide water level data and to provide additional information on site geol gy and naturally
occurring geochemical behaviors. One well ha been installed adjacent to MW-24 (MW-24A)
for additional studies of regional geochemistry. Monitoring well MW-41 will be in tailed during
the additional studies associated with MW-24/MW-24A.
51
Based on groundwater flow direction and velocity, the compliance monitoring network, with the
fo regoing addjLional new wells, was considered to be adequate for compliance monitoring in the
perched aquifer at the site.
Further, as mentioned in Section 2.9.2.2 above, the leak detection systems in Cell 4A and 4B can
also be considered to be compliance monitoring areas for these cells.
2.9.4 Monitoring of the Vadose Zone
Monitoring is not performed in the vadose zone at the site.
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation,
Including Post-Operational Monitoring
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation
Please see Section 2.19 below for a detailed discussion of the measures to prevent groundwater
contamination after the cessation of operations.
2.9.5.2 Post-Operational Monitoring
Groundwater monitoring will continue during the post-operational phase through final closure
until the Permit i terminated. EFRI understands that the final closure will take place and the
Permit will be terminated upon termination of the Mill License and transfer of the reclaimed
TMS to the United States Department of Energy pursuant to U.S.C. 2113. See Section 2.19.1.1
below.
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where
Applicable to Specified Guidance
2.9.6.1 Monitoring Well Construction
a) New Wells
All new compliance monitoring wells installed after the original issuance of the Permit were
installed in accordance with the requirements of Part I.E.4 of the Permit. Part I.E.4 requires that
new groundwater monitoring wells installed at the facility comply with the following design and
construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other
potential origin of groundwater pollution;
b) Screened and completed in the shallow aquifer;
c) Designed and constructed in compliance with UAC R317-6-6.3(I)(6), including
the EPA RCRA Ground Water Monitoring Technical Enforcement Guidance
Document, 1986, OSWER-9950.1 (the "EPA RCRA TEGD"); and
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
52
As-built reports for all new groundwater monitoring wells were submitted to the Director for his
approval, in accordance with Part I.F.6 of the Permit. Part I.F.6 requires those reports to include
the following information:
a) Geologic logs that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs were prepared by a
Professional Geologist licensed by the State of Utah or otherwise approved
beforehand by the Director ;
b) A well completion diagram that details all physical attributes of the well
construction, including:
1) Total depth and diameters of boring;
2) Depth, type, diameter, and physical properties of well casing and screen,
including well screen slot size;
3) Depth intervals, type and physical properties of annular filterpack and seal
materials used;
4) Design, type, diameter, and construction of protective surface casing; and
5) Survey coordinates prepared by a State of Utah licensed engineer or land
surveyor, including horizontal coordinates and elevation of water level
measuring point, as measured to the nearest 0.01 foot; and
c) Aquifer permeability data, including field data, data analysis, and interpretation of
slug test, aquifer pump test or other hydraulic analysis to determine local aquifer
hydraulic conductivity in each well.
Between April and June 2005, EFRI installed wells MW-23, MW-24, MW-25, MW-27, MW-28,
MW-29, MW-30, and MW-31. On August 23, 2005, EFRI submitted a Perched Monitoring
Well Installation and Testing at the White Mesa Uranium Mill April through June 2005 Report,
prepared by Hydro Geo Chem, Inc., that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover.
Between August 30 and September 2, 2010, EFRI installed wells MW-33, MW-34, and MW-35.
On October 11, 2010, EFRI submitted Installation and Hydraulic Testing of Perched Monitoring
Wells MW-33, MW-34, and MW-35 at the White Mesa Uranium Mill Near Blanding Utah,
prepared by Hydro Geo Chem, Inc. that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover. During the week of April 25, 2011, EFRI installed wells MW-36, and
MW-37. On June 28, 2011, EFRI submitted Installation and Hydraulic Testing of Perched
Monitoring Wells MW-36, and MW-37 at the White Mesa Uranium Mill Near Blanding Utah,
prepared by Hydro Geo Chem, Inc. that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover. Between February 12 and February 21, 2018, EFRI installed wells MW-
38, MW-39, and MW-40. On June 18, 2018, EFRI submitted Installation and Hydraulic Testing
of Perched Monitoring Wells MW-38, MW-39, and MW-40 at the White Mesa Uranium Mill
Near Blanding Utah, prepared by Hydro Geo Chem, Inc. that documented how these wells had
been installed in accordance with requirements of the Permit. A copy of that Report was
previously submitted under separate cover. During the week of December 2, 2019, EFRI
installed Well MW-24A. On January 29, 2020 EFRI submitted Installation and Hydraulic
53
Testing of Perched Well MW-MW~24A White Mesa Uranium Mill Near Blanding Utah, prepared
by Hydro Geo Chem, Inc. that documented how this well had been installed in accordance with
requirements of the Permit. A copy of that Report was previously submitted under separate
cover.
b) Existing Wells
The Existing Well , MW-1 MW-2, MW-3 (now abandoned) MW-5, MW-11, MW-12, MW-14,
MW-15, MW-.17, MW-18 MW-19 MW-26 and MW-32 as well as wells MW-20 and MW-22,
which are not compliance monitoring well , and piezometer P-1, P-2, P-3 (replaced with P-3A),
P-4 and P-5 were all con trncted and jnstaJled prior to original issuance of the Permit. Some of
those wells date back to 1979.
During everal ite vi its and four split groundwater sampling events between May 1999 and the
date of original is ·uance of the Permit, and a review of available as built information, DWMRC
taff noted the need for remedial construction, maintenance, or repair at several of these wells,
including:
(i)
(ii)
(iii)
A.
B.
C.
D.
16 of the ex1stmg monitoring well failed to produce cJear groundwater in
conformance with the EPA RCRA TEGD, apparently due to incomplete well
development. Consequently, the Permit required that MW-5 MW-11, MW-18
MW-19, MW-26, TW4-16, and MW-32 be developed to en ure that groundwater
clarity conforms to the EPA RCRA TEGD to the extent reasonably achievable·
The Permit required the Mill to in tall protective steel surface casings to protect
the exposed PVC well and piezometer casings for piezometer P-1, P-2, P-3 (now
replaced w.ith P-3A), P-4 and P-5 and wells MW-26 and MW-32; and
Several problem were observed with the construction of MW-3, including:
A review of the MW-3 well as-built djagram howed that no geologic Jog wa
provided at the time of well in. tallation. Con equently, the Director was not
able to ascertain if the screened interval wa adequately located across the ba e
of the shallow aquifer;
MW-3 was constructed without any filter media or sand pack across the
screened interval;
An excessively long casing sump (a 9 or 10 foot long non-perforated section of
well casing), was constructed at the bottom of the well; and
The well screen appeared to be poorly positioned, based on the low
productivity of the well, (there is no geologic log to verify proper positioning).
The Mill developed the wells as required and installed the protective casings required. The
Director concluded that EFRI had fulfilled the requirements and sent EFRI a Closeout Letter on
August 5, 2008.
With respect to the concerns raised about MW-3 the MilJ in talled MW-3A approximately 10
feet southeast of MW-3, in order to verify the depth to the upper contact of the Brushy Ba in
Member of the Morrison Formation (the "UCBM"). After in tallation, the Director reviewed the
geologic log for MW-3 and the as-built reports for both MW-3 and MW-3A and concluded that
54
the well screen for MW-3A was 2.5 feet below the UCBM and the well screen for MW-3 was
4.5 feet above the UCBM. Therefore MW-3 was a partially penetrating well; whereas MW-3A
is fully penetrating. The Director concluded that semiannual sampling was to continue in both
wells until sufficient data is available and the DWMRC could make a conclusion regarding the
effects of partial well penetration and screen length. As a result, the GWDP was modified to
require that MW-3A be completed with a permanent surface well completion according to EPA
RCRA TEGD. EFRI completed MW-3A as required, and on August 5, 2008 the DWMRC sent
EFRI a Closeout Letter. Both MW-3 and MW-3A were sampled emi-arurnally through the
fourth quarter of 2016. A review of the MW-3 and MW-3A data in 2016 indicated that MW-3A
lacked the construction issues seen in MW-3. With the concurrence of the DWMRC, EFRI
abandoned MW-3 in November 2016 in accordance with State of Utah regulations R655-4-14.8
by a Utah licensed water well driller. An abandonment report was submitted to DWMRC under
separate cover.
Subsequent to original Permit issuance, on January 6, 2006, DWMRC staff performed an
inspection of the compliance groundwater monitoring wells at the Mill. During the inspection,
well MW-5 was found to have a broken PVC surface casing. The repair of MW-5 was added to
the Permit compliance schedule to require the Mill to repair the broken PVC casing to meet the
requirements of the Permit.
The Permit required EFRI.to submit an As-Built report for the repairs of monitoring well MW-5
on or before May 1, 2008. EFRI submitted the required report, and on Augu t 5, 2008 the
DWMRC sent EFRI a Closeout Letter.
In the 2012 SAR, it was noted that uranium values in MW-5 were erratic and extremely variable
which appeared to be affected by temporal or seasonal conditions as evidenced by concentrations
which rise in either the fourth quarter or first quarter followed by substantial decrea es beginning
in the second quarter. Stati tical analysis of the data showed no need for an increa ed GWCL due
to the presence of tatisticaJ outlier . EFRI proposed that the GWCL for manium in MW-5 of
7 .5 µg/L be retained and additional ·tndie be undertaken lo try and determine the rea on for the
ea onal variation observed in the data. In an effort to addre potential phy. ical cau ·e on the
uranium variability EFRI made changes to the ca ing and urrounding area in May 2017. The
top of the ca ing (' TOC ') for MW-5 was lightly below the ground urface and may have
inadvertently aUowed dust and dirt to enter the well during ampLing activities. To addres thi
i ue EFRI extended the TOC several feet and regraded the area urrounding the well. After the
TOC was extended, the well was overpumped to remove any dirt which may have been
introduced during these field activities. All uranium data collected in MW-5 after the extension
of the casing are below the GWCL and no further actions were required for this well.
MW-12 is west of MW-5 on the dike between Cell 3 and Cell 4B. When wells MW-5 and MW-
12 were installed the TOC for both wells was above the ground surface by several feet. During
the construction of the dike of Cell 4B several feet of fill dirt was placed around MW-5 and
MW-12. MW-5 and MW-12 were not extended and the TOC of both MW-5 and MW-12 was
slightly below the ground surface. As previously noted, MW-5 was extended in May 2017 in
response to variable uranium concentrations likely caused by dust and dirt entering the well
during sampling activities.
55
Since MW-12 has reported exceedances of uranium similar to MW-5 and due to the proximity of
MW-12 to MW-5, prior to completing a SAR, EFRI believed it was appropriate to first address
potential physical causes.
In an effort to address potential physical causes of the exceedances, EFRI made changes to the
casing and urrounding area of MW-12 in October 2020. The TOC for MW-12 was slightly
below the ground surface and may have inadvertently allowed dust and dirt to enter the well
during ampJjng activitie . To addre this is ue EFRI extended the TOC several feet and
regraded the area ·urrounding the well. After the TOC was extended, the well was overpumped
to remove any dirt which may have been introduced during these field activities. These activities
were completed after the third quarter 2020 sampling event was conducted.
EFRI submitted a Plan and Time Schedule as required by the GWDP for MW-12 to address
consecutive exceedances of uranium and selenium in MW-12. The Plan and Time Schedule
stated that EFRI would continue accelerated monitoring of selenium and uranium in MW-12 for
four quarters beginning with the fourth qua1ter 2020 through the third quarter 2021. Progress
and results will be discussed in the routine quarterly groundwater reports. The fourth quarter
MW-12 results for selenium and uranium were below their respective GWCLs. No further
actions for MW-12 were required.
The groundwater monitoring program at the Mill has historically had oumerou well wilh
elevated turbidjty, tmbidity levels which could not tabilize to within 10% Relative Percent
Difference (10% RPO) or both. Identification of equipmen problem and jmprovements to field
sampling practices did not result in improvements to measured turbiditie . Ongoing turbidity
issues were the result of monitoring requirements which were most likely ill-suited to the site
geology. It is uspected that many well at the Mill might not be capable of attaining a turbidity
of 5 nephJometric turbidity unit ( NTU ') due to the natural conditions in the formation hosting
tb perched monitoring well (the Burro Canyon Formation and Dakota Sand tone). Clay
interbed occur in both the Burro Canyon Formation and Dakota Sandstone, and friable materials
occur within the Burro Canyon Formation. Saturated clays aad friable materials will likely
continue to be mobilized using standard purging technique current1y in u e for the ampli.ng
program at the Mill. Mobilized kaolinite (a cementing material within lhe formation) is expected
to be an additional continuing source of turbidity in perched well . EFRI ruscu ed the turbidity
issues with DWMRC and agreed to complete a redevelopment program for the elected we.II at
the Mill in a "good-faith" effort to reduce the turbidity level. Surging, bailing, and overpumping
were determined to be the preferred well devel pment technique ·. The rationale for u ·ing
surging and bailing followed by overpumping i con ·istent with EPA guidance and guidance
provided in other technical papers and publications.
Select, nonpumping, chloroform, nitrate and groundwater POC, wells were redeveloped during
the period from fall 2010 to pring 2011 by surging and bailing followed by overpumping. The
results of the redevelopment are provided in the Report entitled: Redevelopment of Existing
Perched Monitoring Wells White Mesa Uranium Mill, Near Blanding Utah, prepared by Hydro
Geo Chem, Inc. September 30, 2011 (the 'Redevelopment Report"). The Redevelopment Report
provides a qualitative description of turbidity behavior before and after redeveJopment and
56
provides a number of conclusions and recommendations. A copy of the Redevelopment Report
wa previously submitted under eparate cover. The Redevelopment Report was closed out by
the Director in a letter dated November 15, 2012.
As described above, the existing wells have been reviewed by the Director, and repairs,
modifications, retrofits, etc. have been made as required to conform those wells to the
requirements of Part I.E.4 of the Permit, to the extent reasonably practicable.
2.9.6.2 Ground Water Sampling
Groundwater sampling is performed in accordance with the requirements of Part I.E.5 of the
Permit, which requires that all monitoring shall be conducted in conformance with the following
procedures:
a. Sampling -grab samples shall be taken of the groundwater, only after adequate removal
or purging of standing water withi11 the well casing has been performed.
b. Sampling Plan -all sampling hall be conducted to ensure collection of representative
ample , and J·eliability and validity of groundwater monitoring data.
c. Laboratory Approval -all analy es . hall be performed by a laboratory certified by the
State of Utah to perform the tests required.
d. Damage to Monitoring Wells -if any monitor well is damaged or is otherwise rendered
inadequate for its intended purpose, the Permittee shall notify the Director in writing
within five calendar days of discovery.
e. Field Monitoring Equipment Calibration and Records -immediately prior to each
monitoring event, the Permittee shall calibrate all field monitoring equipment in
accordance with the respective manufacturer's procedures and gujdeJine . The Permittee
shall make and preserve on-site written records of such equipment calibration in
accordance with Part II.G and H of this Permit. Said records shall identify the
manufacturer's and model number of each piece of field equipment used and calibration.
In accordance with the requirements of Part I.E. I (a) of the Permit, groundwater ampling at the
MiJJ i performed in accordance with the White Mes-a Uranium. Mill Ground Water Monitoring
Quality Assurance Plan (QA.P) (the "QAP') which bas been approved by the Director. The
QAP complie with UAC R3 l7-6-6.3(I) and (L) and by reference incorporates the relevant
requirements of the Hcmdbook of Suggested Practices for Design and bistallation of Ground-
Water Monitoring Wells (EPN600/4-89/034 March 1991), ASTM Standards on Grou,zd Water
and Vadose Investigations (1996), Practical Guide for Ground Water Sampling EPA/600/2-
85/104, (November 1985) and RCRA Ground Water Monitoring Technical Enforcement
Guidance Document (1986), unless otberwi e pecified or approved by the Director. A copy of
the current version of the QAP, Date: 02-05-2022 Revision 7.7, is included as Appendix K.
2.9.7 Description and Justification of Parameters to be Monitored
The groundwater parameter to be monitored are described in Table 2.9.1.3-1. The proce · of
electing the groundwater quality monitoring parameters for the original Permit included
examination of several technical factor . The e factors are Li ted below and discussed in detail in
Section 4 on pages 9-19 of the 2004 Statement of Basis. :
57
a) The number and types of contaminants that might occur in feedstock materials
processed at the Mill;
b) Mill process reagents as a source of contaminants;
c) Source term abundance in the Mill's tailings cell solutions, based on historic
wastewater quality sampling and analysis that had been done at the Mill's TMS; and
d) A consideration of contaminant mobility in a groundwater environment, based on site
specific Ki information where available and lowest Kct values in the literature where
site specific Ki information is not available.
One additional parameter, tin, was added to the list of groundwater monitoring constituents in
2007. Tin was not originally a required groundwater monitoring parameter in the Permit, and
was omitted from the original Permit due to non-detectable concentrations reported by EFRI in
three tailings leachate samples (2004 Statement of Basis, Table 5). With the addition of the
alternate feed material from Fansteel Inc., tin was estimated to increase from 9 to 248 tons in the
tailings inventory. The Director concluded that, with an estimated Ki of 2.5 to 5, tin is not as
mobile in the groundwater environment as other metals; however, with the acidic conditions in
the tailings wastewater, tin could stay in solution and not partition on aquifer materials. As a
result, tin was added as a monitoring constituent to Table 2 of the Permit.
2.9.8 Quality Assurance and Control Provisions for Monitoring Data
Part I.E.1 ( e) of the Permit sets out some special conditions for groundwater monitoring. Under
those conditions, the Mill must ensure that all groundwater monitoring conducted and reported
complies with the following:
1) Depth to groundwater measurements -shall always be made to the nearest 0.01 foot;
2) Minimum Detection Limits -all groundwater quality analyses reported shall have a
minimum detection limit or reporting limit that is less than its respective GWCL
concentration defined in Table 2 of the Permit; and
3) Gross Alpha Counting Variance -all gross alpha anaJy ·is shall be reported with an
error term. All gross alpha analysis reported wjth an activity equal to or greater than the
GWCL, shall have a counting variance that is equal to or less than 20% of the reported
activity concentration. An error term may be greater than 20% of the reported activity
concentration when the sum of the activity concentration and error term is less than or
equal to the GWCL.
4) All equipment used for purging and sampling of groundwater shall be made of inert
materials.
As mentioned in Section 2.9.6.2 above, Part I.E.l(a) of the Permit requires that all groundwater
sampling shall be conducted in accordance with the currently approved QAP. The detailed
quality assurance and control provisions for monitoring data are set out in the QAP, a copy of
which is attached as Appendix K to this Application.
58
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of Discharge
Systems (R317-6-6.3.J)
A di cus ed in Section 2.7. l above, the Mill bas been designed as a faciHty that does not
discharge to groundwater or urface water. Tailing and other wastes a . ociated with Mill
operation are de igned to be permanently dispo ed of in the MiU s TMS. The Mill' TMS can
therefore be con idered the Mill' di. charge sy tern in that they permanently contain discharges
from the Mill's process circuits and all other Mill tailings and wastes.
The following plans and specifications and as built reports relating to TMS Cells 1, 2, 3, 4A and
4B are referenced in this ApplicaLion and were previously submitted on the dates noted below
under separate cover:
a. Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Con ulting Engineers, Inc.;
b. Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 198], prepared by D' Appolonia
Consulting Engineers, Inc.;
c. Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February l982, prepared by D' Appolonia Consulting
Engineers, Inc.;
d. Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983 prepared by Energy Fuels Nuclear, Inc.;
e. Cell 4 Design, White Mesa Projecl Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation;
f. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by EFRI (then named International
Uranium (USA) Corporation);
g. Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants; and
h. Cell 4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah, July
2008 prepared by Geosyntec consultants.
1. Cell 4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007, prepared
by Geo yntec Con uJtants
J. Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geo yntec Consultants
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-6-6.3.K)
2.11.1 General
The groundwater most likely to be affected by a potential discharge from Mill activities is the
perched aquifer.
The deep confined aquifer under White Me a is found in the Entrada and underlying Navajo
Sandstones, is hydraulically i olated from the perched aquifer, and i therefOJe extremely
unlikely to be affected by any uch potential discharge . The top of the Entrada Sand tone at the
59
site is found at a depth of approximately 1,200 feet below land surface (see the discussion in
Section 2.5 above). This deep aquifer is hydraulically i o.lated from the shallow perched aquifer
by at least two shale members of the Morrison Formation, including the Brushy Basin
(approximately 295 feet thick) and the Recapture (approximately 120 feet thick) Members.
Other geologic units are also found between the perched and deep confined aquifers that include
many layers of thin shale interbeds that contribute to hydraulic isolation of these two
groundwater systems, including: the Morrison Formation We ·twater Canyon (approximately 60
feet thick), and Salt Wash (approximately 105 feet thick) Member , and the Summerville
Formation (approximately 100 feet thick). Arte ion groundwater co11ditions found in the deep
Entrada/Navajo Sandstone aquifer also reinforce this concept of hydraulic isolation from the
shallow perched system. See the discussion on page 2 of the 2004 Statement of Basis.
2.11.2 Background Ground Water Quality in the Perched Aquifer
This Section describes the groundwater quality in the perched aquifer. See Sections 2.5.1.3,
2.5.1.4 and 2.5.1.5 above for a more detailed de cription of the perched aquifer itself, the depth
to ground water the aturated thick.ne , flow dil'ection, porosity, hydraulic conductivity and
flow system characteristics of the perched aquifer.
As mentioned in Section 2.9 .1.5 above, a significant amount of historic groundwater quality data
had been collected by EFRI and previous operators of the Mill for many wells at the facility.
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality a urance
issues. The Director also noted several groundwater quaLity issues that needed to be resolved
prior to a determination of background groundwater quality at the site ucb a · a number of
constituents that exceeded their respective GWQS and long term trend in uranium in
downgradient wells MW-14, MW-15 and MW-17, and a spatial high of uranium in those three
downgradient wells.
As a result of the foregoing, the Director required that the Existing Well Background Report be
prepared to address and re olve these issues. EFRI (formerly DUSA) prepared the Exi ting WeH
Background Report that evaluated all historic data for the thirteen exi ting wells (MW-3 ha
been abandoned as discussed in Section 2.9.6.1) for the purpo e of establishing background
groundwater quality at the site and developing groundwater compliance limits GWCLs under the
GWDP. Prior to review and acceptance of the cooclu ion. in the Existing Well Background
Report, the GWCLs were set on an interim basis in the GWDP. The interim limits were
established as fractions of the state GWQSs for drinking water, depending on the quality of water
in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells based primarily on the analysis performed in the Existing Well
background Report. It should be noted, however, that, because the GWCLs had been set at the
mean plu second standard deviation or tbe equivalent, un-impacted groundwater would
normally be expected to exceed the GWCL approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of aJl sample results, and do not oeces, arily
represent impacts to groundwater from Mill operations.
60
As required by the Permit, the Existing Well Background Report addre ·sed all available historic
data, which includes pre-operational and operational data, for the compliance monitoring wells
under the Permit that were in existence at the date of issuance of the Permit. The Regional
Background Report focuse on the pre-operational site data and the available regional data to
develop the be t available et of background data that could not have been influenced by Mill
operation . The New Well Background Report, which was required by the Perm.it, analyzed the
data collected from tbe new weUs, which were installed in 2005, to determine background
concentrations for constituents listed in the Permit for each new well.
The Exjsting Well Background Report and the New Well Background Report were prepared to
atisfy everal objectives. Fir t in the case of the Existing Well Background Report, to perform
a quality a surance evaluation and data validation of the existing and historical on-site
groundwater qualHy data in accordance with the requirements of the Permit, and to develop a
databa. e consisting of hi t.orjcal groundwater monitoring data for "existing" wells and
constituents.
Second in the case of the New Well Background Report, to compile a database consisting of
monitoring results for new wells, whlch were colJected subsequent to issuance of the Permit, in
accordance with the MiJJ's QAP data quality objectives.
Third, to perform a statistical, temporal and spatial evaluation of the exi ting well and new well
data bases to determine if there have been any impact to groundwater from Mill activities.
Since the Mill is an existing facility that has been in operation ince 1980, such an analy i of
historic groundwater monitoring data wa required in order to verify that the monitoring re ults
to be used to determine background groundwater quality at the site and GWCLs have not been
impacted by Mill activities.
Finally, since the analysis demonstrated that groundwater has not been impacted by Mill
activities, to develop a GWCL for each constituent in each well.
The Regional Background Report was prepared as a supplement to the Existing Well
Background Report to provide further support to the conclusion that Mill activities have not
impacted groundwater.
In evaluating the historic data for the existing wells, lNTERA used the following approach:
• If historic data for a constituent in a well do not demonstrate a statistically significant
upward trend then the propo ed GWCL for that con tituent i accepted a repre entative
of background, regardless of whether or not the propo ed GWCL exceed the GWQS for
that con tituent. This is becau e the monitoring re ults for the con tituent can be
considered to have been consistently representative since commencement of Mill
activities or installation of the well; and
• If historic data for a con tituent in a monitoring well represent a tati ·ticalJy significant
upward trend or downward trend in the case of pH, then the data is further evaluated to
61
determine whether the trend is the result of natural causes or Mill activities. If it is
concluded that the trend results from natural causes, then the GWCL propo ed in the
Existing Well Background Rep01t will be appropriate.
After applying the foregoing approach INTERA concluded that, other than some detected
chloroform and related organic contamination at the Mill site which is the ubject of a . eparate
inve tigation and remedial action, and that is the re ult of pre-Mill activitie ·, and some elevated
nitrate concentration · in certain wells which were considered to be a ooiated with the
chloroform plume, there have been no impacts to groundwater from MiJJ activities (See Section
2.16.1 below relating to the chloroform contamination and Section 2.16.2 [elating to the nitrate
contamination).
In reaching this conclusion, INTERA noted that, even though there are a number of increasing
trends in various constituents at the site, none of the trends are caused by Mill activities, for the
following reasons:
• There are no noteworthy correlations between chloride and uranium iu wells with
increa ing trends in uranium, other than in upgradient well MW-19 and MW-J 8, which
INTERA concluded are not related to any potential tailings eepage. INTERA noted that
it is inconceivable to have an increasing tret1d in any ther parameter cau ed by seepage
from the Mill tailings without a corresponding increa e in chloride;
• There are ignificant increasing trends upgradient in MW-J , MW-18 or MW-19 in
uranium, ulfate, TDS iron, elenium thallium, ammonia and fluoride ,md far
downgradient in MW-3 in uranium and elenium sulfate, TDS and pH (decrea ing
trend). INTERA concluded that thi provi.des very strong evjdence that natural force at
the site are causing increasing trend in these con tituent (decrea ing in pH) in other
wells and supports the conclusion that natural force are also cau ing increa ing trends in
other constituents as well; and
• On a review of the spatial distribution of constituents, it is quite apparent that the
constituents of concern are dispersed across the site and not located in any systematic
manner that would suggest a tailings plume.
JNTERA concluded that, after extensive analysi. of the data and given the conclu ion that there
have been no impacts to groundwater from Mill activities, the GWCL. ·et out in TabJe J 6 of the
Existing Well Background Report are appropriate and are indicative of background ground
water quality. INTERA did advj e, however, that propo ed GWCL for all the trending
con tituents should be re-evaluated upon Permit renewal to determine if they are till appropriate
at the time of renewal. See Table 16 of the Existing Well Background Report for INTERA
calculation of background ground water quality as repre ented by the proposed GWCLs. See
Section 6.0 of the Existing Well Background Report for a discus ion of lhe tati tical manner
used to calculate each proposed GWCL.
Upon approval of the Exi ting Wells Background Report, the Director required that the New
Well Background Report be prepared to addre and resolve similar issues in the newer wells.
EFRI prepared the New Well Background Report that evaluated all historic data for the nine new
wells for the purpo e. of establi hing background grmmdwater quality at the site and developing
62
GWCLs under the GWDP. Prior to review and acceptance of the conclusions in the New Well
Background Report, the GWCLs for the new wells were set on an interim basis in the GWDP.
The interim limits were established as fractions of the state GWQSs for drinking water,
depending on the quality of water in each monitoring well at the site.
In evaluating the new well data, INTERA used the same approach in the New Well Background
Report that was used in the Existing Well Background Report for existing well data. In addition,
INTERA compared the groundwater monitoring results for the new wells to the results for the
existing wells analyzed in the Existing Well Background Report and to the pre-operational and
regional results analyzed in the Regional Background Report. This was particularly important
for the new wells because there is no historic data for any constituents in those wells dating back
to commencement of Mill operations. A long-term trend in a constituent may not be evident
from the available data for the new wells. By comparing the mean concentrations of the
constituents in the new wells to the results for the existing wells and regional background data,
INTERA was able to determine if the constituent concentrations in the new wells were consistent
with background at the site.
INTERA concluded that after applying the foregoing approach, there have been no impacts to
groundwater in the new monitoring wells from Mill activities. INTERA concluded that the
groundwater monitoring results for the new wells are consistent with the results for the existing
wells analyzed in the Existing Well Background Report and for the pre-operational and regional
wells, seeps and springs analyzed in the Regional Background Report. INTERA noted that there
were some detections of chloroform and related organic contamination and degradation products
and nitrate and nitrite in the new wells, which are now the subject of two separate investigations
(see Sections 2.16.1 and 2.16.2), but that such contamination was the result of pre-Mill activities.
As a result, given the conclusion that there have been no impacts to groundwater from Mill
activities, INTERA concluded that the calculated GWCLs for new wells set out in Table 10 of
the New Well Background Report are appropriate, and are indicative of background ground
water quality. Again, INTERA noted that GWCLs for trending constituents should be re-
evaluated upon Permit renewal to determine if they are still appropriate at the time of renewal.
Additionally, the Flow Sheet states to "Consider an Alternate Approach" for determination of
GWCLs in trending constituents. In its report, INTERA recommended, as an alternative, that
GWCLs be set at the highest of a) the Flow Sheet approach, b) the highest historical value or c)
the fractional approach; provided that in no event would the GWCL be less than mean plus 20% .
This approach was rejected by the DRC in favor of the mean plus two standard deviation or
equivalent. See Table 10 of the New Well Background Report for INTERA's calculation of
background ground water quality as represented by the proposed GWCLs. See Section 2.2 of the
New Well Background Report for a discussion of the statistical manner used to calculate each
proposed GWCL.
The University of Utah Study confirmed INTERA's conclusions in the Background Reports that
groundwater at the site has not been impacted by Mill operations (see the discussion in Section
1.3 above).
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed during the New Well
63
Background Report. IL houJd be noted bowever, that, because the GWCLs were set at the mean
plus two tandard deviation , or the equivalent un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedance. are
expected in approximately 2.5% of al.I ample re ults, and do not necessarily represent impacts to
groundwater from Mill operations.
The GWDP dated January 20 20 IO required the completion of eight con ·ecutive quarters of
groundwater ampling and anaJy is of MW-20 and MW-22, and later ubmjttal of another
Background Report to determine if weUs MW-20 and MW-22 hould be added a POC
monitoring weJls. Data from MW-20 and MW-22 were analyzed in the pre-operational and
regional background addendum (INTERA 2007a)· however there wa not a complete data et at
the time. Although well MW-20 and MW-22 were in ·cal.led in 1994, they were not ampled
regularly until the second quarter of 2008. The~ ejghth full round of ampling wa, completed
dming the fir t quarter of 2010, and EFRI submitted to the Director the Background
Groundwater Quality Report for Wells MW-20 and MW-22 for Denison Mines (USA) Corp. 's
White Mesa Mill Site, San Juan County, Utah, June 1, 2010, prepared by INTERA, Inc. (the
"MW-20 and MW-22 Background Report"). DWMRC classified MW-20 and MW-22 as
general monitoring wells, and GWCLs have not been e tabli. hed for the e well . MW-20 and
MW-22 are sampled semiannually. The background report for MW-20 and MW-22 upport the
conclusions of the previous background assessments that groundwater at the site ha n t been
impacted by Mill operations.
Part I.H.6 of the GWDP dated June 21, 2010 requjred the in tallation of three hydraulically
downgradient wells adjacent to Tailings Cell 4B (MW-33, MW-34, and MW-35) prior to
placement of olids or fluid in Cell 4B. The purpo e of the e monitoring well wa to provjde
earl y detecti n of potential impact: to the hallow groundwater from Tailings Cell 4B. EFRI
installed MW-33 MW-34 and MW-35 as required. Of thee three weJls installed near tailing
Cell 4B, only MW-35 was hydraulically acceptable, with five feet or more of saturated thickness.
MW-35 was sampled quarterly since fourth quarter 2010 to collect eight statistically valid data
points for the comp.letion of the Background Report and calculation of GWCLs. MW-33 and
MW-34 had insufficient water for sampling, with aturated thicknesses less than five feet. MW-
33 is completely dry, and no samples or depth to water measurements are collected from this
well. Quarterly depth to water is measured in MW-34, but no sampling or analysis is required.
Part l.H.4 of the February 15 2011 GWDP required the installation of two wells hydraulically
downgradient of Tailing CeU 4B as replacement for MW-33 and MW-34. EFRI installed
MW-36 and MW-37 as required. MW-36 and MW-37 were sampled quarterly beginning in the
third quarter 2011 to collect eight statistically valid data points for the completion of the
Background Report and calculation of GWCLs.
The Background Report for wells MW-35, MW-36, and MW-37 was submitted to the Director
on May 1, 2014. The findings of the Background Analysis for wells MW-35, MW-36, and MW-
37 support previous conclu ·ions that the groundwater at the Mill is not being affected by any
potential TMS seepage. The Director incorporated MW-35, MW-36 and MW-37 in a , ub equent
revision of the GWDP and these wells are , ampled as required. The background reporl for MW-
35, MW-36 and MW-37 support the conclusions of the previou background as e sments that
groundwater at the site has not been impacted by Mill operations.
64
Three wells have been added by EFRI in response to request from the UMUT far cro -gradient
to the TMS to provide water level data and to provide additional information on ite geology and
naturally occurring geochemical behavior ·. The three well MW-38, MW-39 and MW-40, were
in tailed in February 2018. The Background Report for well MW-38, MW-39 and MW--40 was
ubmitted to the Director on June 7, 2021 after sufficient data had been collected to complete the
stati ticaJ evaluation. The finding· of the Background Analy i for well · MW-38, MW-39, and
MW-40 support previou conclu ion that the groundwater at the Milli not being impacted by
any potential TMS seepage. The Director approved the background report for MW-38 MW-39,
and MW-40 by Jetter dated June I 6 2021. MW-38, MW-39, and MW-40 will be incorporated
into a ub equenl revi. ion of the GWDP. Until uch time a the e well are incorporated into the
GWDP, they are sampled on a quarterly ba is.
Part I.G.2 of the Permit provides that out-of-compliance . tatu exi t when the concentration of a
p llutant in two consecutive sample from a compliance monitoring point exceeds a GWCL in
Table 2 of the Permit. Per the requirement of Part I.G.4(c) of the Permit, EFRJ is required to
prepare and ubmit written pJaus and time chedule., for Director approval, to fully comply with
the requirements of Part I.G.4(c) of the Permit reJati11g to any uch out-of-compliance situation,
including, but not limited to:
(i) submittal of a written assessment of the source(s);
(ii) submittal of a written evaluation of the extent and potential dispersion of said
groundwater contamination; and
(iii) ubmittal of a written evaluation of any and all potential remedial actions to restore and.
maintain ground water quality at the facility for the po.int of compliance well · and
contaminants in que tion to en ure that: l) halJow groundwater quality at the facility
will be restored and 2) the contaminant concentration. in ·aid point of compliance well
will be returned to and maintained in compliance with their respective GWCLs.
Twenty-five Plan and Time Schedules and twenty-two SAR have been ubmitted to address
consecutive exceedances which have been noted in wells ince thee tablishmenl of the GWCLs
in the January 20, 2010 GWDP. The Plans and Time Schedule and the SARs are inclllded in
Table 2.11.2-l. These Plans and Time ScheduJe and SAR were previou Jy submitted under
separate cover.
Plan and Time Schedules submitted to the Director have been approved by the Director in letters
to EFRI. The submission dates and the associated DWMRC approval dates of the Plans and
Time Schedules and the associated SARs are listed on Table 2.11.2-1.
Given the varied background groundwater quality at the site, previously identified rising trends
in some wells and other factors, it cannot be assumed that consecutive exceedances of a
constituent in a monitoring well means that contamination has been introduced to groundwater in
that well. The exceedances may very well be the result of background influences. The approach
in these Plans therefore is to first determine if the recent exceedances are the result of
65
background influences. If they are determined to be the result of background influences, then no
remedial actions are required. If, however, they are determined to not be the result of natural
background influences, then further analyses will be required.
Based on the information available in the SARs, EFRI believes that the GWCL exceedances
observed are the result of natural influences and reflect the need to adjust some of the GWCLs
for the site. In addition to the SARs listed in Table 2.11.2-1, EFRI completed a supplementary
investigation of rising trends present in MW-24/MW-24A.
Tbe results of the analytical and te t data collected during the MW-24A study demon traced that
natural proce-ses unrelated to dispo al of material in the TMS can account for the behavior of
all trace metal of concern, as well as fluoride, in groundwater at MW-24 and MW-24A. Bottle-
roll test results indicated that naturally-occurring trace metals can be mobi.lized at concentrations
similar to or greater than in groundwater even without a large pH decrea e, suggesting that
agitation alone, such as would occur during routine purging and sampling of low permeability
wells such as MW-24A, could result in metals mobilization.
The perched g.rollndwater y. tern ho ted by the Burro Canyon Formation and Dakota Sandstone
does not approach teady tate over much of the monitored area. A large part of the site perched
water ystem is in a transient state and affected by long-term changes in water levels due to past
and current activities unrelated to U1e di posal of material. to the TMS. Based on the results of
the MW-24A tudy EFRI has voluntarily agreed to implement a Pha e 2 . tudy to determine what
geochemical and hydrogeological influence are pre ent that may be affecting monitoring data
collected at other well aero 'S the Mill , ite. Thi voluntary study will commence in mid to late
2022.
2.11.3 GWCL Determination for Field pH
During the completion of the 4th Quarter 2010 Quarterly Groundwater Monitoring Report EFRl
noted eleven perched groundwater monitoring well with pH measurements below the GWCL..
These wells are located upgrad.ient, cro s-grad.ient, and downgradient of the Mill and TMS.
Investigation into the eleven pH GWCLs in que tion fodicated that the GWCL for groundwater
pH in all wells established in the January 20, 20 IO GWDP were erroneou ly ba ed on historic
laboratory results instead of field measurement as contemplated by Table 2 of the GWDP. EFRI
noLified DWMRC that the existing GWCLs for groundwater pH were incorrectly based on
laboratory results rather than field measurements and propo ed to ubmit revised descriptive
statistics for field pH to be used as revised pH GWC by the end of the econd quarter 2011.
EFRI received approval from DWMRC to proceed with the revision of the pH GWCLs based on
field measurements. The data processing and statistical assessments necessary to revise the
GWCLs based on historic field pH data were completed. The data proce sing and tati ticaJ
assessments completed were based on the DWMRC-approved method · in the logic flow diagram
included as Figure 17 of the New Well Background Report. Following the stati tical evaluation
of pH data, EFRI compared the Mill groundwater pH data from the 2nd Quarter of 2011
including accelerated ampling results through June 2011 , and noted that all of the June 2011
groundwater result ·, and many of the other results from the 2nd Quarter, were already outside
the revi ed GWCLs to be propo ed based on the logic flow diagram.
66
It was noted that the hi. torical trend of decrea ing pH, which wa addre ed in the Background
Study Report , appeared to be present in nearly all well · throughout the Mill ite area, including
upgradient downgradient and cro. -gradient wells in the groundwater monitorjng program. A
of June 2011, all groundwater monitoring well demon trated a downward trend in the fieJd pH
data over time.
EFR[ notified DWMRC that the 2nd Quarter 20 I l data exceeded the recalculated GWCLs. EFRl
advi ed DWMRC that, as a re ult of these finding , EFRI did not believe it wa appropriate to
contfoue with it · effort: to re et the GWCL for pH ba ed on field pH data a originally
planned, but in tead it appeared that it would be more appropriate to undertake a tudy to
determine whether the decreasing trend in pH are due to natural influence and, if . o to
determine a more appropriate way to determine GWCLs.
EFRI and DWMRC agreed on further inve. ligation to be completed, as well a the ·teps and
mile tone date to be incorporated into a pH Report. The procedures for inve ·tigating the
decrea ing ite-wide pH trend i documented in the Plan to Investigate pH Exceedances in
Perched Groundwater Monitoring Wells White Mesa Uranium Mill Blanding, Utah, Prepared by
HydJO Geo Chem, Inc, April J3 2012 (HGC 2012a) (the pH Plan and Time Schedule'). The
pH Plan and Time Schedule de cribed the pH awe. tigation which wa incorporated into the July
12, 20 J 2 Stipulated Con ent Agreement referred to above. The pH Plan and Time Schedule wa.
previously submitted under separate cover.
The Stipulated Consent Agreement of July J 2, 20 L2 specified that a pH Report be completed as
well a a eparate inve tigation into the natural phenomenon that wa causing the ite-wide trend.
As a result two report investigating and describing the causes of the pH trend were completed.
The e report are the pH Report dated November 9 2012 (INTERA 2012b) and the
Investigation of P)rite in the Perched Zone, White Mesa Uranium Mill ("Pyrite Report'), dated
December 7 2012 (HGC, 2012c).
The pH Report con i t. of a tati ·tical and geochemical evaluation of the decline in pH in
groundwater wells at the Mill. The primary conclusion from the pH Report was that the
hi toricaJ trend of decrea:ing pH, which was addre ed in the Background Study Reports,
appear. to be present in nearly all wells tlu·oughout lbe Mill site area, including upgradient
downgradient and cro sgradient wells in the groundwater monitoring program and there seems
to be no abatement of the trend. The wide-pread nature of the decrease in pH in upgradient,
downgradient and cro · ·gradient well sugge ts that the pH decrea e result from a natural
phenomenon unrelated to Mill operation , which i al o confirmed by the indicator parameter
analysi conducted as patt of the pH Report. A discus ·ed in The Pyrite Report, the mo ·t likely
cau e of declining pH across the site appear · at this time to be the oxidation of pyrite, po ibly
due to increasing water level. at the ite attributed primarily to recharge of wildlife pond. and/or
the introduction of oxygen into the perched water zone a a re ult of increased groundwater
ampling frequency. Ba ed on the concJa. ion that the pH trend wa. caused by natural
phenomenon, the pH Report recalculated the Groundwater Compliance Limit ("GWCL ") for
all compliance monitoring well at the ite.
The Pyrite Report evaluated and quantified the presence of pyrite throughout the Mill site, and
identified and quantified the mechanism by which it contributes to the sitewide decline in pH.
67
The results of the inve tigation support pyrite oxidation as the most likely mechanism to explain
decreases in pH and increases in sulfate concentrations in site wells and indicates that pyrite
must be considered in assessing perched water cbemi try in the future. The complex interaction
of the various naturally occurring factor · identified at the ite, including the presence of pyrite at
varyi11g concentrations, variable oxygen tran port, and variable carbonate species concentrations,
i expected to re ult in relatively large background variation in pH, sulfate (and therefore TDS)
concentration , a well as variation in background concentrations of pH sensitive analyte. such
as metals. The expected impact of the e various factors on pH and analyte concentration , all of
which are unrelated to Mill operations, is generally consi tent with site analytical results,
suggesting that pyrite oxidation plays a significant role in perched water chemistry at the site.
The primary conclusion from the activities conducted to date and described above is that the pH
trends are not due to potential TMS cell leakage or Mill activities, but to a natural phenomenon
unrelated to Mill operations.
In an effort to diminish any trends that may have resulted in whole or in part, from increasing
water levels attributed to the Wildlife ponds at the Mill, EFRI discontinued recharging the two
most northern of these ponds, commencing in March 2012.
Although decreasing pH trends occurred in nearly all MW-series wells until about 2016, pH
began to tabilize and then increase. The mechani m(.) for thi. apparently ite-wide change from
generally decrea ing to increa ing pH, affecting well that, with i:e, pect to perched groundwater
flow, a.re located far upgradient far cros -gradient and far downgradient of the TMS in addition
to wells located near and within the TMS, are not known at this time. Such cban_ge could re ·ult
from several potential mechanisms.
First, the pH increases may result from reduced acid generation caused by a general reduction in
pyrite reactivity near site wells. Reduced pyrite reactivity could result from passivation of pyrite
surfaces caused by increases in dissolved oxygen via the mechanisms discussed above. The
passivation process could potentially have been accelerated by the site-wide well redevelopment
effort that occurred during late 2010 and early 2011.
Second, the pH increases may result from reduced acid generation caused by degradation and
reduction in concentration of the more reactive fractions of pyrite present near the wells. The
more reactive fractions would include the generally more fine-grained fractions (which have a
larger ratio of surface area to volume); or perhaps the fraction composed of the less stable
polymorph of iron sulfide (marcasite).
Third, the change in pH trends could be related, at least in part, to the non-steady state conditions
that exist over much of the site due to long-term changes in water levels related to former
seepage from formerly used wildlife ponds and due to changes induced by chloroform and nitrate
pumping.
Finally although the . pecific mechanj ms can only be speculated upon, pH changes could
potentially re. ult from long-term change in groundwater chemistry related to climatic variation.
For example, groundwater cbemi try change could result from changes in recharge rates
68
resulting from changes in precipitation amounts; and changes in groundwater chemistry could
result from changes in precipitation pH.
Regardless of the specific potential mechanism(s) however, the po t-20 L6 ite-wide pH increase
measured in site wells cannot result from a TMS impact because TMS olutions have very Jow
pH. The post-2016 increasing pH trends indicate that TMS operation has not impacted
groundwater.
2.11.4 Quality of Ground Water at the Compliance Monitoring Point
The analytical results from groundwater sampling are reported quarterly in Groundwater
Monitoring Reports, which are filed with the Director pursuant to Part I.F.1 of the Permit.
2.12 Compliance Sampling Plan (R317-6-6.3.L)
The Mill's plan for sampling groundwater compliance monitoring points is discu ed in detail in
Section 2.9.1.3 above, and the plan for sampling the leak detection systems in CeU 4A and 4B is
discussed in Sections 2.15.3 and 2.15.4 below. This section addresses other sampling required
under the Permit. As the Mill is designed not to discharge to groundwater, there are no flow
monitoring requirements in the Permit.
2.12.1 Tailings Cell Wastewater Quality Sampling Plan
Part I.E.10 of the Permit requires that, on an annual basis, EFRI collect wastewater quality
amples from each wastewater ource at each tailings ceH at the facility, includfog wa tewater
in urface impoundment , and limes drain . The sampling i conducted in August of each
calendar year in compliance with an approved plan. The Tailings SAP (dated July 8 2016) was
approved by the Director on Augu t 8 2016. A copy of the approved Tailings and Slim.es Drain
Sampling Program Revision 3.0, July 8, 2016 is attached a Appendix L to this Applkation.
The purpose of the Tailings SAP is to characterize the source term quality of all tailings cell
wastewaters, including impounded wastewaters or process waters in the TMS, and wastewater or
leachates collected by internal limes drains. The Revision 3.0, Tailings SAP requires:
• Collection of samples from the pond area of each active cell and the slimes drain of each
cell that has commenced de-watering activities;
• Sample · of tailings and slimes drain material will be analyzed at an off ite contract
laboratory and subjected to the analytical parameters included in Table 2 of the Permit
and general inorganics listed in Part I.E.l(d)(2)(ii) of the Permit, as well a-semi-volatile
organic compounds;
• A detailed description of all sampling methods to be employed;
• The procedures utilized to conduct these analyses will be standard analytical methods
utilized for groundwater sampling and a.· shown in Section 8.2 of the QAP;
• The contracted laboratory will be certified by the State of Utah in accordance with UAC
R317-6-6. l 2A; and
• 30-day advance notice of each annual sampling event must be given, to allow the
Director to collect split samples of all tailings cell wastewater sources.
69
The tailing and lime drain ampJing events are subject to the currently approved QAP, unless
otherwi e specifically modified by the Tailing SAP to meet the specific needs of this type of
ampling. Tbe QAP has been approved by the Director and satisfies the most applicable
requirements of the following reference , unless otherwise specified by the Director through his
approval of the Tailings SAP:
• Standard Methods for the Examination of Water and Wastewater, twentieth edition,
1998; Library of Congress catalogue number: ISBN: 0-87553-235-7;
• E.P.A. Methods for Chemical Analysis of Water and Wastes, 1983; Stock Number EPA-
600/4-79-020;
• Techniques of Water Resource Investigations of the U.S. Geological Survey, (1998);
Book 9;
• Monitoring requirement in 40 CFR part 14 l and 142, 2000 ed. Primary Drinking
Water Regulations and 40 CFR parts 264 and 270, 2000 ed.; and
• National Handbook of Recommended Methods for Wat er-Data Acquisition GSA-GS
edition; Book 85 AD-2777, U.S. Government Printing Office Stock Number 024-001 -
03489-1.
2.12.2 White Mesa Seeps and Springs Sampling Plan
The in.itial Permit required EFRl to ubmil a plan for groundwater ampJing and analysi of all
eeps and spring found downgradient or cro s gradient from the TMS for DiJector review and
approval. Tbe Djrector approved the plan on March 17, 2009. Pur uant to a reque. t from the
DWMRC, the plan wa rev.i ed in 2016. A copy of the Sampling Plan.for Seeps and prings in
the Vicinity of the White Mesa Uranium Mill, Revi ion: 3 November 11 2019 is attached a
Appendix C to this Application. The Sampling Plan for Seeps and Springs in the Vicinity of the
White Mesa Uranium Mill wa approved by DWMRC on November 22, 2019.
Under the Seep. and Spring. SAP sampling i conducted on an annual basis between May 1 and
July 15 of each year, to the extent ufficient water is available for sampling, at six identified
eep. and . pr.ing near the Mill. The ampling locations were selected to correspond with those
. eeps and prings sampled for the ini tial Mill site characterization performed in the 1978 ER,
plus additional ites located by EFRI, the United States Bureau of Land Management and Ute
Mountain Ute Indian Tribe representatives.
Sample are analyzed for all groundwater monjtoring parameters found .in Table 2 of the Permit.
The laboratory procedures utilized to conduct the analyse · of parameter listed in Table 2 are the
, ame a utilized for groundwater arnpling and a hown in Section 8.2 of the QAP. In addition
to these laboratory parameter , the pH, temperature, redox potential, DO and conductivity of
each ample will be mea ured and recorded in the field. Laboratories selected by EFRI to
perform analyse· of eeps and springs sampl are required to be certified by the State of Utah in
accordance with UAC R317-6-6.12.A.
The seeps and pring sampling events are subject to the currently approved QAP unless
otherwise specifically modified by the Seeps and Spring SAP to meet the specific needs of this
type of sampling. The QAP has been approved by the Director and ati fie the applicable
70
requirement of the references listed in Section 2.12.1 above, unless otherwise specified by the
Director thrnugh his approval of the Seeps and Springs SAP.
2.12.3 Monitoring of Deep Wells
Due to the fact that the deep confined aquifer at the site is hydraulically isolated from the
shallow perched aquifer ( see the discussion in Section 2.11.1 above) monitoring of the deep
aquifer is not required under the Permit.
2.13 Description of the Flooding Potential of the Discharge Site (R317-6-6.3.M)
2.13.1 Surface Water Characteristics
The Mill site is located on White Mesa, a gently loping (l % SSW) plateau that i · phy ically
defined by the adjacent drainages which have cut deeply into regional sand tone formations.
There is a small drainage area of approximately 62 acres (25 ha) above the . ite that could yield
surface runoff to the site. Runoff from the mesa i conveyed by the general urface topography
to either Westwater Creek, Corral Creek, or to the outb into an unnamed branch of Cottonwood
Wa h. LocaJ porou oil condition topography and low average annual rainfall of 13.3 inches
(reported as 11.8 by Dames and Moore in bj tori reports) cau e these streams to be
intermittently active re ponding to pring nowmelt and local rainstorms (particularly
thunderstorms). Surface mnoff from approximately 624 acres of the Mill drains westward and is
collected by We twater Creek, and runoff from another 384 acres drains east into Corral Creek.
The remaining 4,500 acres of the outhern and outhwe tern portions of the site drain indirectly
in to Cottonwood Wa h (1978 ER, p. 2-143). The ite and vicinity drainages carry water only on
an intermittent basis. The major drainages in the vicinity of the Mill are depicted in Figure 12
and their drainage areas are tabulated in Table 2.1.3.1-1. Total runoff from the mesa (total yield
per watershed area) is estimated to be less than 0.5 inch annually (1978 ER, p. 2-143).
There are no perenniaJ urface waters on or in the vicinity of the Mill site. This is due to the
gentle slope of the me a on which the . ite is located, the low average annual rainfall of 13.3
inches per year at Blanding, .local oil characteristics and the porous nature of local stream
channels. Prior to MilJ con Lruction three small ephemeral catch basins were present to the
northwest and northeast of the Mill site.
Corral Creek is an intermittent tributary to Recapture Creek. The drainage area of that portion of
Corral Creek above and including drainage from the eastern portion of the site is about 5 square
miles. Westwater Creek is also an intermittent tributary of Cottonwood Wash. The Westwater
Creek drainage basin covers nearly 27 square miles at its confluence with Cottonwood Wash 1.5
miles west of the Mill site. Both Recapture Creek and Cottonwood Wash are similarly
intermittently active, although they carry water more often and fo.r longer period of time due to
their larger water bed area . They both drain to the ·outh and are tributarie. of the San Juan
River. The confluence of Recapture Creek and Cottonwood Wa b with the San Juan River are
approximately 18 mile outh of the Mill site. The Sao Juan River a major tributary for the
upper CoJorado River has a drainage of 23,000 square miles measured at the USGS gauge to the
we t of Bluff Utah () 978 ER, p. 2-130).
71
Storm runoff in these streams is characterized by a rapid rise in flow rates, followed by rapid
recession primarily due to the small storage capacity of the surface soils in the area. For
example, on August 1, 1968, a flow of 20,500 cubic feet per second was recorded in Cottonwood
Wash near Blanding. The average flow for that day, however, was only 4,340 cubic feet per
second ("cfs"). By August 4, the flow had returned to 16 cfs (1978 ER, p. 2-135). Monthly
streamflow summaries as updated from Figure 2.4 of the FES are presented in Figure 13 for
Cottonwood Wash, Recapture Creek and Spring Creek. Flow data are not available for the two
smaller water courses closest to the Mill site, Corral Creek and Westwater Creek, because these
streams carry water infrequently and only in respon ·e to local heavy rainfall and snowmelt,
which occurs primarily in the months of April, Augu t and October. Flow typically ceases in
Corral Creek and Westwater Creek within 6 to 48 hours after precipitation or snowmelt ends.
2.13.2 Flood Protection Measures
The Mill was designed and constructed to prevent runon or runoff of storm water by a) diverting
runoff from precipitation on the Mill site to the TMS; and b) diverting runoff from surrounding
areas away from the Mill site via three drainage ditches that have been constructed north
(upslope) of the Mill facility.
A detailed description of the flooding potential of the site, including the 6-hour probable
maximum precipitation (which is more conservative than the 100-year flood plain), and
applicable flood protection measures is provided in the UMETCO Minerals Corporation: White
Mesa Mill Drainage Report for Submittal to NRC, January 1990.
In addition to the foregoing designed control features, the facility has developed a Stormwater
Best Management Practices Control Plan which includes a description of the site drainage
features and the best management practices employed to ensure appropriate control and routing
of stormwater. A copy of the Mill's Stormwater Best Management Practices Plan is included as
Appendix G to this Application.
2.14 Contingency Plan (R317-6-6.3.N)
As required by Part I.H.15 of the Permit, the Mill has a Contingency Plan for regaining and
maintaining compliance with the Permit limits and for re-establishing best available technology
as defined in the Permit. A copy of the most current approved version of the Mill's Contingency
Plan is included as Appendix M to this Application.
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting Failure
of the System (R317-6-6.3.0)
Part I.D. of the Permit sets out a number of DMT and BAT standards that must be followed. Part
I.E. of the Permit sets out the Ground Water Compliance and Technology Performance
Monitoring requirements, to ensure that the DMT and BAT standards are met. These provisions
of the Permit, along with the DMT Plan, Cell 4A and Cell 4B BAT Monitoring Operations and
Maintenance Plan and other plans and programs developed pursuant to these Parts, set out the
methods and procedures for inspections of the facility operations and for detecting failure of the
system.
72
In addition to the programs discussed above, the following additional DMT and BAT
performance standards and associated monitoring are required under Parts I.D and I.E. of the
Permit
2.15.1 Existing Tailings Cell Operation
Part I.D.2 of the Permit provides that authorized operation and maximum disposal capacity in
each of the existing TMS CeJJs 1, 2 and 3 hall not exceed the levels authorized by the Mill
License and that under no circumstance · shall the freeboard be less than three feet, as measured
from the top of the FML. Part I.E.7(a) of th Permit require · that the wa tewater pool elevation
in Cells 1 and 3 must be monitored weekly to en ure compliance with the maximum wastewater
elevation criteria mandated by Condition 10.3 of the Mill Licea e. However, a letter from the
Director dated January 27, 2011, which approved the use of Cell 4B, and a subsequent letter
dated March 14, 2011, stated that authorization of the use of Cell 4B and approval of the DMT
and Cell 4A Operations and Maintenance ("O&M") Plans effectively eliminated the former
freeboard elevation requirements for tailings Celli 3 and 4A.
Part I.D.2 further provide that any modification by EFRI to any approved engineering design
parameter at these exi ting TMS cell require prior Director appr val, modification of the
Permit and i. uance of a con t:ruction permit.
2.15.2 Existing Facility DMT Performance Standards
Part I.D.3 of the Permit requires EFRI to operate and maintain certain Mill site facilities and the
exi ting TMS to minimize the potential for wastewater release to groundwater and the
environment, including, but not limited to the following additional DMT compliance measures
described in Sections 2.15 .2.1 through 2.15 .2.5 below.
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3
Parts I.D.3 (a) and (d) require that at all time EFRl operate and maintain Cell l 2 and 3 to
prevent groundwater quality conditions in any nearby monitoring well · from exceeding the
GWCLs in Table 2 of the Permit. The groundwater compliance monjtoring program de cribed
in detail in Section 2.9.1.3, is designed to provide early detection of a y tem failure in the TMS.
2.15.2.2 Slimes Drain Monitoring
The Permit revi ions is. ued prior to the January 20 I 8 renewal included a provi ion at Pait
l.D.3(b)(l) (now I.D.3(b)(3)) to calculate the phreatic surface above the ·limes drain evacuation
pump and with that data to calculate the three-year running average of that elevation. The
three-year mnning average would then be plotted along with previou. years calcu.lations. The
mea. urement. that facilitate that calculation were taken quarterly o the p.lot would pre ent the
tlu·ee-year running averages in temporal sequence. EFRI wa required to maintain a downward
trajectory with no more than two consecutive calculations failing to show a downward trend.
That formula erved to encourage EFRI to do the maximum possible to dewater. Prior to the
2018 i uance of the renewal Permit, EFRI ha been required to calculate accorcLing to that
formula DWMRC staff ha noticed that the pace of dewatering bas decrea ed and approached a
73
horizontal asymptote. Factors beyond EFRI s control have intervened. However, EFRI has
installed piezometer · and bas collected sample of the tailings to analyze what is happening in
the tailing mass. There wa Lhe potential that EFRI could be in violation of this provision of the
Permit through no fault of it. own bllt becau e the natural system would not cooperate with the
regulatory authority.
EFRJ ha since placed several feet of soil on Cell 2 to complete the primary radon barrier. That
material ba surcharged lhe tailing ma , creating exce pore pre ure as the fluid i
compressed along with the tailings. A a result of the increased pore pres ure, the phreatic
urface ha risen, and the amount of fluid available for pumping has al o increa. ed. DWMRC
has exercised discretion in not citing EFRI for missing wba amounted to an arbitrary date 'et by
the Division, before it could be known how long the proce. would actuaHy take ba ed on the
conditions of the system. The circumstances were beyond the rea onable control of EFRI.
Moreover, the GWDP has been modified to remove the arbitrary date.
Currently, Part I.D.3(b)(l) of the Permit requires that EFRI at all time maintain the average
wastewater head in the slimes drain access pipe to be s low as rea onably achievable
(' ALARA") in each tailings disposal cell in accordance with the approved DMT Plan.
Compliance is documented in the average annual wastewater recovery report, which verifies that
the maximum fluid volume which could practicably be extracted from the slimes drain in
accordance with the systems in place was removed.
Part I.E.7(b) of the Permit requires that EFRI monitor and record quarterly the depth to
wastewater in the slimes drain access pipes a de ·cribed in the currently approved DMT Plan at
Cell 2, and upon commencement of de-watering activities, at Ce!J 3, in order to en ure
compliance with Part I.D.3 of the Permit. Specifically Part I.E.7(b) requires:
1. Perform at least 1 separate slimes drain recovery test at each disposal cell in each
quarterJ y period of each calendar year that meets the requirement of Part I.D.3
2. De ignate operate maintain, and preserve one water level measuring point at the
centerline of the .lime drain acce s pipe that has been surveyed and certified by a Utah
licensed engineer or land surveyor,
3. Make all slimes drain recovery head test (depth to fluid) measurements from the same
designated water level measuring point, and
4. Record and report all fluid depth measurements to the nearest 0.01 foot.
5. For Cell 3 these requirements shall apply upon initiation of tailings de-watering
operations.
At this time, de-watering of Cell 3 has not commenced.
Quarterly mea urements of the wastewater bead in CeU 2 are reported in the quarterly DMT
report. submitted to DWMRC pursuant to the requirement of Part I.F.l, Table 7 of the GWDP.
The historic measurement · for 2009 thrnugh 2022 are included graphicaUy in Appendix J.
Annual compliance assessments pursuant to Part I.D.3.b of the GWDP are submitted to
DWMRC on or before March 1 of the following year. Part l .D.3.b specifically requires:
TMS Cells 2 and 3 -including the following performance criteria:
74
1. Slimes Drain Maximum Allowable Head -the Permittee shall at all times maintain the
average wastewater recovery head in the slimes drain access pipe to be as low as
reasonably achievable (ALARA) in each tailings disposal cell, in accordance with the
currently approved DMT Monitoring Plan.
2. Quarterly Slimes Drain Recovery Test -effective July 11, 2011, the Permittee shall
conduct a quarterly slimes drain recovery test at each tailings cell slimes drain that meets
the following minimum requirements:
i. Includes a duration of at least 90-hours, as measured from the time that pumping
ceases, and
ii. Achieves a stable water level at the end of the test, as measured by three consecutive
hourly water level depth measurements, with no change in water level, as measured to
the nearest 0.01 foot.
3. Annual Slimes Drain CompUance -The Perm.ittee hall submit an annual report on or
before March 1 following the reporting year which includes but is not limited to; 1)
Monthly volumes of fluid pumped from the slime draim for each applicable tailings
disposal cell; 2) The results of all quarterly slime drain recovery tests; 3) A calculation
of average annual wastewater recovery elevation in the slimes drain access pipe, and; 4)
The annual report shall include an assessment and verification that the maximum fluid
volume which could practicably be extracted from the slimes drain in accordance with
the systems in place was removed.
Appendjx J includes the Cel1 2 slimes drain annual information submitted in the routine DMT
report ince 2018. A noted above, the regulatory regime regarding Cell 2 slimes drain pumping
and compliance point. ha been changed to address the addition of 4.5 feet of cover material and
natural phenomenon inherent in the system. EFRI has met the current requirements and has
pumped the maximum possible volume of fluids annually as described below.
The amount of fluid pumped from the Cell 2 slimes is maximized. The slimes drain pump was
lowered to the lowest point practicable to maximize the length of time the pump operates. In
addition, 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 solution level reaches the lower probe which
turns the pump off. This system, rather than a timed system, assures that the pump operate the
maximum time practicable thus maximizing the amount of fluid pumped. Unscheduled
downtimes of the pump in the Cell 2 slimes are minimized, and the maximum fluid volume
which could practicably be extracted from the slimes drain in accordance with the systems in
place was removed. No additional optimization of the system is possible and EFRI has
maximized the system components.
EFRI has evaluated all data collected to date, data collection methods, and all related calculations
required by the Permit, and has verified the accuracy and reliability of both the data and
calculations reported. The Cell 2 slimes drain data are usable for the intended purpose of
75
determining compliance with the GWDP requirements.
Cell 2 slimes drain pumping and monitoring are completed in accordance with Part I.D.3(b) and
I.E.7(b) of the Permit for the reasons stated above. Additional detail regarding the Cell 2 slimes
drain pumping system are included in the Slimes Drain Compliance Plan, which was submitted
to DWMRC under separate cover on January 16, 2020.
2.15.2.3 Maximum Tailings Waste Solids Elevation
Part I.D.3(c) of the Permit requires that upon closure of any tailings cell, EFRI must ensure that
the maximum elevation of the tailings waste solids does not exceed the top of the FML liner.
2.15.2.4 Inspection of Feedstock Storage Area
Part I.D.3(e) of the Permit requires that open-air or bulk storage of all feedstock materials at the
Mill facility awaiting Mill processing must be limited to the eastern portion of the Mill site (the
"ore pad") described by the coordinates set out in that Part of the Permit, and that storage of
feedstock materials at the facility outside of this defined area, must meet the requirements of Part
I.D.11 of the Permit. Part I.D.11 requires EFRI to store and manage feedstock materials outside
the defined ore storage pad in accordance with the following minimum performance
requirements:
a) Feedstock materials shall be stored at all times in water-tight containers or water-tight
container overpacks, and aisle ways will be provided at all times to allow visual
inspection of each and every feedstock container and container overpack, or
b) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical requirements:
l)A storage area composed of a hardened engineered surface of asphalt or concrete, and
2)A storage area designed, constructed, and operated in accordance with engineering
plans and specifications approved in advance by the Director. All such engineering
plans or specifications submitted shall demonstrate compliance with Part I.D.4,
3)A storage area that provides containment berms to control stormwater run-on and run-
off,
4)Stormwater drainage works approved in advance by the Director, or
5)0ther storage facilities and means approved in advance by the Director.
Part I.E.7(c) of the Permit requires that EFRI inspect the feedstock storage areas weekly to:
a) Confirm that the bulk feedstock materials are maintained within approved feedstock
storage defined by Table 4 of the Permit; and
b) Verify that all alternate feedstock materials located out ide the feedstock storage area
defined in Table 4 are stored in accordance with the requirements found in Part I.D.11.
76
Part I.E.7(d) further provides that EFRI inspections of feed material stored outside the feedstock
storage area include the following:
a) Feed tock MateriaJ Stored Outside the Feed lock Storage Area Inspections a) Weekly
Inspection -the Permjttee will conduct weekly in pections to verify that each feed
material container complies with the requirements of Part I.D.11.
b) Hardened Surface Storage Area -in the event the Permittee constructs a hardened surface
storage area for feed material pursuant to Part I.D.11. prior Director approval will be
secured for the following: Part I.E. Permit No. UGW370004
1. Engineering Design and Specifications -in accordance with the requirements of Part
I.D.4, and
11. Operation and Maintenance Plan.
The Mill's procedure for inspection of the Mill's ore pad is contained in Section 3.2 of the DMT
Plan, a copy of which is attached as Appendix H to this Application.
2.15.2.5 Monitor and Maintain Inventory of Chemicals
Part I.D.3(f) of the Permit requires, EFRI to provide secondary containment to capture and
contain all volumes of reagent(s) that might be released at any individual storage area. This
requirement applies to all chemical reagents stored at existing storage facilities and held for use
in the milling process. Response to spills, cleanup thereof, and required reporting must comply
with the provisions of an approved Emergency Response Plan and an approved Stormwater Best
Management Practices Plan. Part I.D.3(f) also stipulates that for any new construction of reagent
storage facilities, such secondary containment and control must prevent any contact of the spilled
or otherwise released reagent or product with the ground surface.
Part I.E.9 of the Permit requires that EFRI monitor and maintain a current inventory of all
chemicals used at the facility at rates equal to or greater than 100 kg/yr. This inventory is to be
maintained on-site, and must include:
(i) Identification of chemicals used in the milling process and the on-site laboratory;
and
(ii) Determination of volume and mass of each raw chemical currently held in storage
at the facility.
A copy of the Mill's chemical Inventory is attached as Appendix Oto this Application. A copy
of the Mill's Stormwater Best Management Practices Plan, Revision 2.0; January 10, 2022 is
attached as Appendix G to this Application.
It is important to note that the chemical inventory included with this application has been
modified from the previous submittal to exclude any chemicals not used at the rate specified in
I.E.9 of 100 kg/yr.
77
2.15.3 BAT Performance Standards for Cell 4A
2.15.3.1 BAT Operations and Maintenance Plan
Part I.D.6 of the GWDP requires EFRI to operate and maintain Cell 4A so as to prevent release
of wastewater to groundwater and the environment in accordance with a BAT Operations and
Maintenance Plan. Performance standards for Cell 4A include the following:
a) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
b) The leak detection y tern maximum allowable daily leak rate shall not exceed 24,160
gallon. /day;
c) After EFRI initiates pumping conditions in the slimes drain layer in Cell 4A, EFRI will
provide conlinuous declining fluid head in the slimes drain layer in a manner
equivalent to the requirement found in Part I.D.3(b) for Celt 2 and 3 and a maximum
bead of 1.0 feet in tbe tailing (as mea ured from the lowest point of the upper FML) in
6.4 years or less; and
d) Under no circumstances shall the freeboard be less than 3-feet in Cell 4A, as measured
from the top of the FML.
The BAT Operations and Maintenance Plan required under Part I.D.6 was approved by the
Director on December 21, 2011. A copy of the most currently-approved BAT Operations and
Maintenance Plan is included as Appendix F to this Application.
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.8 of the Permit provides tbal, in accordance with the currently approved Tailing Cell 4A
BAT Operations and Maintenance Plan EFRI mu t immediately implement all monitoring and
recordkeeping requirement contained in the plan . At a minimum, such BAT monitoring hall
include:
a) Weekly Leak Detection System (LDS) Monitoring -including:
1) continuous operation of the leak detection y tern pllmping and monitoring
equipment, including but not limited to the ubmer ihle pump, pump controller
head monitoring, and flow meter equipment approved by the Director. Failure of
any pumping or monitoring equipment not repaired and made fully operational
within 24-hours of discovery shall con titute failure of BAT and a violation of the
Permit;
2) measurement of the fluid head above the lowe t point on the econdary FML by
the use of procedures and equipment approved by the Director. Under no
circumstance shall fluid head in the leak detection ystem sump exceed a 1-fool
level above the lowest point in the lower FML on the cell fJoor. For purpo es of
compliance monitoring this I-foot distance shall equate to 2.28 feet above the
leak detection system transducer;
78
3) measurement of the volume of all fluids pumped from the leak detection system.
Under no circumstances shall the average daily leak detection system flow
volume exceed 24,160 gallons/day; and
4) operation and maintenance of wastewater levels to provide a 3-foot Minimum of
vertical freeboard in tailings Cell 4A. Such measurements must be made to the
nearest 0.1 foot.
b) Slimes Drain Recovery Head Monitoring will commence immediately after the Mill
initiates pumping conditions in the Cell 4A slimes drain system, quarterly recovery
head tests and fluid level measurements are to be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of the Permit and the currently approved Cell
4A BAT Operations and Maintenance Plan.
2.15.4 BAT Performance Standards for Cell 4B
2.15.4.1 BAT Operations and Maintenance Plan
Part I.D.13 requires EFRI to operate and maintain Cell 4B so as to prevent release of wastewater
to groundwater and the environment in accordance with a BAT Operations and Maintenance
Plan, and that at a minimum such plan must include the following performance standards:
a) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner and operate the LOS pump and transducer in a
horizontal position at the lowest point of the LOS sump floor;
b) The leak detection system maximum allowable daily leak rate shall not exceed 26,145
gallons/day;
c) After EFRI initiates pumping conditions in the slimes drain layer in Cell 4B, EFRI will
provide continuous declining fluid heads in the slimes drain layer, in a manner
equivalent to the requirements found in Part I.D.3(b) for Cells 2, 3 and 4A and a
maximum head of 1.0 feet in the tailings (as measured from the lowest point of the
upper FML) in 5.5 years or less; and
d) Under no circumstances shall the freeboard be less than 3-feet in Cell 4B, as measured
from the top of the FML.
As mentioned above, the BAT Operations and Maintenance Plan was approved by the Director
on December 21, 2011. A copy of the most currently-approved BAT Operations and
Maintenance Plan, is included as Appendix F to this Application.
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.12 of the Permit provides that EFRI must implement all monitoring and recordkeeping
requirements contained in the Tailings Cell 4B BAT Operations and Maintenance Plan. At a
minimum, such BAT monitoring includes weekly LOS Monitoring including:
79
1) continuous operation of the leak detection ·ystem pumping and monitoring
equipment, including, but not limited to, Lbe ubmer ibJe pump, pump controller,
head monitoring, and flow meter equipment approved by the Dfrector. Failure of
any pumping or monitoring equipment not repaired and made fully operational
within 24-hours of discovery shall con titute fa ilure of BAT and a violation of the
Permit;
2) measurement of the fluid head above the lowest point on the secondary FML by
the use of procedures and equipment approved by the Director. Under no
circumstance shall fluid head in the leak detection system sump exceed a 1-foot
level above the lowest point in the lower FML on the cell floor. For purposes of
compliance monitoring this 1-foot distance shall equate to 2.25 feet above the
leak detection system transducer;
3) measurement of the volume of all fluids pumped from the leak detection system.
Under no circumstances shall the average daily leak detection system flow
volume exceed 26,145 gallons/day; and
4) operation and maintenance of wastewater levels to provide a 3-foot Minimum of
vertical freeboard in tailings CelJ 4B. Such measurements must be made to the
nearest 0.1 foot.
Slimes Drain Recovery Head Monitoring immediately after the Mill initiates pumping conditions
in the Cell 4B slimes drain system, monthly recovery head tests and fluid level measurement are
to be made in accordance with the reqnirements of Parts I.D.3 and I.E.7(b) of the Permit and any
plan approved by the Director.
2.15.5 Stormwater Management and SpiJI Control Requirements
Part I.D.10 of the Permit requires EFRI to manage all contact and non-contact stormwater and
control contaminant spills at the facility in accordance with an approved stormwater best
management practices plan. Such plan must include the following minimum provisions:
a) Protect groundwater quality or other water · of the state by design, construction, and/or
active operational mea ure that meet the requirements of the Ground Water Quality
Prnte tion Regulation found in UAC R3 17-6-6.3(G) and R317 -6-6.4(C);
b) Prevent control and contain pill of stored reagents or other chemical at the Mill site;
c) Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
d) Report reagent spills or other releases at the Mill site to the Director in accordance with
UAC 19-5-114.
The Mill's Stormwater Best Management Practices Plan, Revision 2.1, dated April 12, 2022, is
included as Appendix G to this Application.
2.15.6 Tailings and Slimes Drain Sampling
80
Part I.E.10 of Lhe Permit requires EFRI to annuaJJy collect wa tewater quaLity ·ample from each
wa 'tewater ource at each tailings cell at the facility incJuding surface impounded wa tewater.,
the leak detection ystems (if pre. ent) and limes drain wa tewaters. AJI uch sampling must be
conducted in August of each calendar year in compliance with the approved Tailings Sampling
Plan. See Section 2.12.1 above for a more detailed description of this program.
The Mill's Sampling and Analysis Plan for the Tailings Management System, Leak Detection
System and Slimes Drains, Revision 3.0, dated July 8, 2016 is included as Appendix L to this
Application.
2.15.7 Additional Monitoring and Inspections Required Under the Mill License
Under the Mill License daily, weekly, and monthly inspection reporting and monitoring are
required in accordance with NRC Regulatory Guide 8.31, biormation Relevant to Ensuring that
Occupational Radiation Exposures at Uranium Recovery Facilities will be As Low As i
Reasonable A hievable, Revision 1 May 2002 (' Reg Guide 8.3 J ') by Section 2.3 f the Mill '
ALARA Program and by the Mill's Environmental Protection Manual ("EPM"). The e
requirements are over and above the in pections described above that are required under the
Permit.
Additional daily, weekly, monthly, quarterly, and annual inspection and reporti11g requirements
are specified in the Tailing Management System Procedure and the EFRI DMT Plan (Sections
3.1 and 3.2 of the EPM re pectively). The DMT Plan and Tailings Management System are
included as Appendix Hand Appendix I to this Application, respectively.
2.15.7.1 Daily Inspections
Three types of daily inspections are performed at the Mill under the Mill License:
a) Radiation Staff Inspections
Paragraph 2.3.1 of Reg. Guide 8.3 L provide. that the MilJ Rad iation Safety Officer ("RSO') or
designated health phy ic technidan should conduct a daily walk-through (vi ual) in pection of
all work and torage area of the Mill to en ure proper implementation of good radiation safety
procedures, including good housekeeping that would minimjze unneces ary contamination.
Thee inspecti n are required by Section 2.3.1 of the Mill's ALARA Program, and are
documented and on file in the MiJJ s Radiation Protection Office.
b) Operating Foreman Inspections
30 CFR Section 56.18002 of the Mine Safety and Health Administration regulations requires that
a competent person designated by the operator mu t examine each working place at least once
each shift for conditions which may adver ely affect safety or health. These daily inspections are
documented and on file in the Mill's Radiation Protection Office.
81
c) Daily Tailings Inspection
Section 3.1 of the MiJI' EPM require that during Mill operation, the Shift Foreman or other
per on with the U'aining pecified in paragraph 2.4 of the Tailings Management Procedure,
designated by the RSO, will perform an in pection of the tailings Jine and tailings area at Jea t
once per shift, paying do e attention for potential leak and to the di charge from the pipelines.
Ob ervations by the In pector are recorded on the appropriate line on the Mill s Daily Inspection
Data form.
2.15.7.2 Weekly Inspections
Three types of weekly inspections are performed at the Mill under the Mill License:
a) Weekly Inspection of the Mill Forms
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the RSO and the Mill foreman should, and
Section 2.3.2 of the Mill's ALARA Program provides that the RSO and Mill foreman or their
respective de ignee shall, conduct a weekly in pection of all Mill areas to ob ·erve general
radiation control practices and review required changes in procedure and equipment. Particular
attention is to be focused on areas where potential exposure: to per onnel might exist and in
areas of operation or locations where contamination is evident.
b) Weekly Ore Storage Pad Inspection Forms
Paragraph 3.2 of the DMT Plan and Part I.E.7.d of the Permit require · that weekly feedstock
torage area inspection be performed by the Radiation Safety Department to confirm that the
bulk feedstock materials are . tored and maintained within the defined area of the ore pad and that
all alternate feed materials located outside the defined ore pad area are maintained in accordance
with the requirements of the Permit. The result. of these inspection are recorded on the Mill'
Ore Storage/Sample Plant Weekly Inspection Report.
c) Weekly Tailings and DMT Inspection
Sections 3.1 and 3.2 of the EPM requires that weekly inspections of the tailings area and DMT
requirements be performed by the radiation safety department.
2.15.7.3 Monthly Reports
Two types of monthly reports are prepared by Mill staff:
a) Monthly Radiation Safety Reports
The RSO review the result. of daily and weekly in pections, including a review of all
monitoring and exposure data for the month, and provide to the Mill Manager a monthly report
containing a written summary of the month s ignificant worker protection activitie (Section
2.3.4 of the ALARA Program).
82
b) Monthly Tailings Inspection Reports
Sections 3.1 and 3.2 of the EPM, requires that a Monthly Inspection Data form be completed for
the monthly tailings inspection. This inspection is typically performed in the fourth week of
each month and is in lieu of the weekly tailings inspection for that week.
Mill staff also prepares a monthly summary of all daily, weekly, monthly and quarterly tailings
inspections.
2.15.7.4 Quarterly Tailings Inspections
Sections 3.1 and 3.2 of the EPM requires that the RSO or his designee perform a quarterly
tailings inspection.
2.15. 7.5 Annual Evaluations
The following annual evaluations are performed under the Mill License, as set out in Sections
3.1 and 3.2 of the EPM.
a) Annual Technical Evaluation
An annual technical evaluation of the tailings management system must be performed by a
registered profe ional 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 (b) below).
All TMS cells and corresponding dikes are inspected for signs of erosion, subsidence, shrinkage,
and seepage. The drainage ditches are inspected to evaluate surface water control structures.
In the event tailings capacity evaJuations 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.
As discussed above, tailings inspection records consist of daily, weekly, monthly, and quarterly
tailings inspections. These inspection records are evaluated to determine if any freeboard limits
are being approached and to identify any areas of potential concern. The evaluation also
involves discussion with the Environmental and/or Radiation Technician and the RSO regarding
activities around the tailings area for the past year. During the annual inspection, photographs of
the tailings area are taken. The training of individuals is also reviewed as a part of the Annual
Technical Evaluation.
83
The regi tered engineer obtain copies of elected tailings inspections, along with the monthly
and quarterly ummarie of ob ervations of concern and the corrective actions taken. These
copies are then included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted to DWMRC and the Directing Dam
Safety Engineer, State of Utah, Natural Resources by March 1st of the following year.
b) Annual Movement Monitor Survey
A movement monitor survey is 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 po. ible . enlement or movement of the dike . The data
generated from thi survey i · reviewed and incorporated into the Annual Technical Evaluation
Report of the TMS.
c) Annual Leak Detection Fluid Samples
Annually, the leak detection system fluids in Cells 1, 2, 3, 4A and 4B are sampled when present
as described in the Tailings Sampling Plan in Section 2.12.1.
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to Remedy
any Violation of Applicable Ground Water Quality Standards (R317-6-6.3.P)
There are two circumstances where applicable groundwater standards have been exceeded at the
site that are not associated with natural background: chloroform contamination, and nitrate
contamination. As discussed below, none of these circumstances appear to be related to
di ·charges from milling activities. See Section 2.11.2 for a discussion of the current
inve tigati.on into exceedances of GWCLs for certain constituents at the site, which EFRI
believe · are a sociated with natural background.
2.16.1 Chloroform Investigation
In May, 1999, excess chloroform concentration were di ·covered in monitoring well MW-4
which is screened in the shallow perched aquifer along the eastern margin of the MilJ site.
Repeated groundwater sampling by both the Mill and DWMRC confirmed the presence of
chloroform in concentrations that exceed the GWQS along the eastern margin of the site in wells
that are upgradient or cross gradient from the TMS. Other VOC contaminants and nitrate and
nitrite were also been detected in these samples. Based on the location of the plume and
characterization studie completed to date the contamination appears to have resulted from the
operation of temporary laboratory facilitie. that were located at the site prior to and during
construction of the Mill facility, and septic drainfields that were used for laboratory and sanitary
wastes prior to construction of the Mill's TMS.
In the 2004 GWDP Statement of Basis, DWMRC noted on page 3 that, whjJe the contaminant
inve tigation and groundwater remediation plan were not complete at that time, the DWMRC
beljeved that additional time was available to re olve the e requirement based on the following
factors: 1) hydraulic isolation found between the hallow perched aquifer in which the
contamination has been detected and the deep confined aquifers which are a source of drinking
84
water in the area, 2) the large horizontal distance and the long groundwater travel times between
the existing groundwater contamination on site and the seeps and springs where the shallow
aquifer discharges at the edge of White Mesa, and 3) lack of human exposure for these shallow
aquifer contaminants along this travel path.
The discovery resulted in the issuance of State of Utah Notice of Violation ("NOV") and
Groundwater Corrective Action Order ("CAO") DWMRC Docket No. UGW-20-01, which
required that EFRI submit a Contamination Investigation Plan and Report pursuant to the
provisions of UAC R317-6-6.15(D). In response to the NOV, EFRI submitted a series of
documents outlining plans for investigation of the chloroform contamination. This plan of action
and preliminary schedule was set out in EFRI submittals dated: September 20, 1999; June 30,
2000; April 14, 2005; and November 29, 2006. EFRI submitted a draft Groundwater Corrective
Action Plan ("GCAP") dated August 22, 2007. The draft GCAP was reviewed by the Director,
who advised EFRI in 2013 that modifications were required. In an effort to expedite and
formalize active and continued remediation of the chloroform plume, both parties have agreed to
the GCAP found in Attachment 1, of the final Stipulation and Consent Order ("SCO") dated
September 14, 2015. Between the time of discovery and the fourth quarter of 2021, the plume
has been delineated by installation of 43 TW4-series wells and placed under remediation by
pumping.
Physical factors that have influenced the transport of chloroform (and the size and shape of, and
concentration distribution within, the chloroform plume) include the following: 1) the nature of
the source(s); 2) perched groundwater flow in the vicinity of the plume; 3) the permeability
distribution; 4) natural attenuation; 5) initiation of long term pumping within the plume at wells
MW-4, MW-26, and TW4-19 in 2003; 6) the addition of TW4-20 to the pumping system in 2005
(which has since been abandoned); 7) the addition of TW4-4 to the pumping system in 2010; 8)
reduced wildlife pond recharge (since the first quarter of 2012); 9) nitrate pumping in TW4-22,
TW4-24, TW4-25, and TWN-2 (since the first quarter of 2013); 10) the addition of TW4-1,
TW4-2, TW4-11, TW4-21, and TW4-37 to the pumping system during the first half of 2015; and
11) the addition of TW4-39, TW4-40 and TW4-41 to the pumping system since 2015. Although
pumping well TW4-20 failed and was abandoned during 2020, little or no impact to chloroform
mass removal rates and capture effectiveness has occurred. Increased pumping at TW4-19
subsequent to TW4-20 failure more than compensated for the loss in pumping at TW4-20.
The number of chloroform pumping wells doubled (from five to ten) during the first half of
2015. Doubling the number of chloroform pumping wells more than tripled the short-term rate of
chloroform mass removal from approximately 10.2 pounds ("lbs")/quarter in the third quarter of
2014 to 32.3 lbs/quarter by the fourth quarter of 2015. Since 2015, the chloroform pumping
system has continued to expand through the addition of TW4-39, TW4-40 and TW4-41.
Chloroform pumping since 2015 has exceeded the conservatively large calculated 'background
flow' through the plume (3.4 gpm) by between approximately 0.9 gpm and 2.5 gpm (26% to
74%), or on average 1.8 gpm (53%), indicating that pumping is adequate.
Since implementation of the GCAP in the third quarter of 2015, chloroform plume residual mass
estimates have trended downward. The decrease in residual mass estimates is a consequence of
decreases in average concentrations and reduced saturated thicknesses within the plume. In
85
addition, since implementation of the GCAP, pumped mass removal rates have trended
downward. Decreasing mass removal rates are attributable primarily to the reduced
concentrations within the plume. As concentrations decrease in pumping wells within the plume,
the pumped mass removal rates also decrease, even if pumping rates remain relatively stable.
Doubling the number of chloroform pumping wells during 2015 also expanded the area of the
plume under hydraulic capture by approximately 30%. As of the fourth quarter of 2015,
approximately 74% of the plume area and approximately 89% of the re idual plume mas were
under hydrnulic capture. Although the area under capture increased by approximately 30% (from
approximately 27 acre. to approximately 35 acres) between the fourth quarter of 20 I 4 and
20J 5 the increa e in the proportion of total plume mass under hydraulic capture did not change
significantly and remained at approximately 90%.
Additional expansion of capture since 2015 has re ulted from adding TW4-39 TW4-40 and
TW4-4J to the pumping system. As of the fourth quarter of 2021 , approx_imately 85% of the
plume area and approximately 97% of the plume ma are under captur . Since the end of 2012
total pumping from the chloroform plume (incJucling pumping from nitrate wells TW4-22 and
TW4-24 located within and ju t in ide the margin of the chloroform plume, respectively) has
increased from approximately 2.8 gpm to approximately 5.1 gpm.
The chloroform plume is completely bounded by twenty compliance wells having concentrations
that are below the GCAL of 70 µg/L: seventeen of these wells are ·pecified in Table IA of the
GCAP and TW4-38, TW4-42 and TW4-43 are new compliance wells installed since
implementation of the GCAP. Fourteen of these twenty bounding wells are non-detect for
chloroform as of the fourth quarter of 2021. The fourteen non-detect wells are MW-32, TW4-3,
TW4-12, TW4-13, TW4-14, TW4-23, TW4-25, TW4-28, TW4-34, TW4-35, TW4-36, TW4-38,
TW4-42 and TW4-43. The plume is also nearly 1 200 feet from the closest (eastern) property
boundary (as of the fourth quarter of 2021), and becau. e perched water flow is approximately
parallel to that boundary, any chloroform encroaching on that boundary is unlikely to cros the
boundary. The southern portion of the p.lume i bounded immediately to the south by TW4-42,
and far to the south by MW-22 and MW-40 (all non-detect for chloroform). TW4-40 was
installed once concentrations at TW 4-26 exceeded 70 µg/L for two consecutive quarters;
likewise, TW4-42 was installed once concentrations at TW4-40 exceeded 70 µg/L for two
consecutive quarters. TW4-40 has been converted to a pumping well.
Likewi e generally decrea ing chloroform concentrations at downgradient well TW4-6 since the
first quarter of 2015 and i ncrea ·ing to table concentrations at TW 4-26 since the first quarter of
2016 suggest that chloroform migration ha been arrested at TW4-6 by TW4-4 (and TW4-41)
pumping and that increa ·ing to stable chloroform at TW4-26 results from a remnant of the plume
that migrated downgraclient to the outh.
Based on the above factors, the chloroform plume is under control and the GCAP has been
effective in protecting public health and the envirnnment. In particular current pumping y ·tern
effectiveness is demonstrated by 1) the slowing to near halting of plume boundary ex pan 'ion
attributable to reduced dilution from reduced wildlife pond recharge and redistribution of
chloroform resulting from nitrate pumping; and 2) maintaining a large proportion of the plume
86
mass under hydraulic capture (approximately 97% as of the fourth quarter of 2021). High rates of
capture have been maintained even considering reduced productivities at some of the pumping
wells and the failure and subsequent abandonment of TW4-20.
Furthermore, natural attenuation calculations provided in HGC (2007) suggest that all
chloroform concentrations will be below the GCAL within less than 200 years, not taking into
account the effects of any pumping. Specifically, using the average calculated chloroform
degradation rate h wn in Appendix C of the 2022 Chloroform CACME, reducing the highest
2021 chloroform concentration of 14,800 µg/L to the GCAL of 70 µg/L would take
approximately 61,353 days or 168 years, even in the absence of pumping. If the degradation rate
is based onJy on MW-26 data, the time to reduce the highest 2021 concentration of 14,800 µg/L
to the GCAL of 70 µg/L would take approximately 16,890 days or only 46 years.
2.16.2 Nitrate Investigation
During review of the New Well Background Report and other reports a Nitrate contaminant
plume was identified by DWMRC ·taff in five monitoring wells in the Mill ite area, including
wells: MW-30, MW-3 L TW4-22, TW4-24 and TW4-25. TW4-25 is located upgradient of the
Mill's TMS. Elevated concentrations of chloride also appear to be associated with the nitrate
plume.
On September 30, 2008, the Director issued a request for a voluntary plan and schedule for EFRI
to investigate and remediate this Nitrate contamination. On November 19, 2008 EFRI submitted
a plan and schedule prepared by INTERA, Inc., which identified a number of potential sources
for the contamination, including several potential historic and off site sources. On January 27,
2009, the Director and EFRI signed a Stipulated Consent Agreement ("SCA") by which EFRI
agreed to conduct an investigation of the Nitrate contamination, determine the sources of
pollution, and submit a report by January 4, 2010.
EFRI submitted a Contaminant Investigation Report ("CIR") on December 30, 2009. On October
5, 2010 the Director issued a Notice of Additional Required Action ("NARA") letter that notified
EFRI of the Director's determination that the 2009 CIR was incomplete.
On December 20, 2010 EFRI and the Director entered into Revision O of a Tolling Agreement,
allowing a tolling period until April 30, 2011 in order to provide time for EFRI to prepare a Plan
and Schedule for Director review addressing additional investigations to resolve open issues
identified in the October 5, 2010 NARA, and to execute a revised SCA.
EFRI submitted a Plan and Schedule on February 14, 2011 and a revi ed Plan and Schedule on
February 18, 2011. The Director provided comment on the revi ed Plan and Schedule on
March 21, 2011. In an April 20, 2011 meeting, EFRI and the Director agreed that the Plan and
Schedule to conduct additional nitrate investigations would be composed of four to five phases
of study, including geoprobe drilling and soil sampling/analysis to investigate natural nitrate salt
reservoir sources in the vadose zone beyond the Mill site, potential Mill sources, and other
potential source ; groundwater sampling and analy is of existing monitoring wells for non-
isotopic analyte · deep bedrock core sampling/analy i of possible natural nitrate reservoir and
87
potentiaJ nitrate source locations; stable i otopic sampling/analysis of groundwater in existing
monitoring wells; and stable isotopic sampling/analysi. of oil/core samples, if needed.
On April 28, 2011, EFRI and the Director entered into Revi ion 1 of the Tolling Agreement to
extend the Tolling Period through June 30, 2011 and adopt the agreements made on April 20,
2011. Under the Tolling Agreement Revision 1, EFRI agreed to ubmit a Revi. ed Pha e 1 (A
through C) Work Plan on or before May 6, 2011 and a Revi ed Pha. e 2 through 5 Work Plan and
Schedule on or before June 3, 2011.
EFRI submitted a May 6, 2011 Revised Phase 1 Work Plan and Schedule for the Phase 1 A -C
investigation for Director review. EFRI conducted field and laboratory work for the Phase 1 A-C
study in May and June, 2011.
EFRI submitted a Revised Phase 2 through 5 Work Plan and Schedule for Director review on
June 3, 2011. The Director provided comments on this document on June 23, 2011 and advised
EFRI that in order to revise the 2009 SCA to incorporate needed deliverable and timelines, the
Phase 2 through 5 Work Plan would need to be expanded to the same level of detail as was
provided for Phase 1 in Attachment 1 of the Revision 1 Tolling Agreement.
On June 30, 2011, EFRI and the Director entered into Revision 2 of the Tolling Agreement
extending the Tolling Period to August 31, 2011, to facilitate the revision of the Phase 2 through
5 Work Plan to provide the required level of detail to construct a replacement SCA. EFRI
submitted a separate July 1, 2011 detailed Revision O of the Work Plan and Quality Assurance
Plan ("QAP") for the Phase 2 investigation. The Director provided comments on this document
on July 7, 2011. EFRI provided a July 12, 2011 Revision 1.0 to the Phase 2 QAP and Work Plan,
which DWMRC conditionally approved in a letter dated July 18, 2011. On August 1 and 2, 2011
EFRI submitted by email preliminary laboratory results for the Phase 1 A-C study to the Director.
On August 4, 2011, EFRI provided a Revision 1.0 to the Phase 2 -5 Work Plan for Director
review. The Director provided comments on the Phase 2-5 Work Plan, Revision 1.0 and the
August 1, 2011 preliminary laboratory results on August 11, 2011. EFRI submitted Revision 2.0
of the Phase 2-5 Work Plan for Dfrector review on August 11, 2011.
On August 25, 2011, the Director determined that based on review of the Revision 2.0 Phase 2-5
Work Plan, a finalized Plan and Schedule that meets the satisfaction of the Director, and which
would allow the preparation of a replacement SCA, was not possible at that time; and that the
development of a replacement SCA for continued contaminant investigation activities was not
supported.
At a meeting on August 29, 2011, EFRI and DWMRC agreed that:
1. After more than two years of investigation it has been determined that there are site
conditions that make it difficult to determine the source(s) of the contamination at the
White Mesa site;
2. As a result, resources will be better spent in developing a CAP in accordance with UAC
R317-6-6.15(D), rather than continuing with further investigations as to the source(s) of
the contamination.
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In discussions during October 2011, EFRI and the Director acknowledged that it has not been
possible to date to determine the source(s), cause(s), attribution, magnitudes of contribution, and
proportion(s) of the local nitrate and chloride in groundwater, and thereby cannot eliminate Mill
activities as a potential cause, either in full or in part, of the contamination. As a result, EFRI and
the Director agreed that resources will be better spent in developing a Corrective Action Plan in
accordance with UAC R317-6-6.15(D), rather than continuing with further investigations.
On October 3, 2011 EFRI and the Director entered into a revised Stipulated Consent Agreement
which required EFRI to submit a Corrective Action Plan for Director review that included plans
to:
Phase I -determine the physical extent of soil contamination observed at the Ammonium
Sulfate Crystal Tanks, and provide a control measure consisting of either removal of the
areal extent of contamination down to bedrock, or a Plan and Schedule for covering the
areal extent of contamination with at least 6 inches of concrete, followed by removal
action during or before site closure.
Phase II -implement near term active remediation of the nitrate contamination by
pumping contaminated water into the Mill's TMS for disposal. This phase is to include
development, implementation, operation, and monitoring of a pumping well network to
contain and hydraulically control the nitrate plume; monitoring of chloride
concentrations; and any required increases to the Mill's surety for activities in this Phase.
Phase III -develop, if necessary, a comprehensive long-term solution for the nitrate
contamination at the Mill Site. This Phase is to be determined after public participation
and Director approval, and may include continuation of Phase I and II activities alone or
in combination with any of the following: monitored natural attenuation, additional
remediation and monitoring, determination of additional hydrogeologic characterization,
contaminant travel times, points of exposure to public or wildlife, risk analysis,
cost/benefit analysis, and possible development and petition of the Board for alternate
corrective action concentration limits.
EFRI submitted a Draft Corrective Action Plan on November 30, 2011. The Director provided
comments on the Draft Corrective Action Plan on January 19, 2012. EFRI provided Revision
1.0 of the Corrective Action Plan on February 27, 2012, and received comments from the
Director on March 19, 2012. Pursuant to the revised SCA, EFRI provided Revision 2.0 to the
Director on May 7, 2012 (HGC 2012b).
On December 12, 2012, DRC signed the SCO, Docket Number UGW12-04, which approved the
EFRI CAP, dated May 7, 2012 (HGC 2012b). The SCO ordered EFRI to fully implement all
elements of the May 7, 2012 CAP (HGC 2012b).
Based on the schedule included in the CAP and as delineated and approved by the SCO, the
activities associated with the implementation of the CAP began in January 2013.
The nitrate plume has been under remediation by (Phase II) pumping since the first quarter of
2013 . The plume, defined by groundwater concentrations exceeding 10 mg/L nitrate as nitrogen,
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originates upgradient (northeast) of the TMS at the site (HGC, 2017). Likewise, the commingled
chloride plume, defined by groundwater concentrations exceeding 100 mg/L chloride, also
originates upgradient of the TMS.
The 2017 CA CME report for the nitrate plume (HGC, 2017) represents a 5-year review of the
Phase II Corrective Action as specified in the final SCO Docket No. UGW12-04. As discussed in
the nitrate CACME, between the second quarter of 2010 and the third quarter of 2017, the mass
of nitrate contained within the plume has been reduced by approximately 11 % to 25%. Based on
data presented in EFRI (2022c), the residual mass of the nitrate plume has continued to decline.
Furthermore, there is enough pyrite in the perched zone within the path of the nitrate plume to
completely attenuate the plume through natural reduction of nitrate alone. As discussed in HGC
(2017), estimated natural nitrate degradation rates range from approximately 172 lb/ year ("yr")
to 200 lb/yr, indicating that less than 200 years would be required to remediate the nitrate plume,
even in the absence of any direct mass removal by pumping. However, considering both
pumping and estimated natural attenuation rates presented in HGC (2017), the mass of the plume
is expected to be reduced by approximately 573 to 601 lb/yr, and nitrate concentrations within
the plume are expected to be reduced to negligible values (less than 10 mg/L) within
approximately 54 to 57 years. As the estimated time for impacted water to reach the nearest
discharge point (Westwater Seep or Ruin Spring) is greater than 3,000 years, there is no concern
at this time that the continuation of current corrective actions will not result in remediation of the
plume well before it can reach any exposure to the public or wildlife.
In response to a DWMRC request, additional attenuation modeling of the nitrate plume was
conducted to further study and refine the conclusions presented in the 2017 nitrate CACME.
Accordingly, a Phase III Planning Document was prepared (HGC 2018e).
The Phase III planning document included conceptual-level numerical groundwater flow and
solute transport assessments to evaluate the maximum distance that the nitrate plume could
travel, assuming hypothetical 'worst-case' conditions, before all concentrations are reduced
below 10 mg/L, indicating that full attenuation has occurred.
These 'worst-case' transport assessments:
1. Disregard the natural degradation of nitrate within the plume via pyrite oxidation which
will cause overestimation of simulated plume migration;
2. Disregard the (relative) stability of the southern (downgradient) margin of the nitrate
plume which suggests that pumping and natural attenuation processes are minimizing or
preventing plume expansion to the south;
3. Disregard nitrate mass removal by pumping and natural dilution of nitrate concentrations
via recharge by precipitation, which will cause overestimation of simulated plume
migration;
4. Substantially overestimate hydraulic conductivities (by as much as two orders of
magnitude) and hydraulic gradients (by nearly a factor of two) down gradient of the TMS,
which will cause substantial overestimation of simulated plume migration rates; and
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5. Underestimate dispersivities which will cause underestimation of hydrodynamic
dispersion and overestimation of simulated plume migration.
The conceptual-level transport assessments indicate that the nitrate plume will not migrate
beyond the site property boundary or to a discharge point before fully attenuating, even under
hypothetical 'worst-case' assumptions. Therefore, under any currently conceivable conditions,
including hypothetical 'worst-case' conditions that greatly overestimate plume migration rates,
underestimate mechanical dispersion, and disregard mass removal by pumping and natural
degradation, there will be no expected hazard to public health, safety or the environment; no
expected exposure to the public, wildlife or the environment; and, as a result, no additional
hazard or exposure assessments are needed at this time.
In summary, the assessments provided in the 2017 nitrate CACME indicate that the plume would
fully degrade via natural pyrite oxidation alone before reaching a discharge point. This
degradation would occur within 200 years assuming no pumping, dilution by natural recharge, or
hydrodynamic dispersion. The conceptual-level transport assessments performed in 2019
indicate that, even without mass removal via pyrite oxidation or pumping, and assuming
hypothetical 'worst case' conditions regarding future nitrate transport, the plume will fully
attenuate before reaching the site property boundary or a discharge point.
2.17 Other Information Required by the Director (R317-6-6.3.Q)
As discussed below, a chemical inventory report and a Hydrogeologic investigation report for the
southwest portion of the Mill site have been completed at the request of the Director. No other
information has been specifically required by the Director to be included in this Application at
this time. EFRI will provide additional information as requested by the Director.
2.17.1 Chemical Inventory Report
Part I.E.9 requires that an On-site Chemicals Inventory be maintained. Specifically, I.E.9 states:
On-site Chemicals Inventory -the Permittee shall monitor and maintain a current inventory of all
chemicals used at the facility at rates equal to or greater than 100 kg/yr. Said inventory shall be
maintained on-site, and shall include, but is not limited to:
a. Identification of chemicals used in the milling process and the on-site laboratory, and
b. Determination of volume and mass of each raw chemical currently held in storage at the
facility.
Part I.F.8 states:
Chemicals Inventory Report -at the time of submittal of an application for Permit renewal the
Permittee shall submit a report to update the facilities chemical inventory report. Said report
shall include:
a. Identification of all chemicals used in the milling and milling related processes at the
White Mesa Mill, and
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b. Provide all inventory information gathered pursuant to Part I.E.9,
c. Determination of the total volumes currently in use and historically used, as data is
available.
The updated chemical inventory is included Appendix 0. It is important to note that the
chemical inventory included with this application has been modified from the previous submittal
to exclude any chemicals not used at the rate specified in 1.E.9 of 100 kilograms per year
("kg/yr").
2.17.2 Southwest Hydrogeologic Investigation
In response to previous Permit requirements, EFRI performed a detailed Southwest
Hydrogeologic Investigation to define, demonstrate and characterize: 1) the hydraulic connection
and local groundwater flow directions between the area near Tailings Cell 4B, and the western
margin of White Mesa, and 2) the full physical extent of the unsaturated area between former
well MW-16, MW-33 and the western margin of White Mesa.
During 2011, EFRI installed 18 piezometers to define the geologic and physical extent of the
apparent unsaturated structural high between Tailings Cell 4B and the western margin of White
Mesa and the location and direction of groundwater flow paths between Tailings Cell 4B and
Westwater and Cottonwood Seeps and Ruin Spring. Consistent with Part I.H.6.c) of the Permit,
EFRI submitted an investigation report, the Hydro geology of the Perched Groundwater Zone in
the Area Southwest of the Tailings Cells, White Mesa Uranium Mill Site (the "Southwest
Hydrogeology Report"), prepared by Hydro Geo Chem, on January 12, 2012. The Director
provided comments in a conference call during May 2012, and in a letter dated May 30, 2012.
EFRI submitted a revised version of the Report on August 3, 2012 and agreed to repeat slug
testing of piezometer DR-08. DRC's September 20, 2012 review Summary and RFI, specifically
requested that EFRI:
• repeat slug testing of piezometer DR-08,
• recalculate hydraulic properties, and
• recalculate travel times if necessary based on new data.
The Second Revision to the Report, addressing the data and re-calculations resulting from
retesting of piezometer DR-08, was submitted on November 7, 2012.
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-6.3.R)
This Application has been performed under the direction, and bears the seal, of Timo Groves,
EFRI Chief Metallurgist. Mr. Groves is a Registered Professional Engineer in the State of Utah,
No. 11793034.
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2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent Ground
Water Contamination During the Closure and Post Closure Phases of Operation (R17-6-6.3.S)
2.19.1 Regulatory Requirements for Uranium Mills
2.19.1.1 Long Term Custodian
One unique feature of the regulatory scheme for uranium mill tailings is that Section 83 of the
Atomic Energy Act of 1954, as amended by the Uranium Mill Tailings Radiation Control Act of
1978 ("UMTRCA") (the Atomic Energy Act of 1954 as so amended is referred to herein as the
"AEA")1 requires that, prior to license termination, title to uranium mill tailings (1 le.(2)
byproduct material) must be tran ferred to the United States Department of Energy ("DOE") or
the State in which the activity occurred if the State so elects, for custody and long term care. 10
CFR 40.28 provides a general license to DOE or the State for that purpose.
2.19.1.2 Responsibility For And Manner Of Clean Up
UMTRCA amended the AEA to require that all Title II facilities (i.e., active mills) comply with
the decontamination, decommissioning, and reclamation standards prescribed by the
Commission2 and to require that such facilities post reclamation bonds or surety3.
Re ponsibility for reclamation of Title II facili ties rest with th e Jicen ee. 10 CFR Part 40
Appenrux A Criterion 6A requires the adoption of a Director-approved red amation plan for the
site, Criterion 9 requires that financial surety mu t be e tabli bed to fund the co. t of reclamation
in accordance with such plan, and Criterion 10 requires that each licensee include in its financial
surety an amount equivalent to $250,000 (1978 dollars) to cover the costs of long-term
surveillance by the long-term government custodian (DOE). Criteria 6, 9 and 10 have been
incorporated by reference into the Utah rules by UAC R313-24-4.
2.19.1.3 Surface
The reclamation plan adopted by the Mill at the outset, as required by 10 CFR Part 40, Appendix
A, Criterion 9, addresses the decontamination and decommissioning of the Mill and Mill ite and
reclamation of tailings and other waste disposal areas.
As is the case for most uranium mills, the Mill's reclamation plan requires that, upon closure, all
mill buildings, unsalvageable equipment, contaminated soils (impacted by Mill operations within
the Mill site itself as well as surrounding areas that may be impacted by windblown radioactive
dusts from milling operations) etc. be deposited in the TMS and the TMS capped in place.
Appendix A, Criterion 6(6) sets the standard for determining when all impacted areas other than
the TMS have been adequately cleaned up. Criterion 6(6) provides that byproduct material
containing concentrations of radionuclides other than radium in soil, and surface activity on
remaining structures, must not result in a total effective dose equivalent ("TEDE") exceeding the
dose from cleanup of radium contaminated soil to the benchmark standard of 5pCi/g
t See 42 U.S.C. 2113.
2 See 42 U.S.C. 2113.
3 See 42 U.S.C. 2201.
93
concentration of radium in the upper 15 cm (6 in) of surface soils and 15 pCi/g concentration of
radium in the subsurface soils, and must be at levels which are ALARA. If more than one
residual radionuclide is present, the sum of the ratios for each radionuclide present will not
exceed "1" (unity). Further details on the NRC's approach to evaluating reclamation plans and
release criteria for uranium mill sites, including the manner of modeling the relea e 'tandard set
out in Criterion 6(6), are contained in NUREG-1620, Rev 1, Standard Review Plan for the
Review of a Reclamation Plan for Mill Tailings Sites Under Title II of the Uranium Mill Tailings
Radiation Control Act of 1978, Final Report, June 2003 ("NUREG-1620").
2.19.1.4 Groundwater
Each uranium mill is required to have a groundwater monitoring program. In the case of the
Mill, the Permit implements the applicable requirements of UAC R317-6. If there is
groundwater contamination after cessation of operations, the requirements of UAC R317-6.15
must be satisfied.
2.19.1.5 License Termination
Section 83. 7 of the AEA 4 provides that material and land transferred to the long term custodian
must be transferred without cost to the long-term custodian other than administrative and legal
costs incurred in carrying out such transfer.
In order to cover the costs of long-term surveillance, Criterion 10 requires that a minimum
charge of $250,000 (1978 dollars) must be paid by each mill operator to the general treasury of
the United States or to an appropriate State agency prior to the termination of a uranium mill
license.
In most case! if there i a groundwater ontamination problem, the problem must be remediated
prior to Jicen e termination or an alternate corrective action concentration limit under R317-6-
6.15.G must be achieved that i. protective of public health and the environment. In some
circumstances DOE may agree to take some additional actions after it takes title to the site, such
as additional monitoring, if not onerous and provided adequate funding is provided.
Upon the Director and the NRC being satisfied that alJ regulatory requirements have been met
and the site is reclaimed in a manner that sati fie aU applicable tandard , the Mill's licen e will
be terminated upon transfer of the tailings to DOE. 10 CPR 40.28 provide a general license in
favor of the long-term custodian for custody of and long-term care of the tailings impoundments
and any surrounding lands transferred to it. 5 The surrounding areas not transferred to DOE
would generally be free-released.
4 See 42 U.S.C. 2113.
5 In circumstances where th e facility has a groundwater contamination p.lume, addilional lands may be acquired by
the licensee in order to bound the plume. In these circumstances these adcliti nal lands w uld be transfe rTed along
with the capped tailings impoundments, to DOE.
94
2.19.2 Current Reclamation Plan
The Mill's Reclamation Plan, Revision 3.2B, was approved by DWMRC under the Mill License
on January 26, 2011. The Reclamation Plan sets out the requirements to be met by EFRI for the
final reclamation and closure of the Mill facility, including the tailings cells and all impacted
surrounding areas, in accordance with the requirements of 10 CFR Part 40, Appendix A (which
have since been incorporated by reference into UAC R313-24). A copy of the Mill's
Reclamation Plan, Revision 4.0 was previously submitted to the Director in November 2009 and
is on file at the DWMRC.
EFRI submitted Revision 5.0 of the Reclamation Plan in September 2011. DWMRC provided
one round of interrogatories for this document in March 2012. EFRI provided responses to
these interrogatories in May and August 2012. DWMRC provided review comments on EFRI's
May and August 2012 responses in February 2013. . EFRI completed supplemental
investigations in 2013 and 2014 in response to the Director's February 2013 review comments.
EFRI submitted responses to the Director's February 2013 review comments in August 2015.
Infiltration modeling was conducted for the monolithic ET cover presented in Revision 5.0 of the
Reclamation Plan and a complete description of the analyses were provided in EFRI's March
2010 Revised Infiltration and Contaminant Transport Modeling (ICTM) Report, White Mesa Mill
Site, Blanding, Utah,. The modeling was updated to address the Director's March 2012 and
February 2013 comments on the ICTM Report and to incorporate supplemental field
investigations conducted in 2010 and 2012 for cover borrow material and in 2013 for in situ
tailings. The updated infiltration modeling results were presented in EFRI's submitted responses
to the Director's March 2012 and February 2013 review comments in August 2012 and August
2015.
On November 11, 2015, the Director held a conference call with EFRI and recommended
submittal of an agreement outlining a plan to complete reclamation of tailings Cell 2. This plan
would consist of completing placement of the cover design presented in Revision 5.0 of the
Reclamation Plan on Cell 2 and demonstrating acceptable cover performance via a performance
monitoring program.
On August 11, 2016, EFRI submitted Reclamation Plan, Revision 5.1, with an Updated Tailings
Cover Design Report and incorporated comment received from the Director. On December 5,
2016, EFRI submitted the final ver ion of Reclamation Plan, Revision 5.1, which incorporated
additional comments received from the Director.
EFRI and the Director executed a Stipulation and Consent Agreement (SCA) on February 23,
2017 (DWMRC, 2017) defining the commitments and timeframes for completing placement of
reclamation cover on Cell 2 and performance assessment of the cover system, in accordance with
the Reclamation Plan Revision 5.1. EFRI updated the Reclamation Plan on February 8, 2018 to
Revision 5. lB and submitted to the Director, but the guidelines, monitoring, and reporting
requirements for the test sections did not change.
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Per the 2017 SCA, the Director will approve Reclamation Plan 5.1 upon completion of a public
notice and comment period, and in conjunction with and conditional upon the execution and
delivery of the SCA by EFRI and the Director.
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan
The Mill GWDP was issued by DWMRC on January 19, 2018 for 5 years. The current revision
of the GWDP was issued March 8, 2021. The Permit ensures that the final reclamation design
approved by the Director will provide adequate performance criteria to protect local groundwater
quality.
To this end, Part I.D.8 of the Permit states that:
Closed Cell Performance Requirements -before reclamation and closure of any tailings disposal
cell, the Permittee shall ensure that the final design, construction, and operation of the cover
system at each tailings cell will comply with all requirements of an approved Reclamation Plan,
and will for a period of not less than 200 years meet the following minimum performance
requirements:
a. Minimize infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon barrier,
b. Prevent the accumulation of leachate head within the tailings waste layer that could rise
above or over-top the maximum FML elevation internal to any disposal cell, i.e. create a
"bathtub" effect, and
c. Ensure that groundwater quality at the compliance monitoring wells does not exceed the
Ground Water Quality Standards or Ground Water Compliance Limits specified in Part
I.C. l and Table 2 of this Permit.
In addition, Pait I.D.9 was included in the Permit, which provides that upon commencement of
decommissioning, EFRI will reclaim the Mill site and all related facilities, stabilize the tailings
cells, and construct a cover system over the tailings cells in compliance with all engineering
design and specifications of the approved reclamation plan. Part I.D.9 also provides that the
Director reserves the right to require modifications to the Mill's Reclamation Plan for purposes
of compliance with the Utah Ground Water Quality Protection Regulations, including but not
limited to containment and control of contaminants, or discharges, or potential discharges to
waters of the State.
In response to the GWDP requirements, the EFRI Reclamation Plan delineates the activities that
will assure that the uranium and vanadium processing areas of the Mill, including equipment,
structures and support facilities, will be decommissioned and disposed of in tailings or buried at
the Mill site as appropriate. Equipment (including tankage and piping, agitation, process control
instrumentation and switchgears, and contaminated structures) will be cut up, removed, and
buried in tailings prior to final cover placement. Concrete structures and foundations will be
demolished and removed for disposal in tailings or covered in place with soil as appropriate.
96
The sequence of demolition will proceed so as to allow the maximum use of support areas of the
facility, such as the office and shop areas. Uncontaminated or decontaminated equipment to be
considered for salvage will be released in accordance with NRC guidance and in compliance
with the conditions of the EFRI's License No. UT1900479. As with the equipment for disposal,
contaminated soils from the Mill and surrounding areas and ore or feed materials on the Mill site
will be disposed of in the tailings cells in accordance with the Reclamation Plan.
2.19.4 Post-Operational Monitoring
Monitoring will continue under the Permit after cessation of operations, during reclamation and
after reclamation has been completed until such time as the Mill License and Permit are
terminated and the reclaimed tailings impoundments are transferred to the Department of Energy
for perpetual care and maintenance.
3.0 CONCLUSIONS
This Application describes the key monitoring and DMT performance standard requirements and
other protections contained in the Permit.
EFRI believes that with this Application, the accompanying Background Reports and other
documentation, the Director has been provided sufficient information to determine that:
a) EFRI has demonstrated that the applicable class TDS limits, ground water quality
standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) EFRI utilizes treatment and discharge minimization technology at the Mill
commensurate with plant process design capability and similar or equivalent to that
utilized by facilities that produce similar products or services with similar production
process technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
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4.0 SIGNATURE AND CERTIFICATIONS
This Application is being submitted by Energy Fuels Resources (USA) Inc.
Energy Fuels Resources (USA) Inc.
By:
Scott Bakken Date
Vice President, Regulatory Affairs
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the .information submitted. Based on my inquiry of the person or
per ons who manage the y tern, or those person · directly re ponsible for gathering the
information, the information ubmitted i to the be t of my knowledge and belief true accurate
and complete. I am aware that there are significant penaltie for . ubmitting false .information,
including the possibility of fine and imprisonment for knowing violations.
Scott Bakken
Vice President, Regulatory Affairs
CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that the foregoing Application has been prepared under my direction, that I have
reviewed this Application, that I am familiar with the Mill facilities, and attest that this
Application has been prepared in accordance with good engineering practices.
Timo Groves
Registered Professional Engineer
State of Utah No. 11793034
(seal)
98
5.0 REFERENCES
American Society for Testing and Materials. 1996. Standards on Ground Water and Vadose
Investigations.
Dames & Moore. January 30, 1978. Environmental Report, White Mesa Uranium Project San
Juan County, Utah.
D'Appolonia Consulting Engineers, Inc. June 1979. Engineers Report: Tailings Management
System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. May 1981. Engineer's Report: Second Phase Design-
Cell 3 Tailings Management System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. February 1982. Construction Report: Initial Phase -
Tailings Management System, White Mesa Uranium Project Blanding, Utah.
Division of Radiation Control, Utah. December 1, 2004. Statement of Basis For a Uranium
Milling Facility at White Mesa, South of Blanding, Utah, Owned and Operated by
International Uranium (USA) Corporation.
Energy Fuels Nuclear, Inc. March 1983. Construction Report: Second Phase Tailings
Management System, White Mesa Uranium Project.
Energy Fuels Resources (USA) Inc. ("EFRI") August 2000. Construction Report: Tailings Cell
4A, White Mesa Uranium Mill -Tailings Management System. Prepared by EFRI
(formerly International Uranium (USA) Corporation).
EFRI, July 12, 2011. Revised Phase 2 QAP and Work Plan, Revision 2.0.
EFRI, August 15, 2012a. Responses to Interrogatories -Round 1 for Reclamation Plan, Revision
5.0, March 2012.
EFRI, August 15, 2012b. Responses to Interrogatories -Round 1 for the Revised Infiltration and
Contaminant Transport Modeling Report, March 2010.
EFRI August 31, 2015. Responses to Review of September 10, 2012 Energy Fuels Resources
(USA) Inc. Responses to Round 1 Interrogatories on Revised Infiltration and
Contaminant Transport Modeling Report, White Mesa Mill Site, Blanding Utah, Report
Dated March 10.
EFRI, February 8, 2018. Reclamation Plan White Mesa Mill Blanding, Utah, Revision 5.1.
EFRI, October 19, 2020. Source Assessment Report for Selenium and Uranium in MW-28,
White Mesa Uranium Mill, Blanding Utah.
99
EFRI, April 29, 2021 (EFRI 2021a). Source Assessment Report for Uranium in MW-31, White
Mesa Uranium Mill, Blanding Utah.
EFRI, September 7, 2021 (EFRI 2021b). Source Assessment Report for Uranium in MW-29,
White Mesa Uranium Mill, Blanding Utah.
EFRI, June 14, 2021 (EFRI 2021c). White Mesa Mill MW-24A Report, White Mesa Mill,
Blanding Utah.
EFRI, January 28, 2022. Source Assessment Report for Uranium and Selenium in MW-30,
White Mesa Uranium Mill, Blanding Utah.
Environmental Protection Agency. March, 1991. Handbook of Suggested Practices for Design
and Installation of Ground-Water Monitoring Wells (EP A/600/4-89/034 ).
Environmental Protection Agency. November, 1985. Practical Guide for Ground Water
Sampling (EPA/600/2-85/104).
GeoSyntec Consultants. January 2006. Cell 4A Lining System Design Repmt For The White
Mesa Mill Blanding, Utah.
GeoSyntec Consultants. December 8, 2007. Cell 4B Design Report For The White Mesa Mill
Blanding, Utah.
Geosyntec Consultants. July 2008. Cell 4A Construction Quality Assurance Report, White
Mesa Mill Blanding, Utah.
Geosyntec Consultants. November 2010. Cell 4B Construction Quality Assurance Report,
Volumes 1-3.
Hydro Geo Chem, Inc. 2001. Update to report: Investigation of Elevated chloroform
concentrations in Perched Groundwater at the White Mesa Uranium Mill Near Blanding,
Utah.
Hydro Geo Chem, Inc. August 29, 2002. Letter Report.
Hydro Geo Chem, Inc. August 20, 2007. Preliminary Corrective Action Plan, White Mesa Mill
Near Blanding, Utah.
Hydro Geo Chem, Inc. April 13, 2012. (2012a). Plan and Time Schedule for Assessment of pH
Uner Groundwater Discharge Permit UGW370004.
Hydro Geo Chem, Inc. May 7, 2012. (2012b). Nitrate Corrective Action Plan.
Hydro Geo Chem, Inc. December 7, 2012. (2012c). Investigation of Pyrite in the Perched Zone,
White Mesa Uranium Mill, Blanding, Utah.
100
Hydro Geo Chem, Inc. July 13, 2022. Hydrogeology of the White Mesa Uranium Mill Site Near
Blanding, Utah.
HydroSOLVE, Inc. 2000. AQTESOL VE for Windows. Users Guide.
INTERA, Inc. October 2007. (2007a). Revised Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. November 16, 2007. (2007b). Revised Addendum: --Evaluation of Available Pre-
Operational and Regional Background Data, Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. April 30, 2008. Revised Addendum: --Background Groundwater Quality Report:
New Wells For Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County,
Utah.
INTERA, Inc. December 30, 2009 Nitrate Contamination Investigation Report White Mesa
Uranium Mill Site Blanding, Utah.
INTERA, Inc. June 1, 2010 Background Groundwater Quality Report for Wells MW-20 and
MW-22 for Denison Mines (USA) Corp.'s White Mesa Mill Site, San Juan County, Utah.
INTERA, Inc. May 11, 2011. Revised Phase 1 (A through C) Work Plan and Schedule for Phase
1 A -C Investigation.
INTERA, Inc. June 3, 2011. Revised Phase 2 through 5 Work Plan and Schedule.
INTERA, Inc. October 10, 2012. Source Assessment Report, White Mesa Uranium Mill,
Blanding Utah. INTERA, Inc. November 9, 2012. pH Report White Mesa Uranium Mill,
Blanding Utah.
INTERA, Inc. May 7, 2013 (INTERA 2013a) Source Assessment Report for TDS in MW-29,
White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. August 30, 2013 (INTERA 2013b).Source Assessment Report for Selenium in
MW-31, White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. December 17, 2013 (INTERA 2013c). Source Assessment Report for
Tetrahydrofuran in MW-01, White Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. January 13, 2014 (INTERA 2014a). Source Assessment Report for Gross Alpha
in MW-32, White Mesa Uranium Mill, Blanding, Utah.
101
INTERA, Inc. March 19, 2014 (INTERA 2014b). Source Assessment Report for Sulfate in MW-
01 and TDS in MW-03A, White Mesa Uranium Mill, Blanding, Utah.
INTERA, Inc. May 1, 2014 (INTERA 2014c). Background Groundwater Quality Report for
Wells MW-35, MW-36 and MW-37 for Denison Mines (USA) Corp.'s White Mesa Mill
Site, San Juan County, Utah.
INTERA, Inc. June 7, 2021. Background Groundwater Quality Report for Wells MW-38, MW-
39 and MW-40 White Mesa Mill Site, San Juan County, Utah.
INTERA, Inc. December 9, 2015. Source Assessment Report for Selenium, Sulfate, TDS and pH
in MW-31, White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. June 24, 2016. Source Assessment Report for Sulfate in MW-18 and Fluoride,
Cadmium Thallium and pH in MW-24, White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. August 20, 2017. Source Assessment Report for Selenium, Sulfate, and Uranium
in MW-31, White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. June 25, 2018. Source Assessment Report for Fluoride in MW-14, White Mesa
Uranium Mill, Blanding Utah.
INTERA, Inc. January 16, 2019. (INTERA 2019a). Source Assessment Report for Uranium,
Selenium and pH in MW-30, White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. June 27, 2019. (INTERA 2019b). Source Assessment Report for Manganese in
MW-11, and fluoride, pH, cadmium, beryllium, nickel, and thallium in MW-24 White
Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. September 23, 2019. (INTERA 2019c) Source Assessment Report for Cadmium
in MW-25, White Mesa Uranium Mill, Blanding Utah.
INTERA, Inc. June 24, 2020. Source Assessment Report for TDS and Sulfate, in MW-31, White
Mesa Uranium Mill, Blanding Utah.
Kirby, 2008. Geologic and Hydrologic Characterization of the Dakota-Burro Canyon Aquifer
Near Blanding, San Juan County, Utah. Utah Geological Survey Special Study 123.
Knight-Piesold LLC. November 23, 1998. Evaluation of Potential for Tailings Cell Discharge
-White Mesa Mill.
MWH Americas November 2007. Denison Mines (USA) Corp. Infiltration and Contaminant
Transport Modeling Report, White Mesa Mill Site, Blanding, Utah.
MWH Americas (Now Stantec). March, 2010. Revised Infiltration and Contamination Transport
Modeling Report, White Mesa Mill Site, Blanding Utah, Denison Mines (USA) Corp.
102
Nuclear Regulatory Commission. May 1979. Final Environmental Statement related to operation
of White Mesa Uranium Project Energy Fuels Nuclear Inc., Docket No. 40-8681.
Resource Conservation Recovery Act. 1986. Ground Water Monitoring Technical Enforcement
Guidance Document.
Revised Tolling Agreement, Revision 3, between DUSA and the Director, Revision 2. August
21, 2011.
Stipulated Consent Agreement Docket No. UGW12-03 between Denison Mines (USA) Corp.
and the Director of the Divi ion of Radiation Control. July 12, 2012.
T. Grant Hurt and D. Kip Solomon, Department of Geophy ic University of Utah. May 2008.
Summary of work completed data re ults, interpretation and recommendations for the
July 2007 Sampling Event at the Deni on Mine , USA White Me. a Uranium Mill Near
Blanding Utah.
United States Geological Survey. 1998. Techniques of Water Resource Investigation of the US
Geological Survey, Book 9.
TITAN Environmental Corporation. July 1994. Hydrogeological Evaluation of White Mesa
Uranium Mill.
Umetco Minerals Corporation. April 10, 1989. Cell 4 Design, White Mesa Project Blanding,
Utah.
Umetco Minerals Corporation. January 1990. White Mesa Mill Drainage Report for Submittal
to NRC.
Umetco Minerals Corporation and Peel Environmental Services. 1993. Groundwater Study,
White Mesa Facilities, Blanding, Utah.
United States Department of Agriculture Natural Resource Conservation Service
http ://www.nrcs .usda.gov/wp /portaJ/nrcs/detail/ut/technical/dma/nri accessed 6/ 19/22.
Utah, State of. January 20, 2010. Ground Water Discharge Permit No. UGW370004.
Utah, State of. June 21, 2010. Ground Water Discharge Permit No. UGW370004.
Utah, State of. February 15, 2011. Ground Water Discharge Permit No. UGW370004.
Utah, State of. June 13, 2011. Ground Water Discharge Permit UGW370004.
Utah, State of. July 14, 2011. Ground Water Discharge Permit No. UGW370004
103
Utah, State of. September 7, 2011. Ground Water Discharge Permit UGW370004.
Utah, State of. August 24, 2012. Ground Water Discharge Permit No. UGW370004.
Utah, State of. July 27, 2021 (Amendment 10) Radioactive Materials License No. UT 1900479
(the "Mill License").
Utah, State of. December 23, 2021. Air Approval Order No. DAQE-ANl 12050024-21 (the "Air
Order").
Utah, State of. Department of Environmental Quality, Stipulation and Consent Agreement
between Ene.rgy Fuel Re ource (USA) Inc. and the Director of the Utah Division of
Wa te Management and Racliation Control ("Division") (Cell 2 Cover SCA).
104
Table No.
1.2-1 ............. .
1.2-2 ............. .
2.4-1 .............. .
2.5.2.1-1 ......... .
2.5.3-1 ........... .
2.5.3-2 ........... .
2.5.3-3 ........... .
2.5.3-4 ........... .
2.5.3-5 ........... .
2.9.1.3-1 ......... .
2. L1 .2-1 .......... .
2.13.1-1 ........... .
INDEX OF TABLES
Description
Chloroform Monitoring Wells (Depth and Purpose)
Nitrate Monitoring Wells (Depth and Purpose)
Groundwater Monitoring Wells (Depth and Purpose)
Water Quality of Entrana/N avajo Aquifer in the Mill Vicinity
Results of Quarterly Sampling Ruin Spring (2003-2004)
Results of Annual Sampling Ruin Spring (2009-2022)
Results of Annual Sampling Cottonwood Spring (2009-2022)
Results of Annual Sampling Westwater Seep (2009-2022)
Results of Annual Sampling Entrance Spring (2009-2022)
Groundwater Monitoring Constituents Listed in Table 2 of the
Permit
Plan & Time Schedule and Source Assessment Report Status
Drainage Areas of Mill Vicinity and Region
Table 1.2-1
Chloroform Monitoring Wells (Depth and Purpose)
Wd: L0,wjj, D "f01tal Dqlh Jhwvns:e
TW4-1 111.04 Chloroform Monitoring Well
TW4-2 121.125 Chloroform Monitoring Well
TW4-3 141.00 Chloroform Monitoring Well
TW4-4 114.50 Chloroform Pumping Well
TW4-5 121.75 Chloroform Monitoring Well
TW4-6 98.55 Chloroform Monitoring Well
TW4-7 119.80 Chloroform Monitoring Well
TW4-8 126.00 Chloroform Monitoring Well
TW4-9 121.33 Chloroform Monitoring Well
TW4-10 111.00 Chloroform Monitoring Well
TW4-11 100.00 Chloroform Monitoring Well
TW4-12 101.50 Chloroform Monitoring Well
TW4-13 102.50 Chloroform Monitoring Well
TW4-14 93.00 Chloroform Monitoring Well
MW-26 121.33 Chloroform Pumping Well/Groundwater
Monitoring Well
TW4-16 142.00 Chloroform Monitoring Well
MW-32 130.60 Chloroform Pumping Well/Groundwater
Moni toring Well
TW4-18 137.50 Chloroform Monitoring Well
TW4-19 121.33 Chloroform Pumping Well
TW4-20 106.00 Collapsed/ Abandoned
TW4-21 120.92 Chloroform Monitoring Well
TW4-22 113.50 Chloroform Monitoring Well/Nitrate
Pumping Well
TW4-23 113.50 Chloroform Monitoring Well
Well Location Total Depth Purpose
I
TW4-24 113.50 Chloroform Monitoring Well/Nitrate
Pumping Well
TW4-25 134.80 Chloroform Monitoring Well/Nitrate
Pumping Well
TW4-26 86.00 Chloroform Monitoring Well
TW4-27 96.00 Chloroform Monitoring Well
TW4-28 105.00 Chloroform Monitoring Well
TW4-29 91.00 Chloroform Monitoring Well
TW4-30 90.00 Chloroform Monitoring Well
TW4-31 104.00 Chloroform Monitoring Well
TW4-32 113.00 Chloroform Monitoring Well
TW4-33 84.70 Chloroform Monitoring Well
TW4-34 94.00 Chloroform Monitoring Well
TW4-35 86.5 Chloroform Monitoring Well
TW4-36 99.41 Chloroform Monitoring Well
TW4-37 113.72 Chloroform Pumping Well
TW4-38 113.92 Chloroform Monitoring Well
TW4-39 120.74 Chloroform Pumping Well
TW4-40 86.00 Chloroform Pumping Well
TW4-41 97.80 Chloroform Pumping Well
TW4-42 86.00 Chloroform Monitoring Well
TW4-43 95.50 Chloroform Monitoring Well
Table 1.2-2
Nitrate Monitoring Wells (Depth and Purpose)
Dum.atbm 1:qtalDe]dh ~p-o e
TWN-1 112.50 Nitrate Monitoring Well
TWN-2 95.00 Nitrate Pumping Well
TWN-3 110.00 Nitrate Monitoring Well
TWN-4 136.00 Nitrate Monitoring Well
TWN-5 155.00 Abandoned
TWN-6 135.00 Water Level Monitoring Well
TWN-7 120.00 Nitrate Monitoring Well
TWN-8 160.00 Abandoned
TWN-9 102.50 Abandoned
TWN-10 107.50 Abandoned
TWN-11 147.50 Abandoned
TWN-12 115.00 Abandoned
TWN-13 120.00 Abandoned
TWN-14 135.00 Water Level Monitoring Well
TWN-15 155.00 Abandoned
TWN-16 100.00 Water Level Monitoring Well
TWN-17 100.00 Abandoned
TWN-18 100.00 Nitrate Monitoring Well
TWN-19 110.00 Water Level Monitoring Well
TWN-20 95.50 Nitrate Monitoring Well
TWN-21 105.70 Nitrate Monitoring Well
PIEZ-01 107.50 Nitrate Monitoring Piezometer
PIEZ-02 100.00 Nitrate Monitoring Piezometer
PIEZ-03A 79.00 Nitrate Monitoring Piezometer
Table 2.4-1
Groundwater Monitoring Wells (Depth and Purpose)
W:eJI Location Total Depth Purpose
MW-1 115.00 General Monitoring Well
MW-2 125.00 Semi-Annual Groundwater Compliance
MW-3 96.00 Abandoned
MW-3A 95.00 Semi-Annual Groundwater Compliance
MW-4 122.00 No Longer Included In Groundwater
Program
MW-5 138.50 Semi-Annual Groundwater Compliance
MW-11 135.00 Quarterly Groundwater Compliance
MW-12 129.00 Semi-Annual Groundwater Compliance
MW-14 127.00 Quarterly Groundwater Compliance
MW-15 134.00 Semi-Annual Groundwater Compliance
MW-17 110.00 Semi-Annual Groundwater Compliance
MW-18 148.50 General Monitoring Well
MW-19 149.00 General Monitoring Well
MW-20 114.50 General Monitoring Well
MW-22 140.00 General Monitoring Well
MW-23 129.00 Semi-Annual Groundwater Compliance
MW-24 119.90 Semi-Annual Groundwater Compliance
MW-24A 120.00 Additional Studies
MW-25 115.10 Quarterly Groundwater Compliance
MW-26 121.33 Quarterly Groundwater Compliance
MW-27 91.00 Semi-Annual Groundwater Compliance
MW-28 106.00 Semi-Annual Groundwater Compliance
W<41 L<Joatiu T~tal lte,pth Pu.t-,pQse
MW-29 125.00 Semi-Annual Groundwater Compliance
MW-30 107.00 Quarterly Groundwater Compliance
MW-31 129.00 Quarterly Groundwater Compliance
MW-32 133.70 Semi-Annual Groundwater Compliance
MW-33 103.50 Dry, Not sampled
MW-34 109.00 Water Level Monitoring only
MW-35 123.60 Semi-Annual Groundwater Compliance
MW-36 119.90 Quarterly Groundwater Compliance
MW-37 120.20 Semi-Annual Groundwater Compliance
MW-381 90.00 Quarterly Groundwater for Background
MW-391 102.50 Quarterly Groundwater for Background
MW-401 120.00 Quarterly Groundwater for Background
TW4-242 113.50 General Monitoring Well
Notes: 1 -The Background Report for MW-38, MW-39, and MW-40 was submitted on June 7, 2021. These wells
will continued to be sampled quarterly until such a time that these wells are incorporated into the GWDP and the
frequency is changed as appropriate.
2 -TW4-24 is a chloroform monitoring well and nitrate pumping well. It is sampled semi-annually under
the groundwater program as a general monitoring well.
Table 2.5.2.1-1
Water Quality of Entrana/Navajo Aquifer in the Mill Vicinity
FES, Test Well Well#2 Well#S Parameter (G2R) 6/01/991 6/08/991
(1/27/77 -3/23/781)
Field Specific Conductivity 310 to 400 (umhos/cm)
Field pH 6.9 to 7.6
Temperature (0C) 11 to 22
Estimated Flow m/hr (gom) 109(20)
pH 7.9to8.16
Determination, mwliter
TDS (@ l 80°C) 216 to 1110
Redox Potential 211 to 220
Alkalinity (as CaCOS3) 180 to 224
Hardness, total (as CaC03) 177 to 208
Bicarbonate 226 214
Carbonate (as C03) 0.0 <1.0 <1.0
Aluminum 0.003 0.058
Aluminum, dissolved <0.1
Ammonia (as N) 0.0 to 0.16 <0.05 <0.05
Antimony <0.001 <0.001
Arsenic, total .007 to 0.014 0.018 <0.001
Barium, total 0.0 to 0.15 0. I 19 0.005
Beryllium <0.001 <0.001
Boron, total <0.1 to 0.11
Cadmium, total <0.005 to 0.0 <0.001 0.018
Calcium 50.6 39.8
Calcium, dissolved 51 to 112
Chloride 0.0 to 50 <1.0 2.3
Sodium 7.3 9.8
Sodium, dissolved 5.3 to 23
Silver <0.001 <0.001
Silver, dissolved <0.002 to 0.0
Sulfate 28.8 23.6
Sulfate, dissolved (as SQ4) 17 to 83
Vanadium 0.003 0.003
Vanadium, dissolved <.002 to 0. I 6
Manganese 0.011 0.032
Manganese, dissolved 0.03 to 0.020
Chromium, total 0.02 to 0.0 0.005 0.005
Copper, total 0.005 to 0.0 0.002 0.086
Fluoride 0.18 0.18
Fluoride, dissolved 0.1 to 0.22
Iron, total 0.35 to 2.1 0.43 0.20
Iron, dissolved 0.30 to 2.3
Lead, total 0.02 -0.0 <0.001 O.Dl8
Ma.!!;nesium 20.4 21.3
Magnesium, dissolved I 5 to 21
Mercury, total <.00002 to 0.0 <0.001 <0.001
Molybdenum 0.001 <0.001
1 Zero values (O.O) are below detection limits.
FES, Test Well Well#2 Well#5 Parameter (G2R) 6/01/991 6/08/991
(1/27/77 · 3/23/781)
Molybdenum, dissolved 0.004 to 0.010
Nickel <0.001 0.004
Nitrate + Nitrate as N <0.10 <0.10
Nitrate (as N) <.05 to 0.12
Phosphorus, total (as P) <0.0 l to 0.03
Potassium 3.1 3.3
Potassium, dissolved 2.4 to 3.2
Selenium <0.001 <0.001
Selenium, dissolved <.005 to 0.0
Silica dissolved (as Si02) 5.8 to 12
Strontium, total 0.5 to 0.67
Thallium <0.001 <0.001
Uranium, total (as U) <.002 to 0.16 0.0007 0.0042
Uranium dissolved (as U) <.002 to 0.031
Zinc 0.010 0.126
Zinc, dissolved 0.007 to 0.39
Total Organic Carbon 1.1 to 16
Chemical Oxvll:en Demand <l to 66
Oil and Grease 1
Total Suspend1::d Solids 6 to 1940 <1.0 10.4
Turbidjty 5.56 19.1
Determination (pCi/liter)
Gross Alpha <1.0
Gross Alpha + precision 1.6+1.3 to 10.2+2.6
Gross Beta <2.0
Gross Beta+ precision 8+8 to 73+J9
Radium 226 + precision 0.3+0.2
Radium 228 <1.0
Ra-226 + precision 0.1 +.3 to 0.6+0.4
Th-230 + preci sion 0.1+0.4 to 0.7+2.7
Pb-210 + precision 0.0+4.0 to 1.0+2.0
Po-210 + precision 0.0+0.3 to 0.0+0.8
Source: Adapted from FES Table 2.25 with additional Mill sampling data
Parameter
Ma.ior Ions (m2'L)
Alkalinity
Carbon Dioxide
Carbonate
Bicarbonate
Hydroxide
Calcium
Chloride
Fluoride
Magnesium
Nitrogen, Ammonia As N
Nitrogen, Nitrate+Nitrite as N
Phosohorous
Potassium
Sodium
Sulfate
Physical Properties
Conductivity (umhos/cm)
pH
TDS (m.l!/L)
TSS (mg/L)
Turbidity (NTU)
Metals-Dissolved (me/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Coooer
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Uranium
Vanadium
Zinc
Radionuclides (pCi/L)
Gross Alpha Minus Rn & U
Lead 210
Radium 226
Thorium 230
Thorium 232
Thorium 228
Table 2.5.3-1
Results of Quarterly Sampling
Ruin Spring (2003-2004)
Ruin Sprine.
Ql-03 02-03 QJ-03 Q4-3 Ql-04
--196 198 193
--ND ND ND
--ND ND ND
--239 241 235
-ND ND ND
153 156 149 158 158
28. l 21.5 27.4 28.0 29.3
--ND 0.5 0.5
34.8 34.2 31.7 34.2 35.8
ND ND ND ND ND
1.6 1.5 1.4 1.4 1.73
0.10 ND -ND ND
2.6 3.3 3.3 3.9 3.4
110 105 103 113 104
503 501 495 506 539
. . 1440 1410 1390
. -7.91 7.98 -. . 1040 1000 1050
-. 13.5 ND ND
. . 0.16 0.13 ND
ND ND 0.40 ND ND
ND ND ND ND ND
0.001 ND ND 0.001 ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND 0.082 ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
0.013 0.012 0.012 0.012 0.012
ND ND ND ND ND
ND ND ND ND ND
0.009 0.011 0.010 0.010 0.011
ND ND ND ND ND
0.014 ND ND ND ND
----ND
42 ND ND ND ND
0.3 ND 0.3 ND ND
0.3 0.2 0.5 ND ND
--ND ND ND
. -ND ND ND
Q2-04 Q3-04 Q4-04
191 195 183
ND 12 ND
ND ND ND
232 238 223
ND ND ND
162 176 186
28.5 26 25
0.6 0.6 0.6
35.l 37. l 38.6
0.06 ND 0.06
1.85 1.34 1.7
ND ND ND
3.6 4.0 3.7
110 113 116
468 544 613
1440 1320 1570
--
1110 1050 1070
ND ND ND
0.12 --
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
0.012 0.012 0.012
ND ND ND
ND ND ND
0.011 0.009 0.010
ND ND ND
ND ND ND
ND 1.4 ND
ND ND ND
ND 1.3 ND
ND 0.4 ND
ND ND -
ND --
Table 2.5.3-2 Results of Annual Sampling Ruin Spring (2009-2022)
Ruin Spring
Range of
Average
Constituent 2009 2010 2011 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Historic Avg2003
May July 2022 Values for 20042
Monitoring
Wells 1 *
Major Ions (mg/I)
Carbonate <I <I <I I <I <I <I <I <l <I <I <I <I <l <l -= -
Bicarbonate 233 254 241 239 237 208 204 200 193 208 202 202 186 200 185 --
Calcium 151 136 145 148 147 149 150 162 138 145 158 165 169 154 141 --
Chloride 28 23 25 44 28 26.3 27.1 27.4 24.4 27.4 29.9 23.9 25.8 28.1 28.4 ND-213 27
Fluoride 0.5 0.53 0.45 0.5 0.52 0.538 <I 0.445 0.541 0.5 0.414 0.505 0.473 0.468 0.5 ND-1.3 0.6
Magnesium 32.3 29.7 30.6 31. J 31.9 32.1 35.4 31.8 31.1 30.2 33.9 45.6 36.9 34.8 32.9 --
Nitrogen-Ammonia 0.09 <0.05 ND <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.2 --
Nitrogen-Nitrate 1.4 1.7 1.7 1.6 1.6 1.56 1.54 1.31 1.64 1.55 1.35 1.56 1.39 1.26 1.2 --
Potassium 3.3 3.07 3.2 3.3 3.5 3.46 3.24 3.14 3.18 3.07 3.58 3.31 4.09 3.83 3.2 --
Sodium 104 93.4 110 111 115 118 119 126 105 113 128 128 139 119 117 --
Sulfate 528 447 486 484 464 553 553 528 490 476 547 474 469 557 595 ND-3455 521
TDS 1010 903 942 905 1000 952 984 1000 916 972 1000 900 1240 1080 992 1019 -5548 1053
Metals (ug/1)
Arsenic <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <0.5 --
Beryllium <0.5 <0.5 <0.5 < 0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 --
Cadmium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 ND-4.78 0.01
Chromium <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 4.2 --
Cobalt <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <0.5 --
Copper <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <1.0 "'--
Iron <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <20 ND-7942 25
Lead <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <l.0 <l.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <0.5 ---
Manganese <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <0.5 ND-34,550 5
Mercury <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 --
Molybdenum 17 17 16 17 16 16.1 16.0 18.3 17.8 17.2 18 20.2 18.7 18.7 17.7 --
Nickel <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 0.6 ND-61 0.05
Selenium 12.2 10 11.8 10.2 10.8 10.2 12 10 10 10.5 12.2 10.8 10.5 11.2 11.7 ND-106.5 12.1
Silver <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <0.5 --
Thallium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 --
Tin <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <20 --
Uranium 9.11 8.47 9.35 8.63 8.68 9.12 9.61 9.03 8.38 8.49 9.35 9.02 9.32 9.31 9.1 ND-59.8 10
Vanadium <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 1.3 --
Zinc <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 --
Table 2.5.3-2 Results of Annual Sampling Ruin Spring (2009-2022)
-Ruin Spring
Range of
Average
Constituent 2009 2010 2011 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2022 Historic Avg2003
May July 2021 Values for 20042
Monitoring
Wells 1*
Radiologies (pCill)_
Gross Alpha <0.2 <0.2 <-0.3 <-0.05 <-0.09 <LO <I <1.0 <1.0 <LO <1.57 <1.0 <1.0 <LO <1.0 ND -36 0.28
VOCS(ug/L)
Acetone <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <10 --
Benzene <LO <1.0 <LO <1.0 <LO <LO <LO <LO <1.0 <LO <1.0 <LO <1.0 <1.0 <1.0 --
Carbon <LO <1.0 <LO <1.0 <LO <LO <1.0 <LO <LO <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 Teirachloride --
Chloroform <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <LO <1.0 <1.0 <LO <1.0 <l.0 <1.0 <l.0 ---
Chloromethane <LO <1.0 <1.0 <LO <1.0 <LO <1.0 <1.0 <1.0 <LO <1.0 <1.0 <1.0 <l.0 <1.0 -.,.
MEK <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <10 --
Methylene Chloride <LO <1.0 <LO <LO <LO <1.0 <LO <1.0 <LO <LO <1.0 <LO <1.0 <LO <2.0 --
Naphthalene <LO <LO <LO <1.0 <LO <LO <1.0 <LO <1.0 <LO <1.0 <1.0 <1.0 <LO <1.0 --
Tetrahydrofuran <1.0 <1.0 <LO <1.0 <LO <1.0 <LO <LO <1.0 <1.0 <1.0 <LO <1.0 <LO <1.0 --
Toluene <1.0 <1.0 <1.0 <1.0 <LO <1.0 <LO <1.0 <1.0 <LO <1.0 <LO <1.0 <LO <1.0 --
Xylenes <1.0 <LO <1.0 <LO <1.0 <1.0 <1.0 <1.0 <LO <1.0 <LO <1.0 <1.0 <1.0 <1.0 --
1 From Figure 3, Table IO and Appendix B of the Revised Addcmlum. Background Grom1d .. wer Qua/If)' Re11or1: New \\'ellf ft1r Denison Mines (USA) Corp·.~ \\fhite Mesa Mill Sire. San Juan Cou11f)·. Uwlt . April 30. 2008. prepared by INTERA,
Inc. and Table 16 and Appendix D of the Revised Backgr<111nd Gmundwater Quality Re11on: £,risring Wells/or Deni.,m1 Mi11u.~ (USA) Corp. ·s White M,m, Uranium Mill Sire. San Juan Counf)'. Utah. October 2007. prepared by INTERA. Inc.
2 From Figure 9 of the Revised Addendum, Evalua1ion of Available Pre-Operario,u1I and Regional Backrvound Data. Background Groundwater Quality Report: Existing Wells for Deni.wn MineJ (USA) Co,p. 's While Mesa Mill Sire. San Juan
Couinf)•, Utah, November 16, 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-l, MW-2. MW-3, MW-3A, MW-4, MW-5. MW-I I, MW-12, MW-14. MW-15, MW-17, MW-18, MW-19, MW-20. MW-22, MW-23, MW-24,
MW-25. MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)1
Table 2.5.3-3 Results of Annual Sampling Cottonwood Spring (2009-2022)
Cottonwood Spring
Range of
Average
Constituent 2009 2010 2011 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Historic Avgl~7
May July Values for 1982 1
Monitoring
Wells1"'
Major Ions (mg/I)
Carbonate <I <I <l 6 <I <I <I <I <I <I <I <l <I <l <I --
Bicarbonate 316 340 330 316 326 280 251 271 256 280 283 286 280 298 267 --
Calcium 90.3 92.2 95.4 94.2 JOI 87.9 99.7 Ill 102 99.6 109 122 120 108 99.0 --
Chloride 124 112 113 134 149 118 128 133 138 129 153 138 146 143 143 ND-213 31
Fluoride 0.4 0.38 0.34 0.38 0.38 0.417 <I 0.318 0.466 0.344 0.282 0.249 0.233 0.317 0.3 ND-1.3 0.8
Magnesium 25 24.8 25.2 25.2 27.7 23.6 29.0 27.5 29.5 27.1 30.2 35.3 32.9 31.3 28.5 --
Nitrogen-<0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.0512 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.2 Ammonia --
Nitrogen-Nimue 0.1 <0.1 0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.124 0.108 <0.1 <0.1 <0.1 <0.1 --
Potassium 5.7 5.77 6 5.9 6.2 5.53 6.18 5.91 6.11 5.72 6.35 6.78 7.14 7.40 5.9 --
Sodium 205 214 229 227 247 217 227 251 221 213 234 268 273 223 214 --
Sulfate 383 389 394 389 256 403 417 442 443 409 428 423 417 443 528 ND-3455 230
TDS 1010 900 1030 978 1040 996 968 1020 1070 1080 1080 1010 860 1110 1130 10l9 -5548 8.11
Metals (ug/1)
Arsenic <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 1.8 --
Beryllium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 --
Cadmium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 ND.-4.78 -
Chromium <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 6.6 --
Cobalt <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <0.5 --
Copper <10 <10 <10 <10 <10 <10 <JO <10 <10 <10 <10 <10 <10 <10 <1.0 --"
Iron <30 <30 53 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <30 <20 ND -7942 150
Lead <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <0.5 --
Manganese <JO <10 <10 <JO <JO <10 <10 <10 <JO <10 <10 <10 <10 <10 0.9 ND -34.550 580
Mercury <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 -
Molybdenum <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <IO <10 <10 1.4 ·--"
Nickel <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <0.5 ND-61 ·-
Selenium <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5 <5 <5 <5 <5 <5 <5 1.4 ND · 106.5 -·
Silver <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <0.5 --
Thallium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <5 <5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 --·-
Tin <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <20 .. --
Uranium 8.42 8.24 7.87 8.68 8.17 8.95 9.62 9.12 8.84 9.17 10.3 10.1 10.5 10.6 9.7 ND -59,8 -
Vanadium <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 2.4 --
Zinc <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 --
Table 2.5.3·3 Results of Annual Sampling Cottonwood Spring (2009·2022)
Cottonwood Spring
Range of
Average
Constituent 2009 2010 2011 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Historic Avg1977
May July Values for 1982 1
Monitoring
Wells1*
Radiologies (pCi/1)
Gross Alpha <0.2 <0.2 <0.1 <-0.1 <-0.2 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ND ·36 7.2_
VOCS(ug/L)
Acetone <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <10 --
Benzene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Carbon <1.0 <.1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <l.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 tetrachloride --
Chloroform <1.0 <1.0 <1.0 <1.0 <1.0 <l.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Chloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
MEK <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <10 --
Methylene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <2.0 -Chloride -
Naphthalene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Tetruhydrofuran <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Toluene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 --
Xylenes <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 ----
1 From Figure 3, Table LO and Appendix B of the Revised Addendum, Backgroulld Grou1Zdwater Quality Repor1: New Wells.for Denison Mines (USA) Corp 's White Mesa Mill Site, San Juan Count.·, Utah, April 30, 2008, prepared by
INTERA, Inc. and Table 16 and Appendix D of the Revised Background Groundwater Qua/in• Repor1: Existing Wells for Denison Mines (USA) Corp. 's White Mesa Uranium Mill Sire, San Juan Count.-, Utah, October 2007, prepared
by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reponed on April 30, 2008 (MW-L MW-2, MW-3. MW-3A, MW-4, MW-5. MW-11. MW-12. MW-14, MW-15. MW-17. MW-18. MW-19, MW-20. MW-22, MW-23.
MW-24. MW-25. MW-26, MW-27. MW-28, MW-29, MW-30. MW-3 l and MW-32)
Table 2.5.3-4 R fA IS line. Wi s (2009-2022)
Westwater·Seep·
Range of
Average
Constituent 2009 2010 2011 May 2011 July 2012 2013 2014 2015 2016 2017 2018 2019 2020 2020 2021 2022 Historic
(March) (June) Values for
Monitoring
Wells1 *
Major Ions (llll! )
Carbonate <I <I <I <1 <1 <1 <l <I <I <1 <I <I -
Bicarbonate 465 450 371 359 399 369 444 450 270 450 320 257 -
Calcium 191 179 247 150 176 125 204 185 118 204 125 104 -
Chloride 41 40 21 32.6 38.0 27.5 36.2 41.6 26.6 40.6 29.2 21.9 ND-213
Fluoride 0.7 0.6 0.54 0.424 0.618 0.574 0.659 0.505 0.555 0.429 0.473 0.5 ND-1.3
Magnesium 45.9 44.7 34.7 Not Not Sampled Not Sampled Not Sampled 34 47.3 31.7 56.6 43.7 30.8 54.6 30.9 26.4 -
Nitrogen-Ammonia <0.05 0.5 0.06 Sampled Dry Dry Dry 0.123 <0.05 <0.05 0.0832 <0.05 0.0593 <0.05 <0.05 <0.2 Dry -
Ni1rogen-Nitrate 0.8 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 -
Potassium 1.19 6.57 3.9 1.98 2.32 2.33 2.94 3.99 1.76 5.28 1.78 1.3 -
Sodium 196 160 l 12 139 185 133 218 152 117 245 111 98.7 -
Sulfate 646 607 354 392 573 318 580 436 307 460 340 278 ND-3455
TDS 1370 1270 853 896 1060 820 1220 1110 1200 1480 876 672 1019-5548
Metals (ue/1)
Arsenic <5 <5 12.3 <5.0 <5.0 <.5.0 <5.0 <5.0 <5.0 <5.0 <5.0 1.8 -
Beryllium <0.5 <0.5 0.91 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 -
Cadmium <0.5 <0.5 0.9 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 ND-4.78
Chromium <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 1.4 -
Cobalt <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 I -
Copper <10 <10 16 <10 <lO <10 <10 <10 <10 <10 <10 <1.0 -
Iron 89 56 4540 <30 40.l 181 575 1200 401 <30 948 920 ND-7942
Lead <1.0 <1.0 41.4 <1.0 <1.0 <1.0 <l.0 <1.0 <1.0 <l.0 <1.0 <0.5 -
Manganese 37 87 268 Not 171 55.5 144 312 528 369 35.4 432 206 ND-34,550
Mercury <0.5 <0.5 <0.5 Sampled Not Sampled Not Sampled Not Sampled <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 Dry Dry Dry -
Molybdenum 29 29 <10 Dry <10 <10 <10 <10 <10 <10 <lO <10 1.4 -
Nickel <20 <20 29 <20 <20 <20 <20 <20 <20 <20 <20 1.7 ND-61
Selenium <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5 .0 <5.0 1.4 ND-106.5
Silver <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <lO <0.5 -
Thallium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 -
Tin <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <20 -
Uranium 15.1 46.6 6.64 2.1 19.0 5.17 13.2 4.92 2.34 12.90 2.07 1.40 ND-59.8
Vanadium <15 <15 34 <15 <15 <15 <15 <15 <15 <15 <15 0.6 -
Zinc <10 <10 28 <10 <10 <10 <10 <10 <10 <10 <10 <10 -
Table 2.5.3-4 Results of Annual SamplinjL Westwater Seep (2009-2022)
Westwater Seep
Range of
Average
Constituent 2009 2010 2011May 2011 July 2012 2013 2014 2015 2016 2017 2018 2019 2020 2020 2021 2022 Historic
(March) (June) Values for
Monitoring
Wells1 "'
RadioJQJ?ics (pCi/1)
Not Not Sampled Not Sampled Not Sampled Gross Alpha <-0.1 <0.3 0.5 Sampled <l.0 <l.0 <1.0 <1.0 <1.0 <l.0 <1.0 <1.0 <l.0 ND-36
Dry Dry Dry Dry
voes (u!!IL)
Acetone <20 <20 <20 <20 <20 23.l <20 <20 <20 <20 <20 <10 -
Benzene <l.0 <l.0 <l.0 <l.0 <1.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <0.4 -
Carbon tetrachloride <1.0 <l.O <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.O <l.0 -
Chloroform <1.0 <l.0 <1.0 <l.0 <l.0 <l.0 <1.0 <1.0 <l.0 <1.0 <l.0 <l.0 -
Chloromethane <l.0 <l.0 <l.0 Not <l.0 <1.0 <l.0 <l.0 <l.0 <1.0 <1.0 <l.0 <l.0 -
MEK <20 <20 <20 Sampled Not Sampled Not Sampled Not Sampled <20 <20 <20 <20 <20 <20 <20 <20 <10 Dry Dry Dry -
Mc1hylcne Chloride <1.0 <1.0 <1.0 Dry <1.0 <l.0 <l.0 <l.0 <l.0 <1.0 <l.0 <l.0 <2.0 -
Naphthalene <l.0 <l.0 <1.0 <l.0 <1.0 <l.0 <1.0 <l.0 <1.0 <1.0 <l.0 <1.0 ~ -
Te1rahydrofumn <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <1.0 <l.0 <l.0 <l.0 <l.0 <l.0 -
Toluene <l.0 <l.0 <l.0 <1.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 -
Xylenes <l.0 <l.0 <l.0 <l.0 <l.0 <1.0 <l.0 <l.0 <l.0 <l.0 <l.0 <l.0 -·-~ .. . -.. ·--· -... -.. -.. .. .. -. .. I • o-. • • ·----·-___ ., .. .. .. --·-
by INTERA, Inc. and Table 16 and Appendix D of the Revised Background Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan County, Utah , October 2007,
prepared by INTERA, Inc.
-
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-!, MW-2, MW-3, MW-3A, MW-4, MW-5, MW-! I, MW-1 2, MW-14, MW-15, MW-17, MW-18, MW-19, MW-20, MW-22, MW-
23, MW-24, MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)
Table 2.5.3-5 Results of Annual Sampling Entrance Spring (2009-2022)
-Entrance Sj>ring
-
Range of A vetage,
Constituent 2009 2010 2011 May 2011 July 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Historic Values
for Monitoring
Wells1*
Major Ions (mwl)
Carbonate <I <I <I 7 <I <I <I <I <I <I <I <I <I <I <I -
Bicarbonate 292 332 270 299 298 292 247 324 340 402 236 480 242 260 308 -·
Calcium 90.8 96.5 88.8 96.6 105 121 103 131 131 129 116 155 144 138 123 -
Chloride 60 63 49 64 78 139 76.8 75.6 75 84.6 75.9 104 76.7 90.3 91.8 ND-213
Fluoride 0.7 0.73 0.58 0.58 0.64 0.71 <I 0.606 0.668 0.615 0.454 0.912 0.638 0.625 0.8 ND-1.3
Ma~nesium 26.6 28.9 26.4 28.4 32.7 43 34.9 33.3 38.6 36.4 42.4 48.0 45.1 47.7 44.8 --
Nitrogen-Ammonia 028 <0.05 <0.05 0.32 <0.05 <0.05 <0.05 0.202 0.0962 0.247 0.102 0.168 <0.05 <0.05 <0.2 -
Nitrogen-Nitrate 1.4 1 1.4 0.5 2.8 2.06 3.65 <0.1 0.403 <I 2.34 <I 2.46 1.55 0.2 -
Potassium 2.4 2.74 2.6 2.9 2 3.83 1.56 1.62 <1.0 3.88 3.64 4.66 4.31 4.04 4.5 -
Sodium 61.4 62.7 62.5 68.6 77.4 127 78.9 93.1 90.8 90.3 96 126 108 98.3 100 --
Sulfate 178 179 166 171 171 394 219 210 245 187 243 160 317 362 323 ND-3455
TOS 605 661 571 582 660 828 688 680 828 752 820 892 964 888 904 1019-SS{S
Metals ( 112/1)
Arsenic <5 <5 <5 <5 <5 <5 <5 5.02 <5 9.16 <5 8.94 <5 <5 3.1 ·-
Beryllium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 -
Cadmium <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 ND-4.78
Chromium <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 <25 5.S -
Cobalt <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 I -
Coooer <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <1.0 -
Iron <30 <30 37 55 34 162 37.2 295 94.4 371 <30 453 <30 <30 390 Nll>-7942
Lead <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <l.0 <0.5 -
Manganese 54 II 47 84 <10 259 16.1 367 210 9 13 405 587 56.3 27.2 629 !ID • 34 .5SO
Mercury <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.2 -
Molybdenum <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 14.30 <10 <10 1.8 --
Nickel <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 1.0 ND-61
Selenium 12.1 9 .. 2 13.1 5.5 13.2 1 l.2 15.9 <5 <5 <5 15.3 <5 15 13.6 5.2 NE>'-106.5
Silver <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <0.5 -
Thallium <0.5 <0.5 <0.5 <O·.S <0.5 <O.S <0.5 <O.S <0.5 <0.5 <0.5 <O.S <0.5 <0.5 <0.2 -
Tin <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <20 -
Uranium 15.2 17.8 18.8 15.3 21.1 38.8 23.2 36 22.0 14.6 27.6 70.I 24.7 36.1 17.5 ND-59.8
Vanadium <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 <15 3.4 -
Zinc <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 -
Table 2.5.3-5 Results of Annual Sampling Entrance Spring (2009-2022)
Entrance Spring -
Range of Average
Constituent 2009 2010 2011 May 2011 JuJ:i: 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Historic Values
for Monitoring
Wells1 •
Radioloeics (pCi/1)'
Gross Aloha 0.9 <0.5 I 1.5 1.6 0.5 2.3 <I 3.05 <I 2.53 <I 2.63 <I <I <I ND-36
voes c mill.)
Acetone <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <ID --
Benzene <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Carbon tetrachloride <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Chloroform <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Chloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
MEK <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <10 -
Methvlene Chloride <1.0 <l.0 <1.0 <l.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <2.0 -
Naphthalene <1.0 <1.0 <1.0 <l.0 <l.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Tetrahvdrofuran <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
Toluene <1.0 <1.0 <l.0 <1.0 <1.0 <1.0 1.32 <1.0 <1.0 13.1 <1.0 5.59 <1.0 <1.0 <l.0 -
Xylenes <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 -
1 From Figure 3, Table lO and Appendix B of the Revised Addendum, Background Groundwater Qualiry Report: New Wells.for Denison Mines (USA) Corp 's White Mesa Mill Site, San Juan Counly, Utah , April 30, 2008,
prepared by INTERA, Inc. and Table 16 and Appendix D of the Revised Background Groundwater Qua lily Report: Existing Wells.for Denison Mines (USA) Corp. 's White Mesa Uranium Mill Site, San Juan Counry, Utah,
October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-I, MW-2, MW-3, MW-3A, MW-4, MW-5, MW-11. MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-20, MW-
22, MW-23, MW-24, MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)
Table 2.9.1.3-1
Groundwater Monitoring Constituents Listed in Table 2 of the Permit
Nutrients:
Ammonia ( as N)
Nitrate & Nitrite (as N)
Heavy Metals:
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Uranium
Vanadium
Zinc
Radiologies:
Gross Alpha
Volatile Organic Compounds:
Acetone
Benzene
2-Butanone (MEK)
Carbon Tetrachloride
Chloroform
Chloromethane
Dichloromethane
Naphthalene
Tetrahydrofuran
Toluene
Xylenes (total)
Others:
Field pH (S.U.)
Fluoride
Chloride
Sulfate
Plan and Time
Schedule (P&TS)
Date
6/13/2011
9/7/2011
4/13/2012
12/13/2012
3/15/2013
8/28/2013
9/20/2013
12/5/2013
12/4/2014
5/19/2015
9/10/2015
12/3/2015
3/3/2016
3/10/2017
3/2/2018
8/28/2018
12/5/2018
2/21/2019
5/13/2019
2/27/2020
5/21/2020
11/18/2020
1/25/2021
5/11/2021
8/25/2021
*30 day extension for SAR
** Install MW-24A
Monitoring Periods
Covered
Ql, Q2, Q3, Q4 of
2010, Ql of 2011
Q2 2011
Multiple
Q3 2012
Q4 2012
Ql 2013
Q2 2013
Q3 2013
Q3 2014
Ql 2015
Q2 2015
Q3 2015
Q4 2015
Q4 2016
Q4 2017
Q2 2018
Q3 2018
Q4 2018
QI 2019
Q4 2019
Ql 2020
Q3 2020
Q4 2020
QI 2021
Q2 2021
*** No SAR for MW-12 extend casing
Table 2.11.2-1
Plan & Time Schedule and Source Assessment Report Status -
DWMRCP&TS DWMRCSAR
Approval Date SAR Date Approval Date
7/12/2012 10/10/2012 4/25/2013
7/12/2012 10/10/2012 4/25/2013
pH report -11/9/12 Pyrite
7/12/2012 Report -12/7/12 4/25/2013
2/4/2013 5/8/2013 7/23/2013
5/30/2013 8/30/2013 9/17/2013
9/17/2013 12/17/2013 1/7/2014
10/16/2013 1/13/2014 3/10/2014
12/18/2013 3/19/2014 6/5/2014
NO SAR -OOC due to NO SAR -OOC due
1/8/2015 well damage to well damage
8/11/2015 12/9/15* 2/19/2016
11/10/2015 No SAR -install packer NOSAR
2/25/2016 No SAR -install packer NOSAR
4/4/2016 6/24/2016 12/20/2016
5/23/2017 8/20/2017 3/20/2018
3/30/2018 6/25/2018 7/25/2018
10/18/2018 1/16/2019 7/9/2019
3/5/2019 6/27/2019 9/5/2019**
3/5/2019 6/27/2019 9/5/2019
6/26/2019 9/23/2019 11/26/2019
3/26/2020 6/24/2020 8/6/2020
6/22/2020 10/19/20* 1/21/2021
2/1/2021 4/29/2021 7/7/2021
NoSAR NoSAR
6/9/2021 9/7/2021 1/18/2022
9/29/2021 1/28/2022 5/5/2022
Constituents
Multiple
Multiple
pH -multiple wells
TDS-MW-29
Se -MW-31
THF-MW-01
Gross Alpha -MW-32
S04 -MW-01, TDS -MW-03A
U in MW-28
MW-31 -Se, S04, TDS, pH
MW-3-Cd, Zn, Be, Ni
MW-3 S04
MW-18 -S04 and MW-24 F, Cd, Tl,
and pH
MW-31 -Se, S04, U
MW-14-F
MW-30 -U, Se, pH
MW-24 -Tl, Cd, pH
MW-11 Manganese
MW-25 Cd
MW-31 TDS, S04
MW-28 Se, U
MW-12-Se, U and MW-31 -U***
MW-26TDS
MW-29-U
MW-30U,Se
Table 2.13.1-1
Drainage Areas of Mill Vicinity and Region
Basin Description Draina~e Area
sa. miles km2
Corral Creek at confluence with Recapture Creek 5.8 15.0
Westwater Creek at confluence with Cottonwood Wash 26.6 68.8
Cottonwood Wash at USGS Gauge west of project site ::::205 <531
Cottonwood Wash at confluence with San Juan River
:::: 332 <860
Recapture Creek at USGS gauge 3.8 9.8
Recapture Creek at confluence with San Juan River
::::200 <518
San Juan River at USGS gauge downstream at Bluff, Utah :::: 23,000 <60,000
Source: Adapted from 1978 ER, Table 2.6-3
Figure No.
1 ....................... .
2 ....................... .
3 ....................... .
4 ....................... .
5 ....................... .
6 ....................... .
7 ....................... .
8 ....................... .
9 ....................... .
10 ....................... .
11 ....................... .
INDEX OF FIGURES
Description
White Mesa Mill Location Map
White Mesa Mill Land Map
Generalized Stratigraphy of White Mesa Mill
Kriged Top of Brushy Basin White Mesa Site
Kriged 4th Quarter, 2021 Water Levels
Showing Inferred Perched Water Flow Paths
Southwest of Tailings Management System
Seeps and Springs on USGS Topographic
Base White Mesa
4th Quarter, 2021 Depths to Perched Water in
Feet, White Mesa Site
4th Quarter, 2021 Perched Zone Saturated
Thickness in Feet White Mesa Site
Groundwater (Well and Spring) Sampling
Stations in the White Mesa Vicinity
White Mesa Mill Site Plan Showing
Locations of Perched Wells and Piezometers
Mill Site Layout
12... .. . . . . . . . . .. .. . . . .... Drainage Map of the Vicinity of the White
Mesa Mill
13. . . . . . . . . . . . . . . . . . . . . . .. Streamflow Summary Blanding, UT Vicinity
WYOMING
UTAH
White Mesa Mill
Legend
* Public Land Ownership
White Mesa Mill Private
• Town
• Village
-Highway
--Road
--··-· -Stream
-·-·-·-Intermittent Stream
Tribal Land
Bureau of Land Management
Forest Service
State Trust Land
1:300,000
3 1.5 0
MILES
N
3 I
~RGYFUELS
REVISIONS Project: WHITE MESA MILL
Dale: By: county: San Juan State; Utah
Location Portions ofT37S R22E S28
Author: a re ither
FIGURE 1
WHITE MESA MILL
LOCATION MAP
Date: 5/20/2014 Drafted By: areither
S:\EnvironmentanUliWhlteM_esaMilnGroundwater Discharge Pennlt~enewal Appllcatlon\Ffgures\2022 Renev,al Draft figures\Land0wnershi!l_Map2022 No Lebels,mxd / 6/22/2022 8:04:31 AM by joapp
.fD :J' ~ j
L < -ff
24
·-:.... 25
~ ~ ~ -=>.;
C:::. "' r-~
19
""'"'"of ... ~ .....
]= \
30 ie' .,,,ti
~e"
+
,1/, ..... (il:,2~
++ * • ••
¢ t
Lyman \
21
Lyman
•
Shumway
Flavel
I,. ' ·""1~Y.5SS 1-'
Meyer
(.
fNIGtv1, ,..--. 1:.tr.'..c S:
+
+
+
---4 " llf
0 #
9.~ ~g
_ Structures
Monitoring Locations
e Boring
• Drinking Water ... MW Chloroform • MW Nitrate • Monitor Well
+ Piezometer Chloroform • Ute Monitoring Well -Seep or Spring
* Air Monitoring Station
* Control Point
Legend
--Canyon Rim Surface Land Ownership
-Highway ~ Bureau of Land Management
--Road L--1 Private
9:-~~
81 7/ ,I
Coordinate System: NAO 1983
StatePlane Utah South FIPS 4303 Feet
28 .. L-
--lb
REVISIONS I Project:
15 ~4
Grover Niels·on
-------.
Grover
FROG POND
w O! i cf i\ 26
ENTRANCE $PRIii\
35 I of Land Manag\ment
T37S
27
WHITE MESA MILL
!I l!Property Boundary~ Mill Site Claim Date: I By: I County: San Juan State: Utah
CJ Tailings Cell ISSSI Utah State Lease
C=:J Utah Land Trust School Section 1 IN = 3,333 FT
CJ Ute Mountain Ute 3,000 1,500 0
•
N
3,000
Location: Portions of T37S R22E
FIGURE 2
MONITORING LOCATIONS
C: 0 "' ai z
~c.;ALE IN FEET ! Author: joapp Date: 6/23/2022 Drafted By: joapp
Cl)
Cl) w z ~
()
I 1-
w ~ ~
>< 0 a: a.. a..
<(
LO
N
l
0
lO z
.
0
0)
2
.
0
0 n z
0
({)
.
0
U) n z
0
0
2
.
0
0
N z
.
LO
CX)
z
• -~ t
COVERED BY UNCONSOLIDATED ALLUVIUM,
COLLUVIUM AND TALUS ~----~---------------
EOLIAN SAND SAND AND SILT, REDDISH BROWN VERY
FINE-GRAINED
• ~ -o.-. J ~ • ~ •• : == == == == == == = MANCOS SHALE= == = SHALE, LIGHT GRAY, SOFT
'"'''"'"'' '' ''' ''' DAKOTA SANDSTONE
'" '"" '" '' ,,,,,,,,
, , , , , , , · BURRO CANYON FORMATION ,,,,,,, ..
''"'''' ''''"'' -~~~~--------------
BRUSHY BASIN MEMBER
____ ___,_ -------------
WESTWATER CANYON MEMBER
RECAPTURE MEMBER
~ SALT WASH MEMBER
~--/~---------------
SUMMERVILLE FORMATION
ENTRADA SANDSTONE
NAVAJO SANDSTONE
z 0 ~ ~ a: 0 LL
z 0 Cl) oc a:
0 ~
SANDSTONE, QUAfHZ. LIGHT YELLOW BROWN,
POORLY SORTED, IRON CON CREATIONS WELL
INDURATED
SANDSTONE, QUARTZ. LIGHT GRAY TO LIGHT
BROWN, CROSS-BEDDED, CONGLOMERATIC.
POORLY SORTED INTERBEDDED WITH GRAY-GREEN
SHALE
SHALE, GRAY, GRAY-GREEN, AND PURPLE, SILTY
IN PART WITH SOME SANDSTONE LENSES
SANDSTONE, ARKOSIC, )1:LLOW TO GREENISH GRAY.
FINE TO COARSE GRAINED. INTERBEODED WITH
GREENISH-GRAY TO REDDlSH-BROWN SHALE
SHALE, REDDISH-GRAY SILTY TO SANDY
INTERBEDDED IMTH SANDSTONE. ARKOSIC,
REDDISH-GRAY, TO YELLOW-BROWN, FINE-TO
MEDIUM-GRAINED
SANDSTONE, QUARTZ, YELLOWISH-TO
REDDISH BROWN, PINE-TO COARSE-GRAINED
INTERBEODED WITI·I REDDISH-GRAY SHALE
SANDSTONE, RED-BROWN, THIN-BEDDED, WITH RIPPLE
MARKS, ARGILLACEOUS WITH SHALE INTERBEDS
SANDSTONE, QUARTZ WHITE TO GRAYISH
BROWN, MASSIVE, CROSS-BEDDED, FINE-TO
MEDIUM-GRAINED
SANDSTONE, QUARTZ. LIGHT Yt:LLOWISH-BROWN TO
LIGHT-GRAY AND WHITE. MASSIVE, CROSS-BEDDED,
FRIABLE, FINE-TO MEDIUM-GRAINED
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
Date By County: Son Juan tate: Utah
5-1 4 DLS Location:
FIGURE 3
GENERALIZED STRATIGRAPHY OF
WHITE MESA MILL
ale: N/A Dale: Au • 2009 ralted By' D.Sledd
Taken from Stratigraphic Section near Water Well #3 Sira!igraphy.dwg Figure 3
--
~· , ,
, ,
TW443
~5504
TWN-20
[]5546
TW4-42
¢ 5508
MW-38
"9-5459
MW-5
.5491
TW4-12
kriged top of Brushy Basin elevation
contour and label (feet amsl)
approximate axis of Brushy Basin
paleoridge
approximate axis of Brushy Basin
paleovalley
temporary perched monitoring
well installed September, 2021
showing elevation in feet amsl
temporary perched nitrate monitoring
well installed April, 2021 showing
elevation in feet amsl
temporary perched monitoring well
installed April, 2019 showing
elevation in feet amsl
perched monitoring well
installed February, 2018 showing
elevation in feet amsl
perched monitoring well showing
elevation in feet amsl
0 5521 temporary perched monitoring well
showing elevation in feet amsl
TWN-7 h d . . . A.5545 temporary perc e nitrate monrtonng
-V well showing elevation in feet amsl
PIEZ-1 perched piezometer showing
Q 5552 elevation in feet amsl (X = abandoned)
RUIN SPRING 6 5380 seep or spring showing
elevation in feet amsl
HYDRO
GEO
CHEM, INC. APPROVED
SJS
KRIGED TOP OF BRUSHY BASIN
WHITE MESA SITE
OATE REFERENCE H :/718000/hydrpt2022/
GWDPrenewal/Ubbel1221_gwdp.srf
FIGURE
4
0
0 --
"-.. ssoo -, ·-@
4th quarter 2021
nitrate plume
4th quarter 2021
chloroform plume
potential perched water pathline
(assuming hypothetical connection
to Cottonwood Seep)
4th quarter 2021 water level
contour and label in feet amsl
saturated thickness estimated
to be less than 5 feet
estimated dry area
TW4-43 temporary perched monitoring
~5524 well installed September. 2021
showing elevation in feet amsl
TWN-20 temporary perched nitrate monitoring
[]5565 well installed April, 2021showing
elevation in feet amsl
TW4-42
¢ 5525
MW-38
~5463
temporary perched monitoring well
installed April, 2019 showing
elevation in feet amsl
perched monitoring well
installed February, 2018 showing
elevation in feet amsl
M;·:504 perched monitoring well showing
elevation in feet amsl
TW4-12 d . . II
0 5569 temporary perche monitoring we
showing elevation in feet amsl
TWN-7 . . . A.5569 temporary perched nitrate monitoring
V well showing elevation in feet amsl
PIEZ-1 perched piezometer showing
~ 5588 elevation in feet amsl
RUIN SPRING b 5380 seep or spring showing
elevation in feet amsl
NOTES: MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-21, TW4-37, TW4-39, TW4-40 and TW4-41 are chloroform pumping wells;
TW4-22, lW4-24, TW4-25 and TWN-2 are nitrate pumpin_g wells; TW4-1 , TW4-2 and TW4-11 water levels are below the base of the Burro Canyon Formation
HYDRO
GEO
CHEM, INC.
KRIGED 4th QUARTER, 2021 WATER LEVELS
SHOWING INFERRED PERCHED WATER FLOW PATHS
SOUTHWEST OF TAILINGS MANAGEMENT SYSTEM
APPROVED DATE
SJS
REFERENCE H:/718000/hydrpt2022/
GWDPrenewal/UpathNchl4021_gwdp_r1 .srf
FIGURE
5
0
"' S! :> rt
(!)
N 0 w 0
Cl) Q) 0 E 00 <( "' .... "'m ",;;,...
(!) (.) if z-0 -:I:<( a: c.. Cl) ....
c.. <( w iD
Cl) a: :i: ....
!! " cgw ~o z c.. I-
<( 0 ~
Cl) I-;;: Cl)
c.. Cl) :ti (!) Cl) Cl) => z 0
0 ~
0 ~ ::c
-a: _g C
~
0 .... ~ .... ~ 0) ~o
-g Cl) > "") !? Cl) j
u z -"' ~
0~
~ ::c <., u
ai > .l!!
111 Q) Ill
C: 111 Q)
E
Q) > 0 ..c 111 ti):;:;-c: Q) i~
Cl) C:
... 0 o:;: g-~
Q) .l!!
Cl) w
a: w ~ ;;:
!;; l8
~;j!j
•
I
V'Jd sg:00: r oroc: 'n ,aqwa1das 'AllP!'=' :pxw·£>c:ooosws1mooos tl\:>t
@ estimated dry area ,-, saturated thickness estimated -to be less than 5 feet
TW-443 temporary perched monitoring
~73
well installed September, 2021
showing depth to water in feet
TWN-20 temporary perched nitrate monitoring
[]78 well installed April, 2021 showing
depth to water in in feet
TW4-42 temporary perched monitoring well
9 70 installed April, 2019 showing
depth to water in feet
MW-38 perched monitoring well
-¢-10 installed February, 2018 showing
depth to water in feet
MW-5 perched monitoring well showing e 108 depth to water in feet
TW4-12
0 56 temporary perched monitoring well
showing depth to water in feet
TWN-7 temporary perched nitrate monitoring ~81 well showing depth to water in feet
PIEZ-1 perched piezometer showing g 57 depth to water in feet
RUIN SPRING b seep or spring
Note: Q4 2021 water levels for TW4-1 , TW4-2 and TW4-11 are below the base of the Burro Canyon Formation
HYDRO
GEO
CHEM,INC. APPROVED
4th QUARTER, 2021
DEPTHS TO PERCHED WATER IN FEET
WHITE MESA SITE
DATE REFERENCE FIGURE
SJS H :/718000/hydrpt202/
GWDPrenewal/Udtw1221_gwdp.srf 7
® estimated dry area
,-} saturated thickness estimated
to be less than 5 feet -, approximate axis of Brushy Basin , paleoridge -, approximate axis of Brushy Basin , -paleovalley
TW4-43 temporary perched monitoring
~20 well installed September, 2021
showing thickness in feet
TWN-20 temporary perched nitrate monitoring
IJ19 well installed April, 2021 showing
thickness in feet
TW4-42 temporary perched monitoring well
¢ 17 installed April, 2019 showing
thickness in feet
MW-38 perched monitoring well
-<:>-4 installed February, 2018 showing
thickness in feet
MW-5 perched monitoring well showing e 12 thickness in feet
TW4-12
Q 47 temporary perched monitoring well
showing thickness in feet
TWN-7 temporary perched nitrate monitoring <>24 well showing thickness in feet
PIEZ-1 perched piezometer showing
~37 thickness in feet
RUIN SPRING
c!, seep or spring
Note: 04 2021 water levels for TW4-1, TW4-2 and TW4-11 are below the base of the Burro Canyon Formation
HYDRO
GEO
CHEM, INC. APPROVED
SJS
4th QUARTER, 2021 PERCHED ZONE
SATURATED THICKNESS IN FEET
WHITE MESA SITE
DATE REFERENCE H:/718000/hydrpt2022/
GWDPrenewal/Usat1221_gwdp.srf
FfGURE
8
I ' I >J ,. :' ! " •• ~ -=~-· ---T --------~~ \_ ,~ ! -· ------=--,-~ ~ ... J,'! N
I I--l --· 1'----J 1 -r --• _.,._.-._
' I i ,. -. .t ( l".:.
I~( , I . ,:,
-I & .... V \
I
.,. lfa.ait• , 'I ., j\ !° '-'~ .ri .. ~-··'l# r : ,.. /·· 1
I \ ,.. / •• • , .... L
I &.. • t ,· itt , 1 ----~ -i v~/ ;~---
I ~. : , ~ ~,.! I ~\ \
, # \,\ *.-. I • \
=1 -#' i\ , • .,. I ~ I • / .• G1R : ~ ' 1 i ! ,~~l t A (
/ I~ : ) : :a••• ••1••1•• •• ••t•• •, '· ..... j.: I ·1' I ; i1 ,, : (
/.
/
-1 ..
r
~:
/ I
y{~£
I I .j. s
1500' 0 1500'
I --
1 --
I
I
SCALE: 1" = 3,000'
3000,1 I I
I --{-----~· tt:t --~-!' .. '~ --------+\-1 : j'
,.,., I (~ I --).·· ta? ;·:
?. ,,, I I ... ... I • ,, I ~
1
\f!_s 'i •• :. 1 > ~··"'a 1 , 1 ; i lt ~-----, ' \ r ,, I + a !=: l~~,
I
-1
J
<. ., .,,,...... Ir-·· ,J I I! .~ l·, •.. ,,; I ... ._.., \( '/ .. • , ' ., I • -.. ~".. cree,:__/.l , -G2R f " ' ., ,.. • ,
I -\------ter-:::...---:··· .:..•! ..... \=· :-f \ ! --i I -!ii i_
I " ii ~
··. sl'l'/ .. ,-,.,..#\ .... ""ti,, -~ '"\ ~..... •
"" I /"' ~' : G5R = ! \ .. *'1 I J. , ,.. • ~ • .. I ) • , .... I CJ-. \ i = '-t \;.. 12. : ..... I
/ •,, % ; \ <"~ 'f> } I ."--4-. • I , ' ! .. ~ , I
I .._ A G4R ~ II + II ~ ~ I ~ : I
j ? ,. 5 ' • ) ... ,, I yL. I I ... -· I : ~,'\I I -I ---) -:!-·l··J-ri --~----r------.••·-------#~\~ 1 ~ -;----~-1-· ' • -I • I \\\, ~ O .,. I • .. • -#.,._-....-,"" '" ~ "\
,,# .. ,
'
\ • t i ~ 1···/i "t .,. ,. , • .... • • \., .:. ., I j • .l-~ ,.,.._,. ) 4-1.-~ \ I\ ~ : I : '-1#1 \,\ i' :\ I '·l ~ • : • ~"#<:e, ·-. ,,. # ( • I • °" ..,,, 'I\__.,, .,., I • •
, ) 1 : : ! . \ ··, ( .. ~. .~ , /
t
--___ J ·,., l. -~:<••1•• ........... ~----. ~ --.. ~ --\ ---,: ~., .. , ! ! ~>-.··1
I ) %. f Ruin Spring • • '-' c ·.. ,.,;
l (_/.. ··,··~·-··'; : ; Q 1··, .• ;;,\? ,J ~ I I • I .. • V ., ···~ J ., . -. ..... . ,
# .. • •••••• I.. ...._:• " \ "'""'-I
\ • L_ ... " ' ! .. ! • \ I # "i
I
~, \ \ : ; ! i : 1 ,-..,... t .. 1
_ : , i ! : ; ... : \, I ... , -~
,_.. \ !. l -i ,~ ' • ·~ _.. I. --,--. ------~\ --_, ___ ----! -f -·--.,,v,. • \J ~ • l ~~ ~ I ' ~-_.> : : I \ \! : ~
(···~--= ,.. i ,.,
. . ' ·--, : ii : I ,.,. ~ i ! ·.. j ~"'tt 0 ~ ... _)_ . -~-+-_; -0 -Jfa ., ••.•
. I .. " ~ \ ~ ( l~ J....~ ,,.l
,,,
\., # .,,. ,,'I-"'~ ~ .,. .... ~ ' -I -.. .,
~~ ,~. « -r-~ ~ -I #. ; { r··' ~~·· I i
\ \ ,.. U TE ~ 0 UN ;fliA IN
., ~·-.... '~ U1
·--
'J ~1 ~ ," I
L_. .. .. ~I ~ -~r!f!''; __ __.__ *l , ~~ 11 Ii I .
---' ---~--~----·-~ t
,A. G4R GROUNDWATER (WELL OR SPRING) • • •a ,•• • PROPERTY BOUNDARY
SAMPLING LOCATION
RESERVATION BOUNDARY
5+ WATER SUPPLY WELL
-••-••-CANYON RIM
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 500
Lakewood, CO 80228
WHITE MESA MILL
Date I By I County: Soo Juon ,ta\e: Utah
5-14 I DLS I Location:
Figure 9
Groundwater (Well and Spring) Sampling
1 1 1 Stations in the White Mesa Vicinity
S-cale: 1 "=300~Date: Auq, 2009 ] DraftedBy: D.Sledd
GW,Sam_011rig W&S dwg Figure 9
TW4-43 temporary perched monitoring well ~ Installed September, 2021
TWN-20 temporary perched nitrate monitoring C well installed April, 2021
MW-24A perched monitoring well installed • December 2019
TW4-42
¢ temporary perched monitoring well
installed April 2019
TW4-40 perched chloroform pumping well EB installed February 2018
TW4-19 perched chloroform or EB nitrate pumping well
MW-38
-¢-perched monitoring well installed
February 2018
MW-5 • perched monitoring well
TW4-12
0 temporary perched monitoring well
TWN-7 temporary perched nitrate monitoring <> well
PIEZ-1 perched piezometer (,i)
RUIN SPRING
b seep or spring
~·fll
• ~21
HYDRO
GEO
CHEM,INC.
WHITE MESA SITE PLAN SHOWING LOCATIONS OF
PERCHED WELLS AND PIEZOMETERS
APPROVED DATE REFERENCE H:/718000/hydrpt2022/
GWDPrenewal/Uwelloc0322.srf
FIGURE
10
5620
HCL TANKS
~
SUBSTATION
Cl
D Q wATER
TANK cu
GRIZZLY
0 OLD
DECONTAMINATION
~ PAD
MILL o
BUILDING
o Q PROCESS WATER
0 0 I
VPL STORAGE 0 Oa-o·
CAUSTIC SODA
oo ooQASH ~~ AMMONIA Do c=:!:=L---'--'-'-----=..:; Lldl SALT
BOILERS ~
0 0 0 00
D0°0
D o 0o o
ALTERNATE
FEED
CIRCUIT
C
DRY REAGENT
STORAGE
c:=i
REAGENT YARD
sx
BUILDING
b Cl
Qo KEROSENE 0~
00
0 •
SODIUM
CHLORATE
X J
SHOP
1-
0 o ::> Cl'. 0 <( ~ >-
0..
0
0
=
c L----'-<--1
---5630-
CJ
TRUCK
SHOP
_1[ __
ORE PAD
SAMPLE PLANT
I
D
5646
-6640 ·~~ HOUSE <;>,~
----_____ __,
>-c:: c3 2 ::> 0 co
~ -c:: <(
0 UJ l-o ~ Cf) UJ er
\l
\
\\f
100 50
~,gyFue/s
REVISIONS
Dale By San Juan
10-11 GM
5-14 DLS
4-16 RE
1-22 ss
N
_,,
E
, '1
-;-
'
s
0 100 200
SCALE IN FEET
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Sufte 600
Lakewood, CO 80228
WHITE MESA MILL
!ale: Utah
Figure 11
MILL SITE LAYOUT
ate: May 12, 2000 rafted y: D.Sledd
Mill Site Layout 1 5 22 dwg Figure 11
• 1 USGS GAUGE NO. 09376900
e 2 USGS GAUGE NO. 09378630
• 3 USGS GAUGE NO. 09378700
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
Juan ta e: Utah
Figure 12
Drainage Map of the Vicinity
of the White Mesa Mill
1 :250,000 Dale Au , 2009 Draftea By: D.Sledd
Drainage Map.dwg Figure 12
400
I-350 w w u.. w 300 0:: () <( s· 250
0 ...J u.. 200 ~ I I-150 z 0 :!;
w 100 c.,
ii 50 w ~
tu 400
w Ji 350
0:: ~ s 0 ...J u..
~ ~ z 0 :!;
300
250
200
150
w ~ 100
~ 50
AVERAGE ANNUAL FLOW=950 AF -(1966-2001)
DRAINAGE AREA=3.77 SQ. Ml.
AVERAGE ANNUAL YIELD=252.1 AF/SQ. Ml.
YIELD-AF/SQ. Ml
MIN. AVG.
2,7 252
(1990)
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
MONTH
RECAPTURE CREEK NEAR BLANDING
USGS GAUGE 09378630
AVERAGE ANNUAL FLOW=7757 AF -(1966-1971)
DRAINAGE AREA=4.95 SQ. Ml
AVERAGE ANNUAL YIELD=153 AF/SQ. Ml.
MAX.
881
(1983)
YIELD-AF/SQ. Ml
MIN.
46.9
(1971)
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
MONTH
SPRING CREEK ABOVE DIVERSIONS,
USGS GAUGE 09376900
AVG.
153
1600
tu 1400
w u.. ~ 1200
~1000
0 ...J u.. 800 ~ I !z 600
0
:!;
w 400 ~ w 200 ~
MAX •
262
(1966)
AVERAGE ANNUAL FLOW=6547 AF -(1965-1986)
DRAINAGE AREA=205 SQ. Ml.
AVERAGE ANNUAL YIELD=32 AF/SQ. ML
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
MONTH
COTTONWOOD WASH NEAR BLANDING
USGS GAUGE 09378700
NOTES
1. FOR THE LOCATION OF WATER COURSES
SUMMARIZED, SEE FIGURE 3.7-1
YIELD-AF/SQ. Ml
MIN. AVG .
4.9 32
(1976)
2. SOURCE OF DATA. WATER RESOURCES DATA RECORDS.
COMPILED AND PUBLISHED BY USGS.
MAX •
88
(1983)
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
San Juan taie: Utah
Figure 13
Streamflow Summary
Blanding UT Vicinity
N/A Dale: Au • 2009 Dratted By: D.Sledd
Streamflow Summary dwg Figure 13
Appendix
A .................... .
B .................... .
C .................... .
D .................... .
E .................... .
F .................... .
G .................... .
H .................... .
I. ..................... .
1 ..................... ..
K ..................... .
L ...................... .
M ....................... .
N ..................... ..
INDEX OF APPENDICES
Description
Radioactive Materials License Amendment No.
4: March 31, 2007
White Mesa Mill Site Maps with Well
Locations
Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill,
Revision: 3, November 11, 2019
Results of Soil Analysis at Mill Site
Tables: Chemical and Radiological
Characteristics of Tailings Solutions, Leak
Detection Systems and Slimes Drains
Cell 4A and 4B BAT Monitoring, Operations
and Maintenance Plan 07/11 Revision: Denison
2.3
Stormwater Best Management Practices Plan,
Revision 2.1: April 2022
White Mesa Mill Discharge Minimization
Technology (DMT) Monitoring Plan, 1/2022,
Revision: EFRI 13.0
White Mesa Mill Tailings Management System,
3/2017, Revision: EFR 2.5
Cell 2 Slimes Drain Calculations and Figure
2009-2022
White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP)
Date 2/15/2022 Revision 7.7
Tailings and Slimes Drain Sampling Program,
Revision 3.0, July 8, 2016
Contingency Plan, 12/11 Revision: DUSA-4
White Mesa Mill Containerized Alternate
Feedstock Material Storage Procedure, PBL-
19, Revision: 3.0, March 1, 2017
0.. . . . . . . . . . . . . . . . . . . . . . . White Mesa Mill Chemical Inventory
Appendix A
Radioactive Materials License Amendment No. 4: March 31, 2007
i:t...G.15.1997 1:3::flM l'0.340 P.4
TECHNICAL EVALUATION REPORT
REQUEST TO RECEIVE AND PROCESS ALTERNATE FEED MAlERIAL
DOCKET NO. 40--8681
LICENSEE: International Uranium (USA) Corporation
FACILITY: VVhite Mesa Uranium Mill
PROJECT MANAGER: James Park
SUMMARY AND CONCLUSIONS:
LICENSE NO. SUA-1358
The U.S. Nuclear Regulatory Commission staff has reviewed Energy Fuels Nudear, Inc. 's
(EFN's) request dated Apnl s, "i997, ta receive and process uranium-bearing material currently
contained at Cabot Perfonnance Materials' (CPM's) facility near Boyertown, Pennsylvania.
The material would be processed at the White Mesa mill, of which EFN is the former owner.
The current owner of the mill and NRC licensee, International Uranium (USA) Corporation
(IUC), previously has agreed to abide by all commitments and representation made _by EFN.
Based on its review of the Apnl 3, 1997, submittal and additional information provided by letters
dated May 6, May 19, June 20, and August 6, 1997, the NRC staff considers the amendment
request acooptable.
QESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:
By its submittal dated April 3, 1997, EFN requested that NRC Source Material License
SUA-1358 be amended to allow receipt and processing of alternate feed material (i.e., material
other than natural uranium ore) at its White Mesa uranium mill located near Blanding, Utah.
This uranium-bearing material, weighing approximately 16,000 dry tons, is held currently by
CPM at its facility near Boyertown, Pennsylvania. The material is a moist solid (up to
40 percent moisture content) which contains uranium at an average concentration of
0.3 percent by weight, and ~r..onomically attractive concentrations of tantalum and niobium.
CPM is authorized to possess this material under NRC Source Material License SMB-920.
The material will be shipped by train and exclusive-use trucks from CPM's facility to the White
Mesa mill in intennodal containers. After being loaded and sealed at CPM's facility, the
containers will be transpcrted by truck to a nearby inteimodal rail terminal. The containers will
be loaded on flatbed railcani and transported cross--cauntry to the final ran destination (either
Grand Junction, Colorado or Green River, Utah), where they will be transferred to trucks far the
final leg of the journey to the White Mesa mill. Each ccntainer ha5 a capacity of 25 cubic yards,
and it is expected that approximately 15 containers will be loaded and transported each day.
At the mill site, the uranium-bearing material will be emptied from the intermodal containers into
the ore receiving hopper. From there, the material will be processed through the semi-
autogenous grind (SAG) mill, where water will be added to create a sluny, which is then
1
f'.l,.G.15.1997 t:34A'1 l'().340 P.S
pumped to~ pulp storage tank and from there into the leach circuit. ln the leach circuit, the
slurry will be treated to separate the uranium from the tantalum and niobium, and rue wm utilize
the uranium and vanadium solvent extraction circuits, respectively, to recover these metals.
IUC plans to add two filter presses and some additional piping to itS mill circuit to aid in the
processing of this material.
Water spray systems will be utilized to reduce the potential for dust dispersion and airborne
contamination in emptying the intermodal containers. Other than the slight circuit changes
mentioned previously, IUC anticipates that processing the uranium-bearing material will not
differ from processing natural uranium/vanadium ores.
rue will provide personal protective equipment (coveralls, gloves, and full-face respirators (to
be used if needed)) to indiViduars engaged in process( ng the material. The efficiency of
airborne contamination control measures durfng the material handling operations will be
assessed in the immediate vicinity of these operations. Airborne particulate samples and
breathing zone samples will be collected during initial material processing activities and
analyzed for gross alpha. Sampling results will be used to establish health and safety
guidelines to be implemented throughout the processing operations.
Additional environmental air samples will be collected at nearby locations to the material
processing activities and analyzed to ensure that the established contamination control
measures are adequate and effective.
Trucks used to transport the material to the mill site will be radiometrically scanned upon arriVal
to ensure that leakage has not occurred and that radiation levels are_ within appropriate limits.
TruckS will again be scanned prior to their release from the site restrlct&d area. In addition, the
intermodal containers used to transport the material will be property closed, cleaned (if
necessary), surveyed, and documented before leaving the site.
TECHNICAL EVALUATION:
The NRC staff has revfewad IUC's request In accordance with 10 CFR Part 40, Appendix A.
requirement& and NRC staff guidance "Final Position and Guidance on the Use ot·uranium MIii
Feed Material Other Toan ~miral Ores" (60 FR 49296; September 22, 1995). This guidance
(referred to hereinafter as the alternate feed guidance) requires that: the staff make the following
detenninationa in its reviews of ffcensee requests to precess material other than natural
uranium ores.
1. Whettler the faed material meets the definition of "ore;"
2. VVhether the feed matelial contains hazardous waste: and
,....
3. Whether tne ore is being processed primarily for its source-material content.
2
~.15.1997 1=34A1 -l'fJ. 340 P. 6
netecmioation ar whether the feed material ;s ·ore·
FOT the tailings and wastes from the proposed processing ta qualify as 11 e.(2) byproduct
material, the feed material must qualify as "are.• In the aJtemate feed guidance, ore IS defined
as
" ... a natural or native matter that may be n,ined and treated for the extraction of
any of its constituents or any other matter from which source material is
extracted in a licensed uranium or thorium mill."
The proposed allemate feed material contains uranium at an average concentration of 0.3
percent by weight; therefore, it meets the definition of •source materia~" as defined at 1 o CFR
40.4. IUC Is proposing to extract this uranium. Therefore, the material meets the definition of
ore, because it is a· "matter from which source materiaJ Is extracted In a llcensed uranium or
thorium mill."
Determination of whether the feed material contains hazardous,waste
Under the alternate feed guidance, proposed feed material whiCh contains a listed hazardous
waste will not be approved by the NRC staff for processing at a licensed min. Feeq materials
which exhibit only a characteristic of hazardous waste o.e., lgnltabilJty, corrcslvity, reactivity, er
toxicity) would not be regulated as hazardous waste and could therefore be approved by the
staff for recycling and extraction of source material. However, this does not apply to residues
from water treatment. Therefore, NRC staff acceptance of aud1 residue& as feed material
would depend on their not containing any hazardous or Characteristic hazardous waste.
The NRC staff has reviewed the fallowing sources of information In determining whether the
uranium-bearing material is or contains hazardous waste: (1) the average composition data for
the material, as submitted by IUC on June 20, 1997, (2) the results of additional testing, as
provided by letter dated May 6, 1997, (3) NRC flies far the Boyertown facility, which address, in
part, the pracas used to produae the material and the methOds used to store the materfal, and
(4) supplementary information concerning the State of Pennsylvania Department of
Environmental Protection's hazardous waste regulations. In addition, as an attachment to
a letter dated August 6, 1997, IUC provided an anadavit from CPM in which CPM afflnned that
the material is ~ot and does not contain hazardous waste.
Based on its revtew, U\e NRC staff finds that the uranium-bearing material la not hazardous
waste and does not contai'I hazardous waste. The NRC staff has determined alao that the
uranium-beartng ma18rial is nat a residue from water natl 1.ent. Thia material is the result of
the initial processing of raw ares containing tantalum and niobium.
Therefore, the NRC staff considers the uranium-bearing material acceptable for recycling and
extraction of source material
3
~.15.1997 1:35PM l'().340 P.7 -
Detennioattea ot whether v,e feed material is being processed primarily toe its soy,:ce--material
con1ent
To show that potential alternate feec1 material is being processed primarily for its source-
material content, a licensee must either (1) demonstrate that U,e material would be approved
for disposal In the tailings impcundment under the "Final Revised Guidance on Disposal of Non-
Atomic Energy Act of 1954, Section 11e.(2) Byproduct ~aterial In Tailings Impoundments;" or
(2) certify, under oath or affirmation, that the material is being processed primarily for the
recovery af uranium and for no other primary purpose. Any such certification must be
supported by an appropriate justification and accompanying dOaJmentation.
The licensee has provided a signed affirmation that the uranium-bearing material is being
processed primarily for the recovery of uranium and tor no other primary purpose. IUC states
that the uranium content of the material, in canjunction with the reduced uranium processing
costs associated with the recovery of the tantalum and niobium, makes processing the CPM
material economically attractive to IUC. The NRC staff has discussed with IUC the business
arrangements regarding the material and finds that IUC is paying CPM for the acquisition of the
material.
The NRC staff has reviewed the ana&ytical data provided by IUC and infcrmation contained In
the NRC's flies for the CPM facility, and finds that the uraniUm concentration in the material is
comparable With that in natural uranium ores whld'I are and were normally processed by
uranium mills in the U.S.. These natural ores contained uranium at concentrations of 0.3
percent and below. Therefore, the NRC staff considers IUC'a juatitication to be acceptable.
Conclusions concemina alternate feed matenal designation
Based on the information provided by the licen&ee, the NRC staff finds that tha CPM's uranium-
bearing material is altemate feed material because: (1) It meets the definition of "ore," (2) It
does not contain hazardous waste, and (3) it Is being processed primarily for its source-material
content
Other considerations
The NRC staff has also concluded that the processing of this material wtl not result In (1) a
significant change or increase in the types or amounts of effluents that may be released offsite;
(2) a significant incn!ase In individual or cumulative occupational radiation exposure; (3) a
significant construction impact; or (4) a significant increase In the potential for or consequences
from radiological accidents. This ccndusion Is based on the following Information:
a. YeUowcake produced from the processing of this matertal wlll not cause the currantJy-
approved yeOowcake production limit of 4380 tons per year to be exceeded. In addition,
and as a result, radiological doeea to members of the public in the vicinity af the mill will
not be elevated above levels previously assessed and approved.
4
~.15.1997 1:35PM -l'0.340 P.8
b. The-physicar changes to the miU circuit that IUC will implement to process this materiaJ
are not significant No construction impacts beyond those previously assessed will be
involved with these changes.
c. Tailings produced by the processing of this material will be disposed of on-site In an
existing llned tailings impoundment (Cell 3). The addition af these tailings (a maximum
of 16,000 tons) to Cell 3 wm increase the tCJb!l' amount of tailings in the cell by one
percent. to a total of approximately 69 percent of cell capacity; therefore, na new
impoundments are necessary. The design of the uisting impoundments previously has
been approved by the NRC, and IUC is required by ils NRC 6cense to conduct regular
monitoring of the impoundment liners and of the groundwater around the Impoundments
to detect leakage if it should occur.
d. The uranium-bearing material contains metals and other parameters which already are
present in the mill taiDngs disposed of in the Cell 3 impoundment. Analysis of samples
from the uranium-bearing material and from Cell 3 show that the only.~ 1:11,neters
present in signific;antly higher concentrations in the uranium-bearing material are fluorine
and carbon. HC7N9V8r, these concentrc•J.-, ... should not have an acfvenla Impact an the
overall Cell 3 tafflngs c:ompositian, because the amount of tail!!1gs (a maximum of 16,000
tons) produced by processing u,e material is not significant in comparison to the total
amount of tailings currently in the cell (approximately 1.4 mDlion tans). AdditfonaJIJ, as
stated previously, IUC is required to conduct regular manitaring cf the impoundment
leak detection systems and of the groundwater in the vieinity of the impoundments to
detect leakage tr it ahaulc:f occur.
e. For the following reasons, it is not expected that transportation impact& associated with
the movement of the material by train and buck fn>m Pennsylvania to the White Mesa
mill will be significant
• The material will be shipped as ·row specific aetivity" material in exclusive-use
containers (I.e., no other materials wlll be In the containers with the uranium-
bearing material). The containers will be appropriately labeled, placarded, and
manifested, and shipments will be tracked by the shipping company from CPM's
facility until they reach the White Masa mm.
• On average during 1996, 370 trucks per day traveled the sb etch of State Road
191 between Monticello, UT and Blanding, UT (personal communication with the
State d Utah Department of Transportation). An additional 15 true.ks per day
travelng this room to the mill represents an inaeased traffic load of only four
percent. Shipnenta are expected to take place over the course of a limited time
penod (three to soc months).
• The cantainens end trucks involved in transporting the material to the mm site will
be surveyed and decontaminated, as necessary, prior to leaving CPM's facility
far Whlta Meaa and again prior to leaving the mm site for the return bip.
5
~.15.1997 1:36PM f'(),340 P.9
f. MIii-empioyees lnvclved in handling the material wiD be prwided with personal protective
equipment. induding respiratory protection. AJrbome particulate and breathing zone
sampling result& wm be used to establish health and safety guideHnes to be
implemented throughout the precessing operations.
RECOMMENDED LICENSE CHANGE:
Pursuant to Trtle 1 O of the Code of Fede~I Regulations, Part 40, Source Material Ucense
SUA-1358 will be amended by the addition of Ucense Condition No. 10.9 as follows:
10.9 The licensee is authorized to receive and prt1cess source material from Cabot
Perfonnance Materials' facility near Boyertown, Pennsylvania, in accordance with the
amendment request dated April 3, 1997, as amended by submittals dated May 19, and
August 6, 1997.
ENVIRONMENTAL :;.n?ACT EVALUATION:
Because IUC's receipt and processing of the 'T11lterial will not result in (1) a significant change
or increas9 in the types or amounts of effluents that may be released offilite; (2) a significant
increase in indiVidual or cumulative occupational radiation exposure; (3) a significant
construdion impact; er (4) a significant increase In the patential for or consequences from
radiological accidents, an environmental review was not performed since actions meeting theS8
critaria are categorically exduded under 10 CFR 51.22(c)(11).
6
ii ii: WW 'liihihitii jniiili Ww: WW j\'i I
U.S. NUCLEAR REGULATORY COIDl1SSION
MATERIALS UCENSE
f'0.340 P.10
···--····-·--Sllil PAGE 1 OF • 8 -~es
Pw"Suaat to tbe Atomic Eneru Jr.a. ·oe J9S4, as amcuded, the El1eT8Y Reorpuiz&ti01t Aci of 1974 (Public Law 93-438), and Title 10, Code of
Federal Rcgvtauom, Chaptu I. P:im :30, 3 J. 32. 33. 34, 35. 36. 39, 40, and 70. and in tcliatiCe on sraterneun md repRKnwions hctetofcfc made
by the licc11See. a license i.J hereby iuued wcbonzing the licensee to receive, acquire, possess. and tnns&r byproduct. source, and special nuclear
material designated below; to use JUGh mmterial for tbe pw'!)C)Se(I) and at the place(s) desipatad below; to deliver or trllllfer such matmial to
pcrsom aulborized to re<:cive il in acconlance with tile regulations of the applicable Part(s). This li=mc shall be deemed to contain the conditions
specified in Section 183 of the Atomic Ensgy Act of 1954, u amended, and ii .liDbject to all appliculc rul~. regulations, and orden of the
Nuclear Regula.tor, Commiuion now or hereafter in effect and t0 any condiciom specified below.
l.
2.
Licensee
International Uranium (USA) corporation
[Applicable Amendments: 2]
6425 S. HighWay 191
P.O. Box809
Blanding, utah 84511
3. License Number
s. Docul<* .. ··
Rcfemu:e No.
6. Byproduct, Source, .md/or
Special Nuclear Material
7. Chemical and/or P11y,,.....;. .
Form
. 8. MaxirnnrnAmountthatLicemec
May Posscas at.Any One Tune
' Uuda' 'lb.is UCCDSC . .
Natural Uranium Any
SECTION 9: Administrative Conditions
9.1 The authorized place of use shall be the licensee's VVh1ta Mesa ~ium mil6ng facility,
located in San Juan County, Utah. ·
9.2 All written notice9 and reports to the NRC required Ul'lder this license, with the exception of
incident and event notifications under 10 CFR 20.2202 and 10 CFR 40.60 requiring
telephone notfflcation, shall be addressed to the 01ief, Uranium Recovery Brandl, Division of
Waste Management, Office of Nuclear Material safety and Safeguards.
Incident and event notifications that require telephone notification shaU be made to the NRC
Operations Canter at [phone].
9.3 The licensee shall conduct operations in accordance with statements, representations, and
conditions contained in the license renewal applicatJon submitted by letter dated August 23,
1991, as revised by submittals dated J~nuary 13, and April 7, 1992, November 22, 1994,
July 27, 1996, December 13, and December 31, 1998, and Janumy 30, 1997, whieh are
hereby Incorporated by reference, and for the standby Trust Agreement, dated April 29,
1997, except whera super&eded by license conditions below.
9.4
VVhenever the wcrd "wilr is used in 1ha above referenced documents, it shall denote a
requirement [Applicable Amendments: 2)
A. The licensee may, Mthout prior NRC approval, and subject to the conditions specified
in Part B of thi$ conaltion:
(1) Make changes in the fadfity or process, as presented in the application.
l'O. 340 P.11 i::t..)'.;. 15.1937 1: 37A'1 ,. •wwawawww+wwwwww
U.S. NUCt.EAR REGULATORY COMIIISSION Jll'Gf OF 8 f'll.GES
I':.-,.,....~ ,-n.,""""'N,..,..umtl-=-IG'-----=--------'----
-MATERIALS LICENSE
SUPPLEMENTARY SHEET
SlJA..1
August 15, 1997
(2) Make changes in the procedures presented in the application.
(3) Conduct tests or experiments not presented in the application.
8. Toe ricensee shall file an application fer an amendment to the license, unless the
following conditions are satisfied.
(1) The change, t~t, or experiment does not conflict 'Nith any requiroment
specifically stated in this license, or impair the licensee's ability ta meet au
applicable NRC regulations.
(2) There ~ r,o degfadatiot1h ~-£~,;~ or environmental corrmlltments in
the licen~pplit!ation, or provided by~ ipen:>ved reclamation plan . • , 'l ...,..,v. ~'. • ::> • ·~'/ ),
(3) The c.[taage, test, or experiment is consistent wftn\ie conclusions of actions
anatymd and selected in the i:A dated Febru1uy @.
11 • .... -,,: •
•,1 ' • -... ,, •
c. The li~1s 'd~enrunations concerning Part B ,of1ft~l'fditior'I, shall be made by a
"Safety and Envi~htal Review Panel (SeRffl'· ·nie seRJ,1ihall co~ist of a
minimum of thl'H inanriduals, One .member'of,Vte;..SERP shalU•ve expertise in
management and ~ l'!l&ponsibre-for~al and financfal approval changesj
one member shall have ~11iS, in operatjo~~or con~n and shall have
respqosibility f\lr ffflP,lementing,a...y ~,1Jat;'cbanges; and, Or:J,~ member shall be the
~rate radia,ian ~·.bffic?.ar iCR~) ~-~•lent. with ~ ,:esponsfbifrty of
ass~ng chana.,,confoan ~ rad~.IJ ,~ty . .and ~ufrements. .
Additional members may be Jnduded 111 .the SERP8$:appropria'.ltt, to address technical
aspects.such u .._ ~st~ •. grt,u~ar hy~. su,fa~ water hydrology,
spacifi~,,arth ~c:Hi and alb.et techn~J~~nes. T~~rary members or
permanent ~bets, other thari 'the three ~~s~J~'IViduats, may be
consuharits. · . 4 ,,. ,, •:,,. ·:.I' • , • • • \ ... • ·'.J .o,Q\'('\:.,
I&,, •. •• :, • ~ I J •• ... ,1
D. The ficensee~ll maintain records of any chang~·:Uiacfa pursuant ta th: ... condition
until license terrnl~~n. These records s~~ fI,cluVll!Witten safety and environmental
evaluations, made byj\at SERP, that ~e basis for detennining changes are in
compliance with the rvquintRM1nlB.(Bf~ to'ln Part B of this concfltion. The licensee
shall fumlsh. in an aMual repor( to NRC, a descriptian of such changes, tests, or
experiments. Including a summary Of the safety and environmental evaluation of eadl.
In addition, the licensee shall annually submit to the NRC changed pages to the
Operations Plan and Reclamation Plan of the approved license application to reflect
changes made under this condition.
Toe licensee's SERP shaH function in accordance with the standard operating procedures
submittad by letter dated June 10, 1997.
[Applicable Amendments: 3)
9.5
9.6
•stwwvww•.,.,WWWWWWP M•-~-e~1~•••w1
_ .... NUCLEAA REGULATOfn' COMMSSION
MATERIALS LICENSE
SUPPLEMENTARY SHEET
OF
Au ust 15 1997
The licensee shall maintain an NRC-approved flnandal surety arrangament. consistent with
10 CFR 40, AppendiX A, Criteria 9 and 1 o, adequate to caver the estimated costs, if
accomplished by a thjnj party, fer decommissioning and decontamination of the mm and mm
site, fer redamation of any tailings er waste dispesal areas, grcund-wata-restoration as
warranted and for the long-term surveilJance fee. Within three months cf NRC approval of a
revised redamation/dec:a 1 ,l'ti5sloning plan, the licensee shall submit, fOf' NRC reYiew and
approval, a proposed revision tc the financial surety arrangement if estimated costs In the
newly approved plan exceed the amount covered in the existing financial surety. The revised
surety shall ttlen be In effect within 3 months of 'Mitten NRC approval.
Annual updates to the surety~mou~~~O.CFR40, AppencflXA, Criteria 9 and 10,
shall be submitted to tne NRC:~sf 3 mo~-in*,r>.Jha anniversary date which is
designated as June 4 {If~ year. If the NRC has not'l.ae~ved a proposed revision to the
surety eoverage 3Q~~-prior to the expiration date of the lixi~ surety arrangement, the
licensee shall ~.oa"1he existing surety arrangement for 1 ~~,Along wi1h each proposed
revision or annL1a11pdate1 the licensee shall submit supporting' .d~mentation showing a
breakdown o~tl:)e costs-and the basis far the cost estimat~ttrfid)JStments for inflation,
maintenan~ ·or-a minttn&Jm;;l5 percent contrngency f~~ iitf!tiglneering plans,
activitieS pei1bnned and'.IIJ'1y'· other conditions ~nsf.. , mated costs fOf' site closure. Toe
basis for th• a:ist estimate' is~ "NRC ~d.rilcl~nldeccmmi!isioning plan or NRC
approved revisions to th~_plan.-rllle preYiow.ly P.ro~idance e~ •Recommended
Outline for 'Stta Spedflc ~on ar:1(1 SJablllzaUoll Cost Esti~ .butllnes the minimum
considerations used·ay..the ~t t,:.·~e revtew~~~~U~1estimat!,~·.
Reclamatio~eco~~ioningp~ ~9-~~r:U~es Should foll~\this outline.
• •• ' -I • • I I • .. • 4 • .. :. •
The currentty.approvecfsuraty l~nt;: F'arfonnan~:B9ffll·1e-2~:,. issued by National
Union Fire lnmh:ance ~11Y Jn t'awor .of the tq~~ ~~~ ~ Standby Trust
Agreement. dated Apnl 29, '1997·, 'ittafl .be conttrl~&·mainta!M,d,~ an amount not less
than $11,278, 1_34 for the purp~ of con,plyii,g ~-;JD CFR 40{Mf>endbc A, Criteria 9 and
10, until a raplaC&rTW1nt Is authorized by the NRC. '· · , ·~.: • ·
•••• ... 1 ··1, .•
' J,. ·~:1 [Applicable Amendr,181'1•: 2, 3] l·~
,, f \
11 .. ~ • ·.""".
Standard operating proceddi'ei shall tt,e·e~ti,~wid followed far an operationai process
activities involving radioactive matariabHhat l!ne handled, processed, or stored. SOPs for
operatiaMI activities shaD enumerate pertinent radiation safety practices to be followed.
AdditionalJy, written procedures Shau be established tor non-operational activities to Include
in,,plant and environmental monitoring, bioassay analyses, and instrument calibratians. An
up-to-date copy of each 'Mittan procedure shall ba kept in the mill af'!'8 to 'M'lic:h it appfies.
AD written procedures for both operational and non-.operatianal activities shall be reviewed
and approved in writing by the radiation safety officer (RSO) before implementation and
whenever a chang~ in procedure is prgposed to ensure that proper radiation protection
principles are being applied. In addition, the RSO shall perfonn a documented review of all
existing operating procaduru at least annually.
9. 7 Before engaging in any aetiVity not pruviously assessed by the NRC, the licensee shall
adrrinister a cultural resource inventory. All disturbances associated with the proposed
development will be completed in compliance with the National Histcric PreseNaticn Ad (as
/:l.G.15.1997 1:~ I'(), 340 P.13
NRC FOAM 374A (7-841 U.S. NUQ.~R REGULATOOY COfiNSSIOH 1
-.MATERIALS LICENSE
SUPPLEMENTARY SHEET
Au ust 15 1997
amended) and its implementing regulations (36 CFR 800), and the An:haeological Resources
Proteotion Act (as amended) and Its Implementing regulations (43 CFR n.
In order to ensure that no unapproved disturbance of cultural resources occurs, any work
resulting in the discovery of preViously unknOYffl cultural artifacts shan cease. Toe artifacts
shaD be inventoried and evaluated in accordance with 36 CFR Part 800, and no disturbance
shall occur until the licensee has received authorization from Iha NRC to proceed.
The licensee shall avoid by project design, where feasible, the archeological sites designated
"contributing" in the report submitted by letter dated July 28, 1988. VVhen it is not feasible to
avoid a site designated "conttjb~n~fn ttW>1-P<}i:tttf)e licensee shall institute a data recovery
program for that site based Q~l>tt)&'nlsean:h ~~-~~by letter from C. E. Baker of
Energy Fuels Nuclear ju' M_r;:.Metvin T. Smith, Utah ~ t-!~aric Preservation Officer
(SHPO), dated April-::13";,1981. .. \·~ •·.
' ":"\ •' . ~"' ··:-,,.."'~: • V ,,..,.,
The licensee shG\.t~er through archeological excavation al~,!?')tributing" sites listed in
the report whid'I are-located in or within 100 feet of borrow ~ile areas,
construction areas, a~~~i:iJ'ne1er of the reclaimed ~l,ings "impo6'~dmenl Data recovery
fieldwork at -.c11 site n-.eting·1hese criteria shaU beda,nplltted prfor u, the start of any
project rel~ed. disturbance within 100 feet of the sft~ ~-analysis a'.fld.report preparation
need not be c:omplete. · : . : :.·.:~ .'. ·::.:.'.
I u • I , l I
Additionally, the Ileen~ shst\:~~uct·S\Jcta..testing··~-~ required to:eiiable U,e Commission
to detennina if those. ~ites desigr:t~ .~.:U!1~~~h~" in ,the repo5$11d located Within
100 feet cf'f)resent D~~.OYffl futl!re·~·8f88S ar.e:of ~ch sfQ,:ilflcance to warrant
their redesig~tJon as~l'.itributing,11 In· ~'l'~tlS; ·such 1~ shall ~'completed before any
aspect of th._.undertakinQ.'"1fects. ~.~~-: 1 ~ ; • , :;. f ' · ~~"
• ' • • •• ... I -~ ,/. • .I t !1-:. ,.._. :••-..__ ••• ,/ ~~ \ ,;:, '•w
Art:heolcgfcal~tradoNi sh~ll-be ~~ved.1~ ~~i)t the Cqni"vis1on. Toe commission
wm approve an iar,:tteotogical con11'atjorwba. ~~ minl~'jtandan:Ss for a principal
investigator set f'oF1n' ln 38 CFR Part.~ Appendix C1'"and ~quaUrications are found
acceptable by the Gii~-~~
~ '
9.8 The licensee is hereby ~o ~e~~uct material in the form of uranium
waste taDings and other uran(um&;prdJRict-. fanandad by the licensee's mflling
operations authorized by this license. Mill tailings shall nat be tran.sfem=d fn:Jm the site
witho&rt specific pnor approval or ttte NRC in the form Of a license amendment. The licensee
shall maintain a pennanent record of aJI transfers made under the provisions of this condition.
9.9 The lfcensee is hell!lby exempted from the requirements of Section 20.1902 (e) of 10 CFR
Part 20 for areas within the mill, provided that all entrances to the mill are conspicuously
posted in accordance with Section 20.1902 (e) and with the words, "Any area within this mill
may contain radioactive material.•
9.1 O Release of equipment or packages from the restricted area shall be in accordance with
"Guidelines for Decontamination of Facilities and Equipment Pr1or to Release far Unrestricted
Use or Termination of Licenses for Byproduct, Sourte, or Special Nuclear Materiel," dated
May 1987, or suitable alternative praceduru apprcvad by the NRC prior to any such release.
!'.L(;.15.1997 1:39A1 I'(). 340 P.14
NRCFORM~4A
(7-MJ
u.S. NUCLEAR REGULATORY CO ... SSION
-MATERIALS LICENSE
SUPPLEMENTARY SHEET
. • •• . •. .• • ••. :.. . : -=~: ··: '•. ... • •. ..
OF 1--Utei---.-Nlll'llbcr.....,.. ____ ___...._ _____ _
Au ust 15 199 ---------------------"---~==....!!!,l!:...L....;~:.L__------
SECTION 10: Operational Controls, Limits, and Restrictions
10. 1 The mill production rate shall not exceed ~O tons of yefiowcake per year.
10.2 All Hquid effluents from mill p~ buildings, with the exception of sanitary wastes, shall be
retlffled to the mill circuit or discharged to the tailings impoundment.
10.3 Freeboard rrmits for Cells 1-f, 3, and 4A. and tonnage limits for Cell 3, shan be as stated in
Section 3.0 ta Appendix E af the approved ncense application.
10.4 Disposal of material and equipmenmen(~~--*e mm sfte shall be conducted as
descn~ed in ~e licensee~ ~~ls'.lcfat'ed ~ ~' 1994 and May 23, 1 ~. with the
following addition: . ~,,.., , .. ,. · J ;,•
11, ... "C.o ,f I •
:-.:., '"\-1 '.)
A. The maximurh:,flft thickness for matP.rials placed over'tai\iogs shall be less than 4--feet
thick. Su~uent lifts .shell be less than 2-feet thick. ~ Rft shall be compacted by
traekins;~ ~Y)f. equipment, such as a cat D-6, at I~~ prior to placement of
subsequent lifts.. .. ' ,• ·' (,-.
• 1 , (_ •, 1 ~. ~' • ,•~~t•,.,. '~ I :.J~~
10.5 In acc:on:ta~··with the 11<:ahsee's submittal dated~;20; 1993. the-iicensee is hereby
authorized lo:dispase of by~uct ~I genende(f af·licensed irt"Si\U leach facilities,
b·ect to ...... ._ foUowi . ~ . J .. \ • • ..... SU ~ uiw ng ~U}J&unt: . . ·, ,· :r~ ; :,,->
' ••• (I • • ~ • ,.. • I •• ' •, I •• t ... • %: ... t. ... t ,;a..~,.
A. Oisp~I of ~is n~~ ~1<=,!-l~I ~~.~~-~ ~ngle «,4rce.
• ,. ,• • I t 1 • 0 • '' • ""'-r•
B. All CQf1tP.fflinatliMf ~~wpment.s~all ~ dj~ed. ~. or ~oned to rnlnimize
void spaces. 8~~-~ntaininQ<~ affler tha:soit or sludges shaU be emptied Into
t~e cf~aJ areajlind-the,bari'ets'~:~~-contain.~soil or sludges shall be
verified ~.be fiJII prior to dispoRil. ~n:els J1att;Ctnp1etelv,:fijtshall be fiUed with tailings
or soil '! ;, . ,,-,}f' -. --... ~1".~
• • f I : f..,•{.i. ~ .. -c
.• ,. • 'J J "!L~ ,:.
C. All waste shati.~;buried in cen No. 3 unless prior~ approval IS obtained frt.,n tha
NRC for attamatB bu~ locations. '-< \ "I,
..J. ,).. ~-"' >., '\ ·~"'
o. All disposal ac:tiVitieS shan.f:>e..,do~~. The documentation shall incfude
desctiptions of the waste and the disposal locations, as weH as an actions required by
this concfdlon. An annual SU1T1T1ary of the amounts of waste disposed of from off..site
generators shall be sent to the NRC.
10.6 The licensee is authorized lo receive and process source materials from the Alliad Signal
Corporation's MetropoliS, Illinois, facility in accordance with the amendment request dated
June 15, 1993.
10. 7 The licensee is authorized to receive and process source material from Allied Signal, Inc. of
MetJ:opolis, Illinois, in accordance with the amendment requ,st dated September 20, 1996,
and amended by letters dated October 30, and November 11, 199& . .
10.B The licensee is aU1harized to racaive and process source material, in accordance with the
amendment request dated March 5, 1997. [Applicable Amendments: 1]
.15 .1997 t:39flM ~.340 P.15 · · •••wwwww••••••+• ,· ·•www *****wwww1
MAl'ERIAI.S UCENSE
· --SUPPLEIIENTAR't SHEET
Au ust 15 1997
10. 9 The licensee is authorized to receive and proce~~ source material from ca bot Perfom,ance
Materials' facility near Boyertown, Pennsylvania, in accordance with the amendment request
dated April 3, 1997, as amended by submittals dated May 19, and August 6, 1997.
[Applicable Amendments: 4]
SECTION 1t: Monitoring, Recording, and Bookkeeping Requirements
11.1 The results of sampling, analyses, surveys and monHoring, the results of calibration of
equipment, reports on audits ~~.i~;:i=tings and training courses required by
this license and any su~~ews.-'lnv .... ~·n!.11..and carrective actions, sMall be
documented. Unless Qfl,enivise specified in the NR~~lations all such documentation
shall be maintaine~ 1q;'1t1period of at least five (5) years. ~-; \ .
. · ':·~ ~~.~ .... ~
11.2 The llcensae s~~pfement the effluent and environmental mo.ilitoring program specified in
Section 5.S of (be ·rel)ewal application as revised with the followinef#lodifications or additions: ; . . . , . . •' ,. .,,,
• , .... I '•, "' •' ·.'• '·~ A. stack: sampling shall inau.de a detarmlnation.af'.trow tale.
• , • • • • I ',.•"' • .Y\
' ' ~ " '. 8. SL1rface water samJlles S,,aO al&~ t,e analyzed .leriiannualfy fot,'\t)tal and dissolved U-
nat, Ra-226. and Th-2301 with the ex~ptico Qf..jt,e. Westwater~ek, which shall be
sampled annually for'W&ter sedimehfs· and .~lilYZed as above. :~sediment sample
shaH not be taken In place i:Jf a wat~ s,anyp11!'-'u!11ess. a water s~ple was not available.
I t fl .. i, I ~ ~ f • "• I f • .. ' .,
C. Groundwater sa~Ung shaJIJ:ie can'ductedin aCCQfJia'r¢e ~1, requirements In
License Condition 1,1.3. . '; ,. .: ·' ·:\. '.. ·<·,
• • ' N •• ,'l I : ••• •• •• '•;i :" ,,IP ... ,.
D. The licensee sha1l·u1111ze 1owe·r: Omits of ctetdftn acco~ with Section 5 of '
Regulatory.~uide 4.14 (Revislaf'.11), for an~ of efflu~nd environmental
samples. , .""-'t.1 >
• Y,j j . -. ·~ ):._.)I
E. The inspections·perfo[!Red semiannually af tti~ ~ orifice assembly committed to in
the subrntttaJ dated M~ 'Uiir.1 ~" spll{l ~-~mented. The critfc:al orifice
assembly shall be calibratf!Ct~t 1$51 ew,y 2 ·years against a posttiw displacement
Roots meter ta obtain the raqUirad calibration curve.
11.3 The licensee shall implement a groundwater detection monitoring program to ensure
campHance ta 10 CFR Part 40, Appendix A. The detection monitoring program shall be In
accordance with the report entitled, "Points of Compliance, VVhite Mesa Uranium Mill,"
submitted by letter dated October 5, 1994, as modified by the following:
A. The leak detection system for all pond& wm be checked weekly. If liquid is present, it
shall be analyzed for chloride, sulfate, selenium. and pH. The samples will be
statistically analyzed tc determine if significant linear trends exist, and the results will
be submitted to NRC far review.
,.
11.4
11.5
11.6
l'().340 P.16 --,wwwwwswwww-••••-,™"~«~-~-~-~-~-~-~-~-~-~-~-~-
u.S. NUCLEAJII REGULATOflY COIMSSION
__ MATER.IALS UCENSE
·suPPLEMENTARY SH!ET
OF
August 15, 1997
B. If a significant linear trend is indica1ed, the licensee will submit a proposed corrective
action for review and approvaJ to NRC Toe corrective action shall indude a discussion
on delineation of the areal extent and concentration of hazardous constituents.
C. The licensee shall sample monitoring wells WMMW-5, -11, -12, -14, -15, and -17, on a
quarterly basis. Samples shall be analyzed for chloride. potassium, nickel, and
uranium, and the results of such sampling shall be induded with the environmental
monitoring reports submitted in accordance with 1 o CFR 40.65.
During extended periods of mill standby, eight-hour anm.1al sampling for U-nat, Ra-226, To-
230 and Pb-210 may be eHmi[lated'lifro~A'e.iirt,oe,e sampling show levef5 below 10 percent
of the appropriate 1 O CF~ ~~-~tiimits. · ·~ .\.! t ::' _., ..
,f .. > • , ~.-!• • -.·~ •• ~I
During periods of s~_Cfb'y, sampling frf'""''~"!cies for area an;bo.q,e uranium sampling withJ,,
the mill may be ~ to quarterty, provided measull!d levels remain below 1 o percent of
the derived air d>l'.ltentration (DAC). If these levels exceed 10 "n:ent of the DAC, the
sampling traquency should follow the recommendations in R,.m,il&U!J;Y Guide· 8.30 .
• • :.) •• , • • •• _.,.. J • ;
calibration crf ii;,-plant air and radiation monitoring eq(if p~m shall be'periormed as specified
In the license renewal ap~ic.ation, unde:rs~on 3:o .cf;-tt;\e "Radlatfon~l?,rotectlon Procedures
Manual," with-the exception 1hm i~lantair sampl~llipment sha)I ~ calibrated at least
quarterty amt air sampling equipment c;hecks shall ~·-a~mented. (.
• • ' ' .l • ' I • : <,\. , t ,, •
The licensee-shall perfonn an annual Al.ARA au'diNSf-tha radlation sa~ program in
accordance-'\Mth R~latory Guide 8,31,' ·1 ; •• :· 1 • • • ' • '. .. '.. •
• • + I • •1,,. ,'
••,I .... .. ....;,,
SECTION 12: Reporting Requirements t····· ..•
f) ~ '; ~-~··
12.1
,t • • • .-• •• ~ ,,. -
The licensee shaJl-~ubmft to NRC fQr. review,. l?Y Jut,J . .30, 1997.~atalled reciamation plan
for the authorized tflllings disposal area vmf~ includes the ~l'IDwind:
A. A post-operati~~ inte('im stabirization plan which J~i;: methods to prevent wind and
water erosion and red\ttge 4f_ U,"~ili~~
., ... ._j ~' ~,.~
8. A plan to determine the best methodology to dewater and/or consolidate the tailings
cells prior to placement of the final reclamation cover.
C. Plan and aass-sectianal views af a final l'l!clamation cover which details the location
and elevation af tailings. The plan shaU include details en cover thickness, physical
charaderistics of cover materials, proposed testing of cover materials (specifications
and quality assurance), the estimated volumes of cover materials and their avanability
and location.
D. Detailed plans for placement of rock or vegetative cover on the final reclaimed tamngs
pile and mill site areL
E. A proposed implementation schedule for items A through D above which defines the
sequence of events and expected time ranges.
12.2
MATERIALS UCENSE
-SUPPLEMENTARY SHEET
August 15, 1997
F. An analysis to show that the proposed type and thickness of soil cover is adequate to
provide attenuation of radon and is adequate to assure long-term stability, as wetl as
an analysis and proposal on methodology and time required to res1ore ground water In
conf crmance to regulatory requirements.
G. The licensee shall include a detailed cost analysis of each phase of the reclamation
plan to include c:ontractor costs, projected costs of inflation based upon the schedule
proposed in item E, a proposed contingency cost, and the costs of long-term
maintenance and monitoring.
~.15.199'7 1:3::FM l'0.340 P.4
TECHNICAL EVALUATION REPORT
REQUEST TO RECEIVE AND PROCESS AL TERNA TE FEED MATERIAL
DOCKET NO. :4(H681
UCENSEE: International Uranium (USA} Corporation
FACILl1Y: White Mesa Uranium Mill
PROJECT MANAGER: James Park
SUMMARY AND CONCLUSIONS:
LICENSE NO. SUA-1358
The U.S. Nuclear Regulatory Commission staff has reviewed Energy Fuels Nuclear, Inc. 's
(EFN's) request dated Apnl s, ·i997, to receive and process uranium-bearing material currently
contained at Cabot Perfcnnance Materials' (CPM's) facility near Boyertown, Pennsylvania.
The material would be processed at the White Mesa mill, of which EFN Is the former owner.
Toe current cwner of the mill and NRC licensee, International Uranium (USA) Corporation
(IUC), previously has agreed to abide by all commitments and representation made _t;,y EFN.
Based on its review of the Apnl 3, 1997, submittal and additional information provided by lett~
dated May 6, May 19, June 20, and August 6, 1997, the NRC staff considers the amendment
request acceptable.
DESCRIPTION OF LICENSEE'S AMENDMENT REQUEST:
By its submittal dated April 3, 1997, EFN requested that NRC Source Material License
SUA-1358 be amended to allow receipt and processing of alternate feed material (i.e., material
other than natural uranium ore) at Its White Mesa uranium mill located near Blanding, Utah.
This uranium-bearing material, weighing approximately 18,000 dry tone, is held currently by
CPM at its facility near Boyertown, Pennsylvania. The material is a moist solid (up to
40 percent moisture content) which contains uranium at an average concentration of
0.3 percent by weight, and pr.,onamic:ally attractive cancentraticns cf tantalum and niobium.
CPM is authorized to possess this material under NRC Source Material License SMB-920.
The material will be shipped by train and exclusive-use trucks fron-1 CPM's facility to the White
Mesa mill in intennodal cantainens. After being loaded and sealed at CPM's facility, the
containers will be transported by tnJck to a nearby intermodal rail terminal. The containers will
be loaded on flatbed railan and transported c:ros&-Q)Untry to the final ran destination (either
Grand Junction, Colorado or Green River, Utah), where they will be transferred tc trucks for the
final leg of the journey· to the VVhite Mesa mill. Each amtainer has a capacity of 25 cubic yards,
and it is exr:,ected U,at approximately 15 containers will be loaded and transported each day.
At the mill site, the uranium-bearing material will be emptied from the intermodal containers into
the are recefving hopper. From there, the material will be processed through the seml-
autagenous grind (SAG) mill, whera water will be added to create a sluny, which is then
1
~.15.1997 1:34A'1 l'().340 P.5
pumped to.a pulp storage tank and from there into the leach circuit. In the leach circuit, the
slurry will be treated to separate the uranium frotn the tantalum and niobium, and IUC will ublize
the uranium and vanadium solvent extraction circuits, respectively, to recover these metals.
IUC plans to add two filter presses and some additional piping to its mill circuit to aid in the
processing cf this material.
Water spray systems will be utilized to reduce the potential for dust dispersion and airborne
contamination in emptying the intennodal containers. Other than the slight circuit changes
mentioned previously, IUC anticipates that processing the uranium-bearing material will not
differ from processing natural uranium/vanadium ores.
rue wm provide personal protec.1ive equipment (coveraffs, gloves, and full-face respirators (to
be used if needed)) to individuals engaged in processing the material. The efficiency of
airborne contamination control measures during the material handling operations will be
assessed in the immediate vicinity of these operations. Airborne particulate samples and
breathing zone samptes will be ccllected during initial material processing activities and
analyzed for gross alpha. Samping results will be used to establish health and safety
guidelines to be Implemented throughout the processing operations.
Additional environmental air sample& will be collected at nearby locations to the material
precessing activities and analyzed to ensure that the established contamination control
measures arw adequate and effective.
Trucks used to transport the material to the mill site will be radiometricaUy scanned upon arrival
to ensure that leakage has not occurred and that radiation levels are_ within appropriate limits.
Trucks will again be scanned prior to their release from the site restricted area. In addition, the
intermadal containers used to transport the material will be proper1y closed, cleaned (if
necessary), surveyed, and documented before leaving the site.
TECHNICAL EVALUATION:
The NRC staff has rev1ewad IUC'a request In accordance With 10 CFR Part 40, Appendix A.
requirements and NRC staff guidance "Final Position and Guidance on the Use of Uranium Mill
Feed Material Other Than M9tural Ores" (60 FR 49296; September 22, 1995). This guidance
(refened to hereinafter as the alternate feed guidance) requires that the staff make the following
determinations in its reviews of licensee requests to prac:ess material other than natural
uranium ores.
1. Whether the feed material meets the definition of "ore;"
2. VVhether the feed material contains hazardous waste; and
·-3. Whether tne ore is being processed primarily fer its source-material content.
2
. _,
A...X;.15.1997 1: 34A1 I'(). 340 P. 6
oetermjnation Qf whether the feed material i!i ·m·
For the tailings and wastes from the propased processing to qualify as 11 e.(2) byproduct
material. the feed material must qualify as "ore.• In the alternate feed guidance, ere IS defined
as
" ... a naturat or native matter that may be rr,ined and treated for the extraction of
any of its constituents or any other matter from which source material is
extracted in a licensed uranium or thorium miR.11
The proposed alternate feed material contains uranium at an average concentration of 0.3
percent by weight therefore, it meets the definition at "source materta~" as defined at 1 o CFR
40.4. IUC is proposing to extract this uranium. Therefore, the material meets the definition of
ore, because it is a "matter from whldi source material Is extracted In a llcensed uranium or
thorium mm.•
Determinaticn of whether the feed material contains b!zaedous.waste
Under the alternate feed guidance, proposed feed material which contains a fisted hazardous
waste wm not be apprcved by the NRC staff for processing at a licensed min. Feed materials
which exhibit only a characteristic of hazardous waste (I.e., lgnitabillty, corroaivlty, reactivity, or
toxicity) would not be regulated as hazardous waste and could therefore be approved by the
staff for recycling and extradion of source material. However, this does not apply to residues
from water treatment. Therefore, NRC staff acceptance of audi residues as feed material
would depend on their not containing any hazardous or Characteristie hazardous waste.
The NRC staff has reviewed the following sources of information in detennining whether the
uranium-bearing material is ar contains hazardous waste: (1) the average composition data for
the material, as submitted by IUC on June 20, 1997, (2) the resultB of additional testing, as
provided by letter dated May 6, 1997, (3) NRC files fer the Boyertown fadlity, which address, in
part. the pracega used to produce the material and the methOds used to store the material, and
(4) supplementary information concerning the State of Pennsytvanla Department af
Environmental Protection's hazardous waste regulations. In addition, as an attachment to
a letter dated August 6, 1997, IL.JC provided an anadavit from CPM in which CPM affirmed that
the material Is r:iot and does not contain hazardous waste.
Based on its revieW, tne NRC staff finds that the uranium-bearing material is not hazardous
waste and does not contain hazardous waste. The NRC staff has determined al&a that the
uranium-bearing material is nat a residue from water nab I tent. Thia material is the result of
the initial processing of raw ores containing tantalum and niobium.
Therefore, the NRC staff considers the uranium-bearing material acceptable for recycling and
extraction of source material.
3
Ft.JG.15.1997 1:35R1 l'«J.340 P.7 -
DeterroioiU,eo ot whett)er tf)e feed material is being mocesseg primari!y for rts source-material
content
To show that potential alternate feet1 material is being processed primarily for ilB source-
material content, a licensee must either (1) demonstrate that U,e material would be approved
for disposal in the tailings impoundment under the 11Final Revised Guidance on Disposal Of Nan-
Atomic Energy Act of 1954, Section 11e.(2) Byprodud ~aterial in Tailings Impoundments;" or
(2) certify, under oath or affirmation, that the material is being processed primarily for the
recovery of uranium and for no other primary purpose. Any such certification must be
supported by an appropriate justification and accompanying dOaJmentation.
The licensee has provided a signed affirmation that the uranium-bearing material is being
pracessed primarily for the recovery of uranium and tor no other primary purpose. IUC states
that the uranium content of the material, in canjunction with the reduced uranium processing
costs associated with the recovery of the tantalum and niobium, makes processing the CPM
material economically attractive to IUC. The NRC staff has discussed with IUC the business
arrangements regarding the material and finds that IUC is paying CPM for the acquisition of the
materiaJ.
The NRC staff has reviewed the analytical data provided by IUC and infcnnation contained in
the NRC's flies for the CPM facility, and fincta that the uraniUm concentration in the material is
comparable With that in natural uranium ores Whfd'I are and were normally processed by
uranium mills in the U.S.. These natural om contained uranium at concentrations of 0.3
percent and below. Therefore, the NRC staff considers IUC'a justiffcation to be acceptable.
Conclusjons concerning alternate feed material designation
Based on the information provided by Uie licerwee, the NRC staff finds that tha CPM's uranium-
bearing material is alternate feed material because: (1) it meets the definition of "are," (2) It
does not contain hazardous waste, and (3) it Is being processed primarily for its source-material
content
Other cposeiderationa
The NRC staff has also concluded that the processing of this material wll not result In (1) a
significant change or Increase In the types or amounts of effluents that may be released offsite;
(2) a significant incntase in individual or cumulative occupational radiation exposure; (3) a
significant construction impact; or(~) a significant increase in the potential for or consequerices
from radiological accidents. This concfusion fs based on the fallowing infonnation:
a. YeUowcake produced from the processing of this matarfaf will not cause the aurantty-
approved yeOowcake production limit of 4380 tons per year to be exceeded. In addition,
and aa a result. radiological doeu ta members of the public in the vicinity Df the mill will
not be elevated above levels previously assessed and approved.
4
r:tJ;.15.1997 1:35PM l'Cl.340 P.8
b. Thei,hysicaf changes to the miU circuit that IUC will implement to process this material
are not significant No cons1ruction impacts beyond those previously assessed will be
involVed with these changes.
c. Tailings produced by the precessing af this material wlU be disposed of on-site In an
existing lined tailings impoundment (Cell 3). The addition of these tailings (a maximum
of 18,000 tonsj to Cell 3 wm increase the tctP' amount of tailings in the cell by one
percent. to a total of approximately 69 percent of cell capacity; therefore, no new
impoundments are necessary. The design of the existing impoundments previously has
been approved by the NRC, and IUC iS required by its NRC license to conduct regular
manitaring of the impoundment liners and of the groundwater around the impoundments
to detect leakage if it should occur.
d. The uranium-bearing material contains metals and other parameters which already are
present in the mill taiHngs disposed of in the Cell 3 impoundment. Analysis of samples
from the uranium-bearing material and from Cell 3 show that the only.~ 1:1.neters
present in significantly higher concentrations in the uranium-bearing material are fluorine
and carbon. However, these concentrG •!,.. .... should not hava an advenla impact on the
overall Cell 3 taffings composition, because the amount of tail!!'lgs (a maximum of 16,000
tons) produced by processing the material is not significant in comparison to the total
amount of tailings currently in the cell (approximately 1.4 mDlion tons). Additionally:, as
stated previously, IUC is required ID canduct regular monitoring of the impaundment
leak detection systems and of the grounc:fwater in the vicinity of the impoundments to
detect leakage if it should occur.
e. For the following reasons, it is not expected that transpartation impacts associated with
the movement of the material by train and buck from Pennsylvania to the White Mesa
mill will be significant
• The material will be shipped as "low specific activity" materiaJ in exclusive-use
containers (i.e., no other materials will be In the containers with the uranium-
bearing materfal). The containers will be appropriately labeled, placarded, and
manifested, and shipment& will be tracked by the shipping a>mpany from CPM's
facility until they reach the VVhite Mesa mill.
• On average during 1996, 370 b'ucks per day traveled the stretch of State Road
191 between Monticello, UT and Blanding, UT (personal communication with the
State rA Utah Department of Transportation). An additional 15 trucks per day
traveling this route to the mill represents an inaeased b'afflc load of only four
percent Shipmenta are expected to take place over the course of a limited time
period (three to soc months).
• The containers and trucks involved in transporting the material to the mnl site will
be swvayad and decontaminated, as necessary, prior to leaving CPM's facility
for 'White Mesa and again prior to leaving the mm site for the retum trip.
5
~.15.1997 1:36A'! l'l>.340 P.9
f. MH~ployees invafved In handling the material wil be prwfded with personal protective
equipment. including respiratory protactfon. Alrbome partictJlate and breathing zone
sampling results wm be used to establish health and safety guideHnes 1D be
implemented throughout the processing operations.
RECOMMENDED LICENSE CHANGE:
Pursuant to Trtle 1 O of the Code of Federal Regulations, Part 40, Source Material License
SUA-1358 will be amended by the addition of License Condition No. 10.9 as fellows:
10.9 The licensee la authorized to receive and precess source material fn::lm Cabot
Perfonnance Materials' facility near Boyertown, Pennsylvania. in accordance with the
amendment request dated April 3, 1997, as amended by submittals dated May 19, and
August 6, 1997.
ENVIRONMENTAL ;;.i?ACT EVALUATION:
Because IUC's receipt and processing of the '11flterial will not result in (1) a significant change
or increas~ in the typea or amounts of effluents that may be released offi!rite; (2) a Bignificant
increase in individual or cumulative occupational radiation exposure; (3) a significant
construdion Impact; er (4) a significant increase in the potential for ar consequences from
radiological accidents, an environmental review was not performed since actions meeting theS8
criteria are categorically exduded under 10 CFR 51.22(c)(11).
6
Appendix B
White Mesa Mill Site Maps with Well Locations
. -~
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s::: 0
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Legend
--Canyon Rim Surface Land Ownership
-Highway CJ Bureau of Land Management
--Road D Private
U l!Property Boundary ~ Mill Site Claim
D Tailings Cell ~ Utah State Lease
CJ Utah Land Trust School Sectic
3,000
~ Structures
Monitoring Locations
• Boring
~ Drinking Water
~ MW Chloroform
• MW Nitrate
t Monitor Well
0 Piezometer Chloroform
Ute Monitoring Well
0v Seep or Spring * Air Monitoring Station * Control Point
Coordinate System: NAO 1983
StatePlane Utah South FIPS 4303 Feet
1,500
1 IN = 2,000 FT
0
SCALE IN FEET
3,000
Dale: By: Counly:San Juan
Location: Portions of T37S R22E
Author:joapp
Appendix B-1
White Mesa Mill (North)
Date: 6/21/2022 Drafted By: joapp
N
I
DR-17_....._ _ __,'tr'
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Bareau of Land Management
17
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Legend
Surface Land Ownership __ Canyon Rim ent CJ Bureau of Land Managem
-Highway CJ Utah Land Trust School Sectic
--Road 11 · Ut
L.._J Ute Mountain e II II Property Boundary
3,000
Structures
Monitoring Locations
•
•
0v
*
*
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Drinking Water
MW Chloroform
MW Nitrate
Monitor Well
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Seep or Spring
Air Monitoring Station
Control Point
. t · NAO 1983 Coordinate Sys em. th FIPS 4303 Feet StatePlane Utah Sou
1 IN = 2,000 FT
1,500 0 3,000
SCALE IN FEET
'(/!£,RGYFUELS
REVISIONS Pr ·ect _wttfil ME.C:A_Mll.l
OJ 1s1a1a: Utah Date: By: Counly:San Juan
Location:Portions of T37S R22E
Append ix B-2
White Mesa Mill (South)
Aulhor:joapp J Date: 6/21/2022 J Drafted By: joapp
Appendix C
Sampling Plan for Seeps and Springs in the Vicinity of the White Mesa Uranium Mill,
Revision: 3, November 11, 2019
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
SEEPS AND SPRINGS
Revision 2
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Energy Fue)s Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
JuJy 8, 2016
Table of Contents
1.0 Introduction and Objectives ................................................................................................................... 3
2.0 Seeps and Springs Sampling Locations ................................................................................................... 3
2.1 Timing of Sample Collection ............................................................................................................... 3
3.0 Field Sampling Procedures ...................................................................................................................... 4
3.1 Field Data ........................................................................... -................................................................. 5
3.3 Field QC ............................................................................................................................................... 5
3.4 Sample Handling ................................................................................................................................. 6
4.0 QA and Data Evaluation .......................................................................................................................... 6
5.0 Laboratory Analysis ................................................................................................................................. 6
5.1 Analytical Quality Control ............................................................................................................. 7
5.2 Evaluation of Analytical Data .............................................................................................................. 7
6.0 Reporting ........................................................................................................................................... 7
Attachments
Tab A Seeps and Springs Location Map
Tab B Bureau of Land Management Letter
Tab C Field Data Form
Tables
Table 1 Seeps and Springs Survey Information
1.0 Introduction and Objectives
This Sampling and Analysis Plan ("SAP") describes the procedures for sampling seeps and springs in the
vicinity of the Energy Fuels Resources (USA) Inc. ("EFRI") White Mesa Uranium Mill ("the Mill") in
Blanding, Utah as required by the State of Utah Groundwater Discharge Permit ("GWDP") No.
UGW370004.
The objective of the seeps and springs sampling program is to collect annual surface water samples from
the locations identified below as required by the GWDP. This SAP specifies the sample collection
requirements, procedures, analytical methodologies and associated quality control ("QC") checks, sample
handling protocols and reporting requirements for the annual seeps and springs sampling program.
2.0 Seeps and Springs Sampling Locations
The annual seeps and springs sampling locations correspond with those seeps and springs sampled for the
initial site characterization performed for the Environmental Assessment as shown on Plate 2.6-10 of the
Environmental Report (Dames & Moore, 1978), and additional sites located by EFRI, the Bureau of Land
Management ("BLM") and Ute Mountain Tribal representatives. The locations included in the annual
seeps and springs sampling event are:
• Cottonwood Seep
• Westwater Seep
• Ruin Spring
• Corral Canyon Seep
• Entrance Spring
• Corral Springs
The Permit Section I.F.7 (g) requires that survey data for the seeps and springs be submitted prior to the
collection of samples. The Division of Waste Management and Radiation Control ("DWMRC")
previously clarified the requirement to submit survey data only prior to the first sampling and not on an
annual basis. The survey data submitted with the first annual seeps and springs report in 2009 was
incorrect. In response to the incorrect data, EFRI completed another survey of the seeps and springs in
December 2009. Those survey data are included in Table 1 of this SAP and the locations are shown on
Figure 1 included in Tab A. The surveyed coordinates and elevations of the seeps and springs were within
1 foot of the highest point of the saturated seepage face on the day of the survey
2.1 Timing of Sample CoJJection
EFRI representatives conducted reconnaissance visits to the locations listed in Section 2.0 above in June
2008 in order to determine the status of the listed springs and seeps and to evaluate the feasibility of
physical development with hand tools in order to better accommodate sampling at dry locations. It was
observed at that time that water flow was available for sampling at Ruin Spring, Cottonwood Seep and
Entrance Spring. Alternatively, Westwater Seep, Corral Canyon Seep and Corral Springs were entirely
dry or exhibited only barely moist soil. Annual sampling events conducted from 2009 through 2016
noted that dry conditions continued at Westwater Seep, Corral Canyon Seep and Corral Springs with no
opportunity for sampling even with limited hand tool development. Based on the data collected to date
regarding the conditions at the six locations specified in Section 2.0 above, the following schedule for site
visits and possible sampling will be employed:
• Once per calendar quarter, the Westwater Seep, Corral Canyon Seep and Corral Springs will be
visited. If sufficient water is present, a sample will be collected and no further visits will be
completed for the year. If no sample is collected prior to the annual event, these locations will be
visited during the annual sampling event. If these locations are dry during the annual sampling
event, the calendar quarter checks will continue until either a sample is collected or 4 quarterly
checks (one per calendar quarter) have been completed. NOTE: The annual report is due
December 1 of each year. The fourth quarter check will be limited to October and November to
meet the report deadline.
• Annually, between May 1 and July 15 of each year, a sample will be collected from Ruin Spring,
Cottonwood Seep and Entrance Spring. Should any of these locations be dry during the annual
event, quarterly checks (for the remaining calendar quarter) will be completed starting after the
annual event.
Should a visit reveal a change in conditions at any of these dry locations which may yield water sampling
opportunities, EFRI will proceed with limited hand tool excavation of the sampling location. The hand-
dug excavation will be left open for a maximum of 48 hours and allowed to fill with water. If water
collects in the excavation, it will be sampled. If the location is excavated with hand tools, it will be filled
after sampling has been completed, with the soil that was removed from it per the BLM request included
in Tab B.
EFRI will provide at least 15 days notice of the annual sampling event conducted between May 1 and July
15 in order to allow DWMRC to collect split water quality samples of the seeps and springs.
3.0 Fie)d Sampling Procedures
The field sampling and data collection program will obtain samples to be analyzed for the groundwater
compliance parameters listed in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using the methods specified in the currently approved EFRI Quality Assurance Plan
for Groundwater sampling ("QAP"). Minimum detection limits or reporting limits for seeps and springs
analyses will be less than or equal to the Groundwater Quality Standards defined in Table 2 of the
GWDP. The minimum detection limits for total dissolved solids ("TDS"), sulfate, and chloride will be 10
mg/L, 1 mg/L, and 1 mg/L respectively.
Field activities include collecting samples, recording of field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling procedures employed at each location will be dependent on the site location and access.
Several sampling methodologies may be employed during one annual event based on access limitations
and flow rates of the seeps and springs that are sampled. Potential sampling methodologies are briefly
described below.
Direct Collection
Direct collection of the samples involves collecting the sample directly into the sample container from the
surface water feature or from spring out-flow. In instances where direct collection is employed the
parameters which require filtration will be collected by one of two methods. In the first method, the
peristaltic pump will be used to draw the sample from the out-flow and pump it through a 0.45 micron
filter directly into the appropriate sample container. The second method is used in situations with limited
access for the generator required to run the peristaltic pump. When the generator cannot be used, a large,
unused sample jug will be used to collect the sample. The peristaltic pump will then be used to transfer
the sample from the large sample jug to the sample bottles through a 0.45 micron filter. This filtration
and pumping will be completed at a location where there is access for the generator.
Peristaltic Pump
Sample collection with a peristaltic pump involves collecting the sample from the source or out-flow
using the peristaltic pump. The peristaltic pump is used to deliver the sample from the source or out-flow
to the sample bottles. Filtered parameters are pumped through a 0.45 micron filter prior to delivery to the
sample bottle.
Sample Ladle
Sample collection using a ladle involves dipping or filling a ladle made from an inert material into the
surface water source or out-flow and filling the ladle. The sample is transferred from the ladle to the
sample bottles. This process is repeated until the sample bottles are filled. Filtered parameters are
collected into a large, unused sample jug. The peristaltic pump is then used to transfer the sample from
the large sample jug to the sample bottles through a 0.45 micron filter.
3.1 Field Data
In addition to the analytical parameters noted above, field data will be recorded at the time of sample
collection. Field parameters required by the GWDP include pH, specific conductance and temperature.
Additional field parameters such as oxidation reduction potential ("REDOX") and turbidity may be
measured as available sample volume allows. Field data will be recorded on the Field Data Record
included in Tab C of this SAP.
The dates of the site visits, the availability of surface water for sampling, and the possibility for
development will be recorded on the field data sheets for inclusion in the annual report.
3.2 Decontamination
Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable
sampling equipment is used to collect samples. Decontamination procedures will be as described in the
approved QAP. Rinsate blanks will be collected daily after decontamination of sampling equipment. If
disposable or dedicated sampling equipment is used to collect samples then rinsate blanks will not be
collected.
3.3 Field QC
The field QC samples generated during the annual seeps and springs sampling event will include sample
duplicates, trip blanks, and rinsate blank samples as appropriate.
Sample Duplicate
Sample duplicates will be collected at a frequency of one duplicate per 20 field samples. Sample
duplicates will be collected by filling the sample container for a certain analytical parameter for the
duplicate immediately following the collection of the parent sample for that parameter.
Trip Blanks
Trip blank samples will be included in every shipment of samples that has field samples to be analyzed
for Volatile Organic Compounds ("VOCs"). Trip blank samples are VOC sample containers filled by the
analytical laboratory with laboratory grade deionized water and shipped to the site. Trip blank samples
are taken into the field with the sample containers, never opened, and kept with the field samples from
collection through shipment to the analytical laboratory for analysis. Trip blanks are analyzed to
determine if the sample concentration of VOCs have been effected by the "trip" from collection through
shipment.
Rin ale Blru1k Samples
Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated,
reusable sampling equipment is used to collect samples. If the sampling equipment has a disposable
component that comes in contact with the samples and the component is changed prior to sampling at
each location then a rinsate blank sample will not be collected. For example, if a peristaltic pump is used
to collect and filter seeps and springs samples and the tubing used in the peristaltic is changed at each
location and never reused for more than one sample, no rinsate blank sample would be required.
3.4 Sample Handling
Seeps and springs sampling events will be subject to the applicable sample handling requirements noted
in the approved QAP.
4.0 QA and Data Evaluation
The Permit requires that the annual seeps and springs sampling program be conducted in compliance with
the requirements specified in the Mill's approved QAP, the approved SAP and the Permit itself. To meet
this requirement, the data validation for the seeps and springs sampling program will utilize the
requirements outlined in the QAP, the Permit and the approved SAP as applicable. The Mill QA
Manager will perform a QA/QC review to confirm compliance of the monitoring program with
requirements of the Permit, QAP and SAP. As required in the QAP, data QA includes preparation and
analysis of field QC samples, review of field procedures, an analyte completeness review, and quality
control review of laboratory data methods and data.
The QAP and the Permit identify the data validation steps and data quality control checks required for the
seeps and springs monitoring program. Consistent with these requirements, the Mill QA Manager will
performed the following evaluations: a field data QA/QC evaluation, a receipt temperature check, a
holding time check, an analytical method check, a reporting limit check, a trip blank check, a QA/QC
evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each laboratory's
reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
Samples will be analyzed for the groundwater compliance parameters listed in Table 2 of the GWDP
using the analytical methods and specified reporting limits contained in the approved QAP. Laboratories
used for the seeps and springs sampling program will be Utah certified as required by the GWDP Part
l.E.6 (c). Laboratory data will be validated as described in the approved QAP and as described in Section
4.0 above. Analytical QC is described below.
5.1 Analytical Quality Control
Analytical QC samples and protocols are described in the approved QAP. Laboratory QC procedures will
meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for
by the State of Utah.
The analytical QC samples included at least the following: a method blank, a laboratory control spike
("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where
applicable. It should be noted that:
• Laboratory fortified blanks are equivalent to LCSs.
• Laboratory reagent blanks are equivalent to method blanks.
• Post digestion spikes are equivalent to MSs.
• Post digestion spike duplicates are equivalent to MSDs.
• For method E900. l, used to determine gross alpha, a sample duplicate was used instead of a
MSD.
All qualifiers, and the corresponding explanations reported in the QA/QC Summary Reports for any of
the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager.
The effect on data usability will be discussed in the evaluation section of the annual report.
5.2 Evaluation of Analytical Data
An evaluation of the analytical data will be completed in the annual report. A discussion of the results
will be included which will summarize the data relative to any detections reported in the samples with
comparisons as appropriate to the Mill groundwater quality data.
6.0 Reporting
EFRI will collect seeps and springs samples annually as required by the GWDP Part 1.F.7. Each report
will: 1) document the sampling event by means of providing the field sheets recorded at the time of
sampling; 2) transmit copies of all field measurements and laboratory results; 3) provide a water table
contour map that includes water table elevation of all groundwater monitoring wells at the facility and the
elevations of the phreatic surfaces observed at each of the seeps and springs sampled; and 4) provide an
evaluation and interpretation of the groundwater quality data collected. Specific reporting requirements
for the seeps and springs sampling program will include but are not limited to :
• The annual seeps and springs monitoring report will be included with the 3rd quarter Routine
Groundwater Monitoring Report due on December 1, of each year.
• The seeps and springs water table contour map will include all water level data measurements
from all monitoring wells at the site from the 3rd quarter groundwater monitoring event for each
year.
• The seeps and springs water table contour map shall be at the map scale such that all seeps and
springs listed in this Plan and monitor wells at the site may be seen on one map.
Table 1
s eeps an ,prmgs urvey n orma ion d S S I f f
December 2009 Survey
Location Latitude (N) Longitude (W) Elevation
FROG POND 37°33'03.5358" 109°29'04.9552" 5589.56
CORRAL CANYON 37°33'07.1392" 109°29' l 2.3907" 5623.97
ENTRANCE SPRING 37°32'01.6487" 109°29'33.7005" 5559.71
CORRAL SPRINGS 37°29'37.9192" 109°29'35.8201" 5383.35
RUIN SPRING 37°30'06.0448" 109°3 l '23.4300" 5380.03
COTTONWOOD 37°31 '21. 7002" 109°32'14.7923" 5234.33
WESTWATER 37°3 l '58.5020" 109°31 '25.7345" 5468.23
Verification Survey July 2010
RUIN SPRING 37°30'06.0456" 109°31 '23.4181" 5380.01
COTTONWOOD 37°3 l '21.6987" 109°32' l 4.7927" 5234.27
WESTWATER 37°31 '58.5013" 109°31 '25.7357" 5468.32
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# ..... ·-b, I ...
22
' + ; -----------1 -r----
...... ·1
,. I
INDIAN) R
29 ' •• \ •
.. ,
·,
lx ... -J
V A
~ .. ~ I ~ -
.. .,. .. ..,
I • ~:" ~:.1,: •
-~ • I i 35 ~'!i~\/ " : -,,.-, I I o • ,.
1
I ~ ' --:a ,s\:i , -5. j
32
... ...... ~
Y?
C
C\ ~ : ,.
i f 'i :::) ~ .. I
BLM
--1 ---Denison Property Boundary
-----Ute Mtn. Ute Reservation Boundary
•• Canyon Rim
ENERGY FUELS
White Mesa Mill
N :le, UT
12-11 I GM
SEEPS AND SPRINGS LOCATION MAP
A<ltncr. HRR Dita: Nov. 3, 2003 I D<al!Od ey. BM
Attachment B
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Monticello Field Office
IN REPLY REFER TO:
P.O. Box 7
Monticello, Utah 84535
http://www.blm.gov/utah/monticello
TAKE PRICE:•
INAMERICA
MAY O 3 2011
LOAs
UTY020
Jo Ann Tischler
Denison Mines (USA) Corp.
RECFI\/ED
fit=======--
Director, Compliance and Permitting
1050 17th Street, Suite 950
Denver, CO, US, 80265
Dear Ms. Tischler:
As per your phone conversation with Realty Specialist Maxine Deeter 1ast week, this letter
authorizes Denison to do water sampling on public lands administered by the Bureau of Land
Management adjacent to the White Mesa Mill south of Blanding, Utah. We understand that the
sampling will consist of hand digging two cubic feet square holes at springs which do not contain
standing water and leaving the holes to fill with water so that it can be tested in compliance with
Department of Environmental Quality (DEQ) requirements. As Maxine stated on the phone, we
do not consider this to be "development,, of these springs but rather meets the definition of
casual use of public lands. We would request that these test holes be filled again with the soil
that was removed from them.
If you have questions or concerns, please contact Maxine at 435-587-1522 or via email.
Sincerely,
Thomas A. Heinlein
Field Office Manager
Attachment C
II
Field Data Record-Seeps and Springs Sampling
Seep or Spring Location: ----------------------
Date For Initial Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Second Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Third Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Date For Fourth Sampling Visit: ________ Time: _________ _
Sample Collected: o Yes o No
Sampling Personnel:
Weather Conditions at Time of Sampling: _______________ _
Estimated Seep or Spring Flow Rate: ------------------
Field Parameter Measurements:
-pH
-Temperature (°C) ---------------
-Conductivity µMHOC/cm ------------
-Turbidity (NTU) (if measured) __________ _
-Redox Potential Eh (mV) (if measured) ______ _
Analytical Parameters/Sample Collection Method:
Pat-ameter hmpl Taken Filtered S8fttplin2. Method
Direct Pe:ri&~tic Ladle 0tker
~ (4~:em
11otes sedien}
voes o Yes oNo D Yes D No D D D D
Metals o Yes oNo o Yes D No D D D D
Nutrients o Yes oNo o Yes D No D D D D
Other Non o Yes DNo o Yes DNo D D D D
Radiologies
Gross Alpha o Yes D No o Yes D No D D D D
QC Samples Associated with this Location:
o Rinsate Blank
o Duplicate
Duplicate Sample Name: ___________ _
Notes: -------------------------------
Appendix D
Results of Soil Analysis at Mill Site
f 'I \..._
-·--·-Results Of Soil Analyses At Mill Site
g
i~ l ie ); i-~1 t-. ...... 01{ ti~ ... '!I .§ ~ .J. i!•Q ,:.; ... a, ll't 1,1 '-' ..:i .... , •. , ..... ~~ <i ~ ! ! ...,
I
BIIIDdlng 4 04 SiL 7.6 36.0 7.4 7,9 0.3 .15 1.2 ~Snd)
Ustollic 4-12 SiCL 8.7 49.0 7.6 8.0 0,3 0.14 0,8 Ellplugid
F'me-silty, 18-40 SiCL 8.0 43.7 8.0 8.5 2.0 0.30 0.7 mixeil
9 0-S SiL 8.9 38.7 7.6 8.1 0.3 0.17 0.9
S-12 SiL 9.3 4S.6 8.0 8.4 0.3 0.18 0.9
18-40 SiL 8.0 38.7 8.S 9.0 3.8 0.18 1.2
40-50 SiCL 9.0 38,9 8.8 9.2 1.6 0.18 1.0
Souroe: Adapted from 1978 ER Table 2.10-2.2
SiCL :a ailty clay loam: SIL m &IU loam
·sii ~ j,... '0G
~~ ii c.i8 ]a t,i:::! ga-C, ~ ! ,Q'-' ci. Do
I.I .63 IS 198 12.8
0.2 0.53 3 170 16.6
0.6 0.42 3 165 14.9
1.8 0.53 10 182 13,1
J.4 Q.47 2 138 10.9
11.5 0.37 2 123 11.9
12.5 0.26 1 161 IS.9
·-:' .~~
Appendix E
Tables: Chemical and Radiological Characteristics of Tailings Solutions, Leak Detection
Systems and Slimes Drains
Cell 1
Chemical and Radiological Characteristics
Constituent 1987 2003 2007 2008 2009 2010 2011 2012 2013 2013 2014 2015 2016 2017 2018 2018 2019 2020 2021 Resample Resample
Major Ions (mg/L)
Carbonate <5 <l ND ND <1 <1 <l <l <1 NS <1 <1 <1 <l <l NS <5 <5 <5
Bicarbonate <5 NA ND ND <1 <l <l <I <l NS <1 <1 <1 <1 <1 NS <5 <5 <5
Calcium 630 307 483.8 604 635 711 577 426 768 NS 404 573 647 581 518 NS 720 618 234
Chloride 8000 6728 37340 9830 20700 7440 33800 78000 9900 NS 11600 25500 19200 19900 39300 NS 19800 40000 74700
Fluoride <100 3005 31.72 0.3 0.4 28.4 69.2 62.9 4130 NS 2380 5880 2980 4290 5020 NS 3480 7460 14900
Magnesium 7900 5988 21220 6550 16200 5410 14300 16000 4470 NS 5530 12400 9210 9380 20800 NS 9200 12300 19800
Nitrogen-Ammonia 7800 3353 10628 5250 15200 8120 12900 9750 3900 NS 5700 5.4 7090 1040 9810 NS 10400 10600 5850
Nitrogen-Nitrate <100 41.8 269.4 64.9 142 58 212 556 128 NS 53 192 124 152 328 NS 118 191 27
Potassium NA 647 5698 1880 4140 1840 4510 9750 6580 NS 3010 7330 1970 2700 4790 NS 2600 4580 4030
Sodium 10000 8638 62600 13200 39000 16700 29500 41700 15900 NS 12200 32100 18900 23900 53500 NS 28000 62900 91900
Sulfate 190000 63667 287600 118000 232000 107000 182000 158000 100000 NS 124000 204000 212000 165000 253000 NS 169000 222000 351000
pH (s.u.) 0.70 1.88 0.80 1.53 l.15 2.73 2.23 1.90 2.74 NS 1.30 1.01 <I.DO <I.DO <l.00 NS 1.14 0.92 0.4
TDS 120000 94700 357400 131000 140000 130000 216000 342000 149000 NS 159000 334000 242000 231000 361000 NS 257000 422000 584000
Conductivity (umhos/cm) NA NA NA NA 365000 110000 112000 136000 94200 NS 113000 131000 123000 57600 110000 NS 119000 81500 76000
Metals (ug/L)
Arsenic 440000 121267 849000 271000 436000 74400 299000 25500 9800 NS 249000 377000 407000 391000 641000 NS 270000 599000 1040000
Beryllium 780 475 2262 500 410 338 1270 3180 415 NS 448 1290 1030 749 1510 NS 930 1330 3660
Cadmium 6600 3990 29320 8790 9120 2940 13700 30700 2380 NS 3060 7710 6320 6730 14000 NS 5400 9070 21300
Chromium 13000 6365 29940 6760 18700 5620 22700 12100 8350 NS 13200 19600 14000 15900 21100 NS 15000 25700 29600
Cobalt 120000 NA 88240 23500 97500 16200 56000 53100 25500 NS 56500 82000 77200 91400 113000 NS 66000 51400 59500
Copper 740000 196667 881000 360000 168000 125000 483000 885000 544000 NS 3420000 3560000 4730000 3440000 4550000 NS 1700000 2110000 3760000
Iron 3400000 2820000 13480000 3280000 2390000 3400000 8940000 840000 1420000 NS 2520000 6680000 5650000 2300000 12200000 NS 9100000 15400000 6680000
Lead <20000 3393 27420 11200 10600 9240 23600 17000 2810 NS 13500 16800 22500 23000 41000 NS 22000 42400 91200
Manganese 140000 162500 990200 206000 723000 173000 735000 1560000 188000 NS 162000 515000 713000 510000 936000 NS 540000 833000 1630000
Mercury NA NA ND ND 7.61 7.2 61.4 117 6.16 NS 12.5 24.6 8.59 7.86 16.8 NS 3.7 14 0.035
Molybdenum 240000 50550 415600 106000 142000 35300 235000 434000 16800 NS 68800 127000 97100 128000 239000 NS 120000 247000 418000
Nickel 370000 36950 40860 32000 156000 27500 43700 15000 39100 NS 129000 130000 170000 183000 167000 NS 110000 27100 18400
Selenium <20000 1862 15420 13000 14800 5220 11600 8090 2690 NS 3970 7070 3950 5070 10700 NS 10000 16600 21800
Silver <5000 NA 1559.2 449 558 155 1110 4310 329 NS 336 1390 1240 1240 2320 NS 790 1290 2640
Thallium 45000 NA 407.8 165 387 193 560 13 63.3 NS 876 1130 754 155 442 NS <700 <50 1680
Tin <5000 NA 6512 1240 2290 263 1500 <100 <100 NS <17000 <100 <17000 <17000 <17000 NS 540 1220 1820
Uranium 105000 134517 788600 416000 578000 159000 838000 1450000 140000 NS 137000 363000 131000 102000 248000 NS 81000 200000 655000
Vanadium 280000 348000 2208200 1200000 773000 752000 2500000 1940000 98200 NS 485000 1130000 746000 1520000 2440000 NS 1400000 2090000 4410000
Zinc 1300000 NA 642940 476000 229000 171000 398000 811000 228000 NS 229000 638000 448000 515000 948000 NS 550000 396000 905000
Radiologies (pCi/L)
735000
Gross Alpha NA 1693331 29380 21900 16500 11300 3610 12600 32700 NS 331000 (8/4/2015) 420000 191000 550000 NS 326000 83800 24600 73800
-(5/28/2015)
Cell I
Chemical and Radiological Characteristics
Constituent 1987 2003 2007 2008 2009 2010 2011 2012 2013 2013 2014 2015 2016 2017 2018 2018 2019 2020 2021 Resample Resample
voes (ug/L)
Acetone 35 NA 66.5 110 710 260 80 310 41.1 NS <700 56 40.6 28 50.4 NS 28 32.6 152
Benzene <5 NA ND ND <1 <1 <1 <1 <1 NS <5.0 <1 <l <1 <l NS <1 <1 <5
Carbon tetrachloride <5 NA ND ND <l <I <l <I <1 NS <5.0 <1 <l <l <l NS <l <l <5
Chloroform 8 NA 6.7 6.6 16 4.9 13 19 7.62 NS <70.0 5.54 <l 3.42 114 NS 7.5 2.84 46.2
Chloromethane NA NA ND 9.4 11 4.4 3.6 4 5 NS <30.0 1.93 <1 1.13 1.16 NS 2.3 1.49 <5
MEK NA NA ND ND 120 65 <1 200 <20 NS <4000 <20 <20 <20 <20 NS 11 J 6.41 <25
Methylene Chloride 11 NA ND ND 2 <l <l 2 <1 NS <5.0 1.83 <l 1.09 2.41 NS <I <5 <25
Naphthalene <10000 NA <10 ND 1.1 5.4 2 3 <l NS <100 <1 <1 <l <l NS <l <l <5
Tetrahydrofuran NA NA 150 <20 <100 <10 <500 2.9 <l NS <46.0 <1 <l <1 4.93 NS <35 <5 <25
Toluene <5 NA ND ND <l <l <I <I <1 NS <1000 <l <l <l <I NS <I <1 <5
Xylenes <5 NA ND ND <l <1 <1 <l <l NS <10000 <1 <1 <l <I NS <1 <3 <15
SVOCS (ug/L)
1,2,4-Trichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
1,2-Dichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8 .04 <10 <30 <37.5
1,3-Dichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
1,4-Dichlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
1-Methy !naphthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3.0 <3.75
2,4,5-Trichlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
2,4,6-Trichlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
2,4-Dichlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
2,4-Dimethylphenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37 .5
2,4-Dinitrophenol NA NA NA NA <250 <20 <20 <20 <21.6 <20 <20 <20 <10 <10 <148 <8.04 <50 <50 <62.5
2,4-Dinitrotoluene NA NA NA NA <50 <IO <10 <10 <10.8 <10 <10 <IO <IO <IO <148 <8 .04 <10 <30 <37.5
2,6-Dinitrotoluene NA NA NA NA <50 <10 <IO <10 <10.8 <IO <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
2-Ch loronaphthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <4.1 <5.13
2-Chlorophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
2-Methylnaphthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
2-Methylphenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
2-Nitrophenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
3&4-Methylphenol NA NA NA NA <22 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <37 <46.3
3 ,3-Dich lorobenzidi ne NA NA NA NA <100 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <50 <33 <41.3
4,6-Dinitro-2-NA NA NA NA <250 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8 .04 <50 <30 <37.5 methyl phenol
4-Bromophenyl phenyl NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <IO <10 <10 <148 <8.04 <10 <30 <37.5 ether
4-Chloro-3-methylphenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
4-Chlorophenyl phenyl NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5 ether
4-Nitrophenol NA NA NA NA <250 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <50 <30 <37.5
Acenaphthene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Acenaphthylene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Anthracene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Azobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <IO <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
Benz(a)anthracene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Cell 1
Chemical and Radiological Characteristics
Constituent 1987 2003 2007 2008 2009 2010 2011 2012 2013 2013 2014 2015 2016 2017 2018 2018 2019 2020 2021 Resample Resample
Benzidine NA NA NA NA <100 <10 <10 <10 <10.8 <10 41 <10 <10 <10 <148 <8.04 <100 <39 <48.8
Benzo(a)pyrene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Benzo(b )fluoranthene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Benzo(g,h,i)perylene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Benzo(k)tluoranthene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Bis(2-chloroethoxy) NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <37.5 methane
Bis(2-chloroethyl) ether NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
Bis(2-chloroisopropyl) NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5 ether
Bis(2-ethylhexyl) NA NA NA NA <50 27 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75 phthalate
Butyl benzyl phthalate NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Chrysene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Dibenz(a,h)anthracene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Diethyl phthalate NA NA NA NA 170 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Dimethyl phthalate NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Di-n-butyl phthalate NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Di-n-octyl phthalate NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Fluoranthene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Fluorene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Hexachlorobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
Hexachlorobutadiene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <30 <30 <37.5
Hexachloro -NA NA NA NA <50 <10 <10 <10 <10.8 cyclopentadiene <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
Hexachloroethane NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <30 <30 <37.5
Indeno( 1,2,3-cd)pyrene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Isophorone NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <35 <43.8
Naphthalene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Nitrobenzene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
N-Nitrosodimethylamine NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
N-Nitrosodi-n-NA NA NA NA <50 <10 <10 <10 <10.8 propylamine <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
N-Nitrosodiphenylamine NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
Pentachlorophenol NA NA NA NA <250 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <50 <30 <37.5
Phenanthrene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Phenol NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <30 <37.5
Pyrene NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <10 <3 <3.75
Pyridine NA NA NA NA <50 <10 <10 <10 <10.8 <10 <10 <10 <10 <10 <148 <8.04 <20 <30 146
1 Historic values reported for Gross Alpha from 1987 and 2003 are total gross alpha reported in pCi/L. All other gross alpha data are reported as Gross Alpha minus Rn & U.
Cell 2 Slimes Drain
Chemical and Radiological Characteristics
Constituents 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Major Ions (mg/L)
Carbonate ND ND <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <5 <5 <5
Bicarbonate ND ND <1 <1 <1 <1 <1 <1 <1 <1 <1 <l <5 <5 <5
Calcium 572 528 508 496 474 462 465 322 524 402 477 538 480 513 463
Chloride 3700 3860 2750 3510 3110 3730 3270 3720 3850 4040 3820 4310 3870 4080 4200
Fluoride 3.3 ND <0.1 2.4 2.1 1.32 161 130 204 48.4 110 116 105 130 130
Magnesium 4100 4030 3750 3790 3640 3760 3320 2780 3810 3570 3630 4470 3700 3800 3950
Nitrogen-Ammonia 4020 3620 3240 3820 2940 3540 1880 3500 367 3800 500 5620 4420 7150 2950
Nitrogen-Nitrate 30.9 20.3 38 126 38 27 47.2 35 1.06 12.7 13.7 12.1 33.0 21.6 48.0
Potassium 636 560 689 620 636 611 622 489 659 512 668 774 710 735 661
Sodium 4050 4600 4410 4770 4590 4380 3980 3130 4800 4690 4810 5290 4600 4620 4520
Sulfate 60600 74000 72200 63700 64200 58300 83700 62200 57800 83900 58300 63300 67000 67000 68500
pH (s.u.) 3.18 3.24 3.11 3.39 3.18 3 3.02 3.1 3.1 2.99 3.08 2.89 3.07 3.06 3.0
TDS 84300 74600 84100 79900 80200 83800 92200 87000 88200 93100 85900 99900 94300 89500 95700
Conductivity (umhos/cm) NA NA 88700 60200 51400 52900 51100 54100 58800 44500 52600 58200 55700 53900 53200
Metals ( ug/L)
Arsenic 26900 19300 14200 23500 17800 19400 21000 19800 13300 16900 21100 19600 23000 18000 19300
Beryllium 298 245 271 267 231 251 262 197 275 259 261 241 280 284 217
Cadmium 5500 5840 5510 6370 5580 5290 5780 6480 6260 6610 6790 6380 6500 5220 5890
Chromium 2750 2450 2230 2510 2380 2350 2290 1630 1840 1630 2290 2100 2100 1860 1810
Cobalt 46500 43800 38700 48200 42500 48700 44900 46700 46000 46100 50600 46900 54000 40800 42700
Copper 106000 154000 170000 148000 132000 138000 137000 126000 143000 156000 148000 136000 160000 93900 139000
Iron 2770000 3310000 3230000 2720000 2960000 2850000 2810000 2180000 3000000 3410000 3430000 3030000 3600000 2420000 2840000
Lead 566 528 403 586 501 619 515 638 268 484 593 589 590 400 562
Manganese 117000 130000 160000 144000 123000 141000 122000 98000 136000 149000 151000 137000 170000 133000 138000
Mercury ND ND <0.5 <4 11.1 1.9 <0.5 <0.0020 <0.5 <2.00 <2.00 <2.00 <0.2 0.058 <0.2
Molybdenum 4080 3190 2240 4630 3510 3610 3650 4250 2010 3360 4060 3340 3200 2170 3090
Nickel 123000 122000 108000 126000 111000 125000 108000 127000 120000 134000 133000 121000 140000 104000 119000
Selenium 422 647 726 844 714 711 678 1020 631 615 683 635 1300 585 657
Silver ND ND <10 <10 <10 <10 <10 <100 <20 <100 <100 <100 <50 6 5
Thallium 361 703 368 470 371 338 278 402 233 212 373 374 390 2190 1580
Tin ND ND <100 <100 <100 <100 <100 <17000 <100 <17000 <17000 <17000 <50 <50 <50
Uranium 23000 29200 29900 30600 27100 33400 22800 26400 27200 27300 28600 25200 29000 18600 24300
Vanadium 409000 463000 536000 469000 454000 475000 452000 497000 513000 497000 534000 516000 500000 345000 450000
Zinc 767000 750000 582000 652000 574000 639000 631000 405000 702000 764000 760000 728000 850000 816000 674000
Radiologies (pCi/L)
Gross Alpha 1290 1570 1580 1000 1230 1370 2270 6890 7210 5660 4570 7520 3790 1630 1920 (2400)*
voes (ug/L)
Acetone 550 410 570 460 690 600 384 <700 599 473 551 551 449 501 522
Benzene ND ND <1 <1 <1 <1 <1 <5.0 <l <1 <l <1 <l <5 <5
Carbon tetrachloride ND ND <l <l <1 <1 <1 <5.0 <1 <1 <1 <1 <l <5 <5
Chloroform 20 17 16 15 20 16 21.4 <70.0 18.6 15 17.1 17.1 16 13.7 15.9
Chloromethane 1.8 ND 2.2 2.3 2 3 2.04 <30.0 <l <l 1.46 1.46 2.2 <5 <5
Cell 2 Slimes Drain
Chemical and Radiological Characteristics
Constituents 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
MEK 65 ND 100 83 130 100 95.5 <4000 102 80.3 58.4 58.4 135 74.0 89.9
Methylene Chloride ND ND <1 <1 <l <l <1 <5.0 <l <l 1.02 1.02 0.49 J <25 <25
Naphthalene 14 7.5 16 17 13 12 16.8 <100 16.2 11.9 10.1 10.1 13 7.65 7.15
Tetrahydrofuran 15 NA <100 <10 <10 3.2 3.98 <46.0 2.16 <1 2.88 2.88 <10 <25 <25
Toluene 1.7 ND 2.6 2.6 3 2 3.23 <1000 3.74 2.94 3.20 3.20 2.4 <5 <5
Xylenes 1.5 ND <l 2.2 <l 2 5.97 <10000 <l <l <l <l 0.51 J <15 <15
SVOCS (ug/L)
1,2,4-Trichlorobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
1,2-Dichlorobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
1,3-Dichlorobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
1,4-Dichlorobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
1-Methylnaphthalene NA NA <11 <10 <10 <10 <10 11 <10 <10 <10 <9.03 12 <3.0 11.6
2,4,5-Trichlorophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2,4,6-Trichlorophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2,4-Dichlorophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2,4-Dimethylphenol NA NA <51 <20 <20 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2,4-Dinitrophenol NA NA <11 <10 <10 <20 <20 <20 <20 <10 <10 <9.03 <50 <50 <50
2,4-Dinitrotoluene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2,6-Dinitrotoluene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2-Chloronaphthalene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <4.1 <4.10
2-Chlorophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2-Methylnaphthalene NA NA <11 <10 <10 <10 <10 11 <10 11.1 <10 <9.03 11 <3 10.4
2-Methylphenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
2-Nitrophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
3&4-Methylphenol NA NA <21 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <37 <37
3,3 '-Dichlorobenzidine NA NA <51 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <46 <33 <33
4,6-Dinitro-2-methylphenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <50 <30 <30
4-Bromophenyl phenyl ether NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
4-Chloro-3-methylphenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
4-Chlorophenyl phenyl ether NA NA <51 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
4-Nitrophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <50 <30 <30
Acenaphthene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Acenaphthylene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Anthracene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Azobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Benz( a)anthracene NA NA <21 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Benzi dine NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <92 <39 <39
Benzo(a)pyrene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Benzo(b )flu oran thene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Benzo(g,h,i)perylene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Benzo(k)fluoranthene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Bi s(2-chloroethoxy )methane NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <30
Bis(2-chloroethyl) ether NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Bis(2-chloroisopropy]) ether NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Cell 2 Slimes Drain
Chemical and Radiological Characteristics
Constituents 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Bis(2-ethylhexyl) phthalate NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 1.1 <3 <3
Butyl benzyl phthalate NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Chrysene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Dibenz( a,h )anthracene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Diethyl phthalate NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Dimethyl phthalate NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 1.5 <3 <3
Di-n-butyl phthalate NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Di-n-octyl phthalate NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Fluoranthene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Fluorene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Hexachlorobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Hexachlorobutadiene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <28 <30 <30
Hexachlorocyclopentadiene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Hexachloroethane NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <28 <30 <30
Indeno( 1,2,3-cd)pyrene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Isophorone NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <35 <35
Naphthalene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 5.3 <3 <3
Nitrobenzene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
N-Nitrosodimethylamine NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
N-Nitrosodi-n-propylamine NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
N-Nitrosodipheny )amine NA NA <51 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Pentachlorophenol NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <50 <30 <30
Phenanthrene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Phenol NA NA <11 10.7 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <30 <30
Pyrene NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <10 <3 <3
Pyridine NA NA <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.03 <18 <30 <30
* Sample was reanalyzed due to comparability with the duplicate sample. The reanalysis data are in (parenthesis).
Cell 2 LDS
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Major Ions (mglL)
Carbonate <1 <l
Bicarbonate 168 324
Calcium 711 615
Chloride 1750 1360
Fluoride 0.4 0.4
Magnesium 596 454
Nitrogen-Ammonia 32.6 0.7 Not Not Not Not Not Not Not Not Not Not Not
Nitrogen-Nitrate 2.8 2.2 Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled
Potassium 22 13
Sodium 412 318
Sulfate 2700 1780
pH (s.u.) 6.6 7.36
TDS 6750 5310
Conductivity (umhos/cm) 11000 6500
Metals {ug/L)
Arsenic <5 <5
Beryllium <0.50 <0.50
Cadmium 33.4 1.1
Chromium <25 <25
Cobalt 314 <10
Copper 59 12
Iron 208 37
Lead <LO <1.0
Manganese 1810 395 Not Not Not Not Not Not Not Not Not Not Not Mercury <0.50 0.52
Molybdenum 21 13 Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled
Nickel 948 <20
Selenium 7.9 9.4
Silver <10 <10
Thallium 0.92 <0.50
Tin <100 <100
Uranium 83.8 79.6
Vanadium 22 <15
Zinc 4220 78
Cell 2 LDS
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Radiologies (pCi/L)
Gross Alpha 13.5 7.3 Not Not Not Not Not Not Not Not Not Not Not
Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled
voes (ug/L)
Acetone <20 <20
Benzene <1 <l
Carbon tetrachloride <1 <l
Chloroform <1 <l
Chloromethane <l <1 Not Not Not Not Not Not Not Not Not Not Not MEK <20 <20 Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Methylene Chloride <1 <l
Naphthalene <l <1
Tetrahydrofuran <100 6.13
Toluene <1 <l
Xylenes <1 <l
SVOCS (ug/L)
1,2,4-Trichlorobenzene NA <10
1,2-Dichlorobenzene NA <10
1,3-Dichlorobenzene NA <10
1,4-Dichlorobenzene NA <10
I -Me thy !naphthalene NA <10
2,4,5-Trichlorophenol NA <10
2,4,6-Trichlorophenol NA <10
2,4-Dichlorophenol NA <10
2,4-Dimethylphenol NA <10
2,4-Dinitrophenol NA <20 Not Not Not Not Not Not Not Not Not Not Not 2,4-Dinitrotoluene NA <10 Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled 2,6-Dinitrotoluene NA <10
2-Chloronaphthalene NA <10
2-Chlorophenol NA <10
2-Methylnaphthalene NA <10
2-Methylphenol NA <10
2-Nitrophenol NA <10
3&4-Methylphenol NA <10
3 ,3 '-Dichlorobenzidine NA <10
4,6-Dinitro-2-methylphenol NA <10
4-Bromophenyl phenyl ether NA <10
Cell 2 LDS
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 201S 2016 2017 2018 2019 2020 2021
4-Chloro-3-methylphenol NA <10
4-Chlorophenyl phenyl ether NA <10
4-Nitrophenol NA <10
Acenaphthene NA <10
Acenaphthylene NA <10
Anthracene NA <10
Azobenzene NA <10
Benz(a)anthracene NA <10
Benzidine NA <10
Benzo(a)pyrene NA <10
Benzo(b )fluoranthene NA <10
Benzo(g,h,i)perylene NA <10
Benzo(k)tluoranthene NA <10
B is(2-chloroethoxy )methane NA <10
Bis(2-chloroethyl) ether NA <10
Bis(2-chloroisopropyl) ether NA <10
Bis(2-ethylhexyl) phthalate NA <10
Butyl benzyl phthalate NA <10
Chrysene NA <10
Dibenz( a,h )anthracene NA <10
Diethyl phthalate NA <10 Not Not Not Not Not Not Not Not Not Not Not
Dimethyl phthalate NA <10 Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled Sampled
Di-n-butyl phthalate NA <10
Di-n-octyl phthalate NA <10
Fluoranthene NA <10
Fluorene NA <10
Hexachlorobenzene NA <10
Hexachlorobutadiene NA <10
Hexachlorocyclopentadiene NA <10
Hexachloroethane NA <10
Indeno( 1,2,3-cd)pyrene NA <10
Isophorone NA <10
Naphthalene NA <10
Nitro benzene NA <10
N-Nitrosodimethylamine NA <10
N-Nitrosodi-n-propylamine NA <10
N-Nitrosodiphenylamine NA <10
Pentachlorophenol NA <10
Phenanthrene NA <10
Phenol NA <10
Pyrene NA <10
Pyridine NA <10
Cell 3
ennca an 8 0 Ol!ICa aractens cs Ch . I d R di 1 . I Ch . ti
2013 2018
Constituent 1987 2003 (Avg) 2007 (Avg) 2008 2009 2010 2011 2012 2013 ReSample 2014 2015 2016 2017 2018 ReSample 2019 2020 2021
Major Ions (mg/L)
Carbonate NA <l ND ND <l <l <1 <l <l NS <1 <1 <1.00 <1.00 <1.00 NS <5 236
Bicarbonate <5 NA ND ND <l <I <l <l <l NS <l <I <1.00 <1.00 <1.00 NS <5 175
Calcium 300 418 887 478 628 560 200 591 586 NS 294 713 148 526 498 NS 510 3
Chloride NA 2460 15965 15400 17200 3470 40400 8880 38400 NS 7200 22800 115000 2720 55200 NS 15000 500
Fluoride <100 667 42.8 1.4 0.6 54.8 64.1 2300 12400 NS 1330 5410 46500 189 7400 NS 1340 2.2
Magnesium 5400 3386 15767 13100 17100 2500 22100 5680 15400 NS 1910 12700 31000 84400 22000 NS 10000 11
Nitrogen-Ammonia 13900 1302 13867 9010 21600 2650 6470 6840 100 NS 3030 8.91 6270 88.5 9490 NS 9000 Not 278
Nilrogen-Nitrate <100 20 102 44 142 26 261 64 277 NS 59.5 26.6 582 107 710 NS 925 Sampled-12.2
Potassium NA 254 6657 4760 3820 782 2590 1190 2ll0 NS 386 1620 3120 133 1480 NS 630 Dry 20
Sodium 5900 3198 25583 22900 28600 5620 47900 6660 34400 NS 3630 23800 59800 2120 46900 NS 14000 1210
Sulfate 180000 33400 173667 167000 214000 40400 197000 80000 440000 NS 37000 158000 834000 9970 208000 NS 96000 1630
pH (s.u.) 0.82 2.28 1.6 1.79 1.4 2.18 1.27 2.4 1.05 NS 2.2 1.72 <1.00 3.63 1.32 NS 3.88 LO
TDS 189000 51633 228500 193000 243000 56200 296000 120000 410000 NS 70100 238000 887000 17300 327000 NS 143000 3930
Conductivity (umhos/cm) NA NA NA NA 304000 59800 86400 80300 84300 NS 56200 121000 13600 20300 104000 NS 95500 5870
Metals (ug/L)
Arsenic 163000 32867 256500 489000 ND 52900 263000 4340 66000 NS 2920 21500 194000 870 20900 NS 380 170
Beryl I iu,n 540 430 913 840 905 206 1570 678 2570 NS 222 1520 12500 590 2950 NS 350 <I
Cadmium 2600 1958 9260 15400 ND 1960 12200 3460 24000 NS 2550 14800 41000 1190 52100 NS 7400 2
Chromium 12000 3742 14883 12800 ND 3360 22800 10900 30600 NS 2380 15300 76200 <100 25100 NS 2301 <5
Cobalt 48000 NA 82783 57000 ND 13000 76000 76100 99700 NS 20800 72500 74200 4440 120000 NS 64000 <100
Copper 360000 87333 505000 345000 ND 89000 768000 379000 954000 NS 139000 511000 3000000 9720 515000 NS 35000 454
Iron 2100000 1278333 4874500 4400000 5970000 1460000 10200000 3400000 9700000 NS 688000 4570000 15400000 262000 13300000 NS 2500000 519
Lead <20000 2507 9647 16900 ND 17200 16700 1860 14400 NS 1900 9090 4030 15.8 20500 NS <75 2
Manganese 82000 144000 496833 313000 ND 101000 587000 3110000 2470000 NS 214000 1270000 5690000 102000 4070000 NS 1000000 Not 47
Mercury ND NA ND 16 ND <4 30.9 9.6 21.6 NS 2.4 7.01 873 <2.00 430 NS 0.20 Sampled-<1
Molybdenum 52000 12250 122167 209000 14 21300 96200 790 56100 NS 2930 12500 133000 70.1 3740 NS 550 Dry 759
Nickel 170000 20917 131833 241000 ND 23800 75800 150000 122000 NS 44900 121000 29200 7220 113000 NS 150000 33
Selenium <2000 910 5856 10200 ND 3080 6900 2460 7060 NS 1370 4330 3170 306 3680 NS 2900 135
Silver <2500 NA 305 1010 ND IOI 792 1850 3380 NS 329 1790 6780 <100 3770 NS 110 <I
Thallium 4700 NA 446 1200 ND 190 518 1080 694 NS 290 602 2160 21.3 3760 NS 170 1.6
Tin NA NA 1090 1070 ND 155 325 <100 <100 NS <17000 <100 <17000 <17000 <17000 NS <50 <50
Uranium 118000 67833 332333 636000 3690 180000 458000 835000 1200000 NS 134000 530000 5360000 9630 1110000 NS 19000 533
Vanadium 210000 158333 935000 1130000 ND 692000 2370000 836000 3220000 NS 454000 1720000 10300000 5600 2420000 NS 54000 6740
Zinc 590000 NA 748833 515000 ND 134000 726000 652000 1430000 NS 155000 899000 7810000 68100 2100000 NS 950000 114
Radiologies (pCi/L)
94900 Not
Gross Alpha NA 1015831 16533 21700 17000 4030 11100 1530 81900 NS 19700 (8/4/2015) 86000 292 19700 NS 3890 Sampled-<18.5 8780 Dry (5/28/2015)
Cell 3
ennca an a o oe1ca Ch . I d R di l . J Ch aracter1sttcs
2013 2018
Constituent 1987 2003 (Avg) 2007 (Avg) 2008 2009 2010 2011 2012 2013 ReSample 2014 2015 2016 2017 2018 ReSample 2019 2020 2021
voes (ug/L)
Acetone 28 NA 80 100 67 37 330 64 302 159 <700 82.8 <200 48.4 135 NS 135 46.6
Benzene <5 NA ND ND <I <I <1 <I <5 <I <5.0 <l <I <I <I NS <I <5
Carbon tetrachloride <5 NA ND ND <I <l <I <I <5 <I <5.0 <I <I <I <1 NS <I <5
Chloroform 6 NA ND 11 4.2 2.6 31 2 56.3 21 <70.0 1.75 13.2 <I 5.02 NS 18 <5
Chloromethane NA NA ND ND 1.4 1.8 3.5 I <5 2.58 <30.0 1.03 19.8 <l 5.36 NS 2.8 Not <5
MEK NA NA ND ND <I <I 67 <20 <100 24.5 <4000 <20 <20 <20 <20 NS 34 Sampled -<25
Methylene Chloride 10 NA ND ND <I <I 7.4 <I 6.95 <I <5.0 <l <l <I 10.4 NS 0.67 J Dry <25
Naphthalene <10000 NA ND <10 <I 2.1 1.2 <I <5 <I <100 <l <I <I <I NS 0.57 J <5
TeLrahydrofuran NA NA 150 <20 <100 <10 <10 <I <5 <I <46.0 <I <I <l 3.01 NS <35.0 <25
Toluene <5 NA ND ND <I <I <I <I <5 <l <1000 <I <I <I <I NS <I <5
Xylenes <5 NA ND ND <I <I <I <I <5 <l <10000 <l <I <I <I NS <l <15
SVOCS (ug/L)
1,2,4--Trichlorobenzene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
I .2-Dichlorobenzene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
1,3-Dichlorobenzene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <30
1,4-Dichlorobenzene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
I-Methyl naphthalene NA NA NA NA <I I <10 <IO <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
2,4,5-Trichlorophenol NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
2,4.6-Trichlorophenol NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
2,4-Dichlorophenol NA NA NA NA <I I <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1 ,490 <7.78 <10 <30
2,4-Di methylphenol NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
2.4-Dinitrophenol NA NA NA NA <53 <20 <20 <20 <21.1 <20 <20 <20 <10 <10 <1,490 <7.78 <50 <50
2,4-Diniu·otoluene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
2,6-Di ni trotoluene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 Not <30
2-Chloronaphthalene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 Sampled -<4.10
2-Chlorophenol NA NA NA NA <I I <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 Dry <30
2-Melhylnaphthalene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
2-Methylphenol NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <I ,490 <7.78 <10 <30
2-Nirrophenol NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <30
3&4-Methylphenol NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <i,490 <7.78 <10 <37
3,3 '-Dichlorobenzidine NA NA NA NA <21 <10 <10 <10 <10.5 <10 <10 <IO <10 <10 <1,490 <7.78 <45 <33
4,6-Dinitro-2-methylphenol NA NA NA NA <53 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <50 <30
4-Bromophenyl phenyl ether NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
4-Chloro-3-rnethyl phenol NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <30
4-Chlorophenyl phenyl ether NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
4-Nitrophenol NA NA NA NA <53 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <50 <30
Acenaphthene NA NA NA NA <l I <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Cell 3
em1ca an a 10 Ol!lca Ch . I d R d" I . I Ch aracterishcs
2013 2018
Constituent 1, 1987 2003 (Avg) 2007 (Avg) 2008 1: 2009 2010 2011 2012 2013 ReSample 2014 2015 2016 2017 2018 ReSample 2019 2020 2021
Acenaphthylene NA NA NA NA <11 <LO <10 <10 <10.5 <LO <10 <10 <10 <10 <1.490 <7.78 <LO <3
Anthracene NA NA NA NA <11 <10 <10 <10 <L0.5 <LO <10 <10 <10 <LO <1,490 <7.78 <10 <3
Azobenzene NA NA NA NA <11 <LO <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
Benz( a)anthracene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Benzidine NA NA NA NA <21 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <39
Benzo(a)pyrene NA NA NA NA <11 <10 <10 <10 <L0.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Benzo(b )fluoranthene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Benzo(g,h,i)perylene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Benzo(k)tluoranthene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
B is(2-chl oroethoxy )methane NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <LO <10 <1,490 <7.78 <10 <30
Bis(2-chloroethyl) ether NA NA NA NA <11 <LO <10 <10 <10.5 <10 <10 <10 <10 <10 <l.490 <7.78 <10 <30
Bis(2-chloroisopropyl) ether NA NA NA NA <11 <LO <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
Bis(2-ethylhexyl) phthalate NA NA NA NA <II 10.6 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Butyl benzyl phthalate NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Chrysene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <3
Di benz( a, h )anthracene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Diethyl phthalate NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Dimethyl phthalate NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 Not <3
Di-n-butyl phthalate NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <3
Di-n-octyl phthalate NA NA NA NA <11 <LO <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 Sampled -<3
Auoranthene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 Dry <3
Auorene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Hexachlorobenzene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
Hexachlorobutadiene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <27 <30
Hexachlorocyclopentadiene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
Hexachloroethane NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <27 <30
Indeno( 1,2,3-cd)pyrene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <3
Isophorone NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <35
Naphthalene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <3
Nitrobenzene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <10 <30
N-Nitrosodimethylamine NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
N-Nitrosodi-n-propylamine NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
N-Nitrosodiphenylamine NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
Pentachlorophenol NA NA NA NA <53 <10 <10 <10 <10.5 <10 <10 <10 <10 <IO <1,490 <7.78 <50 <30
Phenanthrene NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1.490 <7.78 <IO <3
Phenol NA NA NA NA <11 <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <10 <30
Pyrene NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <IO <1,490 <7.78 <10 <3
Pyridine NA NA NA NA <II <10 <10 <10 <10.5 <10 <10 <10 <10 <10 <1,490 <7.78 <18 <30
1 Historic values reported for Gross Alpha from 1987 and 2003 are total gross alpha reported in pCi/L. All other gross alpha data are reported as Gross Alpha minus Rn & U.
Cell 4A
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Major Ions (mg/L)
Carbonate <l <1 <1 <1 <1 <l <1 <1 <1 <1 <5 <5 <5
Bicarbonate <1 <1 <1 <1 <1 <1 <1 <1 <l <1 <5 <5 <5
Calcium 627 598 558 591 668 445 604 632 607 707 510 641 637
Chloride 4650 7350 5870 4980 4530 5900 6410 7040 8060 10100 8670 9120 12700
Fluoride 0.3 21.6 30.6 43 1130 1290 1660 2030 1420 2000 1650 1700 3190
Magnesium 3250 4940 4720 2230 3660 2990 3910 3550 4360 7030 4100 4700 5020
Nitrogen-Ammonia 3140 5230 4930 1540 1340 2730 11 4770 924 9060 6700 10000 7250
Nitrogen-Nitrate 28 52 44 27 38.2 39.5 19.9 41.9 53.4 73.4 70.4 84.8 112
Potassium 980 1440 1450 558 773 724 1020 915 1500 2020 1200 1660 1730
Sodium 5980 11300 11400 7130 6860 7190 9760 9580 12000 17600 15000 17700 18800
Sulfate 67600 87100 267000 64900 83300 64900 77200 126000 77800 116000 81300 85700 110000
pH (s.u.) 1.4 1.99 1.73 1.2 1.47 1.7 1.51 1.59 1.53 1.25 2.40 2.36 2.2
TDS 81400 107000 108000 76000 90000 97000 104000 124000 120000 147000 122000 139000 162000
Conductivity (umhos/cm) 131000 101000 82100 78100 66300 73000 89600 81300 89800 115000 81400 84000 91300
Metals (ug/L)
Arsenic 626000 109000 86600 60500 73700 70000 82600 94400 104000 125000 63000 71300 68600
Beryllium 296 215 323 167 247 190 281 320 440 538 420 485 448
Cadmium 1920 3670 2190 844 1450 1780 2090 2850 3360 3850 2500 3490 3540
Chromium 3220 7500 5900 5990 5220 4620 5460 7920 8520 9350 7200 9050 8820
Cobalt 9440 26500 22500 22900 22900 27500 26100 32800 37900 41000 28000 32800 30600
Copper 99200 168000 181000 433000 540000 556000 477000 566000 578000 683000 580000 617000 557000
Iron 2360000 2920000 3390000 3190000 2620000 2280000 3090000 3850000 4480000 5320000 3200000 3690000 3810000
Lead 5360 11800 11000 5270 11500 14800 11700 14000 15100 16400 9000 8680 8380
Manganese 178000 209000 131000 112000 143000 120000 181000 225000 261000 307000 210000 211000 214000
Mercury 1.19 <4 15.2 2.4 0.786 2.5 0.99 <2 2.30 2.52 2.1 3.4 3.7
Molybdenum 24300 43800 24200 58200 25500 40600 35400 43900 40800 59100 19000 25700 32600
Nickel 17100 40900 43500 41300 43300 54100 48700 61300 66800 71900 50000 58800 57100
Selenium 4620 5810 4460 1310 2080 2000 2400 2820 4450 5870 3700 3660 3740
Silver 78 193 216 127 144 197 186 305 379 521 310 487 466
Thallium 162 350 410 250 256 376 436 568 169 727 90 524 185
Tin 257 378 319 169 118 <17000 142 <17000 <17000 <17000 77 181 105
Uranium 118000 217000 153000 91000 112000 159000 171000 214000 193000 244000 35000 42600 43300
Vanadium 918000 1090000 730000 237000 461000 535000 577000 715000 972000 1080000 150000 205000 237000
Zinc 142000 224000 286000 200000 183000 169000 237000 318000 344000 406000 280000 350000 307000
Radiologies (pCi/L)
176000
Gross Alpha 8910 3400 8290 16300 15800 240000 (8/4/2015) 292000 133000 516000 261000 52400 122000 37800
(5/28/2015)
Cell 4A
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
voes (ug/L)
Acetone 60 55 100 25 28.4 <700 42.5 45.1 21.4 42.7 39 J 16.2 <25
Benzene <1 <1 <1 <1 <1 <5.0 <1 <1 <1 <1 <2.5 <1 <5
Carbon tetrachloride <1 <1 <1 <1 <1 <5.0 <1 <1 <1 <1 <2.5 <1 <5
Chloroform 4 8.5 10 <1 <1 <70.0 <1 <1 <1 1.91 1.9 J 1.50 <5
Chloromethane 3.4 5.5 7.9 <1 <1 <30.0 <1 <1 1.35 1.76 1.7 J 1.90 <5
MEK <1 <1 <1 <1 <20 <4000 <20 <20 <20 <20 13 J <5 <25
Methylene Chloride <1 <1 <1 <20 <1 <5.0 <1 <1 <1 <1 <2.5 <5 <25
Naphthalene 1.8 <1 <1 <1 <1 <100 <1 <1 <1 <1 <2.5 <1 <5
Tetrahydrofuran <100 <10 <10 1.36 <1 <46.0 <1 12.6 <1 <1 <35.0 <5 <25
Toluene <1 <1 <1 <1 <1 <1000 <1 <1 <1 <1 <2.5 <1 <5
Xylenes <1 <1 <1 <1 <1 <10000 <1 <1 <1 <1 <2.5 <3 <5
SVOCS (ug/L)
1,2,4-Trichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
1,2-Dichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
1,3-Dichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
1,4-Dichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
1-Methylnaphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3.0 <3
2,4,5-Trichlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2,4,6-Trichlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2,4-Dichlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2,4-Dimethylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2,4-Dinitrophenol <53 <20 <20 <20 <20 <20 <20 <10 <10 <8.57 <50 <50 <50
2,4-Dinitrotoluene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2,6-Dinitrotoluene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2-Chloronaphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <4.1 <4.10
2-Chlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2-Methylnaphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
2-Methylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
2-Nitrophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
3&4-Methylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <37 <37
3,3 '-Dichlorobenzidine <21 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <46 <33 <33
4,6-Dinitro-2-methylphenol <53 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <50 <30 <30
4-Bromophenyl phenyl ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
4-Chloro-3-methylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
4-Chlorophenyl phenyl ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
4-Nitrnphenol <53 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <50 <30 <30
Acenaphthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Acenaphthylene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Anthracene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 1.2 <3 <3
Azobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
Cell 4A
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Benz(a)anthracene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Benzidine <21 <10 <10 <10 <10 <10 <10 <10 <10 <8 .57 <10 <39 <39
Benzo(a)pyrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Benzo(b )fluoranthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Benzo(g,h,i)perylene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Benzo(k)fluoranthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
B is(2-chloroetho xy )methane <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <30
Bis(2-chloroethyl) ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
Bis(2-chloroisopropyl) ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <8 .57 <10 <30 <30
Bis(2-ethylhex_yl) phthalate <11 19.6 <10 <10 <10 <10 <10 <10 <10 <8 .57 <10 <3 <3
Butyl benzyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Chrysene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Dibenz( a,h)anthracene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8 .57 <10 <3 <3
Diethyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Dimethyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Di-n-buty 1 phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <8 .57 <10 <3 <3
Di-n-octyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Fluoranthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Fluorene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
IIexachlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
llexachlorobutadiene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <28 <30 <30
IIexachlorocyclopentadiene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
IIexachloroethane <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <28 <30 <30
Indeno( 1,2,3-cd)pyrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Isophorone <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <35 <35
Naphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Nitro benzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
N-Nitrosodimethylamine <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
N-Nitrosodi-n-propylamine <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
N-Nitrosodiphenylamine <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
Pentachlorophenol <53 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <50 <30 <30
Phenanthrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Phenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <30 <30
Pyrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <8.57 <10 <3 <3
Pyridine <11 <10 <10 <10 <10 <10 <10 <10 <10 34.0 <19 <30 <30
Cell 4A LDS
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Major Ions (mg/L)
Carbonate <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <5 <5 <5
Bicarbonate <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <5 <5 <5
Calcium 558 474 470 453 429 336 510 446 542 516 520 496 500
Chloride 7570 4670 6040 2710 1910 4200 2860 5200 8610 4360 7360 3860 6510
Fluoride 0.7 39.4 46 27 1970 1320 282 1150 1370 716 1530 500 2240
Magnesium 6390 3240 5100 2070 1710 2690 2730 3940 4630 3820 3800 3690 3780
Nitrogen-Ammonia 4480 2290 3480 1320 1010 2920 13.4 5050 846 4580 6080 3050 3680
Nitrogen-Nitrate 69 183 94 15 28.9 39 27.4 40.9 63.1 44.0 58.2 60.2 161
Potassium 1960 934 1500 503 305 415 245 675 1710 539 1000 334 635
Sodium 12600 6700 11000 3500 2930 4190 3490 8050 11500 6780 13000 5260 9550
Sulfate 92400 41700 77400 39600 31400 56000 50500 91300 89100 68600 72600 59900 72900
pH (s.u.) 1.98 2.53 2.32 2.1 2.32 2.4 2.29 2.04 1.50 1.88 2.39 2.25 2.4
TDS 117000 56900 93800 55400 49700 81900 65200 95400 142000 75300 112000 83800 105000
Conductivity (umhos/cm) 150000 49000 66600 39600 31300 53600 50200 62200 97900 63400 75600 53200 65900
Metals (ug/L)
Arsenic 133000 54000 74700 44100 35700 51200 10400 43500 117000 42400 52000 16600 32300
Beryllium 536 295 367 180 188 185 199 289 479 298 370 317 323
Cadmium 4010 2650 3160 921 1170 4720 4270 4500 4080 3740 1900 4410 4220
Chromium 9140 3890 5940 3930 2630 2780 1760 4250 9410 3930 6500 2820 5200
Cobalt 37300 15200 21700 22300 44300 41200 33700 32100 42700 30600 25000 45800 73400
Copper 222000 116000 150000 481000 754000 439000 160000 331000 650000 376000 500000 273000 322000
Iron 3940000 1420000 2530000 2460000 1370000 1850000 1320000 2330000 5140000 2090000 2500000 1440000 1370000
Lead 5270 3400 4520 2300 165 991 46.8 797 15500 118 4200 254 1120
Manganese 389000 157000 207000 95200 86300 98600 96700 184000 296000 136000 190000 137000 195000
Mercury 2.66 6.2 14.7 0.7 <0.5 <0.0020 <0.5 <2.00 <2.00 <2.00 1.4 0.20 0.30
Molybdenum 49200 23900 29300 10200 1200 3970 278 10700 49900 2350 8400 2190 4090
Nickel 43900 23900 29600 35000 54600 99300 86300 72700 74700 70900 46000 110000 67700
Selenium 5250 2820 3780 1260 1020 2170 649 1590 4940 1550 3100 1230 1960
Silver 204 62 127 44 24.8 <100 25.6 144 312 <100 230 150 212
Thallium 252 194 290 332 171 522 218 439 550 281 55 425 245
Tin 504 180 119 <100 <100 <17000 <100 <17000 <17000 <17000 <70 <500 <50
Uranium 284000 145000 168000 90200 75000 82200 25000 116000 247000 78600 38000 48000 76000
Vanadium 1150000 518000 770000 240000 157000 510000 253000 449000 1090000 475000 130000 374000 458000
Zinc 298000 152000 204000 181000 163000 306000 510000 502000 385000 446000 210000 541000 380000
Radiologies (pCi/L)
17200
Gross Alpha 7020 3230 7440 4730 6930 61800 (8/4/2015) 98700 176000 51000 163000 5450 23700 1670
(5/28/2015)
Cell 4A LDS
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
voes (ug/L)
Acetone 240 130 120 55 57 <700 84.7 61.5 79.8 108 84 90.3 262
Benzene <1 <1 <1 <1 <1 <5.0 <1 <1 <1 <1 <1 <5 <5
Carbon tetrachloride <1 <1 <1 <1 <1 <5.0 <1 <1 <1 <1 <1 <5 <5
Chloroform 23 52 26 42 110 95 129 84.5 21.6 33.8 31 120 47.2
Chloromethane 7.9 13 3.8 6 9.93 <30.0 5.35 <1.00 3.00 2.41 3.6 6.90 <5
MEK 78 50 82 36 <20 <4000 <20 <20 <20 <20 43 29.5 92.2
Methylene Chloride <1 <1 <1 <1 <1 <5.0 <1 <1 <1 1.05 0.47 J <25 <25
Naphthalene <1 1.5 <1 1 2.35 <100 <1 <1 <1 <1 <1 <5 <5
Tetrahydrofuran 140 158 102 117 39.1 <46.0 18.5 <1 15.7 19.7 16 <25 <25
Toluene <1 <1 <1 <1 <1 <1000 <1 <1 <1 <1 <1 <5 <5
Xylenes <1 <1 <1 <1 <1 <10000 <1 <1 <1 <1 <1 <15 <15
SVOCS (ug/L)
1,2,4-Trichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
1,2-Dichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
1,3-Dichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
1,4-Dichlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
1-Methy lnaphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3.0 <3
2,4,5-Trichlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2,4,6-Trichlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2,4-Dichlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2,4-Dimethylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 11.1 <10 <30 <30
2,4-Dinitrophenol <54 <20 <20 <20 <20 <20 <20 <10 <10 <9.08 <50 <50 <50
2,4-Dinitrotoluene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2,6-Dinitrotoluene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2-Chloronaphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <4.1 <4.10
2-Chlorophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2-Methylnaphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
2-Methylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
2-Nitrophenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
3&4-Methylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <37 <37
3,3 '-Dichlorobenzidine <22 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <46 <33 <33
4,6-Dinitro-2-methylphenol <54 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <50 <30 <30
4-Bromophenyl phenyl ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
4-Chloro-3-methylphenol <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
4-Chloro_phenyl phenyl ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
4-Nitrophenol <54 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <50 <30 <30
Acenaphthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Acenaphthylene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Anthracene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Azobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 -<30 <30
Cell 4A LDS
Chemical and Radiological Characteristics
Constituent 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Benz( a)anthracene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Benzidine <22 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <39 <39
Benzo( a)pyrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Benzo(b )fluoranthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Benzo(g,h,i)perylene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Benzo(k)fluoranthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
B is(2-chloroethoxy )methane <11 -<10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <30
Bis(2-chloroethyl) ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
Bis(2-chloroisopropyl) ether <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
Bis(2-ethylhexyl) phthalate <11 54.9 54.9 16.6 <10 <10 <10 <10 <10 <9.08 1.1 <3 <3
Butyl benzyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Chrysene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Dibenz( a,h)anthracene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Diethyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Dimethyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Di-n-butyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Di-n-octyl phthalate <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Fluoranthene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Fluorene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Hexachlorobenzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
Hexachlorobutadiene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <28 <30 <30
Hexachlorocyclopentadiene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
Hexachloroethane <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <28 <30 <30
Indeno( 1,2,3-cd)pyrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Isophorone <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <35 <35
Naphthalene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Nitro benzene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
N-Nitrosodimethy !amine <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
N-Nitrosodi-n-propylamine <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
N-Nitrosodiphenylamine <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
Pentachlorophenol <54 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <50 <30 <30
Phenanthrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Phenol 33 23.5 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <30 <30
Pyrene <11 <10 <10 <10 <10 <10 <10 <10 <10 <9.08 <10 <3 <3
Pyridine <11 <10 <10 <10 <10 <10 <10 <10 <10 12.9 <19 <30 <30
Cell 4B
Chemical and Radiological Characteristics
Constituent 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Major Ions (mg/L)
Carbonate <1 <l <l <l <l <l <l <l <5 <5 <5
Bicarbonate <l <l <l <l <l <l <1 <I <5 <5 <5
Calcium 570 580 662 366 655 523 473 664 670 628 534
Chloride 8290 8170 4570 7300 8500 12000 6930 7860 10500 10200 44800
Fluoride 26 .7 23.3 1050 1150 1210 1780 1170 1410 2300 1730 7000
Magnesium 3910 4500 3560 3310 5530 5780 3550 5790 6500 4520 8200
Nitrogen-Ammonia 5220 5580 2060 5380 1.09 8690 724 7590 8150 6580 9100
Nitrogen-Nitrate 39 42 51.4 47 15.2 64.5 31.3 42.2 38.6 70.0 286
Potassium 1370 1650 1110 989 1700 1710 1230 1660 1900 1680 3540
Sodium 9050 11700 3150 7100 12800 14100 10600 15700 18000 17100 54000
Sulfate 134000 119000 98100 91500 108000 285000 708000 98400 124000 97200 259000
pH (s.u.) 1.87 1.5 1.65 1.6 1.35 1.26 1.41 1.24 1.53 2.24 1.2
TDS 98000 128000 108000 131000 149000 172000 103000 117000 180000 150000 423000
Conductivity (umhos/cm) 76900 86900 72800 90100 115000 116000 93800 107000 99600 87300 109000
Metals (ug/L)
Arsenic 67400 80000 65400 70400 106000 139000 82700 97800 140000 67900 307000
Beryllium 311 356 334 275 430 557 347 407 640 455 1280
Cadmium 1990 2540 1990 2290 2980 4260 2340 2520 2000 1800 6760
Chromium 6860 8280 6390 6940 7450 11900 7800 8630 12000 9350 16600
Cobalt 17800 29300 21300 24600 33700 46700 30300 32900 44000 30900 39700
Copper 193000 340000 340000 368000 499000 684000 457000 539000 830000 602000 1170000
Iron 2960000 3580000 2830000 2480000 4340000 6340000 3690000 4400000 5800000 3690000 7610000
Lead 9960 11600 9820 10900 13400 17900 12200 12500 16000 8150 26000
Manganese 128000 148000 154000 129000 231000 325000 207000 242000 320000 201000 602000
Mercury 13.7 2.6 1.49 <0.0020 1.72 <2.00 <2.00 <2.00 0.46 0.40 8.6
Molybdenum 21400 27600 26100 29000 39800 55400 22600 27400 29000 8110 95600
Nickel 33900 50500 35100 42000 56400 79600 53000 57800 78000 56400 48900
Selenium 4670 4470 3900 5010 5600 7300 3740 4510 6600 3540 9080
Silver 137 169 137 142 195 307 <100 160 170 76 741
Thallium 237 368 243 258 408 559 17.5 33 .7 <100 165 2160
Tin 196 215 163 <17000 211 <17000 <17000 <17000 340 138 879
Uranium 133000 171000 110000 133000 200000 278000 23100 28100 36000 47400 279000
Vanadium 660000 783000 163000 666000 881000 868000 746000 828000 710000 113000 1060000
Zinc 191000 270000 184000 144000 313000 476000 267000 323000 280000 334000 475000
Radiologies (pCi/L)
267000
Gross Alpha 8590 13600 14600 148000 (8/4/2015) 42500 262000 132000 320000 310000 54500 87400
(5/28/2015)
voes (ug/L)
Acetone 130 94 43.5 <700 56.2 86.4 38.6 56 .8 39 12.7 97.6
Benzene <1 <1 <l <5.0 <1 <1 <l <l <l <I <5
Carbon tetrachloride <1 <1 <l <5.0 <l <l <1 <1 <1 <1 <5
Chloroform 9.4 4 8.06 <70.0 2.34 3.07 2.39 2.17 3.4 <I <5
Chloromethane 8.5 8 7.12 <30.0 3.62 6.01 1.26 1.72 2.1 1.28 <5
MEK <l <l <20 <4000 <20 <20 <20 27.4 15 J <5 57
Cell 4B
Chemical and Radiological Characteristics
Constituent 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Methylene Chloride <1 <1 <1 <5.0 <1 <1 <1 <l <1 <5 <25
Naphthalene <1 <l <1 <100 <1 <1 <1 <l <1 <1 <5
Tetrahydrofuran <10 11.1 <1 <46.0 <l <1 <1 1.87 <35.0 <5 164
Toluene <1 <1 <1 <1000 <l <l <1 <l <1 <1 <5
Xvlenes <1 <l <l <10000 <1 <l <l <1 <1 <3 <15
SVOCS (ug/L)
1,2,4-Trichlorobenzene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
1,2-Dichlorobenzene <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <30 <30
1,3-Dichlorobenzene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
1,4-Dichlorobenzene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
1-Methylnaphthalene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3.0 <3
2,4,5-Trichlorophenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <30 <30
2,4,6-Trichlorophenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <30 <30
2,4-Dichlorophenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <50 <30 <30
2,4-Dimethylphenol <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
2,4-Dinitrophenol <20 <20 <20 <20 <20 <10 <10 <8.72 <10 <50 <50
2,4-Dinitrotoluene <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <30 <30
2,6-Dinitrotoluene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
2-Chloronaphthalene <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <4.1 <4.10
2-Chlorophenol <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
2-Methy !naphthalene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
2-Methylphenol <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
2-Nitrophenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <30 <30
3&4-Methylphenol <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <37 <37
3,3 '-Dichlorobenzidine <10 <10 <10 <10 <10 <10 <10 <8 .72 <44 <33 <33
4,6-Dinitro-2-methylphenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <50 <30 <30
4-Bromophenyl phenyl ether <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
4-Chloro-3-methylphenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <10 <30 <30
4-Chlorophenyl phenyl ether <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
4-Nitrophenol <10 <10 <10 <10 <10 <10 <10 <8 .72 <50 <30 <30
Acenaphthene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Acenaphthylene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Anthracene <10 <10 <10 <10 <10 <10 <10 <8.72 1.7 <3 <3
Azobenzene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Benz(a)anthracene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <30
Benzidine <10 <10 <10 26 <10 <10 <10 <8.72 <10 <39 <39
Benzo(a)pyrene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <30
Benzo(b )fluoranthene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <30
Benzo(g,h,i)perylene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <30
Benzo(k)fluoranthene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <30
B is(2-chloroethoxy )methane <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <30
Bis(2-chloroethyl) ether <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Cell 4B
Chemical and Radiological Characteristics
Constituent 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Bis(2-chloroisopropyl) ether <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Bis(2-ethylhexyl) phthalate 410 19 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Butyl benzyl phthalate <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Chrysene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Dibenz( a,h)anthracene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Diethyl phthalate <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Dimethyl phthalate <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Di-n-butyl phthalate <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Di-n-octyl phthalate <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Fluoranthene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Fluorene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Hexachlorobenzene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Hexachlorobutadiene <10 <10 <10 <10 <10 <10 <10 <8.72 <26 <30 <30
Hexachlorocyclopentadiene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Hexachloroethane <10 <10 <10 <10 <10 <10 <10 <8.72 <26 <30 <30
Indeno( 1,2,3-cd)pyrene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Isophorone <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <35 <35
Naphthalene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Nitrobenzene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
N-Nitrosodimethylamine <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
N-Nitrosodi-n-propylamine <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
N-Nitrosodiphenylamine <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Pentachlorophenol <10 <10 <10 <10 <10 <10 <10 <8.72 <50 <30 <30
Phenanthrene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Phenol <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <30 <30
Pyrene <10 <10 <10 <10 <10 <10 <10 <8.72 <10 <3 <3
Pyridine <10 <10 <10 15 <10 <10 <10 31.7 <18 <30 118
Cell 4B LDS
Chemical and Radiological Characteristics
Constituent 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Major Ions (mg/L)
Carbonate <1 <1 dry <1 <1 <1 <1 <1 <5 <5 <5
Bicarbonate <1 <1 dry <1 <1 <1 <1 <1 <5 <5 <5
Calcium 486 456 dry 308 538 547 516 592 550 555 526
Chloride 3630 6850 dry 6900 7960 8510 10400 8060 8050 7630 9180
Fluoride 28.4 22 dry 970 1150 1290 1050 1480 1680 1550 1870
Magnesium 3230 3360 dry 3400 5190 4780 5370 5580 4800 4830 4850
Nitrogen-Ammonia 4260 4090 dry 5240 2.43 7540 739 7510 7080 5080 4280
Nitrogen-Nitrate 30 31 dry 43 16.6 49.6 63.9 47.4 41.2 39.5 67.5
Potassium 1130 1060 dry 952 1560 1360 2130 1620 1400 1350 1240
Sodium 8240 8080 dry 6920 11900 10800 13200 14500 13000 12600 12200
Sulfate 59900 99100 dry 82300 104000 163000 117000 100000 89500 88700 99000
pH (s.u.) 2.23 2.4 dry 2.2 1.51 1.88 1.44 1.35 1.73 1.89 2.0
TDS 85800 90200 dry 129000 131000 133000 168000 132000 131000 134000 132000
Conductivity (umhos/cm) 63000 62400 dry 76300 106000 68400 105000 104000 80800 77600 78000
Metals ( ug/L)
Arsenic 54200 41200 dry 67800 98400 98800 135000 94100 89000 84900 74800
Beryllium 274 271 dry 282 411 430 559 416 470 483 318
Cadmium 1670 1740 dry 2290 2790 3250 4500 2610 2000 2060 2140
Chromium 6250 5930 dry 6160 7320 9470 13700 8980 9100 9620 8980
Cobalt 15600 19000 dry 23300 31100 33600 48900 31700 31000 32200 60300
Copper 176000 181000 dry 308000 458000 475000 681000 497000 550000 500000 423000
Iron 2450000 2120000 dry 2590000 4180000 4680000 5910000 4190000 4400000 4180000 3660000
Lead 6060 4420 dry 4120 10100 5860 14000 8770 7800 5110 1860
Manganese 118000 162000 dry 144000 222000 262000 346000 239000 240000 221000 213000
Mercury 12.3 3 dry 0.002 1.47 <2.00 <2.00 <2.00 0.1 lJ 0.10 <0.2
Molybdenum 16700 15000 dry 24300 36300 35500 52900 25900 27000 19800 14300
Nickel 30700 33700 dry 40100 52600 58100 84400 56100 59000 57900 52000
Selenium 3710 2880 dry 4080 5080 5310 6860 4500 4700 3950 3870
Silver 111 117 dry 119 179 224 266 156 170 173 142
Thallium 179 175 dry 336 354 414 427 245 87 98 123
Tin 332 <100 dry <17000 198 <17000 <17000 <17000 200 258 141
Uranium 111000 132000 dry 143000 185000 192000 269000 54200 31000 34600 29400
Vanadium 518000 428000 dry 671000 817000 847000 1260000 811000 760000 743000 683000
Zinc 172000 182000 dry 144000 296000 315000 443000 303000 280000 286000 244000
Radiologies (pCi/L)
375000
Gross Alpha 6000 7500 dry 181000 (8/4/2015) 185000 165000 305000 226000 54100 105000 52500
(5/28/2015)
Cell 4B LDS
Chemical and Radiological Characteristics
Constituent 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
voes (ug/L)
Acetone 390 370 drv <700 218 266 479 147 102 68.5 <25
Benzene <1 <1 dry <5.0 <1 <1 <1 <1 <1 <1 <5
Carbon tetrachloride <1 <1 dry <5.0 <1 <1 <1 <1 <1 <1 <5
Chloroform 20 19 dry <70.0 5.03 9.97 9.13 4.74 3.9 1.22 <5
Chloromethane 11 11 dry <30.0 9.72 10.8 7.16 2.4 2.3 <1 <5
MEK 240 180 dry <4000 71.8 53.6 89.4 34.6 71 42.8 <25
Methylene Chloride <1 <1 dry <5.0 <1 <1 1.01 <1 <1 <5 <25
Naphthalene <1 <1 dry <100 <1 <1 <1 <1 <1 <1 <5
Tetrahydrofuran 198 322 dry 75.6 36.6 75.9 51.2 17.3 53 96.5 <25
Toluene <1 <1 dry <1000 <1 <1 <1 <1 <1 <1 <5
Xylenes <1 <1 dry <10000 <1 <1 <1 <1 <1 <3 <15
SVOCS (ug/L)
1,2,4-Trichlorobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
1,2-Dichlorobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
1,3-Dichlorobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
1,4-Dichlorobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
1-Methylnaphthalene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3.0 <3
2,4,5-Trichlorophenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2,4,6-Trichlorophenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2,4-Dichlorophenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2,4-Dimethylphenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2,4-Dinitrophenol <20 <20 dry <20 <20 <20 <10 <8.79 <50 <50 <50
2,4-Dinitrotoluene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2,6-Dinitrotoluene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2-Chloronaphthalene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <4.1 <4.10
2-Chlorophenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2-Methylnaphthalene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
2-Methylphenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
2-Nitrophenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
3&4-Methylphenol <10 <10 dry <10 <10 <10 <10 <8.79 0.42 <37 <37
3,3 '-Dichlorobenzidine <10 <10 dry <10 <10 <10 <10 <8.79 <45 <33 <33
4,6-Dinitro-2-methylphenol <10 <10 dry <10 <10 <10 <10 <8.79 <50 <30 <30
4-Bromophenyl phenyl ether <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
4-Chloro-3-methylphenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
4-Chlorophenyl phenyl ether <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
4-Nitrophenol <10 <10 dry <10 <10 <10 <10 <8.79 <50 <30 <30
Acenaphthene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Acenaphthylene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Anthracene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Azobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Cell 4B LDS
Chemical and Radiological Characteristics
Constituent 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Benz(a)anthracene <10 <10 drv <10 <10 <10 <10 <8.79 <10 <3 <3
Benzidine <10 <10 dry <10 <10 <10 <10 <8.79 <10 <39 <39
Benzo(a)pyrene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Benzo(b )fluoranthene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Benzo(g,h,i)perylene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Benzo(k)fluoranthene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Bis(2-chloroethoxy )methane <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <30
Bis(2-chloroethyl) ether <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Bis(2-chloroisopropyl) ether <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Bis(2-ethylhexyl) phthalate 191 191 dry 27 <10 132 145 65.9 16 <3 43.1
Butyl benzyl phthalate <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Chrysene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Dibenz(a,h)anthracene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Diethyl phthalate <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Dimethyl phthalate <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Di-n-butyl phthalate <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Di-n-octyl phthalate <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Fluoranthene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Fluorene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Hexachlorobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Hexachlorobutadiene <10 <10 dry <10 <10 <10 <10 <8.79 <27 <30 <30
Hexachlorocyclopentadiene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Hexachloroethane <10 <10 dry <10 <10 <10 <10 <8.79 <27 <30 <30
Indeno( 1,2,3-cd)pyrene <10 <10 drv <10 <10 <10 <10 <8.79 <10 <3 <3
Isophorone <10 <10 dry <10 <10 <10 <10 <8.79 <10 <35 <35
Naphthalene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Nitrobenzene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
N-Nitrosodimethy !amine <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
N-Nitrosodi-n-propylamine <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
N-Nitrosodiphenylamine <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Pentachlorophenol <10 <10 dry <10 <10 <10 <10 <8.79 <50 <30 <30
Phenanthrene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Phenol <10 <10 dry <10 <10 <10 <10 <8.79 <10 <30 <30
Pyrene <10 <10 dry <10 <10 <10 <10 <8.79 <10 <3 <3
Pyridine <10 <10 dry <10 <10 <10 <10 29.1 <18 <30 146
Cell I
Additional RadiologicaJ Analyses
Thorium-228 Thorium-230 Thorium-232 Radium-226 Uranium-233/234 Uranium-235/236 Uranium-238 Specific Gravity <nCi/L) (nCi/L) (pCi/L) (pCi/L) <nCi/L) <nCi/L) (pCi/L)
8/4/15 1310 991000 6150 1110 141000 8920 140000 1.21
5/28/15 204 782000 6730 829 96700 5980 100000 1.13
8/30/16 ND 677000 4480 497 2380 45800 1.15
8/29/17 2890 8100000 76000 391 353000 20400 344000 1.17
8/1 /18 ND 856000 8410 443 97300 6970 97200 1.16
8/21/19 1380 747000 4780 348 28400 1650 28700 1.15
8/21/2019
(Cell 65 -1500 663000 5720 434 25500 1960 27700 1.15 Duplicate
of Cell I)
8/19/20 1090 1030000 6670 801 68300 4020 64600 1.33
9/1/21 469 174000 1060 424 218000 11800 221000 1.38
9/1/2021
(Cell 65 -500 178000 946 281 212000 10300 223000 1.33 Duplicate
of Cell 1)
Thorium-228 Thorium-230
(pCi/L) (pCi/L)
8/4/15 ND 6680
8/30/16 ND 5050
8/29/17 ND 38500
8/1/2018 ND 7390
8/1/2018
(cell 65 -
Duplicate ND 6860
of Cell 2
Slimes)
8/21/2019 ND 1750
8/19/2020 ND 5180
9/1/21 ND 2780
Cell 2 Slimes Drain
Additional Radiological Analyses
Thorium-232 Radium-226 Uranium-
(pCi/L) (pCi/L) 233/234 (pCi/L)
ND 36.6 11300
ND 52.4 11700
ND 51.2 111000
ND 36.2 14900
ND 29.8 10700
ND 62.5 9300
ND 86.0 8680
ND 63.0 9210
Uranium-Uranium-238 Specific Gravity 235/236 (pCi/L) (pCi/L)
858 10500 1.09
599 10700 1.03
ND 75600 1.07
ND 12500 1.07
3440 12600 1.06
484 9150 1.03
917 8760 1.08
582 9040 1.07
Cell 3
Add · itional R . I • acho og1cal Analyses
Thorium-228 Thorium-230 Thorium-232 Radium-226 Uranium-Uranium-Uranium-238 Specific Gravity (pCi/L) (pCi/L) (pCi/L) (pCi/L) 233/234 (pCi/L) 235/236 (pCi/L) (pCi/L)
8/4/15 ND 123000 1640 448 184000 10300 191000 1.21
5/28/15 798 131000 1290 202 557000 37900 591000 1.29
8/30/16 983 72500 1670 584 1960000 130000 2060000 1.62
1S/5U/l 0
(cell 65 -ND Duplicate 67000 788 640 2520000 130000 2490000 1.53
of Cell 3)
8/29/17 ND ND ND 101 37600 ND 32800 0.989
8/1/18 ND 28100 2310 79.8 398000 . 24000 468000 1.21
8/21/19 ND 6610 ND 48.0 6640 ND 5780 1.07
8/19/20 Not Sampled -Dry
9/1/21 ND 31.2 ND ND 144 ND 209 0.984
Cell 4A
Additional Radiological Analyses
Thorium-228 Thorium-230 Thorium-232 Radium-226 Uranium-Uranium-Uranium-238 Specific Gravity (pCi/L) (pCi/L) (pCi/L) (pCi/L) 233/234 (pCi/L) 235/236 (pCi/L) (pCi/L)
8/4/15 ND 374000 3490 663 57500 3720 64400 1.11
5/28/15 327 405000 3440 ND 61200 4030 62700 1.07
5/28/2015
(Cell 65 -
Duplicate 265 315000 3790 772 58600 3020 58300 NS
of Cell
4A)
8/30/16 ND 466000 2870 1050 61100 3320 70900 1.10
8/29/17 ND 4450000 47700 759 637000 30600 692000 1.09
8/29/17
(Cell 65 -
Duplicate ND 4080000 11000 822 602000 44900 616000 1.12
of Cell
4A)
8/1 /I 8 1970 539000 8230 59.2 88700 9900 86300 1.10
8/21/19 941 430000 2870 260 9350 674 10900 1.02
8/19/20 1040 521000 4130 395 17200 991 13700 1.10
8/19/2020
(Cell 65 -
Duplicate ND 488000 2200 372 14100 1000 14300 1.11
of Cell
4A)
9/l /21 1000 662000 6240 686 18000 1150 17900 1.11
Thorium-228 Thorium-230
(pCi/L) (pCi/L)
8/4/15 ND 25300
5/28/15 ND 25300
8/30/16 ND 134000
8/29/17 ND 5410000
8/1/18 ND 76000
8/21/19 1060 366000
8/19/20 ND 39500
9/1 /21 462 101000
Cell 4A LDS
Additional R:1diologicaJ Analyses
Thorium-232 Radium-226 Uranium-
(pCi/L) (pCi/L) 233/234 (pCi/L)
ND 19.3 9380
ND 19.3 9380
1130 51.1 46200
49200 286 852000
ND 38.2 28800
2230 73.4 13500
ND 18.6 19000
731 33.4 38200
Uranium-Uranium-238 Specific Gravity 235/236 (pCi/L) (pCi/L)
504 10800 1.07
504 10800 NS
1900 40400 1.10
66200 851000 1.17
ND 30500 1.05
738 13000 1.02
711 16600 1.07
1720 37500 1.08
Cell 4B
Additional Radiological Amdyses
Thorium-228 Thorium-230 Thorium-232 Radium-226 Uranium-233/234 Uranium-235/236 Uranium-238 Specific Gravity (nCi/L) (nCi/L) fnCi/L) (nCi/L) (oCi/L) (nCi/L) fnCi/L)
8/4/15 ND 410000 2210 611 63500 3710 67000 1.12
5/28/15 122 346000 3790 544 65000 3870 66100 1.08
8/30/16 ND 595000 3510 715 90200 4090 90100 1.13
8/29/17 ND 3390000 56000 489 76000 8100 92700 1.07
8/1/18 ND 461000 7360 307 13700 ND 8420 1.08
8/21/19 1080 434000 3490 296 11600 563 10800 1.10
8/19/20 1280 606000 4320 360 17000 1080 17700 1.11
9/1/21 1590 523000 3240 495 58400 3780 60000 1.25
Thorium-228 Thorium-230
(nCi/L) (nCi/L)
8/4/15 ND 452000
8/4/15
(Cell 65 -
Duplicate ND 436000
ofCell 4B
LOS)
5/28/15 334 487000
8/30/16 ND 368000
8/29/17 4680 5220000
8/1/18 1520 424000
8/21/19 1030 368000
8/19/20 888 541000
9/1/21 803 452000
Cell 4B LDS
Additional Radiological AnaJyses
Thorium-232 Radium-226 Uranium-
(nCi/L) (oCi/L) 233/234 (oCi/L)
3660 161 62600
4000 125 62600
5430 55.2 63500
1010 104 78600
43200 143 846000
5130 88.3 14300
2650 105 8840
4070 153 11700
3110 174 10700
Uranium-235/236 Uranium-238 Specific Gravity <oCi/L) (oCi/L)
3890 60900 1.12
2680 61300 1.12
3900 65500 NS
3820 78900 1.11
64200 894000 1.07
ND 18400 1.09
412 9600 1.05
749 14500 1.11
631 11400 1.10
Appendix F
Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan 07 /11
Revision: Denison 2.3
07/2011 Revision Denison 2.3
Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan.
TABLE OF CONTENTS
1.0 Introduction .............................................................................................................. 2
2.0. Cell Design ............................................................................................................... 2
2.1 Cell 4A Design ................................................................................................. 2
2.2 Cell 4B Design .................................................................................................. 5
3.0 Cell Operation .......................................................................................................... 8
3.1 Solution Discharge to Cell 4A .......................................................................... 8
3.2 Solution Discharge to Cell 4B .......................................................................... 8
3.3 Initial Solids Discharge into Cell 4A ................................................................ 9
3.4 Initial Solids Discharge into Cell 4B ................................................................ 9
3.5 Equipment Access to Cell 4A and Cell 4B ..................................................... 10
3.6 Reclaim Water System at Cell 4A .................................................................. 10
3.7 Reclaim Water System at Cell 4B .................................................................. 10
3.8 Interim Solids Discharge to Cell 4A. .............................................................. 11
3.9 Interim Solids Discharge to Cell 4B ............................................................... 11
3.10 Liner Maintenance and QA/QC for Cell 4A ............................................... 11
3.11 Liner Maintenance and QA/QC for Cell 4B ............................................... 11
4.0 BAT Performance Standards for Tailings Cell 4A and 4B .................................... 11
5.0 Routine Maintenance and Monitoring ................................................................... 13
5.1 Solution Elevation .......................................................................................... 13
5.2 Leak Detection System ................................................................................... 13
5.3 Slimes Drain System ...................................................................................... 15
6.0 Tailings Emergencies ............................................................................................. 16
7.0 Solution Freeboard Calculations ............................................................................ 16
8.0 List of Attachments ................................................................................................ 18.
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1.0 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 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 of Cell 4B 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 I.D.12, I.E.12, and I.F.9 of the GWDP
2.0 Cell Design
2.1 Cell 4A Design
Tailings Cell 4A 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 15-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 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 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
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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
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 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
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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 18-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 HOPE 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 perlorated 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
gee-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 (SOC) pipe found at the downgradient 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. 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.
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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 18-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 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.
t) 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.
2.2 Cell 4B Design
Tailings Cell 4B consists of the following major elements:
a) Dike -consisting of a newly-constructed dike on the south side of the cell
with a 15-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
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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
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 sub grade 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 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 an 18-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 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 has achieved a moisture content of at least 50% by weight.
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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 ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of ~he 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 comer downhill to the far southeast corner of
Cell 48 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) Cell 4B 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 HOPE 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 Cell 4B floor beyond the toe of the slope.
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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 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 4 B. 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.
3.0 Cell Operation
3.1 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
appropriately sized 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 Cell 4A, 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.
3.2 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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from Cell 2 dewatering operations. The solution will be pumped to Cell 4B
through appropriate sized pipelines pipelines. The initial solution discharge will
be in the southeast corner of the Cell. The discharge pipe will be routed 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 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.
3.3 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 appropriately sized
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 lA. 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.
3.4 Initial Solids Discharge into Cell 4B
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 appropriately sized
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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 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.
3.5 Equipment Access to Cell 4A and Cell 4B
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.
3.6 Reclaim Water System at Cell 4A
A pump barge and solution recovery system is operating in the southwest corner
of the cell to pump solution from the cell for water balance pmposes 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.
3.7 Reclaim Water System at Cell 4B
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.
3.8 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.
3.9 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.
3.10 Liner Maintenance and QA/QC 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.
3.11 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.
4.0 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
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
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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 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-10.2,
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 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 lB 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
Perrnittee initiates pumping conditions in the Tailings Cell 4A or Cell
4B slimes drain system, quarterly 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.
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5.0 Routine Maintenance and Monitoring
01/21/2010 Revision
Denison 2.2
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 and RSO.
5.1 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 Cell 4A 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
DMTPlan.
5.2 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 Cell 4B 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
1-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
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
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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
visual strobe light that flashes on the control panel 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 Cell 4B sump) above the lowest level of the leak
detection sump (9 inches [0.75 feet] above the lowest point on the lower
flexible membrane liner for Cell 4A and 2 1/4 inches [0.19 feet] for Cell
4B), to ensure the allowable 1.0 foot (5556.14 feet amsl in the Cell 4A
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 48, 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 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 137.6 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 1s
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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 a re-occurrence.
5.3 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.
(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) After initiation of pumping conditions in Tailings Cell 4A or 4B, n a
quarterly 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 a Quarterly Data form, by
measuring the depth to water below the water level measuring point on the
slimes drain access pipe;
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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.
6.0 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 Darn Safety (801-538-7200).
7 .0 Solution Free board Calculations
The maximum tailings cell pond wastewater levels in Cell 1, Cell 2, Cell 3, Cell 4A, and
Cell 4B are regulated by condition 10.3 of the White Mesa Mill 1 le.(2) Materials
License. However, freeboard limits are no longer applicable to Cell 2, Cell 3, and Cell
4A, as discussed below.
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 Cell 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 license and not included
herein]. Based on approved revisions to the DMT Plan dated
January 2011, the freeboard limit is no longer applicable to Cells 2,
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3 and4A.
01/21/2010 Revision
Denison 2.2
C. The discharge of any surface water, stormwater, or wastewater
from Cells 3, 4A, and 48 shall only be through an Executive
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 48.
Cells 2 and 3 have no freeboard limit because those Cells are full or near full of tailings
solids. Cell 4A has no freeboard limit because it is assumed that all precipitation falling
on Cell 4A will overflow to Cell 48. All precipitation falling on Cell 2, 3, and 4A and
the adjacent drainage areas must be contained in Cell 48. The flood volume from the
PMP event over the Cell 2, 3, and Cell 4A 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 48, it is assumed Cell 4A has no freeboard
limit and all of the flood volume from the PMP event will be contained in Cell 48. The
flood volume from the PMP event over the Cell 48 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 Cell 48. The procedure for calculating the freeboard limit for Cell 48 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 48 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 Cell 4B will be recalculated annually.
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8.0 List of Attachments
01/21/2010 Revision
Denison 2.2
1) Figures IA 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 lB, Calculated Action leakage Rates for Various Head Conditions,
Cell 4B, White Mesa Mill, Blanding, Utah, Geosyntec Consultants
11) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan.
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MIM.II 2lf WIDE 5TR'iP OF -E
ID IIL HDPE IIEIIIIIIM-(SMCllnl)
<alNEJ(llll 14,)
e~PAD ~·'"
~-;;;;-. ~
.......... ----~ . :::-----....
I
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~t--:rn•~ .1,-(lf"=---l
,.
LEGEND
EXISTING GROUND COIITOUR -MA..'OR
EXIS11NG GROUND CONTOUR -t.llNCR
--5590--PROPOSED SURF'ACE CON1tlUR -MAJOR
PROPOSED S\JRF'AC£ COlffl1JR -l#IOR
------LNTCE"UNER
~ SPI.ASHPAD
-• -Hill'£ PIPELINE SL.LIMY OR SOIJLTIOH
sownON RETURN
SUWE'S DRAIN
::,._ VALJUMITS OF LINER -
.............. ---;;---.. =---1 ------..... . -........ ' .
I .
!
I
0 100' 200' --SCALE IN FEET
INITW. Fll.LING Pl.AN, DETAILS AND SECT1DNS
CELl.4"
Bl.ANDING, UTAH
I
Geosyntect>I DAlE: acroBER2010 I FtGUftE
C01\.~1.1l!ant11 PRDJECT IIO. SC0349 2A
-r--.. """~ --~ . --... -------ri·,-:::i.;-;.;;:,,;.";;.-;;.;_--;;_ a-e. _. -I. --7~------,_ ,r t
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l.£GEND
EXISllNG GROUND CllN'TtlUR -MA.JOR
ElCIS11NG GRDUND CQmll.lR -MINOR
--5590--PROPOSED SURFACE CCll111llt -IIAJCR
PftOP0'5E> SURFMZ CClfTtUt -~
------UNIT CF UtlER
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• ~ HDFE Plf'aJNE SUJMY <ll SOOLlDI
.. SCl1JTitN RrlURt,I
• • ------· su.tES DRAN
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IMTIAL Rl.l.lNG Pl.AN, OETAILS AND SECTIONS
CEU.48
Geosyntect>
amsulta:ms
BLANDING. UTAH
DA.TEo OCTOBER zno
PROJECT NO SC0349
1'1GURE
28
• ~--------------------------~
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REl\JRN
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LEGEND
EXISllN6 IRlUND CllN10UR -MAJQft
D1S11NC GAOU1m CON"TDUR --«lR
--SSIIO--.. DPOSED SIJRrACE CQlffllUR -MAJOR
PROPOSE) SURP'ACE CDN'ltlUR -IIINCR
---lJIIIT Of" UN~
~
0 100' 2®" ------SCALE IN FEET
5l'I.AStl PNJ
-• -HDPE l'FEUE SlURRT D1t SOtUlaN
SOWllllN R!'1IRI
INITIAL FIWNG Pl.AN, SOLUTION AMl SLURRY PIPELINE ROUl=S
CB.L<IA
----SUIES llRAl4 Geosyntect>
i:uru.-ulwnts
~.UT.Ni
CIATE: OCTOBER.2010
PRCJECT NO SC0348
..-
3A
SCW110N ·---·r-·-~· ------, ., ,:
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6" CR e• -E -~ \ 1
1 SUJll:RY OR S0\,:11',CN ""\. . ,,
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LEGEND
~ GROOICI CQNTDUR -MAJOR
EXIS'IING CRCIUND CONTClJR -MINOR
--51:590--~ SURFACE CCNTOJR -MAJOR
~~
---P'Ra'OSED SURFACE cancuR -IINOR 0 100' 200'
------UMJT OF' UNER W 1 !
'2 > > t > 2 > .. , SPLASH PAD SCALE IN FEET
-• ~ HOPE PIPELI£ SW1RY OR SOULnc,i ... S0llJ1IOH REtUIIN
INITIAL FIWNG Pl.AN, SOWTION AND SLURR'I PIPELINE RO\JTcS
CELL4B
• -• -• • • • • SUMES llftALN Geosyntect'I
f'ODSIJJfants
BLANDING, UTAH
°"TE: OCTOBER 2010
PROJECT flD SCQ349 3B
) ,/'
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--SS9o--
==---
L£GEND
EXISilNG (iffOUN D CONTOUR -MAJOR
DOSTING GROUND aJllOUR -IQIDR
PROPCSEtl SURF-.a: CONTOUR -MAJOR
PROPOSED 9JRF J.CE !XlNTOJR -MtlOR
UIIIT OF L!NER
Sl'I.ASH PAO
HOPE PIPEl.lNE SUJRRY OR SOULTION
SOWTIOH RETURN
SUMES DRAIN
0 200' 400'
L;;.-I !
SCALE IN F'EET
INTERIM FIWNG Pl.AN
CEl.L4B
Bl.ANDING, UfAH
48
011.-re: OCT0BER2010 l'lQ.IRE Geosyntece>
amsultaDt5 PROJECT NO. SC0349
1s• • SCHEDULE 40 PVC
--------~~--~
'\... 60 Ml!.. HOPE: GEOMEMBRANE (TEXlURED}
SECTION
LEAK DE IECTION SYSTEM SUMP
N..T.S.
LEAK OETECilON SYS'TEM
4" \'I SCHEDULE 40 PVC
/ / -4-" ; SCHEDULE 40 P\/C
/ .-1·
LEAK DETECTION sYSTcM SUMP
CELI.S4AAN04B
BLANDING. UTAH
Ceo~~t>I ::~n~.ocroe::: FICiLIRE
5
I I ~
11 11
i
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jl I
ii I
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I I
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I I I
I
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I ffl M!
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I i
PMPVOW~ 38.1 AC...fT. ·1
PLUS 15!L«J AC-FT FIIDM CEUS • 1
2. 3,AND 4A _J
TOTAL !..<17 •. 50 AC•FT _
CELL48
FREEBOARD UMJ'T
5594.64 FT. MSL
PMPVOLUMf, 36AC.ff.
PLUS 123.4 N;...fT AIOM
CB.l2 AND CB.L3
159.40 AC-flovetFLOWS TO
all.48
PW va.uME, 12S.4 AC.FT
OVERFI..OWS TO CELL4A
CEU2SPIU.WAY
[aEVS611.0
~ ~
NOTTO SCALE
HVORAUIJC PROFILE SCHBMl1C
caL48
BI.AND9,IG, UTAH
Geosyn.tec C>I ~ OCTOBER201D
aznmlllmls JIRO,IEC!" NQ. St::0349
PICIURE:
7
Geos~ntet: Consuftanr, Table 1A
Calcufated Action La•"-1• Rates for Var'°'3 Head Conditions
CeH 4A, White Mesa MIii
Blandfn1, Utah
Head Above Uner C.tcul•'-d Action LHlcap Rate
System (feet) (pllam/1CNJ/d1y)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.S
30 543.88
35 587.5
37 604.0
Geasyntec Consultar,ts Table 18
Calculated Action Leakage Rates far Various Head Conditions
Cell 48, White Mesa MIii
er,ndln1, Utah
Head Abave Uner Sptem Cllcul1ted Action Ltakqe Rita
{feet) (11Hons/acr1/dayJ
5 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
35 570,0
37 581.2
Appendix G
Stormwater Best Management Practices Plan,
Revision 2.1: April 2022
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
April 14, 2022
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
TABLE OF CONTENTS
Best Management Practices Plan
Revi.~ion 2.1; April 2022
1.0 INTRODUCTION/PURPOSE ................................................................................... , ....... 2
2.0 SCOPE ..... , .. , .............................................................................................................................. ~
3.0 RESPONSIBJ:I..,ITY .................... i .................... , •••••••• ,. ••••• ; •• , ........................... ; ........ , ................... 4
4.0 BEST MANAGEMENT PRACTICES .............................................................................. 5
4.1 General Management Practices Applicable to All Areas ....................................... 5
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: ........ 5
4.1.2 Keep Potential Pollutants from Contact with Precipitation ............................ 5
4.1.3 Keep Paved Areas from B~oming Pollutant Sources ..................................... 5
4.1.4 Inspection and Maintenance of Diversion l;>itch~ and Drainage Chan.nets
within the Process and Reagent Storage Area ................................. '., ............................ 5
4.1.5 Recycle Fluids Whenever Possible: ................................................................... , S
4.2 Management Practices for Process and Laboratory Areas .................... , .............. 5
4.2~1 Clean Up Spills Properly .................................................................................... 5
4.2.2 Protect Materials Stored Outdoors .......................................... ; ......................... 6
4.2.3 Ma-nagement .............. , ........ , ................ ~~············-···············,····················· .. ············· 6
4.2.4 Materials Management ....................................................................................... 6
4.3 Management Practices for Maintenance Activities ................................................ 6
4.3.1 Keep.a Clean Dry Shop ........................................................................................ 6
4.J·.2 Manage Vehicle Fluids., ..................................................... , ................. , .............. 6
4.3.3 Use Controls During Paint Removal., ......... ;., ................................................... 7
4.3.4 Use Controls During Paint Application and Cleanup ...................................... 7
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment ........ 7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas ................................... 7
4.4.2 Manage Stockpiles to Prevent Windborne Contamination ..................... ; ....... 7
4.4.3 Keep Earthmoving Activities from Becoming· Pollutant Sources ................... 8
Figures
Figure 1: White Mesa Mill Site Layout
Figure 2:· White Mesa Mill Site Drainage Basins
Figure 3: Energy Fuels Resources (USA) Inc.-White Mesa Mill Management Organization Charl
Tables
TABLB 1.0: Whit~ Mesa Mill Management Personnel Respcmsible for Impltirnenling This BMPP
TABLE 2.0: REAGENT YARD LIST
TABLE 3.0: LABORATORY CHEMlCAL INVENTORY LIST
TABLE 4.0: REAGENT YARD AND BULK CHEMICALS LIST
TABLE 5.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Pagel
1.0 INTRODUCTION/PURPOSE
Best Management Practices Plan
Revision 2.1: April 2022
Energy Fuels Resources (USA) Inc. ("EFRI") operates the White Mesa Uranium Mill (the "Mill")
in Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect
to water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surf ace runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit ("GWDP") No. UGW370004 to EFRI
on March 8, 2005. As a part of compliance with the Permit, EFRI is required to submit a
Stormwater Best Management Practices Plan ("BMPP") to the Director of the Division of Waste
Management and Radiation Control ("DWMRC"), Utah Department of Environmental Quality
("UDEQ"). This BMPP presents operational and management practices to minimize or prevent
spills of chemicals or hazardous materials, which could result in contaminated surface water
effluents potentially impacting surface waters or ground waters through runoff or discharge
connections to stormwater or surface water drainage routes. Although the Mill, by design, cannot
directly impact stormwater, surface water, or groundwater, the Mill implements these practices in
a good faith effort to minimize all sources of pollution at the site.
Page 2
2.0 SCOPE
Best Management Practices Plan
Revision 2.1: April 2022
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings management impoundments in accordance with the
Mill's Radioactive Materials License ("RML") #UT1900479 conditions. All of the process and
laboratory building sinks, sumps, and floor drains are tied to the transfer lines to the tailings
impoundments. A site map of the Mill is provided in Figure 1. A sketch of the site drainage
basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by RML to manage some spills via draining or wash down
to the process sewers, and ultimately the tailings management system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of stormwater, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
EFRI White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP"), and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs").
Page 3
3.0 RESPONSIBILITY
Best Management Practices Plan
Revision 2.1: April 2022
All Mill personnel are responsible for implementation of the practices in this BMPP. EFRI White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implemenuhe..practices-in.thisJ3MPP. .
The EFRI Corporate Management and Mill Management Organization is presented in Figure 3.
An updated spill prevention and control notification list is provided in Table I.
Page4
Best Management Practices Plan
Revision 2.1: April 2022
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in Tables 2
through 5.
4,1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers coveted when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials fo covered tanks or drums.
• Store jars, bottle, or similar smalJ containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and latge container covers closed when not in use (to keep precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sourees
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or lai lings area
as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Ar~a
• Diversion ditches, drainage channels and surface water control structures in and around the Mill
area will be inspected at least monthly in accordance with the regularly scheduled inspections
required by the GWDP, and the RML. Areas requiring maintenance or repair, such as excessive
vegetative growth, channel erosion or pooling of surl'ace water runoff, will be reported to site
management and maintenance departments for necessary action to repair damage or perform
reconstruction in order for the control feature to perform as intended. Status of maintenance or
rep&irs will be documented during follow up inspections and additional action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select tlUtomotive fluids. solvents, and cleaners that can be recycled or reclaimed
• When possjble, select consumable materials from suppliers who will reclaim empty containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for recycle or
transferred to the tailings management system for disposal.
4.2 Management Practices for Pl."ocess and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills With dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
Pages
Best Management Practices Plan
Revision 2.1: April 2022
• CJean spi I ls of stored reagents or other chemicals immediately after discovery.
• (GWDP, Section I.D.10.c.)
• Recove.r and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE") near the areas where they may be needed for spill response.
• If spills m1,1st be washed down, use the minimum amount of water needed for effective cleatmp.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums ~nd containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the out~ides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Managehlent
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities wiJI include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (GWDP, Section J.D.3.g.)
•
4.3 Manasement Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't' let minor spilis spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids. waste fluids, and baueries in an area with secondary containment (double drum,
drip pan) fo capture leakage and contain spills.
4.3.2 M~age Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
dtip pans or plastic tarps to prevent spillage ·and spread of fluids.
Page~
Best Management Practices Plan
Revision 2.1: April 2022
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tai1ings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings management system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing ( oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings management system.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and decontamination pads).
• At the decontamination pads, make sure the water collection and recycJing system is working
before turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep surfaces moist but minimize runoff water.
Page 7
4.4.3 Keep Earthmo\'111,g Aetivitle$ ·rrom Becoming Pollutant Sources
Best Managem~nt Practices PlaJ\
kevi&lon 2J: Aprll 2022
• Sch¢dule excavation, grading, an~ other ~moving activ1tie!! when extreme dryness and high
winds will not be a factor (to prevent the need for-excessive dust suppression}.
• Remove existing vegetation only when al;,solurely necessaey.
• Se(d or plant temporary vege.tatfon for erosion cQntrol on slQpes,
p.age8
TABU£S
TABLEt.O
RESPONSIBILITIES
" · ifljrs-Jffi~tehai:gc·or facUUy:t es· = 1e,to~ention: ·--:-_:
Logan Shumway
6425 South Highway 191
Blanding, 1JT84511
[phone] (work)
[phone] (home)
-Person in·cfiarge of follow-up spill reporting: -
Garrin Palmer
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
,, QU~
2
2
3
1
I
I
1
1
2
I
1
I
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1
1
1
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l
2
TABLE2.0
REAGENT TANK LIST
RB'.AGE,NT
AMMONIUM SULFATE
DIESEL
KEROSENE
USED/WASTE OIL
DIESEL
UNLEADED
PROPANE
LNG
AMMONIA
WEST SALT
SALT DCLUTION
SODIUM HYDROXIDE
SODA ASH SOLUTION
SODA ASH SHIFr
SODA ASH SILO
SODIUM CHLORATE
SODIUM CHLORATE
SODIUM CHLORATE
SULFURIC ACID
SULFURIC ACID
HYDROCHLORIC ACID
CAPACITYtOAL} "
24,366
250
10,152
5,000
6,000
3,000
30,000
30,000
31,409
17,635
9,451
19,904
16,921
8,530
22;841
16,075
21,057
28,788
1,600,000
1 J,000
13,650
TAHL~:.i.U
LABORATORY CHEMICAL INVENTORY L1ST1
'
Chemical in. Lah I l(Qz Typical Quantity ln:Stock· 1 I
'-JI
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 Lor 571 gal.) lOL
Aluminum nitrate 5,000 lb (2,270 kg) 20kg
Ammonium carbonate 5,000 lb (2,270 kg) 2kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4L
Calcium acetate None l kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5L
Ferric chloride 1,000 lb (454 kg) 2kg
Ferric nitrate 1,000 lb ( 454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) IL
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lh (4.54 kg) 1 lb
Potassium Permanganate 0. IN 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate I lb (0.454 kg) 2.6 kg
Sodium hydrosulfidc 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 kg) l k~
Cherg.ical in Volatiles and
Flammabl~ Lockers (A,8,C} II RQ2,3 Typical Quantity in Stock
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) IL
For ma ldeh yde JOO lb (45.4 kg) (approx. 41.7 L) IL
Nitroben1..ene 1,000 lb (454 kg) (approx. 377 L) 12L
Tri ch lo roe thy Jene 100 lb (45.4 kg) (approx. 31.1 L) 2L
Toluene 1,000 Jb (454 kg) (approx. 523 L) 12L
Chemical' in Outside Acid, -
RQ2,,3 Typical Quantity·in Stock Conu --II
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 Lor 501 gal.) 22L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 L
I. This list identifies chemicals :,vhich arc rcgulmcd as hazardous substances under the federal Water Pollution Control Act 40 CFR Pait I 17.
The lab also stores small quantities of other materials that arc not hazardous substances per the above regulation.
2. Reportable Quantities arc those identified in 40 CPR Part 117 Table 117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant lo Section 311 of the Clean Water Act."
3. Eslinmtion of Reportable Quantities in L assumes pure compound ( 100%) concentration, unless otherwise specified.
TABLE4.0
REAGENT YARD AND BULK Clll!:MlCALS LIST1
-·Ty.P,f~l Quantity In .Reageilt RQ1 -Stock
Sulfuric add 93 LO 98% I ,000 lb (454 kg) (approx. 247 L) 4,000,000 lb
Ammonia -East Tank l 00 lb (45.4 k.1t) 50,000 lb
Ammonia-West Tank JOO lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 ~al
Salt (Bags) None 40,000 lh
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bu_g) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel JOO gal• 3,000 gal
Gasoline 100 gal* 1,500 gal
Tcrliary Amine None 30,000 lb
Sall (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 1,000,000 lb
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alaminc 335 Bulk None O lbs
Alamine 310 Bulk None 0 lbs
lsodecanol None 0 lbs
Vanadium Pentoxide'.\ 1.000 lb (454 kg) 50,000 lb
Ycllowcake3 None 200,000 lb
Liquid Natural Gas l 0,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcphol Non\! 20,000 lb
Flocculant 655 None 40.000 lb
Flocculant314 None 4,000 lb
Propane None ]6,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth filter Aid None 30,000 lb
DEHPA None 2,000 lb
Organic Phosphinic/Phosphoric Acid None 5000 gal
Barium Chloride None 15,000 lb
Hydrochloric Acid 5,000 lbs (2,270 kg) (approx.. 1,894 25,000 gal Lor 501 gal.)
Rare Earth Carbonates1 None 200,000 lb.
1. This list identifies the bulk chemicals al rhe Mill and the chemi~Js in the reagent yard whether or
not lhey are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR
Part 117.
2. Reportable Quantities arc those identified in 40 CFR Part l 17 Table l 17.3; "Reportahle Quantitb
of Hazardous Substances Designated Pursuant to Section 31 l of the Clean Waler Act."
3. The Mill's product,; are not stored in the Reagent Yard itself, but arc present in containers in lhe
Mill Buildings and/or Mill Yard.
* These materials do not have an RQ under 40 CFR I I 0, 40 CFR 117, 40 CFR 302 or Utah regulations.
These values are used by the Mill for conservatism as Best Management Practices.
TABLE S.O
PETROLEUM PRODUCTS AND SOLVENTS L1ST1
i Reagent RQz,3,4 Typical Quantity In Stock, 1, i
Lubricating Oils in 55 gallon drums JOO gal* J ,000 gallons
Transmission Oils JOO gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 5001bs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg) 50 gallons (approx. 13.9 gal)
Acetone 5,000 lb (2,270 kg) 55 gallons (362 lbs) (approx. 759 gal)
Methyl Ethyl Ketone 5,000 lb (2,270 kg) 55 gaJlons (369 lbs) (approx. 745 gal)
Toluene 1000 lbs (454 kg) 0 gallons (approx. 138 gal)
Varsol Solvent (2% trimethyl 100 gal* 0 gallons benzene in petroleum distillates)
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None. 20 gallons
Oil Base paints None 25 ga11ons
Paint thinners None 40 gallons
Other paints None 20 gallons
l. This list includes all solvents and petroleum-based products in the Mill warehouse
2. Reportable Quantilies are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound ( 100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGlJIUc:S
5620
HCL TANKS
~
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SCALE IN FEET
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
818: Utah
Figure 1
MILL SITE LAYOUT
1"=200' ie: May 12. 2000
Mill Site u,yout 1 5 22 dwg Rgure 11
,-I
CELL4B
DRAINAGE BASIN ·F"
44.67 AC.
PMF CONTAINED
WITHIN BASIN
~ / (
--'--'-
-4-
' 1000 0 1000 2000
.. \J
+
\\
'~
~___...,
+ ·~ ~ .
CELL4A
DRAINAGE BASI
42.14 AC.
.,-·--,
~
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
n eF
6111/08 BM
1219Al8 DI.$
tll/09 BM
11115/11 GM
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
Lakewood, CO 80228
White Mesa Mill
te: UT
MILL SITE
DRAINAGE BASINS
FIGURE 2
5/29119 I SH I Au1hcr. HRR OIIO: 2005 IOtalledlly.
,_
Harold Roberts
Consultant
AF/AUM Project
Management
ENERGYFUEl.S
Supervisor, Corp
Safety& NAZ
Standby cs Hancock)
-
Mgr. Technical
Services
(D Kapostasy)
New position ,_
-
Director ISR
Operations
(B Bonifas)
TX Operations
Director
(P Luthiger)
Director, Geology
&Land
/BfLtNI I Al"!:An\
..__
-
Figure 3
President/CEO
(M Chalmers)
u,reaor
Conventional
Operations
11 Sl'lumwav}
Asset Mgr.
Colorado Plateau -
(R Fisher)
Mine Geologist
Canyon Mine
(M Germansen)
VPHR &
Administration
(D Nazarenus)
ITMgr.
(L Graham)
VP Marketing &
Corp. Development
(C Moore)
I
VP Regulatory Attain
(S Bakken)
I
ISR Permitting Mgr.
.--(0 Kolkman)
Quality Assurance
~ Mgr.
(KV\leinel)
Sr. V.P. General Co111seV
Corp. Seaetary/CFO
(D Frydenlund)
Staff Attorney
(J Hoffmeier)
I
Controner
(S Luksch)
I
Assistant Conlroller ~ NewPosition
-Tax Mgr.
(KBeck PT)
Appendix H
White Mesa Mill Discharge Minimization Technology (DMT) Monitoring Plan, 1/2022,
Revision: EFRI 13.0
WHITE MESA MILL DISCHARGE
MINJMJZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 13.0
January 2022
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
WHITE MESA MILL
01/22 Revision: EFRT 13.0
Page2 of26
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. .IN'TRODUCTION ......... , ....................................... , ............................................................ , .... 3
1.1. Background ..... , ..........•......•. , ....•.... , ..................................................................................... , 3
2~ DAaY TAILINGS IN'SPECTIONS .......................................................... , .............................. 4
2. l. Daily lllspection ...................................................... "' ............................................................. 4
3. WEEKLYTAil.,JNGS AND DMT INSPECTION ................................................................. 5
3.1. Weekly Tailings Inspections ............................................................................................ 5
Northing ................................ , ......................................................... _ ............................................. 9
Easting .. , ...................................... ,..,. ..... , ............. J, ••••••••••••• ., •••••••••••••••••••••••••••••••••••••• •• •••• •• ··········~·· •• 9
3.2. Weekly Feedstock Storage Area fuspections ................................................................. 11
4. ANNUAL EVALUATIONS ...... , ........................................................................................... 12
4.1. Annual Leak Detection Fluid Samples ........................................................................... 12
4.2. Annual Inspection of the Decontamination Pads ........................................................... 12
4.3, Annual Inspection of Waste Oil and Fuel Tanks ., ......................................................... 13
4.4. Annual Inspection of Hydrochloric Acid ("HCI") Secondary Containment Concrete ... 13
5, INSPECTION OF THE AMMONIUM SULFATE COVER AREA ................................... 13
6. OTHER INSPECTIONS ........................................................................................................ 14
7. REPORTING REQUIR.EMENTS ........................................................................................ 14
7.1, DMT Re.ports ..... , ............ " ........................................................................................ , .... ,. ...... 14
Attachment A
Attachment B
Attachment C
ATTACHMENTS
Forms
Feedstock Storage Area Map
Tables
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
1. INTRODUCTION
01/22 Revision: EFRI 13.0
Page 3 of26
This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, 1.E and I.F of 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 19004 79 ( the "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 of the 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 the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill's Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill's Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells l, 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 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.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 4 of 26
This division of the requirements was discussed with DRC on October 26,201 l. DRC agreed with
the division of the 1'equirements into two distinct. documents as. noted in their correspondence dated
December 20, 201 l. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells l, 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 l, 2, and 3 and to
address anticipated GWDP modifications regarding the LOS 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. The
inspector will place a check by all inspection items that appear to be operatingproper1y. 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 bas been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Managernent System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells l, 2, 3, (as
required by the RML) and CeHs 4A, and 4B (as required by the GWDP) are
recorded. For simpJicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included ai; Attachment
A-1 to this DMT Plan regardless of the 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. lq).
The solution level in Cell 4A or 4B leak detection system is not allowed Lo be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML eleva.tion is 5555.14 amsl and with the ~ddition 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
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 5 of 26
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 of the GWDP 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 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 the 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.
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. 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 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 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.
For Cells 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.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 6 of26
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LOS, a fluid
sample shall be collected and analyzed in accordance with paragraph l l .3C of the
RML as described in the 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, 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 LOS 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 Table lA and lB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LOS 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 closed and Phase
1 cover activities have commenced. Each cell has a slimes drain system which aids
in de watering the slimes and sands placed in the cel1;
(ii) EFRI re-graded the interim fill on Cell 2 in 2011 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the 2011 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 was 6.97 feet in length and the measuring point was 37 .97 feet from
the bottom of the slimes drain. This value was used in all calculations from 4th
quarter 2011 through the 3rd quarter 2016. In April 2016, Phase 1 cover placement
and construction commenced. The Phase 1 cover activities include the placement
and compaction of approximately 4.5 feet of soil materials. During the 3rd quarter
2016, the slimes drain access pipe was extended 5.44 feet as a result of the Phase 1
cover activities. The measuring point on the extension pipe was surveyed by a Utah-
Certified Land Surveyor. The measuring point elevation is now 5624.17 fmsl. For the
quarterly recovery test described in section vi below, this extension has no effect on
the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
43.41 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe .. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 44.31 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
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
. Page 7 of26
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5624.17 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 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:
5624.17 -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 the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii)In accordance with GWDP Part I.F.11 an Annual Slimes Drain Recovery Head
Report will be submitted with the annual DMT report for fourth quarter. The Annual
Slimes Drain Recovery Head Report will be submitted on or before of March 1 of
each year. The report will conform to Part I.D.3, I.E.7 and Il.G of the GWDP;
(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 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 1, 4A, and 4B 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 are first observed, as follows:
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 8 of26
(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 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. The 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 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 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, Cell 4A, or Cell 4B, or
the area of the 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 the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
I. Cell 4A
The Assistant will walk down the slope in the northeast comer of Cell 4A and
place the Survey Rod at the liquid level.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 9 of26
B.
II. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
ill. Cell l
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
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are:
Northinll Eastinll
Cell 1 322,196 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;
Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the 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
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;
(i) 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;
(ii) 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
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page IO of26
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, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.01 feet.
d) 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
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 Weeldy 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 RSO.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 11 of 26
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.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill's maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
3.2. Weekly Feedstock Storage Area fnspections
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 Attachment B;
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 of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
White Mesa Mill -Discharge M,nimizarion Technology Monitoring Plan
water tight containers.
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Page 12 of26
The results of this inspection wi11 be recorded on the Ore Storage/Sample Pla,tt Weekly Inspection
Repon, a copy of which is contained in Attachment 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. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Annual Leak Detection. Fluid Samples
Pursuant to Part J.E. JO(c) of the GWDP, a sample will be collected from the Cells 4A and 48 leak
detection systems annually as part of the Tailings Ce JI Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis PJan.
4.2. Annual In pection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of ~ervicc
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
the use of the facility. All in$pection findings and any repairs required shalJ be documented on the
Annual Decontamination Pad Inspection form. The inspection findings. any repairs required and
repaiJ;S completed shall be summarized in the 2nd Quarter DMT Monitoring Rep01:t due Sept~mber 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarte.r 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 aad bottom of the tank will be visually
inspected for arty areas of damage, cracks, or bubbling indicating corrosion that. may have occurred
since the last inspection. If any abnormalities arc identified, defects or damage wm be reported to
Mi11 management and repairs wiJl 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 fonn. 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 l of each calendar year.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
4.3. Annual Inspection of Waste Oil and Fuel Tanks
01/22 Revision: EFRI 13.0
Page 13 of 26
During the second quarter of each year, the used/waste oil tank and fuel tanks will be inspected to
ensure the integrity of the tanks and support structures. The tanks and any associated piping will be
visually inspected for signs of corrosion or leaking. Any concrete structures, containments and
supports will be inspected to ensure the integrity of the 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 surface, repairs will be made within 7 days. All
inspection findings and any repairs required shall be documented on the Annual Inspection form.
The documentation of the inspection findings, any repairs required and repairs completed will be
maintained at the Mill.
4.4. Annual Inspection of Hydrochloric Acid ("HCJ ') Secondary Containment Concrete
During the second quarter of each year, the HCl secondary containment concrete will be inspected.
Any associated piping will be visually inspected for signs of corrosion or leaking. Any concrete
structures, containments and supports will be inspected to ensure the integrity of the 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 surface, repairs will be made
within 7 days. All inspection findings and any repairs required shall be documented on the Annual
fuspection form included as Attachment A-7. The documentation of the inspection findings, any
repairs required and repairs completed will be maintained at the Mill.
S. INSPECTION OF THE AMMONIUM SULFATE COVER AREA
After installation and approval of the 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 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.
The 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 of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area 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. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
While Mesa Mill -Discharge Minimization Technology Monitoring Plan
6. OTHER INSPECTIONS
01/22 Revision: EFRJ 13.0
Page 14of26
AU daily, weekly. monthly. quarterly and annual inspections and evaluations should be performed as
specifi~d in this DMT Plan. See also the Tailings Management System procedure included in Lhe
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 in this DMT Plan, the following additional reporti, 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 of the GWDP:
a) On a quarterly basis, all required jnfonnation required by Part I .F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3. t (b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Blevation Monitoring), 3. l(d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
including any repairs required, and repairs completed]);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarler for the presence of fluid in all three v~rtij:~ inspection port~s 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 ittspection of the New Decontamination Pad descrjbed
in Section 4.3(a); the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September I of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b ), the inspection findings, any repairs required. and
repair$ completed shall be summarized in the 2nd Quarter report, due September I
of each calendar year;
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Page 15 of 26
e) With respect to the annual inspection (after the completion of 8 quarterly
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, 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
f) 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.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A
FORMS
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Page 17 of26
ATTACHMENT A-1
DAILY INSPECTION DATA
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
Inspector: ______ _
Date:. ________ _
Accompanied by: ___ _
Time:. ________ _
Cell 4A Cell 4B
Leak Checked Checked Checked Checked Checked
Detection
System Wet Dry Wet Dry Wet Dry Wet Dry Wet
Checked
Initial level Initial level Initial level Initial level Initial level
Final Final Final Final Final
level level level level leve·1
Gal. pumrv>.rl Gal. pumnP.rl Gal. pump£>.rl Gal. pumned Gal. pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-1)
Dry
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Page 18 of26
1. Pond and Beach
elevations (msl, ft)
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Inspectors:-------------
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation 5597 __ _
(c) Depth of Water above FML ((a)-(b)) _____ _
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b)) ------
Cell 4B: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) _____ _
( d)Elevation of Beach Area with Highest Elevation
(monthly)
2. Leak Detection Systems
Observation:
New Decon Pad, Portal 1 New Decon Pad, Po11al 2 New Decon Pad Portal 3
Is LDS (Portal) wet or __ wet __ dry __ wet __ dry __ wet __ dry
dry?
If wet, Record liquid Ft to Liquid Ft to Liquid Ft to Liquid
level:
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 ams) for Cell 4A and 5558.50 for Cell 4B)? no __ yes
If 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):--------------------
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-3
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Page 19 of26
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:
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 there any alternate feed materials stored outside the ore storage pad?
yes: ___ no:. __ _
If yes, are the alternate feedstock materials located outside the ore storage pad maintained within water-
tight containers:
yes: ___ no: __ _
comments (e.g., conditions of containe.rs): ______________________ _
Are an 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: __________________________________ _
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes: No: __ _
01/22 Revision: EFRI 13.0
Page 20 of26
Comments: __________________________________ _
Is there any evidence of breakage, spillage or leakage?
Yes: No: __ _
Comments: __________________________________ _
Other comments:
Ore Pad Southwest Stormwater Containment {Kiva):
Is there sediment or debris in the bottom of the Kiva?
Yes: No: __ _
Comments: __________________________________ _
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva deaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva deaned out.
Yes: No: __ _
Comments: __________________________________ _
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-4
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Page 21 of26
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 of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2"d Quarter report, due September
1 of each calendar year.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-5
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Page 22 of26
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection: ____ _
Ammonium Su]fate 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 Su]fate Aspha]t 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 the 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, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2"d Quarter report, due September 1 of each calendar year.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENTA-6
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Page 23 of26
ANNUAL USED/WASTE OIL AND FUEL TANK INSPECTION
Date of Inspection: ___ _
Are there any anomalies on tanks including dents or rusty areas?
_Yes_No
Comments: _________________________________ _
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints: _____________________________ _
Pipeline Supports: _____________________________ +
Valves: ________________________________ _
Point(s) of Discharge: ___________________________ _
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
_Yes_No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
__ Yes __ No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable): ______ _
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENTA-7
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Page 24 of26
ANNUAL HCI SECONDARY CONTAINMENT CONCRETE INSPECTION
Date of Inspection: ___ _
Are there any anomalies on tanks?
_Yes_No
Comments: _________________________________ _
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints: _____________________________ _
Pipeline Supports: _____________________________ +
Valves: ________________________________ _
Point(s) of Discharge: ___________________________ _
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
_Yes_No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
__ Yes __ No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable): ______ _
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT B
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I
UTAH
*
ENERGY FUELS RESOURCES (USA), INC.
WHITE MESA MILL
San Juan County, Utah
Feedstock Storage Area Map
c:::J Feedstock Storage Area
Date: January 2022
Source: Energy Fuels, 2022
--·--~··-··· ,,.,u..,,3,11,,
N
A
0 50 100 200
Feet
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 01/22 ~evision: EFRI 13.0
Page 26 of26
FEEDSTOCK STORAGE AREA
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) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day )
Table 18
Calculated Action leakage Rates
fqr 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 leak.age 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
Appendix I
White Mesa Mill Tailings Management System, 3/2017, Revision: EFR 2.5
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
Revision 2.5
March 2017
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 2 of 37
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
TABLE OF CONTENTS
1. IN"TRODUCTION ................................................................................................................... 3
1.1. Background ....................................................................................................................... 3
2. DAII..,Y TAIIJNGS IN"SPECTIONS ........................................................................................ 4
2.1. Daily Comprehensive Tailings Inspection ....................................................................... .4
2.2. Daily Operations Inspection .............................................................................................. ?
2.3. Daily Operations Patrol ..................................................................................................... ?
2.4. Training .............................................................................. : .............................................. ?
2.5. Tailings Emergencies ........................................................................................................ 7
3. WEEKLY TAILINGS AND DMT IN"SPECTION .................................................................. 8
3.1. Weekly Tailings Inspections ............................................................................................. 8
4. MONTfil Y TAILINGS INSPECTION ................................................................................ 11
5. QUARTERLYTAILIN"GS INSPECTION ............................................................................ 12
6. ANNUALEVALUATIONS .................................................................................................. 13
6.1. Annual Technical Evaluation .......................................................................................... 13
6.2. Movement Monitors ........................................................................................................ 14
6.3. Freeboard Limits ............................................................................................................. 15
6.3.1. Cell l ........................................................................................................................ 15
6.3.2. Cell 2 ........................................................................................................................ 15
6.3.3. Cell 3 ........................................................................................................................ 16
6.3.4. Cell 4A ..................................................................................................................... 16
6.3.5. Cell 4B ..................................................................................................................... 16
7. OTHER IN"SPECTIONS ........................................................................................................ 19
8. REPORTING REQUIREMENTS ......................................................................................... 19
8.1. Monthly Tailings Reports ............................................................................................... 19
8.2. Weekly Cell 1 and Cell 4B Photographs ......................................................................... 19
Appendix A
AppendixB
Appendix C
AppendixD
APPENDICES
Forms
Tailings Inspector Training
Certification Form
Example Freeboard Calculations for Cell 4B
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. INTRODUCTION
03/17 Revision: EFR 2.5
Page 3 of37
This Tailings Management System procedure for the White Mesa Mill (the "Mill") provides
procedures for monitoring the tailings cell systems as required under State of Utah Radioactive
Materials License No. UT1900479 (the "RML"). The procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
Mill's Groundwater Discharge Permit ("GWDP") Number 370004, are presented in the DMT
Monitoring Plan ("DMT Plan"), which is a separate Plan ..
This Tailings Management System procedure and the DMT Plan when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, and inspection of the feedstock storage areas at the Mill.
This Tailings Management System is published and maintained in the Mill's Environmental
Protection Manual while the DMT Plan is issued as a stand-alone document.
1.1. Background
This Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill's
Environmental Protection Manual, under the Mill's NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill's Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that Energy Fuels Resources (USA) Inc. ("EFRI")
develop the initial DMT Plan in response to GWDP requirements. In developing the initial DMT
Plan, EFRI combined the existing Tailings Management System procedure set out as Chapter 3.1 of
the Mill's Environmental Protection Manual with a number of new DMT requirements from the
GWDP to form the initial DMT Plan. The initial DMT Plan and subsequent revisions (through
revision 11.5) maintained the requirements from the RML (i.e., Chapter 3 .1 of the Mill's
Environmental Protection Manual) and the DMT requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. The DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the DMT Plan that flow from the RML and
not from the GWDP have been separated from the DMT Plan and have been returned to their
original status as this Tailings Management System procedure, which comprises Chapter 3.1 of the
Mill's Environmental Protection Manual. This allows the DMT Plan to be managed, inspected and
enforced under the requirements of the GWDP and this Tailings Management System procedure to
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be managed, inspected and enforced under the requirements of the RML.
In addition, EFRI has incorporated in this plan the requirements for operating mill tailings specified
by the Environmental Protection Agency ("EPA") in 40 CFR Part 61, Revisions to National
Emissions Standards for Radon Emissions From Operating Mill Tailings.
This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") have been
included in this DMT Plan. The inclusion of this RML requirement is to address the DRC request
for uniformity in monitoring and reporting requirements for Cells 1, 2, and 3 and to address
anticipated GWDP modifications regarding the LOS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the evaporation cells (Cell 1 and Cell
4B) and the tailings cells (Cells 2, 3, 4A,) will be inspected. Observations will be made of the
current condition of each cell, noting any corrective action that needs to be taken.
The Radiation Safety Officer ("RSO") or his designee is responsible for performing the daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform the daily tailings inspection.
Observations made as required by this Tailings Management System by the inspector will be
recorded on the Daily Inspection Data form (a copy of which is included in Appendix A to this
Tailings Management System procedure). The daily leak detection check for Cells 1, 2, and 3 will be
recorded on the Daily Inspection Data form included as Attachment A-1 of the DMT Plan. The
Daily Inspection Data form included with this Tailings Management System procedure contains an
inspection checklist, which includes a tailings cells map, and spaces to record observations,
especially those of immediate concern and those requiring corrective action. The inspector will place
a check by all inspection items that appear to be operating properly. Those items where conditions
of potential concern are observed should be marked with an "X". A note should accompany the "X"
specifying what the concern is and what corrective measures will resolve the problem. This
observation of concern should be noted on the form until the problem has been remedied. The date
that corrective action was taken should be noted as well. Additional inspection items are required
under the DMT Plan, which requires that the daily inspection form requirements in Attachment A to
the DMT Plan also be completed.
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Areas to be inspected include the following: Cell 1, 2, 3, 4A and 4B, the liners of Cells 1, 2, and 3,
Dikes 4A-S, 4A-E, and 4B-S, wind movement of tailings, effectiveness of dust minimization
methods, spray evaporation, Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A and
4B liquid pools and associated liquid return equipment, and the Cell 1, 2, and 3 leak detection
systems.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell
4A or Cell 4B; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
b) Cell 1.
c) Cell 2.
d) Cell 3.
e) Cell 4A.
f) Cell 4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S.
h) The Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A and Cell
4B liquid pools and associated liquid return equipment.
i) Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
j) Spray evaporation pumps and lines.
k) Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
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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 of the dust control/spray evaporation
system(s).
m) Observations of any abnormal variations in tailings pond elevations in Cells I, 3,
4A, and4B.
n) Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
o) An estimate of flow for active tailings slurry and SX line(s).
p) An estimate of flow in the solution return line(s).
q) Daily measurements in the leak detection system sumps of the tailings Cells I, 2,
and 3 will be made when warranted by changes in the solution level of the
respective leak detection system. Measurement of fluids in the Cells 4A and 4B
leak detection system and recording of the daily measurements cif the Cells 1, 2,
and 3 leak detection systems sumps are discussed in the DMT Plan.
The trigger for further action when evaluating the measurements in the Cells 1, 2,
and 3 leak detection systems is a gain of more than 12 inches in 24 hours. If
observations of trigger levels of fluids are made, the Mill Manager should be
notified immediately and the leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter and
totalizer is recording on Cells 1, 2, and 3, a notation of the date and the time will
be recorded on the Daily Inspection Data form. This data will be used in
accordance with License Condition 11.3 .B through 11.3 .E of the Mill's
Radioactive Materials License, to determine whether or not the flow rate into the
leak detection system is in excess of the License Conditions.
ff an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed following notification to the Director.
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r) Observations regarding visible sediments (Celll and Cell 4B only).
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the RSO and/or Mill
management in the event that during their inspection they discover that an abnormal condition or
tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
Inspectors will notify the RSO and/or Mill management immediately if, during their inspection, they
discover that an abnormal condition exists or an event has occurred that could cause a tailings
emergency. Until relieved by the Environmental or Technician or RSO, inspectors will have the
authority to direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the RSO, one of whom will notify Corporate Management. If
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dam failure occurs, notify your supervisor and the Mill Manager immediately. The Mill Manager
will then notify Corporate Management, MSHA (303-231-5465), and the State of Utah, Division of
Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3 .1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly (as well as
daily) to determine whether it is wet or dry. If marked wet, the liquid levels need
to be measured and reported. In Cell 1, 2, and Cell 3 the leak detection system is
measured by use of a dual-probe system that senses the presence of solutions in
the LDS system ( comparable to the systems in Cells 4A and 4B) and indicates the
presence of solution with a warning light. The water levels are measured to the
nearest 0.10 inch. The water level data in Cells 1, 2, and 3 is recorded on the
Daily Tailings Inspection Form included as Attachment A-1 of the DMT Plan.
If sufficient fluid is present in the leak detection system of Cells 1, 2, and 3, the
fluid shall be pumped from the LDS, to the extent reasonably possible, and the
volume of fluid recovered will be recorded. Any fluid pumped from an LDS
shall be returned to a disposal cell.
For Cells 1, 2, and 3, if fluid is pumped from an LDS, the flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed time
since fluid was last pumped or increases in the LDS fluid levels were recorded,
whichever is the more recent. This calculation shall be documented as part of the
weekly inspection.
For Cells 1 and 3, upon the initial pumping of fluid from an LDS, a fluid sample
shall be collected and analyzed in accordance with paragraph 11.3 C. of the
RML. The LDS requirements for Cells 4A and 4B are discussed in the DMT
Plan.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
t. '
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system which aids in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of storm water on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37 .97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37 .97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. The extension of the Cell 2 slimes drain access pipe did
not require any changes to the measurement procedure. The surveyed measuring
point on the extended pipe is used as required. The elevation of the measuring point
is 5618.73 fmsl. The head measurements are calculated in the same manner, using
the same procedures as those used prior to the extension of the Cell 2 slimes drain
access pipe; however, the total depth to the bottom of the pipe is now 37.97 feet as
noted on the corrected form in Attachment A. All head measurements must be made
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from the same measuring point ( the notch at the north side of the access pipe 5618. 73
fmsl), and made to the nearest 0.01 foot. The results will be recorded as depth-in-
pipe measurements on the Weekly Tailings Inspection Form. The quarterly recovery
test specified in the GWDP is discussed in the DMT Plan. It is important to note that
the extension of the Cell 2 slimes access pipe has not changed the method of
calculation of the pre-and post-pump head calculations, only the constant (Cell 2
slimes drain access pipe height) used in the calculation has changed. The head is
calculated by subtracting the depth to liquid from 37.97 feet rather than from the
previous measurement of 38 feet. The weekly Tailings Inspection form included in
Attachment A has been changed to reflect the extension height;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains
are kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B
slimes drains are inspected and the results reported in accordance with the
requirements of the permit.
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) 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. Weekly and annual inspection requirements for the
New Decontamination Pad are discussed in the DMT Plan.
(ii) Existing Decontaminaiion Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill's maintenance shop and the ore feeding grizzly.
A The Existing Decontamination Pad will be inspected on a weekly basis.
Any soil and debris will be removed from the Existing Decontamination
Pad immediately prior to inspection of the concrete wash pad for
cracking Observations will be made of the current condition of the
Existing Decontamination Pad, including the concrete integrity of the
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exposed surfaces of the pad. Any abnormalities relating to the pad and
any damage or cracks on the concrete wash surface of the pad will be
noted on the Weekly Tailings Inspection form. If there are any cracks
greater than 1/8 inch separation (width), the RSO must be contacted.
The RSO will have the responsibility to cease activities and have the
cracks repaired.
e) Weekly Photographs for EPA Subpart W
Weekly photographs of Cells 1 and Cell 4B documenting observations regarding
sediments present and proof of saturation as necessary. Digital photographs will
be taken and will have at a minimum date and time electronically embedded.
Notations regarding the completion of the photographic documentation will be
made on the Weekly Tailings and DMT Inspection form in Attachment A.
f) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings Inspection form is provided in Appendix A of this
Tailings Management System procedure. A similar form containing DMT inspection requirements is
provided as Attachment A of the DMT Plan.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the RSO or his designee from the Radiation Safety
Department and recorded on the Monthly Inspection Data form, an example of which is contained in
Appendix A. Monthly inspections are to be performed no sooner than 14 days since the last monthly
tailings inspection and can be conducted concurrently with the quarterly tailings inspection when
applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be visually inspected at key
locations to determine pipe wear. The critical points of the pipe include bends, slope
changes, valves, and junctions, which are critical to dike stability. These locations to
be monitored will be determined by the Radiation Safety Officer or his designee from
the Radiation Safety Department during the Mill run.
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Book 11: Environmental Protection Manual, Section 3.1
b) Diversion Ditches
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Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
d) Overspray Dust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results attached to the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the RSO or his designee from the Radiation Safety
Department, having the training specified in Section 2.4 above, once per calendar quarter. A
quarterly inspection should be performed no sooner than 45 days since the previous quarterly
inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
( White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
a) Embankment Inspection
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The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.
d) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
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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.
fu 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 detennine if any freeboard limits are being approached.
Records will also be reviewed to summarize observations of potential concern. The evaluation also
involves discussion with the Environmental and/or Radiation Technician and the RSO regarding
activities around the tailings area for the past year. During the annual inspection, photographs of the
tailings area will be taken. The training of individuals will be reviewed as a part of the Annual
Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Director and to the Assistant State Engineer, Utah Division of Water Rights at the address specified
below.
Assistant State Engineer
Utah Division of Water Rights
1594 West North Temple, Suite 220
P.O. Box 146300
Salt Lake City, Utah 84114-6300
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 4A-
E, 4A-S, and 4B-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
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Book 11: Environmental Protection Manual, Section 3.1
6.3. Freeboard Limits
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The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of 0.77 feet.
The flood volume from the PMP event over the Cell 4B area has been calculated to be 38.1 acre-
feet of water ( 40 acres, plus the adjacent drainage area of 5. 72 acres), times the PMP of 10
inches, with a wave run up factor of 0.77 feet.
The total pool surface area in Cell 1 is 52.9 acres, in Cell 4A is 40 acres, and in Cell 4B is 40
acres. The top of the flexible membrane liner ("FML") for Cell 1 is 5,618.2 FMSL, for Cell 4A
is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.
Based on the foregoing, the free board 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 5,6.15.4 FMSL. Under Radioactive
Materials License condition 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2.
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).
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The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future
tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell 4A will be attributed to Ce114B. A spillway has been added to Cell 4A to allow overflow into
Cell 4B.
6.3.5. Cell 4B
The. freeboard limit for Cell 4B will be set assuming that the total PMP volume for Cells 2, 3, 4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell 4B is as follows:
( a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell 4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Cell 4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres
Wave run up factor
Total required freeboard
38.1 acre-feet
159.4 acre-feet
197 .5 acre-feet
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 of the beach area in Cell 4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
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(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 Cell 4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("80*"), will be determined;
iii) 80* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4B will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell 4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directly proportional to the reduction in the available space in Cell 4B
for solids. That is, the reduced pool surface area for period t=O ("RP Ao"), after the
reduction, will be calculated to be:
(1 -(80* x 1.5) / (2,094,000 -To)) x 40 acres= RPAo
vii) The required freeboard for Cell 4B 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 Cell 4B for
the remainder of period t=O would then be the elevation of the FML for Cell 4B of
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulting free board 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 (ARP At-I)
to reflect actual tonnages deposited in Cell 4B 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-I is merely the RPA that would have
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 18 of37
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
ARP At-t can be calculated using the following formula:
(1 -~t-1 I (2,094,000 -Tt-t)) x ARPAt-2 = ARPAt-t
Where:
• ~t-1 is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;
• Tt-1 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-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 -(~t* x 1.5) / (2,094,000 -Tt)) x ARPAt-t = RPAt
Where:
• ~t* is the expected number of dry tons of tailings to be deposited into Cell 4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Ti is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t; and
• ARPA1-1 is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-1) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for period t can be calculated in feet to be the wave run up
factor for Cell 4B of 0. 77 feet plus the quotient of 197.5 acre feet divided by the RP At.
The freeboard limit for Cell 4B for period t would then be the elevation of the FML
for Cell 4B of 5594.0 FMSL less this required freeboard amount, rounded to the
nearest one-tenth of a foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting free board limit will persist until the next Annual Calculation
Date for period t+ 1.
An example of this calculation is set out in Appendix D.
(e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New Tailings Cell
When a spillway is added between Cell 4B and a new tailings cell then, if an approved freeboard
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 19 of 37
limit calculation method for the new cell is set to cover the entire PMP event for Cells 2, 3, 4A, 4B
and the new tailings cell, the freeboard limit for Cell 4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3, 4, 5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily inspection forms included as Appendix A to this Tailings Management
System procedure, the inspection forms included as Attachment A of the DMT Plan and the
Operating Foreman's Daily Inspection form the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the RSO, the report shall be submitted to the RSO for
review. The Mill Manager will review the report as well before the report is filed in the Mill Central
File. The report will contain a summary of observations of concern noted on the daily and weekly
tailings inspections. Corrective measures taken during the month will be documented along with the
observations where appropriate. All daily and weekly tailings inspection forms will be attached to
the report. A monthly inspection form will also be attached. Quarterly inspection forms will
accompany the report when applicable. The report will be signed and dated by the preparer in
addition to the Radiation Safety Officer and the Mill Manager.
8.2. Weekly Cell 1 and Cell 4B Photographs
Weekly photographs taken in response to EPA 40 CFR Part 61 will be stored on the Mill network
and reported in the EPA Central Data Exchange at least monthly (as available). If the EPA Central
Data Exchange is unavailable, the photographs will be maintained at the Mill in an electronic format.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A
FORMS
03/17 Revision: EFR 2.5
Page 20 of37
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .1
03/17 Revision: EFR 2.5
Page 21 of 37
APPENDIXA-1
DAILY INSPECTION DATA
Inspector: ______ _
Date~--------
Accompanied by: ___ _
Time: _______ _
Any Item not "OK" must be documented. A check mark= OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM I
lnsoection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3
Slurry Pioeline Leaks, Damage, Blockage, Sharo Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Location or Orientation
n. OPERATIONAL SYSTEMS and INTERIOR of CELLS
Insnection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3
N s E w
Interior Cell Walls
Liner Observable Liner Damage
Water Level Greater Than Operating Level, Large
Change Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
Cell4A Cell4B
Ce114A Cell 4B
N s EW N S E w
I
Presence of Sediments Sediments should be saturated YorN NIA NIA NIA YorN Notes:~~~~:::===~==========-=-------------------------------
--
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Ill. DIKES AND EMBANKMENTS
Insgection 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
Dike 1-I
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
I
Dike 1-
lA
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
03/17 Revision: EFR 2.5
Page 22 of37
Dike2 Dike3
No No
visible visible
exterior exterior
slope or slope or
dike to dike to
inspect inspect
No No
visible visible
exterior exterior
slope or slope or
dike to dike to
inspect inspect
Dike
4A-S
Slurrv Line(s) Pond Return S-X Tails
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
Slimes
Cell2
_____ "Y'es
_____ 'Y"es
Ce113
Dike Dike
4A-E 4B-S
Sorav Svstem
-----~No ______ No
Cell4A Ce114B
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
General Meteorological conditions:
VII. DAILY LEAK DETECTION CHECK
03/17 Revision: EFR 2.5
Page 23 of 37
Daily Leak Detection Checks are recorded on the Daily Inspection Data form included
as Attachment A-1 of the DMT Plan
VIll OBSERVATIONS OF POTENTIAL CONCERN
-
Action Required
Tailings Daily Inspection Repmt
Tailings Sluny Discharge Locatiou I
j
,I
I I
I •-------• ' I I I I
I MILL SITE
;
I
i (
I I I ; ; :
, . CELL N0.1 I' l,
I 1-"\ !-L
(/
' ---------j __.._ ...... Dilte 1-l
I t
I , ·--.___ ·---.. _ CELL NO. 2 ; I
, "· ... _ "'·· Fill~ I ! ./! Ctf.LNo Dik.~-----, .... ,,____ / /
( ·-----.:-----.. _ ,'' ' I :· ·-----.
/ ·--D~J··-~----j I
CELL NO. 48 /. 1,
\. :· ·~~ II.:' CELL NO. 4A 1/
• .. -"il."c-q9 . . fg s----! l!;'
Date: N:: / L~ /H 'µ,14~~1.\S .. Inspect or: . ~ ..
N
~--~.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 25 of37
APPENDIX A-2
WHITE MESA MILL
WEEKLY TAILINGS INSPECTION
Date: _______ _
1. Slimes Drain Liquid Levels Cell 2
Inspectors:--------------
Pump functioning properly ___ _
_______ Depth to Liquid pre-pump
_______ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 43.41 '-Depth to Liquid Pre-
pump = __ _
Post-pump head is _43.41' -Depth to Liquid Post-
pump = __ _
2. Existing Decontamination Pad (concrete): ___________________ _
3. Tailings Area Inspection (Note dispersal of blowing tailings):
4. Sediments visible in: Cell 1: Y Or N Cell 4B: Y Or N If yes, are they saturated? Y Or N
5. If no, note corrective actions:. ______________________ _
6. Control Methods Implemented: _____________________ _
7. Remarks: ________________________________ _
8. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 26 of37
APPENDIX A-3
MONTHLY INSPECTION DATA
Inspector:-------------
Date: ---------------
1. Slurry Pipeline: ------------------------------
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Diversion Ditch 1
__ yes __ no
yes __ no
yes __ no
yes __ no
__ yes __ no
__ yes __ no
Diversion Ditch 2
__ yes __ no
yes __ no
__ yes __ no
yes __ no
Diversion Ditch 3 Diversion Berm 2
__ yes __ no
__ yes __ no
__ yes __ no
yes __ no
Comments:, _________________________________ _
3. Summary of Activities Around Sedimentation Pond: ----------------
(
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: ___ __,yes. __ ~no
Overspray carried more than 50 feet from the cell: yes no
If "yes", was system immediately shut off? __ yes __ no
03/17 Revision: EFR 2.5
Page 27 of37
Comments: __________________________________ _
5. Remarks:--------------------------------
6. Settlement Monitors:
Attach the Settlement monitor monthly survey data (spreadsheet). Note any unusual observations
below.
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections: ---------------
9. Monthly LDS Pump Checks in Cells 4A and 4B:
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 28 of37
APPENDIX A-4
WIDTE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:-------------
Date: ---------------
1. Embankment Inspection: ---------------------
2. Operations/Maintenance Review:
3. Construction Activities:--------------------
4. Estimated Areas:
Cell 3 Cell 4A Cell 4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments: ------------
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXB
TAILINGS INSPECTOR TRAINING
03/17 Revision: EFR 2.5
Page 29 of37
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
immediate} y to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A of this Tailings Management System
procedure. A similar form containing DMT inspection requirements is provided as Attachment A of
the DMT Plan. The inspection form contained in this Tailings Management System procedure is
summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
..
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 30 of 37
are to be monitored for leaks, and loose connections. The pipeline supports are to be
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 4B solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
3. Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 4A-S, 4A-E, and 4B-S,, should be inspected closely
for mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
\
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3. l
4. Flow Rates:
03/17 Revision: EFR 2.5
Page31 of37
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 "O". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2, 3, 4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by Environmental, Health and Safety personnel as close to 8:00
a.m. as possible. All snow or ice should be melted before a reading is taken.
7. Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each. area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8. Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
03/17 Revision: EFR 2.5
Page 32 of37
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit on Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area ( other than the Cell 4A and 4B dike) is 15 mph. These limits should not
be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved 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 W orkshee!
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 Rl;1diation Safety Officer authorizes certification. Refer to the Certification
(
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 33 of37
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the RSO and
filed.
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXC
CERTIFICATION FORM
Date:------------
Name: ------------
03/17 Revision: EFR 2.5
Page 34 of37
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System Supervisor
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3 .1
Assumptions and Factors:
APPENDIXD
Example of Freeboard Calculations
For Cell 4B
o Total PMP volume to be stored in Cell 4B -159.4 acre feet
o Wave runup factor for Cell 4B -0.77 feet
o Total capacity of Cell 4B -2,094,000 dry tons
o Elevation of FML of Cell 4B -5,600.35 FMSL
o Maximum pool surface area of Cell 4B -40 acres
03/17 Revision: EFR 2.5
Page 35 of37
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL-1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL-March 1, 2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Tailings Actual Tailings Solids
Tailings Solids Solids Disposition into Disposition into Cell 4B
Disposition into Cell 4B at the determined at end of
Cell4B beginning of the the period (dry tons)*
Determined at period, multiplied by
the beginning of 150 % Safety Factor
the period ( dry (dry tons)
tons)*
March 1, 2012 to 150,000 225,000 225,000
November 1, 2012
November 1, 2012 to 300,000 450,000 275,000
November 1, 2013
November 1, 2013 to 200,000 300,000 250,000
November 1, 2014
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only.
Based on these assumptions and factors, the freeboard limits for Cell 4B would be calculated
as follows:
1. Prior to March 1. 2012
Prior to March 1, 2012, the maximum elevation of the beach area in Cell 4B is less than or
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 36 of37
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March l, 2012 to November 1. 2012
The pool surf ace 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 free board would be 197. 5 acre feet divided by 31. 77
acres equals 6.22 feet. When the wave run up factor for Cell 4B of 0. 77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell 4B would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1. 2012 to November l, 2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since the actual tonnage of 225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as
the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1-450,000/ (2,094,000-1,000,000-225,000)) x 31.77 acres= 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197 .5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave run up factorforCell 4B of0.77 feet is added
to this, the total free board required is 13 .66 feet. This means that the free board limit for Cell
4B would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66
feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2012, and this freeboard limit would persist until November 1, 2013.
4. November 1. 2013 to November 1. 2014.
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(
'
l
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 37 of 37
(1 -275,000/ (2,094,000-1,000,000 -225,000) x 31.77 acres= 21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1, 2013.
Then, calculate the modeled pool surface area to be used for the period:
(1 -300,000 I (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 Cell 4B of 0.77 feet is added
to this, the total freeboard required is 19 .14 feet. This means that the freeboard limit for Cell
4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet,
rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2013, and this freeboard limit would persist until November 1, 2014.
Appendix J
Cell 2 Slimes Drain Calculations and Figure 2009-2022
n tD --N
V, --· 3
tD "' C
@ -::::,
I
N
0 0 \D
I
N 0
N
N
Vl fl)
:::::!.
fl) V> N
C: ::,
fl) Q) ....
vi" fl) -,
it,"
V> N
lJJ 0 i:::::,
0
N ID i:::::, 0
N 00
i:::::,
0
Feet Below Top of Standpipe
N
-..J
i:::::,
0
N a,
i:::::,
0
N V,
i:::::, 0
N :,
i:::::, 0
N
lJJ
i:::::,
0
N
N i:::::,
0
N N I-' 0 i:::::, i:::::, 0 0
1/30/2009
6/30/2009
11/30/2009
4/30/2010
9/30/2010
2/28/2011
7/31/2011
12/31/2011
5/31/2012
10/31/2012
3/31/2013
8/31/2013
1/31/2014
6/30/2014
11/30/2014
4/30/2015
9/30/2015
2/29/2016
7/31/2016
12/31/2016
5/31/2017
10/31/2017
3/31/2018
8/31/2018
1/31/2019
6/30/2019
11/30/2019
4/30/2020
9/30/2020
2/28/2021
7/31/2021
12/31/2021
Cell 2 Slimes Drain Monthly Volumes of Fluids Pumped
Total Pum;pea, by Month
' Date (gal)
January-18 103660
February-18 92178
March-18* 86924
April-18 99087
May-18 100122
June-18* 76523
July-18 109049
August-18 100122
September-18* 85596
"October-18* 95366
November-18 96712
December-18 100183
2018Total U455Z2
*Pursuant to Part I.D.3(b) of the January 19, 2018 GWDP, slimes darin
recovery tests were performed quarterly. The recovery tests (and GWDP)
require the pump to be turned off for 90 hours. No pumping of slimes
drain fluid occurs during the recovery test. Less volumes are reported
during the months in which the recovery tests are conducted.
Cell 2 Slimes Drain Recovery Head and SORE Values for 2018
2018 Test Elevation of Reported Level SORE Values
Closing Date Measurement (feet) (Reported as fmsl)
Point (fmsl)
3/28/2018 5ti24.17 27.88 5596.29
6/28/2018 562..,4.17. 28.48 5:595.69
9/19/2018 5fi24.11 28.17 5.o9a.oo I
10/8/2018 .se24J'7 27.45 5596.:n .
lE2011 22584.:Z,(i) I
N20n 4
2018 Average 55,96.1'8 -
'
Recovery •
Cell 2 S1imes Drain Monthly Volumes of Fluids Pumped
1'etal Pmnpiet by Month
Date (gal)
January-19 94713
February-19* 80084
March-19* 97921
April-19 92178
May-19* 84677
June-19 87619
July-19 90063
August-19 90647
September-19* 79259
October-20 92165
November-19* 80057
December-19 100221
28ff'Te.faf ~4
*Pursuant to Part I.D.3(b) of the January 19, 2018 GWDP, slimes
darin recovery tests were performed quarterly. The recovery tests
(and GWDP) require the pump to be turned off for 90 hours. No
pumping of slimes drain fluid occurs during the recovery test. Less
volumes are reported during the months in which the recovery tests
are conducted.
Cell 2 Slimes Drain Recovery Head and SORE Values for 2019
2019 Test Elevation of Reported Level SDRE Values
Closing Date Measurement (feet) (Reported as fmsl)
Point (fmsl)
3/4/2019 i~24.17' 28.30 55~.S.'87,
5/13/2019 ,$624.1 7 28.57 $595.&0
9/16/2019 5<£24.n 28.40 §S95 .. n
11/25/2019 se:124.11 28.00 559.~.1'7 ..
I.E2019 2238l.4t -
N2019 4
2019 Average 55,g5_g'5 I
Recovery --
Cell 2 Slimes Drain Monthly Volumes of Fluids Pumped
Total .Pumped by .Month
".Date fgpl;)
January-20 85791
February-20* 72593
March-20 91513
April-20 81454
May-20 85725
June-20* 75640
July-20 84720
August-20 84236
September-20* 72815
October-20 87111
November-20* 73744
December-20 87767 .. ~ .. t8;3l&9
*Pursuant to Part I.D.3(b) of the January 19, 2018 GWDP, slimes
darin recovery tests were performed quarterly. The recovery tests
(and GWDP) require the pump to be turned off for 90 hours. No
pumping of slimes drain fluid occurs during the recovery test. Less
volumes are reported during the months in which the recovery tests
are conducted.
Cell 2 Slimes Drain Recovery Head and SORE Values for 2020
2020 Test Elevation of Reported Level SORE Values
Closing Date Measurement (feet) (Reported as fmsl)
Point (fmsl)
2/25/2020 56M.17 I 28.53 II 5.595.M!
6/8/2020 II 562~.17 l 28.61 II 5595.56
9/8/2020 562~.17 28.38 II $595.79
11/23/2020 II 5624.17 28.35 5595.8'2 '
II IE2020 22382.81
N2020 4
II 2020 Average SS9~.70 Ii
II Recovery
II Elevation
II
Cell 2 Slimes Drain Monthly Volumes of Fluids Pumped
TotarPumped by Month
Date (gal)
January-21 82019
February-21 * 62164
March-21 89359
April-21 80045
May-21 80704
June-21 * 72298
July-21 76870
August-21 79833
September-21 * 71715
October-21 82796
November-21 75809
December-21 * 79601
2021 Total 933!l.13
*Pursuant to Part I.D.3(b) of the January 19, 2018 GWDP, slimes
drain recovery tests were performed quarterly. The recovery tests
(and GWDP) require the pump to be turned off for 90 hours. No
pumping of slimes drain fluid occurs during the recovery test. Less
volumes are reported during the months in which the recovery tests
are conducted.
Cell 2 Slimes Drain Recovery Head and SDRE Values for 2021
2021 Test Elevation of Reported Level SDRE Values
Closing Date Measurement (feet) (Reported as fmsl)
Point (fmsl)
3/2/2021 5,(9~.17 28.88 $595.29
6/8/2021 $624.17 29.10 5595.07
9/20/2021 $,624.~7 29.54 5594.t53
12/7/2021 5624.17 28.78 5595.39
I.E2021 223·8@.~'8 '
N2021 4
2021 Average 5595.J.C!)
Recovery
Elevation
Appendix K
White Mesa Uranium Mill Ground Water Monitoring Quality Assurance Plan (QAP)
Date 2/15/2022 Revision 7.7
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 02-15-2022 Revision 7.7
Pagel of61 Quality Assurance Plan (QAP)
WHITE MESA URANIUM MILL
GROUNDWATER MONITORING
QUALITY ASSURANCE PLAN (QAP)
State of Utah
Groundwater Discharge permit No. UGW370004
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
TABLE OF CONTENTS
Date: 02-15-2022 Revision 7.7
Page 2 of61
1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2..2 OveraU Responsibility For the QA/QC Program 6
2,3 »~ta aequestors/Users 6
2.4 Data Generaton 7
2.4.1 Sampling and QC Monitors 7
2.4.2 Analysis Monitor 8
2.4.3 Data Reviewers/Approvers 8
l.S Res.,onsibilities Of Analytical Laboratory 8
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 9
3, 1 Pffl:isi«m 9
3.2 Ateuracy 10
3.3 Represent.tiveness l O
3.4 Completeness 10
J,5 Coffll)arability t1
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11
4.1 Controlling Well Contamination 11
4.2 Controlling Depth to Groundwater Measurements 11
4.3 Water Quality QC Samples 11
4.3.1 voe Trip Blanks 11
4.3.2 Equipment Rinsa~e Samples 11
4:3,3 Field DupJi~tcs J 2
4.3.4 Definition of "Batch" 12
S.O CALffiRATION 12
5.1 Depth to Groundwater Measutemeqts 12
5.2 W~ter Qu•lity 12
Mill -Groundwater Discharge Perm.it
Orol.lndwatcr Mc,nitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 R,evision 7.7
Page 3 of61
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 12
6.1 Groundwater Head Monitoring 12
6.1.1 Location and Frequency of Groundwater Head Monitoring 13
6.1.2 Groundwater Head Monitoring r"fequency l 3
6.2 Grouhd Water Compliance Monitoring 13
6.2.1 Location and Frequency of Groundwater CompJiance Monitoring 13
6.2.2 Quarterly and Semi~Annual Sampling Required Under Parts l.E. I .b) or I.E.1.c) of the GWDP 14
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs LG. I or I.G.2 of the GWDP 14
6.2.4 Sampling Equipment for Gr9undwater Compliance Monitoring 14
6.2.5 Decontamination Procedure 15
6.2.6 Pre-Purging/ Sampling Activities 15
6.2.7 Well Purging/Measurement bfFieJd Parameters 15
6.2.8 Samples to be taken and order of taking samples 15
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 16
7.1 Field Data Worksheets 16
7.2 Chain-Of-Custody and Analytical Request Record 17
7.3 Rerorcl Keeping 18
8.0 ANALYTICAL PROCEDURES AND QA/QC 18
8,1 Analytical Quality Control 18
8.1.2 Spikes, Blan.ks and Duplicates l 9
8.2 Analytical Laboratory Procedu~ 20
9.0 INTERNAL QUALITY CONTROL CHECKS 25
9.1 Field QC Ctu~ck Procedures 25
9. I, I Review of Compliance With the Procedures Contained in this QAP 25
9. J .2 Analyte Completeness Review 25
9.1.3 Blank Comparisons 25
9.1.4 Duplicate Sample Comparisons 26
.9.i Analytical Laboratory QA Reviews 27
9.3 QA Man11ger Review of Analytical Laboratory Results and Pr:ocedures 27
9.4 Analytical Dffta 28
10.0 CORRECTIVE ACTION 29
10.1 When Corrective Action is Required 29
10.:2 Procedure for Corredin Action 29
Mill-Groundwater Oischarge Permit Date: 02-15-2022 Revision 7.7
Groundwater Monit<,>ring
Quality Assurance. Plan (QAP) Page 4 of 61
11.0 REPORTING ·30
12.0 SYSTEM AND PERFORMANCE AUDITS 31
12.1 QA M•Qqer to Pedorm System Audits a.-.d Performance Audits JI
l2.1SystemAudiis 31
12.3 Performance Audits 32
12.4 Follow-Up A.ctions 32
12.S Audit Records 32
13.0 PREVENTIVE MAINTENANCE 32
14.0 QUALITY ASSURAN~ REPORTS TO MANAGEMENT
14.l Ongoing QA/QC Reporting
14.l Periodic Reporting to Management
15.0 AMENDMENT
16.0 REFERENCES
33
33
33
33
34
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENTS
Date: 02-15-2022 Revision 7.7
Page 5 of61
Attachment 1 Field and Data Forms
Attachment 1-1 Quarterly Depth to Water Data Sheet
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example Field Data Report
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures
Attachment 2-2 Decontamination Procedures
Attachment 2-3 Purging Procedures
Attachment 2-4 Sample Collection Procedures
Attachment 2-5 Field QC Samples
APPENDICES
Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa
Uranium Mill Blanding, Utah
Mill -Groundwater Discharge Permil
GruundwaLer Mortitoting
Quality Assurance Plan (QAP)
1.0 INTRODUCTION
Date: 02-15-2022 Revision 7.7
Page 6 of 61
This Groundwater Monitoring Quality Assurance Plan (the "QAP") details and describes all
sampling equipment. field methods, laboratory methods. qualifications of environmental
anaJytical laboratories, data validation, and sampling and other corrective actions necessary to
comply with UAC R317-6-6,3(1) and (L) at the White Mesa Uranium Mill (the "Mill''), as
required by the State of Utah Groundwater Discharge Permit No. UGW370004 (the
"GWDP") for the Mill. This Procedure incorporates the applicable provisions of the United
States Environmental Protection Agency ("EPA'') RCRA Groundwater Monitoring Technical
Enforcement Guidance Document (OSWER-9950.l, September, 1986), as updated byEPA's
RCRA Ground-Water Monitoring: Draft Technical Guidance (November 1992).
Activities in an integrated program to generate quality data can be classified as management
(i.e., quality assurance or "QA'') and as functional (i.e .• quality control or "QC''). The
objective of this QAP is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, completeness, representativeness and comparability
required for management purposes and to comply with the reporting requirements established
by applicable permits and regulations.
2.0 ORGANIZATION AND RESPONSIBILmES
2.1 Func'tional Groups
This QAP specifies roles for a QA Manager as weH as representatives of three different
functional groups: the data users; the data generators, and the data reviewers/approvers. The
roles and responsibilities of these representatives are described below.
2,2 Overall Responsibility For the QA/QC Program
The overall responsibility for ensuring that the QNQC measures are properly employed is the
responsibility of the QA Manager. The QA Manager is typically not directly involved in the.
data generation (i.e., sampling or analysis) activities. The QA Manager is designated by
Energy Fuels Resources (USA) Inc. ("EFRI") corporate management.
2.3 Data Requestors/Users
The generation of data that meets the objectives· of this QAP is necessary for management to
make informed decisions relating to the operation of the Mill facility, and to comply with the
reporting requirements set out in the GWDP and other permits a'nd applicab1e regulations.
Accordingly, the data requesters/users (the "Data Users") are therefore EFRI;s corporate
m.anagement and regulatory authorities through the implementation of s1,1ch pe1miti,; and
regulations. The data quaJity objectives (0 DQ0s;,) required for any groundwater sampling
eventf such as acceptable minimum detection limits, are specified in this QAP.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
2.4 Data Generators
Date: 02-15-2022 Revision 7.7
Page 7 of 61
The individuals who carry out the sampling and analysis activities at the request of the Data
Users are the data generators. For Mill activities, this involves sample collection, record
keeping and QA/QC activities conducted by one or more sampling and quality control/data
monitors (each a "Sampling and QC Monitor"). The Sampling and QC Monitors are
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors
perform all field sampling activities, collect all field QC samples and perform all data
recording and chain of custody activities in accordance with this QAP. Data generation at the
contract analytical laboratory (the "Analytical Laboratory") utilized by the Mill to analyze the
environmental samples is performed by or under an employee or agent (the "Analysis
Monitor") of the Analytical Laboratory, in accordance with specific requirements of the
Analytical Laboratory's own QA/QC program.
The responsibilities of the data generators are as follows:
2.4.1 Sampling and OC Monitors
The Sampling and QC Monitors are responsible for field activities. These include:
a) Ensuring that samples are collected, preserved, and transported as specified in this
QAP;
b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the samples,
to the Analytical Laboratory in accordance with this QAP;
c) Maintaining records of all samples, tracking those samples through subsequent
processing and analysis, and, ultimately, where applicable, appropriately disposing of
those samples at the conclusion of the program;
d) Preparing quality control samples for field sample collection during the sampling
event;
e) Preparing QC and sample data for review by the QA Manager; and
f) Preparing QC and sample data for reporting and entry into a computerized database,
where appropriate.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
2.4.2 Analysis Monitor
Date: 02-15-2022 Revision 7.7
Page 8 of61
The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory.
These include:
a) Training and qualifying personnel in specified Analytical Laboratory QC and
analytical procedures, prior to receiving samples;
b) Receiving samples from the field and verifying that incoming samples correspond to
the packing list or chain-of-custody sheet; and
c) Verifying that Analytical Laboratory QC and analytical procedures are being
followed as specified in this QAP, by the Analytical Laboratory's QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program ("NELAP") certification.
2.4.3 Data Reviewers/Approvers
The QA Manager has broad authority to approve or disapprove project plans, specific
analyses and final reports. In general, the QA Manager is responsible for reviewing and
advising on all aspects of QA/QC, including:
a) Ensuring that the data produced by the data generators meet the specifications set out
in this QAP;
b) Making on-site evaluations and submitting audit samples to assist in reviewing
QA/QC procedures;
c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate
sampling equipment and sample containers, in accordance with this QAP, to
minimize contamination; and
d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP occur.
The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personnel.
2.5 Responsibilities Of Analytical Laboratory
Unless otherwise specified by EFRI corporate management, all environmental analysis of
groundwater sampling required by the GWDP or by other applicable permits, will be
performed by a contract Analytical Laboratory.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 9 of61
The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with
the requirements for maintaining National Environmental Laboratory Accreditation Program
("NELAP") ce1tification, which is a national accreditation program developed by the NELAC
institute ("TNI").
In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U.S. EPA Guideline SW-846 and, to the extent
consistent with NELAP and EPA practices, the applicable portions of NRC Regulatory Guide
4.14.
The Analytical Laboratory will be chosen by EFRI and must satisfy the following criteria:
(1) experience in analyzing environmental samples with detail for precision and accuracy, (2)
experience with similar matrix analyses, (3) operation of a stringent internal quality assurance
program meeting NELAP certification requirements and that satisfies the criteria set out in
Section 8 below, (4) ability to satisfy radionuclide requirements as stipulated in the
applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the State of Utah for
and capable of performing the analytical methods set out in Table 1. The analytical
procedures used by the Analytical Laboratory will be in accordance with Utah Administrative
Code R317-6-6.3L.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA
The objective of this QAP is to ensure that monitoring data are generated at the Mill that
meet the requirements for precision, accuracy, representativeness, completeness, and
comparability required for management purposes and to comply with the reporting
requirements established by applicable permits and regulations (the Field and Analytical QC
samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are
satisfied). Data subject to QNQC measures are deemed more reliable than data without any
QA/QC measures.
3.1 Precision
Precision is defined as the measure of variability that exists between individual sample
measurements of the same property under identical conditions. Precision is measured
through the analysis of samples containing identical concentrations of the parameters of
concern. For duplicate measurements, precision is expressed as the relative percent
difference ("RPD") of a data pair and will be calculated by the following equation:
RPD = [(A-B)/{(A+B) /2}] x 100
Where A ( original) and B (duplicate) are the reported concentration for field duplicate
samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 10 of61
percent recoveries for matrix spike and matrix spike duplicate samples) (EPA SW -846,
Chapter 1, Section 5.0, page 27 -28).
3.2 Accuracy
Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and a known value. The accuracy of laboratory analyses is evaluated based
on analyzing standards of known concentration both before and during analysis. Accuracy
will be evaluated by the following equation:
% Recovery= (IA-BI /C) x 100
Where:
A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added
3.3 Representativeness
Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an
environmental condition. Representativeness is controlled by performing all sampling in
compliance with this QAP.
3.4 Completeness
Completeness refers to the amount of valid data obtained from a measurement system in
reference to the amount that could be obtained under ideal conditions. Laboratory
completeness is a measure of the number of samples submitted for analysis compared to the
number of analyses found acceptable after review of the analytical data. Completeness will
be calculated by the following equation:
Completeness= (Number of valid data points/total number of measurements) x 100
Where the number of valid data points is the total number of valid analytical measurements
based on the precision, accuracy, and holding time evaluation. Completeness is determined
at the conclusion of the data validation.
The Director ("Director") of the Utah Division of Waste Management and Radiation Control)
("DWMRC") approval will be required for any completeness less than 100 percent.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
3.5 Comparability
Date: 02-15-2022 Revision 7.7
Page 11 of 61
Comparability refers to the confidence with which one set of data can be compared to another
measuring the same property. Data are comparable if sampling conditions, collection
techniques, measurement procedures, methods, and reporting units are consistent for all
samples within a sample set.
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY
4.1 Controlling Well Contamination
Well contamination from external surface factors, is controlled by installation of a cap over
the surface casing and cementing the surface section of the drill hole. Wells have surface
covers of mild steel with a lockable cap cover. Radiation Safety staff has access to the keys
locking the wells.
4.2 Controlling Depth to Groundwater Measurements
Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.
4.3 Water Quality QC Samples
Quality assurance for groundwater monitoring consists of the following QC samples:
4.3.l VOC Trip Blanks
Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds ("VOCs") through diffusion during sample transport and storage.
At a minimum (at least) one trip blank will be in each shipping container containing samples
to be analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site, and then returned to the Analytical Laboratory for analysis
along with the samples collected during the sampling event. The trip blank will be unopened
throughout the transportation and storage processes and will accompany the technician while
sampling in the field.
4.3.2 Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non-
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples. Rinsate
blanks will be collected after decontamination and prior to subsequent use. Rinsate blank
samples for a non-dedicated pump are prepared by pumping de-ionized water into the sample
containers. Rinsate blank samples for a non-disposable or non-dedicated bailer are prepared
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 12 of61
by pouring de-ionized water over and through the bailer and into the sample containers.
Equipment rinsate blanks will be analyzed only for the contaminants required during the
monitoring event in which they are collected.
Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
4.3.3 Field Duplicates
Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.
Field duplicate sampling procedures are described in Attachment 2-5.
4.3.4 Definition of "Batch"
For the purposes of this QAP, a Batch is defined as 20 or fewer samples.
5.0 CALIBRATION
A fundamental requirement for collection of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance
with manufacturers' recommendations, and Analytical Laboratory equipment shall be
calibrated in accordance with Analytical Laboratory procedures.
5.1 Depth to Groundwater Measurements
Equipment used in depth to groundwater measurements will be checked prior to use as noted
in Attachment 2 to ensure that the Water Sounding Device is functional.
5.2 Water Quality
The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer's specifications (for
example, by using two known pH solutions and one specific conductance standard.) Per the
manufacturer, temperature cannot be calibrated but will be periodically checked
comparatively by using a thermometer. Conductivity and pH calibration results will be
recorded as described in Section 7 .1.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS
6.1 Groundwater Head Monitoring
Groundwater head measurements ("depth to water") will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
6.1.1 Location ond I~requency of Groundwat~r Head Monitoring
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Depth to groundwater shall be measured quarterly in the following wells and piezometers:
a) All Point of Compliance wells listed in the GWDP;
b) Monitoring wen MW-34~
c) All piezometers (P-1, P-2, P-3A, P-4, P-5 and the Dry Ridge piezometers);
d) All contaminant investigation wells required by the Director as part of a
contaminant investigation or groundwater corrective action (chloroform and
nitrate wells).
6.1.2 Groundwater Bead Monitoring Frequency
Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5--day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an eJectronic
data management system (spreadsheet and/or database). The data from the quarterly depth to
water measurements will be included in the quarterly reports.
In addition, weekly and monthly depth to groundwater measurements are takeo in the chloroform
pumping wells MW-4, MW-26, TW4-l, TW4-'.i, TW4-l l, TW4-l9, TW4-20, TW4-4, TW4-21,
TW4-37, TW4-39 TW4-40 (starting in May 2019) and TW4-41, and the nitrate pumping wells TW4-
22, TW4-24, TW4-25, and TWN-t
The depth to groundwater measured immediately prior to purging/sampling will be recorded
for each w,ell as described in Section 7. 1.
6.2 Ground Water Compliance Monitoring
6.2,1 Location and Frequency of Groundwater Compliance Monitoring
Groundwater quality shall be measured in the wells specified in the GWDP at the frequencies
specified in the GWDP. In addition, the Chloroform Investigation and Nitrate Corrective
Action wells will be sampled quarterly as described in Appendix A and Appendix B of this
QAP.
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Quality Assurance Plan (QAP)
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Accelerated quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in the GWDP. Sampling personnel should
coordinate with the QA Manager prior to conducting any monitoring well sampling to
determine if any parameters in any wells are subject to accelerated monitoring.
6.2.2 Quarterly and Semi-Annual Sampling Required In Accordance With the GWDP
All quarterly and semi-annual samples collected in accordance with the GWDP shall be
analyzed for the following parameters:
a) Field parameters -depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) turbidity and dissolved oxygen ("DO"); and
b) Laboratory Parameters:
(i) All parameters specified in Table 2 of the GWDP; and
(ii) General inorganics -chloride, sulfate, carbonate, bicarbonate, sodium
potassium, magnesium, calcium, and total anions and cations.
6.2.3 Accelerated Quarterly or Monthly Sampling Required .By the GWDP
Any quarterly or monthly accelerated sampling required by the GWDP shall be analyzed for
the specific parameters as required by previous sampling results as determined by the QA
Manager.
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring
All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.
Purging and sampling equipment is described in Attachment 2-3 of this QAP.
Field parameters are measured by using a flow cell system that enables the measurements to
be taken on a real-time basis without exposing the water stream to the atmosphere;
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Gmundwater Monitoring
Quality Assurance Plan (QAP)
6.2.5 Decontamination Procedure
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Page 15 of61
Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using Lhe
procedure described in Attachment 2-2.
6.2.6 Pre-Purging/ Sampling Activities
Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the we)]' s historic recovery rates,
the equipment used for purging. and the analytical suite Lo be completed.
6.2.7 Well Pureinl!{Measurement of Field Parameters
The purging techniques described in Attachment 2-3 wiU be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program.-specific QAPs for the
chloroform and nitrate investigations. The program~specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.
Purging wells prior to sampling removes the stagnant water column present in the well casing
and assures that representative samples of the formation water are collected. Purging will be
completed as described in Attachment 2-3.
There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:
l. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
6.2:.8 Samples to be taken and order of taking samples
For each quarterly or semi-annual sampling event, samp]es will be collected for the anaJyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP. The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single container
due to like sampling requirements (filtering) and/or like preservation. The container
requirements will be detennined by the Analytical Laboratory and specified with the bottles
supplied to the Field Personnel. Bottle requirements may change if the Analytical Laboratory
is changed or if advances in analytical techniques allow for reduced samples volumes. The
following list is a general guideline.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
a) VOCs, 3 sample containers, 40 ml each;
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b) Nutrients (ammonia, nitrate/nitrite as N), 1 sample container, 250 ml;
c) All other non-radiologies (anions, general inorganics, TDS, total cations and total
anions), 2 sample containers, 500 and 250 ml,;
d) Gross alpha, 1 sample container, 500 ml, filtered; and
e) Metals, 1 sample container, 250 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.
Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING
7 .1 Field Data Collection
Documentation of observations and data from sampling provide important information about
the sampling process and provide a permanent record for sampling activities. All
observations and field sampling data will be recorded.
Field data collection will be completed using either an electronic device (such as a tablet) or a
hardcopy form. Hardcopy forms will be completed in waterproof ink. If field data collection
is completed using an electronic device, a data report for each well sampled will be printed
after the completion of the sampling event and signed by one member of the sampling crew.
The signed sheets will be maintained on file and the Mill and will be included in the quarterly
reports. The electronic data collection will be accomplished using a standardized collection
module. An example of a hardcopy field collection form as well as an example data report are
included as Attachment lA and lB respectively.
The hardcopy data sheets and data reports included herein are examples and may be changed
to accommodate additional data collection. If a change is made to a data sheet to
accommodate additional information, a copy will be provided to the Director. Changes to
hardcopy field forms and data reports will not eliminate any data collection activity without
written approval of the Director.
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Quality Assurance Plan (QAP) Page 17 of61
Regardless of the field data collection method, the following information will be collected:
• Name of the site/facility
• description of sampling event
• location of sample ( well name)
• sampler's name(s) and/or initials(s)
• date(s) and time(s) of well purging and sample collection
• type of well purging equipment used (pump or bailer)
• previous well sampled during the sampling event
• well depth
• depth to groundwater before purging and sampling
• field measurements (pH, specific conductance, water temperature, redox
potential, turbidity, DO)
• calculated well casing volume
• volume of water purged before sampling
• volume of water purged when field parameters are measured
• type of well pump
• description of samples taken
• sample handling, including filtration and preservation
• volume of water collected for analysis
• types of sample containers and preservatives
• weather conditions and external air temperature
• name of certified Analytical Laboratory.
Field data collection will also include detailed notes describing any other significant factors
noted during the sampling event as necessary, including, as applicable: condition of the well
cap and lock; water appearance, color, odor, clarity; presence of debris or solids; any
variances from this procedure; and any other relevant features or conditions.
7.2 Chain-Of-Custody and Analytical Request Record
A Chain-of-Custody (the "COC Form") will accompany the samples being shipped to the
Analytical Laboratory. Standard Chain-of-Custody protocol is initiated for each sample set.
A COC Form is to be completed for each set of samples collected and is to include the
following:
• sampler's name
• company name
• date and time of collection
• sample matrix (e.g., water)
• sample location
• number of sample containers in the shipping container
• analyses requested
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Quality Assurance Plan (QAP)
• signatures of persons involved in the chain of p<,sscssion
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• internal temperatures of the shipping container when opened at the laboratory
• remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory. ·
Chain·of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.
The person shipping the samples to the Analytical Laboratol'y will sign the COC Form,
document shipment method, and send the original COC Form with the samples. Upon
receipt of the samples, the person receiving the samples will sign the COC Form and return
an electronic copy to the Mill and the QA Manager.
Copies of the COC Forms and other relevant documentation will be retained at the Mill.
7.3 Record Keeping
The data coJlection records arc retained in an electronic database and hardcopies are retained
at tl)e Mill.
Data from the Analytical Laboratory, showing the laboratory analytical results for the water
samples, are maintained at the Mill.
EFRI wiU ensure that the Analytical Laboratory or Laboratories used, have certifications for
each parameter and method required by Section 8.2! Table I of the QAP. The QA Manager
will check th.e Utah certifications at least annually.
Once all the data for the quarter (all wells sampled during the quarter) is completed, key data
from the field and from the data packages are managed using electronic data management
software. The data management software will be managed and administered by the QA
Manager or designec.
8.0 ANALYTICAL PROCEDURES AND QA/QC
Analytical Laboratory QA provides a means for establishing consistency in the performance
of analytical procedures and assuring adherence to analytical methods utilized. Analytical
Laboratory QC programs include traceability of measurements to independent reference
materials and internal controls.
8.1 Analytical Quality Control
Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In
choosing and retaining the Analytical Laboratory, EFRI shall ensure that the Analytical
Laboratory is certified by the State of Utah and by NELAP, is capable of performing the
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analytical procedures specified in Section 8.2, and that the QA/QC program of the Analytical
Laboratory includes the spikes, blanks and duplicates described in Section 8.1.2.
8.1.2 Spikes, Blanks and Duplicates
Analytical Laboratory QC samples will assess the accuracy and precision of the analyses.
Tb~ following describes the type of QC samples that will be used by the Analytical
Laboratory to assess the quality of the data. The following procedures shall be performed at
least once with each analytical Batch of samples:
a) Matrix Spike/Matrix Spike Duplicate
A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix. on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.
b) Method Blanks
Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks wiJl be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.
c) Surrogate Compounds
Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) shall be spiked with
surrogate compounds prior to purging or extraction. Surrogates are organic
compounds which are similar to analytes of interest in chemical composition,
extraction, and chromatography, but which are not normaJly found in environmental
samples. Surrogates shall be spiked into samples according to the appropriate organic
analytical methods.
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Quality Assurance Plan (QAP)
d) Check Sample
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Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.
8.2 Analytical Laboratory Procedures
The analytical procedures to be used by the Analytical Laboratory will be as specified in
Table 1, or as otherwise authorized by the Director. With respect to Chloroform
Investigation and Nitrate Corrective Action sampling, the analytical procedures for
parameters monitored under those programs are specified in Appendix A and B respectively.
Mill -Groundwater Discharge Permit
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Qu~lity Assurance Plan (QAP)
Contaminant Analytical
Methods
to be Used
Nutrients
Ammonia (as N) A4500-
NH3 Gor
E350.l
Nitrate & Nitrite E353. l or
(as N) E353.2 or
A4500-
N03F
Heavy Metals
Arsenic B200.7 or
E200.8
Beryllium E200.7 or
E200.8
Cadmium E200.7 or
E200.8
Chromium E200.7 or
E200.8
Cobalt B200.7 or
E200,8
Copper E200.7 or
E200.8
Iron E200.7 or
E200.8
Lead E200.7 or
E200.8
Manganese E200.7 or
E200.S
Mercury E 245.l or
E200.7 or
E200.8
Molybdenum E200.7 or
E200.8
Nickel E200.7 or
E200.8
Selenium E200.7 or
E200.8
Silver E200.7 or
E200.8
Table 1
Reporting Maximum
Limit1 Holding
Times
0.05 mg/L 28 days
O;I mg/L 28 days
5 µg/L 6 months
0.50 µg/L 6 months
0.50 µg/L 6 months
25 i-tg/L 6 months
10 µg/L 6 months
10 µg/L 6 months
30 µg/L 6 months
1.0 µg/L 6 months
10 µg/L 6 months
0,50 µg/L 28 days
10 µg/L 6 months
20 µg/L 6 months
5 µg/L 6 months
lO µg/L 6 months
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Sample Sample
Preservation Temperature
Requirements Requirements
H2S04 to S 6°C
pH<2
H2S04 to S6°C
pH<2
HN03topH<2 None
HN03 to pH<2 None
HN03topH<2 None
HN03topH<2 None
HN03to pH<2 None
HN03to pH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Contaminant Analytical
Methods
to be Used
Thallium E200.7 or
E200.8
Tin E200.7 or
E200.8
Uranium E200.7 or
E200.8
Vanadium E200.7 or
E200.8
Zinc E200.7 or
E200.8
Radiolo~ics
Gross Alpha E 900.0 or
E900.1 or
903.0
Volatile
Organic
Compounds
Acetone SW8260B,
SW8260C
or
SW8260D
Benzene SW8260B,
SW8260C
or
SW8260D
2-Butanone SW8260B,
(MEK) SW8260C
or
SW8260D
Carbon SW8260B,
Tetrachloride SW8260C
or
SW8260D
Chloroform SW8260B,
SW8260C
or
SW8260D
Chloromethane SW8260B,
SW8260C
Reporting Maximum
Limit1 Holding
Times
0.50 µg/L 6 months
100 µg/L 6 months
0.30 µg/L 6 months
15 µg/L 6 months
10 µg/L 6 months
1.0 pCi/L 6 months
20 µg/L 14 days
1.0 µg/L 14 days
20 µg/L 14 days
1.0 µg/L 14 days
1.0 µg/L 14 days
1.0 µg/L 14 days
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Sample Sample
Preservation Temperature
Requirements Requirements
HN03topH<2 None
HN03topH<2 None
HN03to pH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HCJ topH<2 S 6°C
HCI to pH<2 S 6°C
HCl topH<2 S 6°C
HCI topH<2 S6°C
HCl topH<2 S6°C
HCl topH<2 S6°C
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance P]an (QAP)
Contaminant Analytical
Methods
to be Used
or
SW8260D
Dichloromethane SW8260B,
(Methylene SW8260C
Chloride) or
SW8260D
Naphthalene SW8260B,
SW8260C
or
SW8260D
Tetrahydrofuran SW8260B,
SW8260C
or
SW8260D
Toluene SW8260B,
SW8260C
or
SW8260D
Xylenes (total) SW8260B,
SW8260C
or
SW8260D
Others
Field pH (S.U.) A4500-H
B
Fluoride A4500-FC
orE300.0
TDS A2540C
General
lnoru;anics
Chloride A4500-Cl
B or
A4500-Cl
E
orE300.0
Sulfate A4500-
S04 Eor
E300.0
Carbonate as A2320B
Reporting Maximum
Limit1 Holding
Times
1.0 µg/L 14 days
1.0 µg/L 14 days
1.0 µg/L 14 days
1.0 µg/L 14 days
1.0 µg/L 14 days
0.01 s.u. Immediate
0.1 mg/L 28 days
lOmwL 7 days
1 mg/L 28 days
1 mg/L 28 days
1 mg/L 14 days
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Sample Sample
Preservation Temperature
Requirements Requirements
HCI to pH<2 S6°C
HCl to pH<2 S6°C
HCI topH<2 :5 6°C
HCI topH<2 S6°C
HCl to pH<2 :5 6°C
None None
None None
None S6°C
None None
None S6°C
None S6°C
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Contaminant Analytical
Methods
to be Used
C03
Bicarbonate as A2320B
HC03
Sodium E200.7
Potassium E200.7
Magnesium E200.7
Calcium E200.7
Reporting
Limit1
1 mg/L
0.5 mg/L
0.5 mg/L
0.5 mg/L
0.5 mg/L
Maximum
Holding
Times
14 days
6 months
6 months
6 months
6 months
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Sample Sample
Preservation Temperature
Requirements Requirements
None ~6°C
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
HN03topH<2 None
1. The Analytical Laboratory will be required to meet the reporting limits ("RLs") in the foregoing Table,
unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the
increased RL will be used, or unless otherwise approved by the Director.
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9.0 INTERNAL QUALITY CONTROL CHECKS
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Internal quality control checks are inherent in this QAP. The QA Manager will monitor the
performance of the Sample and QC Monitors, and, to the extent practicable, the Analysis
Monitor to ensure that they are following this QAP. In addition, either the QA Manager or a
Sampling and QC Monitor will review and validate the analytical data generated by the
Analytical Laboratory to ensure that it meets the DQOs established by this QAP. Finally,
periodic system and performance audits will be performed, as detailed in Section 12 below.
9.1 Field QC Check Procedures
The QA Manager will perform the following QNQC analysis of field procedures:
9.1.1 Review of Compliance With the Procedures Contained in this OAP
Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.
9.1.2 Analyte Completeness Review
The QA Manager will review all Analytical Results to confirm that the analytical results are
complete (i.e., there is an analytical result for each required constituent in each well). The
QA Manager shall also identify and report all instances of non-compliance and non-
conformance as required by the Permit. Director approval will be required for any
completeness (prior to QNQC analysis) less than 100 percent. Non-conformance will be
defined as a failure to provide field parameter results and analytical results for each parameter
and for each well required in Sections 6.2.2 and 6.2.3, for the sampling event, without prior
written Director approval.
9.1.3 Blank Comparisons
Trip blanks, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not an order of magnitude greater than the blank result. (TEGD, Field QNQC
Program, page 119).
Corrective actions for blank comparison non-conformance shall first determine if the non-
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will:
1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
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4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.
9.1.4 Duplicate Sample Comparisons
The following analyses will be performed on duplicate field samples:
a) Relative Percent Difference.
RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD ~20%, unless the measured concentrations
are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review,
February 1994, 9240.1-05-01, p. 25).
b) Radiologies Counting Error Term
All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting
variance that is equal to or less that 20% of the reported activity concentration. An error
term may be greater than 20% of the reported activity concentration when the sum of the
activity concentration and error term is less than or equal to the GWCL.
c) Rad.iologics, Duplicate Samples
Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:
Where:
A = the first duplicate measurement
B = the second duplicate measurement
Sa 2 = the uncertainty of the first measurement squared
Sb 2 = the uncertainty of the second measurement squared
Non-conformance exists when the foregoing equation is > 2.
(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).
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Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section IO. If the non-
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.
9.2 Analytical Laboratory QA Reviews
Full validation will include recalculation of raw data for a minimum of one or more analytes
for ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC
review which will include validating holding times and QC samples. Overall data assessment
will be a part of the validation process as well.
The Analysis Monitor or data validation specialist will evaluate the quality of the data based
on SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The
reviewer will check the following:
(1) sample preparation information is correct and complete,
(2) analysis information is correct and complete,
(3) appropriate Analytical Laboratory procedures are followed,
(4) analytical results are correct and complete,
(5) QC samples are within established control limits,
(6) blanks are within QC limits,
(7) special sample preparation and analytical requirements have been met, and
(8) documentation is complete.
The Analytical Laboratory will prepare and retain full QC and analytical documentation. The
Analytical Laboratory will report the data as a group of one batch or less, along with the
QNQC data. The Analytical Laboratory will provide the following information:
(1) cover sheet listing samples included in report with a narrative,
(2) results of compounds identified and quantified,
(3) reporting limits for all analytes, and
(4) QNQC analytical results.
9.3 QA Manager Review of Analytical Laboratory Results and Procedures
The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:
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Quality Assurance Plan (QAP)
a) Reporting Limit (RL) Comparisons
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The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are
in conformance with the reporting limits set out on Table 1. Non-conformance shall be
defined as:
1) a reporting limit that violates these provisions, unless the reporting limit must be increased
due to sample matrix interference (i.e., due to dilution); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.
b) Laboratory Methods Review
The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory
are those specified in Table 1, unless otherwise approved by the Director. Non-conformance
shall be defined when the Analytical Laboratory uses analytical methods not listed in Table 1
and not otherwise approved by the Director.
c) Holding Time Examination
The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.
d) Sample Temperature Examination
The QA Manager shall review the analytical reports to verify that the samples were received
by the Analytical Laboratory at a temperature no greater than the approved temperature listed
in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.
9.4 Analytical Data
All QA/QC data and records required by the Analytical Laboratory's QA/QC program shall
be retained by the Analytical Laboratory and shall be made available to EFRI as requested.
Analytical data submitted by the Analytical Laboratory should contain the date/time the
sample was collected, the date/time the sample was received by the Analytical Laboratory,
the date/time the sample was extracted (if applicable), and the date/time the sample was
analyzed.
All out-of-compliance results will be logged by the Analysis Monitor with corrective actions
described as well as the results of the corrective actions taken. All raw and reduced data will
be stored according to the Analytical Laboratory's record keeping procedures and QA
program. All Analytical Laboratory procedures and records will be available for on-site
inspection at any time during the course of investigation.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 02-15-2022 Revision 7.7
Quality Assurance Plan (QAP) . Page 29 of61
If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will be
consulted to establish more appropriate analytical approaches for problem samples.
10.0 CORRECTIVE ACTION
10.1 When Corrective Action is Required
The Sampling and QC Monitors and Analytical Laboratory are responsible for following
procedures in accordance with this QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. All deviations from
field sampling procedures will be noted during field data collection. Any QA/QC problems
that arise will be brought to the immediate attention of the QA Manager. Analytical
Laboratory deviations will be recorded by the Analysis Monitor in a logbook as well.
When a procedural or systematic non-conformance is identified, EFRI shall:
a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to be
systematic or procedural, EFRI shall determine the root cause, and provide specific
steps to resolve problems(s) in accordance with the procedure set forth in Section
10.2. Any non-conformance with QAP requirements in a given quarterly
groundwater monitoring period will be corrected and reported to the Director on or
before submittal of the next quarterly ground water monitoring report.
b) When a sample is lost, sample container broken, or the sample or analyte was
omitted, resample within 10 days of discovery and analyze again in compliance with
all requirements of this QAP. The results for this sample(s) should be included in the
same quarterly monitoring report with other samples collected for the same sampling
event; and
c) For any other material deviation from this QAP, the procedure set forth in Section
10.2 shall be followed.
10.2 Procedure for Corrective Action
The need for corrective action for non-conformance with the requirements of this QAP, may
be identified by system or performance audits or by standard QA/QC procedures. The
procedures to be followed if the need for a corrective action is identified, are as follows:
a) Identification and definition of the problem;
b) Assignment of responsibility for investigating the problem;
c) Investigation and determination of the cause of the problem;
Mill -Groundwater Discharge Permit
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d) Determination of a corrective action to eliminate the problem;
e) Assigning and accepting responsibility for implementing the corrective action;
t) Implementing the corrective action and evaluating its effectiveness; and
g) Verifying that the corrective action has eliminated the problem.
The QA Manager shall ensure that these steps are taken and that the problem which led to the
corrective action has been resolved. The corrective actions will be documented either in a
memorandum explaining the steps outlined above, which will be placed in the applicable
monitoring files and the Mill Central Files, or the corrective action will be documented in the
quarterly reports prepared in accordance with Section 11.
11.0 REPORTING
As required by the GWDP, the Mill will send a groundwater monitoring report to the
Director on a quarterly basis. Both the Routine Groundwater Monitoring Reports and
Chloroform Investigation and Nitrate Corrective Action Reports shall be submitted according
to the following schedule:
Quarter Period Due Date
First January -March June 1
Second April-June September 1
Third July -September December 1
Fourth October -December March 1
The Routine Groundwater Monitoring Reports (required by the GWDP) will include the
following information:
• Description of monitor wells sampled
• Description of sampling methodology, equipment and decontamination
procedures to the extent they differ from those described in this QAP
• A summary data table of groundwater levels for each monitor well and
piezometer
• A summary data table showing the results of the sampling event, listing all
wells and the analytical results for all constituents and identifying any
constituents that are subject to accelerated monitoring in any particular wells
pursuant to the GWDP or are out of compliance in any particular wells
pursuant to the GWDP
• Field data recorded during sample collection
• Copies of Analytical Laboratory results
• Copies of Chain of Custody Forms (included in the data packages)
Mill -Groundwater Discharge Permit
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• A Water Table Contour Map showing groundwater elevation data for the
quarter will be contemporaneous for all wells on site, not to exceed a
maximum time difference of five calendar days.
• Evaluation of groundwater levels, gradients and flow directions
• Quality assurance evaluation and data validation description (see Section 9 for
further details)
• All non-conformance with this QAP and all corrective actions taken
With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B to this document.
In addition, an electronic copy of all analytical results will be transmitted to the DWMRC in
comma separated values ("CSV") format, or as otherwise advised by the DWMRC.
Further reporting may be required as a result of accelerated monitoring under the GWDP.
The frequency and content of these reports will be defined by EFRI corporate management
working with the Director.
12.0 SYSTEM AND PERFORMANCE AUDITS
12.1 QA Manager to Perform System Audits and Performance Audits
EFRI shall perform such system audits and performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined
byEFRI.
12.2 System Audits
System audits are qualitative evaluations of all components of field and Analytical
Laboratory QC measurement systems. They determine if the measurement systems are being
used appropriately. System audits will review field and Analytical Laboratory operations,
including sampling equipment, laboratory equipment, sampling procedures, and equipment
calibrations, to evaluate the effectiveness of the QA program and to identify any weakness
that may exist. The audits may be carried out before all systems are operational, during the
program, or after the completion of the program. Such audits typically involve a comparison
of the activities required under this QAP with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data
collection and management activities.
Mill -Groundwater Discharge Permit
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12.3 Performance Audits
Date: 02-15-2022 Revision 7 .7
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The performance audit is a quantitative evaluation of the measurement systems of a program.
It requires testing the measurement systems with samples of known composition or behavior
to evaluate precision and accuracy. With respect to performance audits of the analytical
process, either blind performance evaluation samples will be submitted to the Analytical
Laboratory for analysis, or the auditor will request that it provide results of the blind studies
that the Analytical Laboratory must provide to its NELAP accreditation agency on an annual
basis. The performance audit is carried out without the knowledge of the analysts, to the
extent practicable.
12.4 Follow-Up Actions
Response to the system audits and performance audits is required when deviations are found
and corrective action is required. Where a corrective action is required, the steps set out in
Section 10.2 will be followed.
12.5 Audit Records
Audit records for all audits conducted will be retained in Mill Central Files. These records
will contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit findings or corrective actions.
13.0 PREVENTIVE MAINTENANCE
Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.
Field instruments will be maintained as per the manufacturer's specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in
accordance with Section 5. Batteries will be charged and checked daily when these
instruments are in use. All equipment out of service will be immediately replaced. Field
instruments will be protected from adverse weather conditions during sampling activities.
Instruments will be stored properly at the end of each working day. Calibration and
maintenance problems encountered will be recorded and addressed as soon as practical.
The Analytical Laboratory is responsible for the maintenance and calibration of its
instruments in accordance with Analytical Laboratory procedures and as required in order to
maintain its NELAP certifications. Preventive maintenance will be performed on a scheduled
basis to minimize downtime and the potential interruption of analytical work.
Mill -Groundwater Discharge Permit
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Page 33 of61
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT
14.1 Ongoing QA/QC Reporting
The following reporting activities shall be undertaken on a regular basis:
a) The Sample and QC Monitors shall report to the QA Manager regularly regarding
progress of the applicable sampling program. The Sample and QC Monitors will
also brief the QA Manager on any QNQC issues associated with such sampling
activities.
b) The Analytical Laboratory shall maintain detailed procedures for laboratory record
keeping. Each data set report submitted to the Mill's QA Manager or his staff will
identify the analytical methods performed and all QNQC measures not within the
established control limits. Any QNQC problems will be brought to the QA
Manager's attention as soon as possible; and
c) After sampling has been completed and final analyses are completed and reviewed, a
brief data evaluation summary report (case narrative) will be prepared by the
Analytical Laboratory for review by the QA Manager, by a Sampling and QC
Monitor or by such other qualified person as may be designated by the QA Manager.
The report will be prepared in accordance with NELAP requirements and will
summarize the data validation efforts and provide an evaluation of the data quality.
14.2 Periodic Reporting to Management
The QA Manager shall present a report to EFRI' s ALARA Committee at least once per
calendar year on the performance of the measurement system and the data quality. These
reports shall include:
a) Periodic assessment of measurement quality indicators, i.e., data accuracy, precision
and completeness;
b) Results of any performance audits, including any corrective actions;
c) Results of any system audits, including any corrective actions; and
d) Significant QA problems and recommended solutions.
15.0 AMENDMENT
This QAP may be amended from time to time by EFRI only with the approval of the
Director.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
16.0 REFERENCES
Date: 02-15-2022 Revision 7.7
Page 34 of61
United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.
United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document (TEGD), Office of Solid Waste and
Emergency Response, OSWER-9950.1.
United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.
Standard Methods for the Examination of Water and Wastewater, 201h Edition, 1998.
American Public Health Association, American Water Works Association, Water
Environment Federation. Washington, D.C. p. 1-7.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENT 1
Field and Data Forms
Date: 02-15-2022 Revision 7.7
Page 35 of61
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Attachment 1-1
Quarterly Depth to Water Data Sheet
NAME:
DATE:
Depth to Depth to
D11te Time Well Water (n.) Date Time Well Water (f'C.)
Date: 02-15-2022 Revision 7.7
Date T1me
Page 36 of61
Well
Depth to
Water
(f'l.)
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 37 of61
ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET J'OR GROUNDWATER
A'ITACHMF:NT 1-2
WHfffi MESA URANIUM MILL
FIELD DATA WORI<SHEETJ!'OR GROUNDWA'JER
Description or Sampling Evenl:
Location (well name): ~-------------0
Field Sample ID
Sampler Name
and initials:
Date and Time for Purging..._ _______ __, and Sampling (if different)
Well Purging Equip Used: [filpump or [fil bailer Well Pump (if other lhan Bennet)
Purging Method Used:
1 ) Sec lns11uclion
[filz casings [fil3 casings
Prev. Well Sampled in Sampling Event I..__ _______ __, Sampling Event ~---------__,
pll Buffer 7.0 !..__ ____ _,
Specific Conduclance! .... ____ __..,jµMHOS/ cm
Depth lo Water Before Purging._! ___ __.
Weather Cond.
Time I I Gal. Purged I I
Conductance I I pH I I
Temp. °C I I
Redox Potential Eh (mV) I
Turbidity (NTU) I
Time I I Gal. Purged I
Conductance I I pH I
Temp. °C I I
Rcdox Potential Eh (mV) I I
Turbidily (NTU) I I
pH Ruffer 4.0
Well Dcpth(O.Olft):
Casing Volume (Y) 4" Wcll:I l(.653h)
3" Wcll:1-----1. (.367h)
Ext'I Amb. Temp. •c (prior sampling event) ._I ___ _,
Time I I Gal. Purged I I
Conductance I I pH! I
Temp. °C I I
Rcdox Potential Eh (mV) I I
Turbidity (NTU) I I
Time I I Gal. Purged I I
Conduclnncc I I pHI I
Temp, ~c I I
Redox Potenlial Eh (mY) I I
Turbidity (NTU) I I
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Volume of Water Purged
Pumping Rah: C11lc11ln1ion
gallon(s)
Date: 02-15-2022 Revision 7 .7
Page 38 of61
Flow Rate (Q). in w,11.
S/60 = I.__ ___ __, Time to evacuate two ,using volumes (2Y)
T =2V/Q=I l
Number of casing volumes evacuated (if other than two)
If well evacuated lo dryne.~s. number of gallons evacuated
Name of Certified Analytical Laboratory if Other Than Energy Labs
Sample Taken Sample Vol (indicatc if Filtered Preservative Preservative Added Type or Sample other than as specified Type y N below) y N y N
voes D D 3x40 ml D D HCL D D
Nutrients D D 100ml D D H2S04 D D
Heavy Metals D D 250ml D D HN03 D D
All Other Non Radiolo2ics D D 250ml D D No Preserv. D D
Gross Alpha D D 1,000 ml D D HN03 D D
Other (specify) D D Sample volume D D D D
If preservative is used, specify
Type and Quantity of
Preservative:
Final Depth ~' -----~ Sample Time
Comment
I -, See instruction
.._ _______ __,Do not touch this cell (SheetName)
Mill -GroundwaLcr Discharge Permit
Groundwater Monitoring
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Dace: 02-15-2022 Revision 7.7
Page39 of61
ATTACHMENT 1-3
EXAMPLE FIELD DATA REPORT
White Mesa MIii
Ftald o ... Wort<&IIMI For OICIUl\dMmr
L-nlD MW-11
FIHIBamlllalD MW-U D3062019
l'ur11• o.te & Tlma 3/6/2019 6:55
lamole Da1e & Tllne 3/S/20U U,25
l'ur111na EciutomeM. Pumo
l'umpTIIINI 0£0
PUTlllna Molhod 2casin11S Pr'filo111 Well 811
C•olna Volume 111111 Z!l.12
c11cu10111d Cuing VolUmff Pu.a• Oun,uon (mlnJ 26U2
'oH lutr.r r.o 7.0
'oH luffar •.o 4.0
lloaclflc Conduemnce imleroffllH>I) 1000
Da1a1T1ma Oollons Purald Conductlvltv Jiff TMllllllleaC}
l/6/201911:22 S7.93 2917 HS 14.02
3/6/2019 U :23 58.15 2927 7.46 14.Dl
3/6/201.9 II :24 58.37 2925 7.48 14.DD
3/6/2019 U:25 58.59 29.30 7.48 14.01
!Volumo or w.i.r pmqoc1 (p-"I
&HO
Anll tc;.al " lnt01mat1on
S.mple
Col,ic;J.ed? Matrl• Numllel
V WATER 1
aO',W\4*-tilM Ot\oft41,1 g,11 Pan:tl
O!'...-wMmllonoo_/lsl_ .. Flan
Mardi 2019
TH/OL
!!loud
D
MW-30
130.00
85.40
1 ..... 0 .. _
Rado• TUrbldlll/ O•wan llefMa/Allal
266 0
262 0
259 0
256 0
.217
270.00
UK)
0
Preservative
Added?
y
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
ATTACHMENT 2
Field Procedures
Date: 02-15-2022 Revision 7.7
Page 40 of61
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Attachment 2-1
Date: 02-15-2022 Revision 7.7
Page 41 of61
Groundwater Head (Depth to Water) Measurement Procedures
Measure and record all depth to water data to the nearest 0.01 feet.
Equipment Used For Groundwater Head Monitoring
Measurement of depth to groundwater is accomplished by using a Solinist -IT 300 or
equivalent device (the "Water Level Indicator").
Equipment Checks
Equipment used in depth to groundwater measurements will be checked prior to each day's
use to ensure that the Water Sounding Device is functional.
Check the Water Sounding Device as follows:
• Turn the Water Level Indicator on.
• Test the Water Level Indicator using the test button located on the instrument.
• If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.
Measurement of Depth to Water
All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:
• For monitoring wells -Measure depth to water from the top of the inner well casing at
the designated measurement point.
• For the piezometers -Measure depth to water from the top of the casing at the
designated measurement point.
• Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
• Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Attachment 2-2
Date: 02-15-2022 Revision 7.7
Page 42 of61
Decontamination Procedures
Non-dedicated sampling equipment will be decontaminated using the following
procedures:
Water level meter
Decontaminate the water level meter probe with deionized ("Dr') water.
Field Parameter Instrument (Hydrolab or equivalent)
Rinse the field parameter instrument probe unit with DI water prior to each
calibration.
Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.
Non-Dedicated Purging/Sampling Pump
Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:
a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;
b) pump the detergent/DI water solution through the pump and pump outlet lines;
c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
d) submerge the pump into a 55-gallon drum of DI water;
e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;
t) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;
g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page43 of61
h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).
All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Attachment 2-3
Purging Procedures
Date: 02-15-2022 Revision 7.7
Page 44 of61
The following equipment will be used for groundwater purging and sampling:
• Disgosable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These hailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
• Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
• Non -Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
• Field Parameter Meter: A meter used to measure groundwater quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:
~ Water temperature;
~ Specific conductivity;
~ Turbidity;
~ pH;
~ Redox potential (Eh);
~ Dissolved Oxygen ("DO")
• Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
• Generator: Mobile power supply to provide power for submersible pump.
• 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
"bladder" pumps.
Additional supplies for purging and sampling are as follows:
• IPad, tablet, Cell phone or Field Data Sheets
• 45 micron in-line filters (when metals and gross alpha analyses are required)
• Calculator
• Clock, stopwatch or other timing device
• Buckets
• Sampling containers (as provided by the Analytical Laboratory)
• Field preservation chemicals (as provided by the Analytical Laboratory)
• Disposable gloves
• Appropriate health and safety equipment
• Sample labels (as provided by the Analytical Laboratory)
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Pre-Purging/ Sampling Activities
Date: 02-15-2022 Revision 7.7
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If a portable (non-dedicated) pump is to be used, prior to commencing the event's sampling
activities,
1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) and ice into a cooler that will
transport the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC)
samples throughout the monitoring event.
Well Purging
The purging techniques described below will be used for all groundwater sampling conducted
at the Mill unless otherwise stated in the program-specific QAPs for the chloroform and
nitrate investigations. The program-specific QAPs for the chloroform and nitrate
investigations are included as Appendix A and Appendix B respectively.
Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:
1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.
Turbidity measurement in the water should be 5 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.
A flow-cell needs to be used for field parameters.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 02-15-2022 Revision 7.7
Page 46 of 61 Quality Assurance Plan (QAP)
Procedure
a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)
b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;
c) Determine the casing volume (V) in gallons. When using the electronic data
collection module, input the depth to water in the appropriate location. The module
will calculate the casing volume. Proceed to purging. When the field data are
collected manually, calculate the casing volume where h is column height of the
water in the well (calculated by subtracting the depth to groundwater in the well from
the total depth of the well), V = 0.653*h, for a 4" casing volume and V = .367*h for
a 3" casing volume. Record the casing volume on the Field Data Worksheet;
If a portable (non-dedicated) pump is used:
• Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
• Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.
If a non-dedicated pump or dedicated pump is used:
(i) Commence pumping;
(ii) For a non-dedicated pump only, determine pump flow rate by using a
stopwatch or other timing device and a calibrated bucket by measuring the
number of seconds required to fill to the one-gallon mark. Record this in the
"pumping rate" section on the Field Data Worksheet or in the "flow rate"
section in the electronic field collection module;
(iii) Calculate the amount of time to evacuate two or three casing volumes;
(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);
(v) If two casing volumes will be purged:
Take measurements of field parameters (pH, specific conductance,
temperature, redox potential, turbidity, and DO) during well purging, using the
Mill -Groundwater Discharge Permit
Groundwater Monitoring
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Date: 02-15-2022 Revision 7.7
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Field Parameter Meter. These measurements will be recorded either
electronically or on the Field Data Worksheet. Purging is completed after two
casing volumes have been removed and the field parameters pH, temperature,
specific conductance, redox potential (Eh), turbidity, and DO have stabilized
to within 10% RPD over at least two consecutive measurements.
(vi)lf three casing volumes will be purged:
Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential, turbidity, and DO) after three casing volumes
have been purged immediately prior to sample collection using the Field
Parameter Meter. Record these measurements either electronically or on the
Field Data Worksheet.
(vii) If the well is purged to dryness:
Record the number of gallons purged either electronically or on the Field Data
Worksheet.
The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.
Upon arrival at the well after recovery or when sufficient water is available for
sampling measure depth to water and record either electronica1ly or on the
Field Data Worksheet.
Take one set of measurements of field parameters for pH, specific
conductance and temperature only.
Collect the samples into the appropriate sample containers.
Take an additional set of measurements of field parameters for pH, specific
conductance and temperature after the samples have been collected.
If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.
If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.
Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.
Mill -Groundwater Discharge Permit
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Quality Assurance Plan (QAP)
Purging using a disposable bailer
Date: 02-15-2022 Revision 7 .7
Page 48 of61
For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.
When a bailer is used, the following procedure will be followed:
(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.
(ii) Attach a disposable bailer to a rope and reel.
(iii)Lower the bailer into the well and listen for contact with the solution. Once
contact is made, allow the bailer to gradually sink in the well, being careful
not to allow the bailer to come in contact with the bottom sediment.
(iv)After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.
(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.
(vi)Take field measurements from the water in the buckets.
All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.
After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
Mill -Groundwater Discharg~ Pennit
Ground water Monitoring
Quality Assurance Plan (QAP)
Attachment 2-4
Sample Collection Procedures
Sample Collection Order
Dale; 02-1.5-2022 Revision 7,7
Page 49 of 61
Regardless of the purging method employed samples will be collected in the order specified
below.
All containers and preservatives will be provided by the Analytical Laboratory. ColJect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.
VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologies (general inorganics, TDS, anions. total cations and total anions);
and
Gross alpha and he~vy metals (filtered).
Sample Filt~ri~g
When sampling for heavy metals and for gross alpha, the following procedure shall be
followed:
a) Obtain the specifically identified sample container for the type of samp]e to be
taken, as provided by the Analytical Laboratory;
b) Add the quantity of specified preservative provjded by the Analytical Laboratory to
each sample container;
c) When using a pump to sample:
(i) Place a new 0.45 micron filter on the sample tubing;
(ii) Pump the sample through the filter, and into the sample container containing
the preservative;
(iii) The pump should be operated so that it does not produce samples that are
aerated in the return tube or upon discharge;
d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:
(i) Collect samples ftom the bailer into a large, unused samp]e jug that does not
contain any preservatives.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 50 of61
(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.
(iii) Place dean unused tubing in the peristaltic pump.
(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.
Procedures to Follow After Sampling
a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:
• Sample location
~ Date and time of sample
• Any preservation method utilized
• Filtered or unfiltered
b) Immediately after sample collection, place each sample in an ice-packed cooler;
and
c) Before leaving the sampling location, thoroughly document the sampling event
either electronically or on the Field Data Worksheet, by recording all pertinent
data.
Upon returning to the office, the samples must be stored in a refrigerator at less than or equal
to 6° C. These samples shall be received by the Analytical Laboratory at less than or equal to
6° C. Samples will then be re-packed in the plastic ice-packed cooler and transported via
these sealed plastic containers by overnight delivery services to the Analytical Laboratory.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Field Duplicates
Attachment 2-5
Field QC Samples
Date: 02-15-2022 Revision 7.7
Page 51 of61
Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.
Field duplicate samples should be as near to split samples as reasonably practicable.
Collection of field duplicates is completed as follows:
Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.
Field duplicate samples are labeled using a "false" well number such as MW-65 and MW-70.
Equipment Rinsate Samples
Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples collected from non-
pumping wells. Pumping wells have dedicated pumps and will not be included in the total
sample count for the purposes of calculating the number of required rinsate samples.
Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:
Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;
Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).
Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter "R" added ( e.g. MW-1 lR).
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Appendix A
Date: 02-15-2022 Revision 7.7
Page 52 of 61
Chloroform Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 53 of61
Chloroform Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
This document sets out the quality assurance plan to be used by EFRI for Chlorofonn
monitoring conducted pursuant to the Groundwa.ter Corrective Action Plan ("GCAP") found
in Attachment 1, of the final Stipulation and Consent Order ( .. SCO") dated September 14,
2015. (UDEQ Docket No. UGW-20-01).
Specifically, the Mill will use the same sampling regimen for the Chlorofonn Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
fortn below:
I) Dedicated Purge Pump/Sampling
Chloroform samples are collected by means of disposabie bailer(s) the day following
the purging. The disposable bailer is used only for the collection of a sample from an
individual well and disposed subsequent to the sampling. The wells are purged prior
to sampling by means of a portable pump. Each quarterly purging event begins at the
location least affected by chloroform (b~sed on the previous quarters sampling event)
and proceeds by affected concentration to the most affected location. Although
purging will generally follows this order, the sampling order may deviate slightly
from the generated list. This practice does not affect the samples for these reasons:
any wells sampled in slightly different order have either dedicated pumps or are
sampled via a disposable bailer. This ptactice docs not affect the quality or usability
of the data as there will be no cross~contamination resulting from sampling order.
Decontamination of all sampling equipment will follow the decontamination
procedure outlined in Attachment 2-2 of the QAP.
2) Chloroform lnve tigation,Sampling Frequency, Order and Locations
The chloroform investigation wel1s listed below are required to be monitored on a
quarterly basis under SCA and GCAP. Chloroform wells shall be purged from the
least contaminated to the most contaminated as based on the most recent quarterly
results.
• MW-4 • TW4-22
• TW4-l • TW4-23
• TW4-2 • TW4-24
• TW4-3 • TW4-25
• TW4-4 • TW4-26
• TW4-5 • TW4~27
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
• TW4-6
• TW4-7
• TW4-8
• TW4-9
• TW4-10
• TW4-11
• TW4-12
• TW4-13
• TW4-14
• MW-26
• TW4-16
• MW-32
• TW4-18
• TW4-19
• TW4-20
• TW4-21
• TW4-28
• TW4-29
• TW4-30
• TW4-31
• TW4-32
• TW4-33
• TW4-34
• TW4-35
• TW4-36
• TW4-37
• TW4-38
• TW4-39
• TW4-40
• TW4-41
• TW4-42
• TW4-43
Date: 02-15-2022 Revision 7.7
Page 54 of61
Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform Program or
the Groundwater Discharge Permit Monitoring Program.
3) Chloroform Sample Containers and Collection Volume
The chloroform sampling program requires a specific number of sampling containers
and the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
• For Inorganic Chloride, collect one sample into a 500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laborato1y Requirements
Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Analytical Analytical
Parameter Method
Nitrate & Nitrite E353.1 or
(asN) E353.2 or
A4500-
N03F
Carbon SW8260B,
Tetrachloride SW8260C
or
SW8260D
Chloroform SW8260B,
SW8260C
or
SW8260D
Dichloromethane SW8260B,
(Methylene SW8260C
Chloride) or
SW8260D
Chloromethane SW8260B,
SW8260C
or
SW8260D
Inorganic A4500-CIB
Chloride or A4500-Cl
E
or E300.0
5) Field Parameters
Date: 02-15-2022 Revision 7.7
Page 55 of 61
Reporting Maximum Sample Sample
Limit Holding Preservation Temperature
Times Requirement Requirement
0.1 mg/L 28 days H2S04 to :5 6°C
pH<2
1.0 µg/L 14 days HCI topH<2 :5 6°C
1.0 µg/L 14 days HCl to pH<2 :5 6°C
1.0 µg/L 14 days HCl to pH<2 :5 6°C
1.0 µg/L 14 days HCl topH<2 :5 6°C
1 mg/L 28 days None :5 6°C
Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. However, if a pumping well has been out of service for
48 hours or more, EFRI shall follow the purging requirements outlined in Attachment
2-3 of the QAP before sample collection.
Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.
6) Chl oroform Quarterly Reports
The Chloroform Quarterly Reports will include the information required by Part ID of
the GCAP.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 56 of 61
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill's
QAP.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Appendix B
Date: 02-15-2022 Revision 7.7
Page 57 of61
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 02-15-2022 Revision 7.7
Quality Assurance Plan (QAP)
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Page 58 of61
This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Nitrate Corrective Action Monitoring ("Nitrate Program") conducted pursuant to the
Stipulation and Consent Order ("SCO"), Docket Number UGW12-04, which approved the
EFRI CAP, dated May 7, 2012.
Specifically, the Mill will use the same sampling regimen for the Nitrate program that is
utilized for groundwater sampling under its groundwater discharge permit, as set forth in the
attached groundwater discharge permit Quality Assurance Plan ("QAP"), except as set forth
below:
1) Purge Pump/Sampling
The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s). The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.
Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross-
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.
2) Nitrate Program Sampling Frequency, Order and Locations
The Nitrate Program wells listed below are required to be monitored on a quarterly
basis as required by the SCO, Docket Number UGW12-04, which approved the EFRI
CAP, dated May 7, 2012. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
• TWN-1
• TWN-2
• TWN-3
• TWN-4
• TWN-6**
• TWN-7
**De12th to water measurements only.
•
• •
•
•
•
•
Date: 02-15-2022 Revision 7.7
Page 59 of61
TWN-14**
TWN-16**
TWN-18
TWN-19**
Piezometer-01
Piezometer-02
Piezometer-03A
7) Nitrate Program Sample Containers and Collection Volume
The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:
• For Nitrate/Nitrite determinations, collect one sample into a 250 ml container.
• For Inorganic Chloride, collect one sample into a 500 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements
Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Date: 02-15-2022 RevisiQn 7.7
Page 60 of 61 Quality Assurance Plan (QAP)
Analytical Analytical Reporting Maximum Sample Sample
Parameter Method Limit Holding Preservation Temperature
Times Requirement Requirement
Nitrate & Nitrite E353. l or 0.1 mg/L 28 days HiS04 to ~6°C
(asN) E353.2 or pH<2
A4500-
N03F
Inorganic A4500-CJ B 1 mg/L 28 days None ~6°C
Chloride or A4500-CI
E
or E300.0
9) fjeJd Parameters
Field parameters will be measured in Nitrate Program wells as de.scribed in
Attachment 2-3 of the groundwater QAP.
10) Nitrate Program Investigation Reports
The Nitrate Program Reports will include the following information:
a) Introduction
b) Sampling and Monitoring Plan
• Description of monitor wells
• Description of sampling methodology, equipment and decontamination
procedures
• Identify all quality assurance samples, e.g. trip bJanks, equipment bJanks,
duplicate samples
c) Data Interpretation
• Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: l) A current site groundwater
contour map, 2) hydrographs to show groundwater el~vation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data tabJe,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
Mill -Groundwater Discharge Permit
Groundwater Monitoring
Quality Assurance Plan (QAP)
Date: 02-15-2022 Revision 7.7
Page 61 of61
• Interpretation of all analytical results for each well, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
• Calculate nitrate mass removed by pumping wens (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate mass
removed from each pumping well for the quarter.
d) Conclusions and Recommendations
e) Electronic copy of all laboratory results for Nitrate Program monitoring
conducted during the quarter.
f) Copies of EFRI field records, laboratory reports and chain of custody
forms.
Except as otherwise specified above, the Mill will follow the procedure set out in the Mill's
QAP.
Appendix L
Tailings and Slimes Drain Sampling Program,
Revision 3.0, July 8, 2016
White Mesa Uranium Mill
SAMPLING AND ANALYSIS PLAN
FOR
THE TAILINGS MANAGEMENT SYSTEM, LEAK
DETECTION SYSTEMS AND SLIMES DRAINS
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
July 8, 2016
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
Contents
1.0 Introduction ............................................................................................................................... 3
2.0 Sampling Frequency and Monitoring Requirements ................................................................ 3
3.0 Field Sampling Procedures ....................................................................................................... 3
3.1 Cell Solution Sampling ......................................................................................................... 4
3.1.1 Sampling with a Peristaltic Pump .................................................................................. 4
3.1.2 Sampling with a Ladle ................................................................................................... 5
3.1.3 Sampling with a Bailer ................................................................................................... 5
3.2 LDS Sampling ....................................................................................................................... 5
3.2.1 Cells 1, 2 and 3 LDS ...................................................................................................... 5
3.2.2 Cells 4A and 4B LDS .................................................................................................... 5
3.3 Slimes Drain Sampling ......................................................................................................... 5
3.4 Decontamination ................................................................................................................... 6
3.5 Field QC ................................................................................................................................ 6
3.5.1 Sample Duplicates ......................................................................................................... 6
3.5.2 Trip Blanks ..................................................................................................................... 6
3.5.3 Rinsate Blank Samples .................................................................................................. 6
4.0 QA and Data Evaluation ........................................................................................................... 7
5.0 Laboratory Analysis .................................................................................................................. 7
5.1 Analytical Quality Control ............................................................................................... 7
6.0 Reporting ................................................................................................................................... 8
7 .0 Agency Notification ................................................................................................................. 8
2
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
1.0 Introduction
This Sampling and Analysis Plan ("SAP") describes the procedures for sampling solutions in the tailings
management system, Leak Detection Systems ("LDS") and slimes drains at the White Mesa Mill in
Blanding, Utah as required under Part I.E.10 of the Groundwater Discharge Permit ("GWDP") No.
UGW370004.
The objective of the sampling is to collect annual samples from the locations identified below as required
by the GWDP. This SAP specifies the sample collection requirements, procedures, analytical
methodologies, and associated Quality Control ("QC") checks, sample handling protocols and reporting
requirements for the annual cell solution, LDS and slimes drain sampling program.
2.0 Sampling Frequency and Monitoring Requirements
The sampling frequency and sample monitoring requirements for the cell solutions, LDS and slimes
drains are as specified in the GWDP. Sampling is required to be conducted on an annual basis in August
of each year for the solutions in Cells 1, 3, 4A, and 4B, the solutions in the slimes drains in Cells 2, 3, 4A,
and 4B (for Cells 3, 4A, and 4B after the commencement of dewatering), the solutions in the LDS in
Cells 4A and 4B and any detected solutions in the LDS in Cells 1, 2, and 3 at the time of the August
sampling event. Sampling locations are shown in Attachment 1.
3.0 Field Sampling Procedures
The field sampling and data collection program will obtain samples to be analyzed for the groundwater
compliance parameters listed in Table 2 of the GWDP. Analyses will be completed by a State of Utah
certified laboratory using methods specified in the currently approved Energy Fuels Resources (USA) Inc.
("EFRI") Quality Assurance Plan ("QAP") for Groundwater. Additionally per the GWDP requirements,
cell solutions, LDS and slimes drain samples will be collected and analyzed for Semivolatile Organic
Compounds ("SVOCs"). Per the GWDP, the SVOCs will be analyzed by Environmental Protection
Agency ("EPA") Method 8270D. Minimum detection limits or reporting limits for cell solutions, LDS
and slimes drain samples for those analytes which have Groundwater Quality Standards (GWQSs")
defined in Table 2 of the GWDP, will be less than or equal to the GWQS. The minimum detection or
reporting limits for total dissolved solids ("TDS") sulfate, chloride and SVOCs are specified in the
GWDP and are:
• TDS will be less than or equal to 1,000 mg/L,
• Sulfate will be less than or equal to 1,000 mg/L,
• Chloride will be less than or equal to 1 mg/L, and
• SVOCs will have reporting limits less than or equal to the lower limit of quantitation for
groundwater listed in Table 2 of EPA Method 8270D Revision 4, dated February 2007.
Field activities include collecting samples, recording field data and field parameters, and preparing and
shipping samples to the analytical laboratory.
Sampling information will be recorded on the Tailings Management System and Slimes Drain Field
Sheet, (or its equivalent), included in Attachment 2.
3
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
Sample handling and preservation requirements for cell solutions, LDS and slimes drain samples are as
specified in the QAP, except for SVOCs which are not routinely collected for any other Mill sampling
program. SVOCs do not require any chemical preservation per EPA Method 8270D; however, SVOCs
are required to be chilled. Receipt temperatures, for all analytes except SVOCs, are as specified in the
QAP. The receipt temperature requirement for SVOCs is less than or equal to 6°C.
Sample collection procedures for cell solutions, LDS and slimes drain samples are as described below.
Where more than one sampling method is described, field personnel will choose a sampling method based
on field conditions and safety considerations at the time of sampling.
The gross alpha and metals sample aliquots of the cell solutions, LDSs and slimes drains will not be field
filtered or field preserved due to safety concerns associated with the filtering apparatus and the
backpressure created by the increased viscosity of these samples. The gross alpha and metals aliquots
will be filtered and preserved by the analytical laboratory within 24 hours of receipt. Field preservation of
the gross alpha and metals sample aliquots may interfere with the laboratory's ability to filter the samples
upon receipt. It is important to note that field preservation of the samples is to preclude biological growth
and prevent the inorganic analytes from precipitating. Based on the previous field data, the cell solutions,
LDS and slimes drain samples were at a pH of 3.0 or less at the time of collection without additional
preservative. The addition of preservatives in the field would add minimal if any protection from
biological growth or precipitation. The VOC sample aliquots will be preserved in the field.
Clean sample containers utilized for this sampling effort will be provided by the analytical laboratory.
3.1 Cell Solution Sampling
As noted in Section 2.0, sampling is required to be conducted on an annual basis in August of each year
for the solutions in Cells 1, 3, 4A, and 4B.
Cell solution samples may be collected using a ladle, a peristaltic pump or a bailer. The procedures for
each sampling method are described below. In all instances the sampling equipment will be either
disposable or dedicated and decontamination procedures and rinsate blanks will not be required.
Sampling equipment will be inert and non-reactive.
3 .1.1 Sampling with a Peristaltic Pump
Cell solution samples may be collected using a peristaltic pump. Samples collected with the peristaltic
pump will be collected by extending collection tubing approximately 6 ft. from the edge of the sampling
station. The tubing will be attached to a horizontal rod with sufficient tubing attached to lower the
suction end of the tubing to approximately 2 feet below the surface. The collection tubing will be attached
to a peristaltic pump. The tubing will be replaced prior to each use to preclude cross contamination and to
eliminate the need for decontamination of sampling equipment. Due to the nature of the peristaltic pump,
sample fluids do not come in contact with any surface other than the interior of the tubing, and
decontamination of the pump or rinsate blanks is therefore not required. The sample containers will be
filled directly from the peristaltic pump outflow. Field filtering and field preservation of the gross alpha
and metals sample aliquots will not be required, as noted in Section 3.0.
4
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
3.1.2 Sampling with a Ladle
Cell solution samples may be collected using a ladle. Samples collected with the ladle will be collected
by dipping the ladle directly into the solution. Sample bottles will be filled directly from the ladle. Ladles
used for sampling will be dedicated to each location or will be disposed after each use to preclude cross
contamination and to eliminate the need for decontamination of sampling equipment. Field filtering and
field preservation of the gross alpha and metals sample aliquots will not be completed as noted in Section
3.0.
3.1.3 Sampling with a Bailer
Cell solution samples may be collected using a disposable bailer. Samples collected with the bailer will
be collected by submerging the bailer into the solution and allowing it to fill, taking care not to allow the
bailer to contact the bottom of the cell. The bailer will withdrawn from the solution and the sample bottles
will be filled directly from the bailer. Bailers used for sampling will be disposed after each use to
preclude cross contamination and to eliminate the need for decontamination of sampling equipment.
Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as
noted in Section 3.0.
3.2 LDS Sampling
The LOS systems will be sampled as noted below.
3.2.1 Cells I, 2 and 3 LOS
The Cells 1, 2 and 3 LOSs will only be sampled if there is fluid present during the August sampling
event. If fluids are present during the annual August sampling event, samples will be collected using the
dedicated pumps installed in the riser pipe. Fluid level will be measured using the electronic pressure
transducers currently installed in the LOS systems in the cells. Samples will be collected directly from
the pump outflow lines into the sample containers. Field filtering and field preservation of the gross alpha
and metals sample aliquots will not be required as noted in Section 3.0.
3.2.2 Cells 4A and 4B LDS
Solution from the Cell 4A and 4B LOS will be collected into a dedicated stainless steel bucket. Sample
bottles will be filled from the stainless steel bucket using either the peristaltic pump or a ladle. If the
peristaltic pump is used to transfer the solution to the sample bottles, the tubing in the pump will be
disposed of and not reused, thereby eliminating the need for decontamination of equipment or rinsate
blanks. If a ladle is used to transfer the solution to the sample bottles, the ladle will be either disposed of
or will be dedicated to that location thereby eliminating the need for decontamination or rinsate blanks.
Field filtering and field preservation of the gross alpha and metals sample aliquots will not be required as
noted in Section 3.0.
3.3 Slimes Drain Sampling
Once a tailings cell has started de-watering procedures, a sample should be collected from the slimes
drain system. At this time Cell 2 is the only slimes drain that should be sampled. The location of the
slime drain for Cell 2 is depicted on Attachment 1. While Cell 3, Cell 4A and 4B are each equipped with
5
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
a slimes drain sample access location, these Cells have not started dewatering and the slimes drain will
not be sampled until dewatering operations are underway. Because de watering in Cell 2 is ongoing, this
cell will be included in the annual sampling effort. The Cell 2 slimes drain will be sampled using a
disposable bailer.
A disposable bailer will be used to collect Cell 2 slimes drain samples and will be used to fill clean
sample containers. The bailer will be disposed of and not reused, thereby eliminating the need for
decontamination of equipment or rinsate blanks.
3.4 Decontamination
Decontamination of sampling equipment will be completed if non-dedicated and/or non-disposable
sampling equipment is used to collect samples. Decontamination procedures will be as described in the
approved QAP. Rinsate blanks will be collected daily after decontamination of sampling equipment. If
disposable or dedicated sampling equipment is used to collect samples, then rinsate blanks will not be
collected.
3.5 Field QC
The field QC samples generated during the annual cell solution, LDS and slimes drain sampling event
will include sample duplicates, trip blanks, and rinsate blank samples as appropriate.
3.5.1 Sample Duplicates
Sample duplicates will be collected at a frequency of one duplicate per 20 field samples. Sample
duplicates will be collected by filling the sample container for a certain analytical parameter for the
duplicate immediately following the collection of the parent sample for that parameter.
3.5.2 Trip Blanks
Trip blank samples will be included in every shipment of samples that has field samples to be analyzed
for Volatile Organic Compounds ("VOCs"). Trip blank samples are VOC sample containers filled by the
analytical laboratory with laboratory grade deionized water and shipped to the site. Trip blank samples
are taken into the field with the sample containers, never opened, and kept with the field samples from
collection through shipment to the analytical laboratory for analysis. Trip blanks are analyzed to
determine if the sample concentration of VOCs have been effected by the "trip" from collection through
shipment.
3.5.3 Rinsate Blank Samples
Rinsate blank samples are collected at a frequency of one per day when non-disposable, non-dedicated,
reusable sampling equipment is used to collect samples. If the sampling equipment has a disposable
component that comes in contact with the samples and the component is changed prior to sampling at
each location then a rinsate blank sample will not be collected. For example, if a peristaltic pump is used
to collect and filter tailings, LDS and slimes drain samples and the tubing used in the peristaltic pump is
changed at each location and never reused for more than one sample, no rinsate blank sample would be
required.
6
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
4.0 QA and Data Evaluation
The Permit requires that the annual sampling program be conducted in compliance with the requirements
specified in the Mill's approved QAP, the approved SAP and the Permit itself. To meet this requirement,
the data validation for the sampling program will utilize the requirements outlined in the QAP, the Permit
and the approved SAP as applicable. The Mill QA Manager will perform a QA/QC review to confirm
compliance of the monitoring program with requirements of the Permit, QAP and SAP. As required in
the QAP, data QA includes preparation and analysis of field QC samples, review of field procedures, an
analyte completeness review, and quality control review of laboratory data methods and data.
The QAP and the Permit identify the data validation steps and data quality control checks required for the
tailings cell LDS and slimes drain monitoring program. Consistent with these requirements, the Mill QA
Manager will performed the following evaluations: a field data QA/QC evaluation, a receipt temperature
check, a holding time check, an analytical method check, a reporting limit check, a trip blank check, a
QA/QC evaluation of sample duplicates, a gross alpha counting error evaluation and a review of each
laboratory's reported QA/QC information.
The corrective action procedures described in the approved QAP will be followed as necessary when data
validation and QC reviews indicate a non-compliant situation.
5.0 Laboratory Analysis
As previously stated, samples will be analyzed for the groundwater compliance parameters listed in Table
2 of the GWDP and SVOCs using the analytical methods specified in the approved QAP and EPA
Method 8270D for SVOCs. The Laboratories used for the sampling program will be Utah certified as
required by the GWDP Part l.E.6 (c). Laboratory data will be validated as described in the approved QAP
and as described in Section 4.0 above. Analytical QC is described below.
5.1 Analytical Quality Control
Analytical QC samples and protocols are described in the approved QAP. Laboratory QC procedures will
meet, at a minimum, the requirements set forth in the analytical methods that the laboratory is certified for
by the State of Utah.
The analytical QC samples included at least the following: a method blank, a laboratory control spike
("LCS"), a matrix spike ("MS") and a matrix spike duplicate ("MSD"), or the equivalent, where
applicable. It should be noted that:
• Laboratory fortified blanks are equivalent to LCSs.
• Laboratory reagent blanks are equivalent to method blanks.
• Post digestion spikes are equivalent to MSs.
• Post digestion spike duplicates are equivalent to MSDs.
• For method E900.1, used to determine gross alpha, a sample duplicate was used instead of a
MSD.
7
Tailings Management System, Leak Detections System
and Slimes Drain Sampling and Analysis Plan
Revision 3.0
July 8, 2016
All qualifiers, and the corresponding explanations reported in the QNQC Summary Reports for any of
the analytical QC samples for any of the analytical methods will be reviewed by the Mill QA Manager.
The effect on data usability will be discussed in the evaluation section of the annual report.
6.0 Reporting
An annual Tailings System Wastewater Sampling Report will be included with the 3rd Quarter
Groundwater Monitoring Report, due each year on December 1st.
Each Tailings System Wastewater Sampling Report will include the following information:
• Introduction,
• A description of sampling methodology, equipment and decontamination
procedures identify all quality assurance samples, e.g. trip blanks, equipment
blanks, duplicate samples,
• Analytical data interpretation for each tailing cell, slimes drain, and leak detection system
sample,
• A written summary and conclusions of analytical results,
• A table summarizing historic analytical results,
• A QA evaluation,
• All field data sheets accompanying the sampling event,
• Copies of the laboratory reports, and
• A "Tailings and Slime Drains System Sample Locations Map".
7 .0 Agency Notification
At least 30 days advanced notice will be given to Division of Waste Management and Radiation Control
("DWMRC") prior to sampling activities described in this Tailings Management System, Leak
Detections System and Slimes Drain SAP in order to allow DWMRC to collect split samples of all
samples.
8
Attachment 1
9
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32
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SCALE: 1" • 1,000'
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I
CELL 1
MW-17 •
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33
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•
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• Energy Fuels Resources (USA) Inc.
11/24/1~ RE
Aulhor:
White Mesa Mill
e: Utah
Annual Tailings System,
Cell Solution
Sample Locations
lo: 11/24/15
~ G:i a::
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SAMPLE
LOCATION
4-21
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SCALE: 1" • 1,000'
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REVISIONS
Date By
roJect: White Mesa Mill
San Juan late: Utah
oca ion: T37S, R22E
Author.
Annual Tailings System
Slimes and Leak Detection
Sample Locations
ale: 11/24/15
Attachment 2
10
Field Data Record-Tailings Solutions, LDS and Slimes Drain Sampling
Location: _________ Sampling Personnel: ________ _
Is this a Slimes Drain? D Yes D No
If this is a Slimes Drain, measure depth to wastewater immediately before sampling.
DTW immediately before sampling (slimes only): ___________ _
Weather Conditions at Time of Sampling: ________________ _
Analytical Parameters/Sample Collection Method:
Parametter Sample Takien Pike-Teel ialmub l\fretlto:cl L.al
Per.idttl.1ic: Pump Dai'lv Lmlffe, ~me
voes D Yes D No D Yes DNo D D D
Metals D Yes DNo D Yes DNo D D D
Nutrients D Yes D No o Yes D No D D D
Other Non D Yes D No D Yes D No D D D
Radiologies
Gross Alpha D Yes D No o Yes D No D D D
SVOCs o Yes oNo o Yes DNo D D D
pH/Conductivity o Yes oNo o Yes D No D D D
QC Samples Associated with this Location:
o Rinsate Blank
o Duplicate
Duplicate Sample Name: ___________ _
Notes: ---------------------------------
Appendix M
Contingency Plan, 12/11 Revision: DUSA-4
White Mesa Mill -Standard
Operating Procedures
Book# 19---Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 1 of 15
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
As Contemplated by Part I.G.4(d)
of
State of Utah Groundwater Discharge Permit No.UGW370004
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver CO 80265
December 2, 2010
White Mesa Mill-Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
TABLE OF CONTENTS
Date: 12/11 Revision: DUSA-4
Page 2 of 15
1.0 INTRODUCTION ................................................................................................... 3
2.0 PURPOSE ................................................................................................................ 3
3.0 GROUNDWATER CONTAMINATION ............................................................... 3
3.1 Notification ........................................................................................................... 4
3.2 Continuation of Accelerated Monitoring ............................................................. 4
3.3 Submission of Plan and Timetable ....................................................................... 4
3.4 Groundwater Remediation Plan ........................................................................... 5
4.0 Mil,L DISCHARGE VIOLATIONS -INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONT AMIN ANTS TO THE
T AIT.,IN G CELLS ................................................... -............................................................ 6
4.1 Notifications ......................................................................................................... 6
4.2 Field Activities ..................................................................................................... 6
4.3 Request for Approvals and/or Waivers ................................................................ 7
5.0 DMT VIOLATIONS ............................................................................................... 7
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations ....... 7
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems .............. 8
5.3 Excess Cell 4A Leak Detection System Fluid Head or Daily Leak Rate ............ 9
5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate ........... 10
5.5 Excess New Decontamination Pad Leak Detection System Fluid Head ........... 11
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad .... 11
5.7 Excess Elevation For Tailings Solids ................................................................. 12
5.8 Roberts Pond Wastewater Elevation .................................................................. 13
5.9 Feedstock Storage Area ...................................................................................... 13
5.10 Mill Site Chemical Reagent Storage .............................................................. 14
5.11 Failure to Construct as per Approval.. ............................................................ 15
5.12 Failure to Comply with Stormwater Management and Spill Control
Requirements ............................................................................ _ ..................................... 15
White Mesa Mill -Standard
Operating Procedures
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 3 of 15
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No. UGW370004
1.0 INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
"GWDP") for Denison Mines (USA) Corp.'s ("Denison's") White Mesa Uranium Mill
(the "Mill"). The GWDP specifies the construction, operation, and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into the underlying aquifer.
2.0 PURPOSE
This Contingency Plan (the "Plan") provides a detailed list of actions Denison will take to
regain compliance with GWDP limits and Discharge Minimization Technology Plan
("DMT") and the Best Available Technology Plan ("BAT") requirements defined in Parts
I.C, I.D, and I.H.4 of the GWDP. The timely execution of contingency and corrective
actions outlined in this Plan will provide Denison with the basis to exercise the
Affirmative Action Defense provision in Part I.G.3.c) of the GWDP and thereby avoid
noncompliance status and potential enforcement action 1•
The contingency actions required to regain compliance with GWDP limits and DMT and
BAT requirements defined in Parts I.C, I.D, and I.H.4 of the GWDP are described below.
3.0 GROUNDWATER CONTAMINATION
Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
1 Part I.G.3.c) of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications, that the failure was
not intentional or caused by Denison' s negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions ofUCA 19-5-107 have not been violated.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 4 of 15
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to Part I.G.2 of the GWDP.
When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:
3.1 Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part I.G.4.a) of the GWDP.
3.2 Continuation of Accelerated Monitoring
Denison will continue accelerated sampling for the parameter in that compliance
monitoring well pursuant to Part I.G.1 of the GWDP, unless the Executive Secretary
determines that other periodic sampling is appropriate, until the facility is brought into
compliance, as required under Part I.G.4.b) of the GWDP.
If the accelerated monitoring demonstrates that the monitoring well has returned to
compliance with respect to a parameter in a wen, then, with written approval from the
Executive Secretary, Denison will cease accelerated monitoring for that parameter, and
will continue routine monitoring for that parameter.
3.3 Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT or
BAT will be reestablished, as required under part I.G .4.c) of the GWDP. This plan will
normally include, but is not limited to:
a) The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 5 of 15
b) A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
c) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
contamination. This will normally include a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone, the analytical parameters to be obtained, the
samples of ground water to be taken, and any other means to measure and
characterize the affected ground water and contamination zone; and
d) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions
to restore and maintain groundwater quality to ensure that permit limits will not
be exceeded at the compliance monitoring point and that DMT and BAT will be
reestablished, as well as actions that merely allow natural attenuation to operate
and actions that involve applying for Alternate Concentration Limits ("ACLs").
ACLs require approval of the Water Quality Board prior to becoming effective.
If groundwater remediation is required, Denison will prepare and submit for
Executive Secretary approval a Ground Water Remediation Plan, as described in
Section 3 .4 below.
3.4 Groundwater Remediation Plan
If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary. The Ground Water Remediation Plan will
normally include, but is not limited to:
a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s) or other locations
approved by the Executive Secretary, by removing the contaminants, treating
them in place, or by other means as approved by the Executive Secretary;
b) A description of the remediation monitoring program to demonstrate the
effectiveness of the plan; and
c) Descriptions of how corrective action will apply to each source of the pollution.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 6 of 15
Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.
4.0 MILL DISCHARGE VIOLATIONS -INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS
Part I.C.2. of the GWDP provides that only 1 le.(2) by-product material authorized by the
Mill's State of Utah Radioactive Materials License No. UT-2300478 (the "Radioactive
Materials License") shall be discharged to or disposed of in the Mill's tailings cells.
Part I.C.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as 1 le.(2) material is prohibited.
In the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials'') to the Mill's tailings cells, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
4.1 Notifications
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery.
4.2 Field Activities
a) Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
b) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill
personnel will nevertheless mark or record the location of the Unauthorized
Materials in the tailings cells;
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 7 of 15
c) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from
the tailings cells; and
d) Denison will dispose of the removed Unauthorized Material under applicable
State and Federal regulations with the approval of the Executive Secretary.
4.3 Request for Approvals and/or Waivers
If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will, in accordance with a schedule to be approved by the
Executive Secretary:
a) Submit a written report to the Executive Secretary analyzing the health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
b) Apply to the Executive Secretary for any amendments that may be required to
the GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health, safety and the environment; and
c) Make all applications required under the United States Nuclear Regulatory
Commission's ("NRC's") Non-lle.(2) Disposal Policy (NRC Regulatory Issue
Summary 2000-23 (November 2000), Interim Guidance on Disposal of Non-
Atomic Energy Act of 1954, Section 11 e. (2) Byproduct Material in Tailings
Impoundments), including obtaining approval of the Department of Energy as
the long term custodian of the Mill's tailings, in order to obtain approval to
permanent! y dispose of the Unauthorized Material in the Mill's tailings cells.
5.0 DMT VIOLATIONS
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations
Part I.D.2 and Part I.D.6.d) of the GWDP provide that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorized by the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet, as measured from the top of the flexible
membrane liner ("FML").
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 8 of 15
In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirements of the Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Upon discovery, Mill personnel will cease to discharge any further tailings to
the subject tailings cell, until such time as adequate freeboard capacity exists in
the subject tailings cell for the disposal of the tailings;
d) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly pump
fluids from the subject tailings cell to another tailings cell until such time as the
freeboard limit for the subject tailings cell is in compliance. If there is no room
available in another tailings cell, without violating the freeboard limit of such
other cell, then, as soon as reasonably practicable, Mill personnel will cease to
discharge any further tailings to any tailings cell until such time as adequate
freeboard capacity exists in all tailings cells;
e) If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject
tailings cell will be reduced through natural evaporation; and
f) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems
Part I.D.3.b)l) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable, in accordance with the Mill's currently approved DMT Monitoring Plan, and
that for Cell 3, this requirement shall apply only after initiation of de-watering operations.
Similarly, Part I.D.6.c) of the GWDP provides that after Denison initiates pumping
conditions in the slimes drain layer in Cell 4A, Denison will provide: 1) continuous
declining fluid heads in the slimes drain layer, in a manner equivalent to the requirements
found in Part I.D.3.b); and 2) a maximum head of 1.0 feet in the tailings (as measured
from the lowest point of the upper FML) in 6.4 years or less.
White Mesa Mill -Standard
Operating Procedures
Book # 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 9 of 15
In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
after initiation of de-watering activities, Cell 3 or initiation of pumping conditions in the
slimes drain layer in Cell 4A exceeds the levels specified in the DMT Monitoring Plan,
Denison will, subject to any specific requirements of the Executive Secretary as set forth
in any notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to minimize the chance of a recurrence.
5.3 Excess Cell 4A Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.6.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
4A shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.6.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4A shall not exceed 24,160 gallons/day.
In the event that the fluid head in the LOS for Cell 4A exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4A LDS
exceeds 24,160 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/1 l Revision: DUSA-4
Page IO of 15
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to remediate the exceedance and to minimize the chance of
a recurrence.
5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.13.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
4B shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.13.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4B shall not exceed 26,145 gallons/day.
In the event that the fluid head in the LDS for Cell 4B exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4B LDS
exceeds 26,145 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
If not due to an identified equipment failure, Denison will perform a root cause analysis
of the exceedance and will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 11 of 15
5.5 Excess New Decontamination Pad Leak Detection System Fluid Head
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 in each of the three settling tanks, a vertical
inspection portal has been installed between the primary and secondary containment of
each settling tank.
Section 3.l(e) of the Mill's DMT Monitoring Plan provides that the fluid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete floor in
any of the three standpipes. Compliance is defined in Part I.D.14 a) of the GWDP as a
depth to standing water present in any of the LDS access pipes of more than or equal to
6.2 feet as measured from the water measuring point (top of access pipe).
In the event that the fluid head in the standpipe for a settling tank exceeds 0.10 feet above
the concrete floor in the standpipe, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within the
ensuing 24 hours followed by a written notification within five days;
c) Mill personnel will promptly pump the fluid from the settling tank's LDS as
well as the fluids in the settling tank into another settling tank or into an active
tailings ce11, or other appropriate containment or evaporation facility approved
by the Executive Secretary, until such time as the cause of the exceedance is
rectified or until such time as otherwise directed by the Executive Secretary; and
d) Denison will perform a root cause analysis of the exceedance and, if
appropriate, will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad.
Soil and debris will be removed form the wash pad of the NDP in accordance with the
currently approved DMT Monitoring Plan. In the event that cracks of greater than 1/8
inch (width) are observed on the concrete wash pad, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 12 of 15
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
· b) The NDP shall be taken out of service and the cracks will be repaired utilizing
industry standard materials and procedures appropriate for the defect within five
working days of discovery. Following recommended cure times, the cracks or
deficiencies will be re-inspected and, if acceptable, the NDP will be placed back
into service.
c) A record of the repairs will be maintained as a part of the inspection records at
the White Mesa Mill.
5.7 Excess Elevation For Tailings Solids
Part I.D.3.c) of the GWDP provides that upon closure of any tailings cell, Denison shall
ensure that the maximum elevation of the tailings waste solids does not exceed the top of
the FML.
In the event that, upon closure of any tailings cell, the maximum elevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly remove
tailings solids from the subject tailings cell to another tailings cell, or other
location approved by the Executive Secretary, until such time as the maximum
elevation of the tailings waste solids in the subject tailings cell does not exceed
the top of the FML; and
d) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.
White Mesa Mill -Standard
Operating Procedures
Book # 19 -Groundwater
Discharge Permit Plans and
Procedures
5.8 Roberts Pond Wastewater Elevation
Date: 12/11 Revision: DUSA-4
Page 13 of 15
Part I.D.3.e) of the GWDP provides that the Permittee shall operate Roberts Pond so as to
provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Cell 1 within 72
hours of discovery, as specified in Part I.D.3.e) of the GWDP.
In the event that, Denison fails to remove the excess wastewater within 72 hours of
discovery, Denison will, subject to any specific requirements of the Executive Secretary
as set forth in any notice, order, remediation plan or the equivalent, implement the
following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.9 Feedstock Storage Area
Part I.D.3.f) and Part I.D.11 of the GWDP provide that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
eastern portion of the Mill site area described in Table 4 of the GWDP, and that storage
of feedstock materials at the facility outside that area shall be performed in accordance
with the provisions of Part I.D.11 of the GWDP.
In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.f) and Part I.D.11 of the GWDP, Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Mill personnel will:
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
Date: 12/11 Revision: DUSA-4
Page 14 of 15
(i) move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
(ii) ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in
accordance with the provisions of Part I.D.11 of the GWDP; and
(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers or
otherwise dealt with in accordance with the provisions of Part I.D.11 of
the GWDP, and any impacted soils will be removed and will be deposited
into the Mill's active tailings cell; and
d) Denison will perform a root cause analysis of the non-compliant activity and
will implement new procedures or change existing procedures to minimize the
chance of a recurrence.
5.10 Mill Site Chemical Reagent Storage
Part I.D.3.g) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction of reagent storage facilities, the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.
In the event that Denison fails to provide the required secondary containment required
under Part I.D.3.g) of the GWDP, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and
c) Denison will promptly remediate any spilled re-agent resulting from the failure
to provide the required secondary containment under Part I.D.3.g) of the
GWDP, by removal of the contaminated soil and disposal in the active tailings
cell.
White Mesa Mill -Standard
Operating Procedures
Book# 19 -Groundwater
Discharge Permit Plans and
Procedures
5.11 Failure to Construct as per Approval
Date: 12/11 Revision: DUSA-4
Page 15 of 15
Part I.D.4 of the GWDP provides that any construction, modification, or operation of new
waste or wastewater disposal, treatment, or storage facilities shall require submittal of
engineering design plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.
In the event that, any new waste or wastewater disposal, treatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.12 Failure to Comply with Stormwater Management and Spill Control Requirements
Part I.D.10 of the GWDP provides that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the Mill facility in accordance with the
currently approved Stormwater Best Management Practices Plan.
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Stormwater Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery; and
c) To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill's approved Stormwater Best
Management Practices Plan. To the extent it is no longer practicable to so
manage any such spill, Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
Appendix N
White Mesa Mill Containerized Alternate Feedstock Material Storage Procedure, PBL-19,
Revision: 3.0, March 1, 2017
•
No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 3 STANDARD OPERATING PROCEDURES Page 1 of 3
Date: March 1, Title: Feed Material Receipt/Storage Procedure
2017
1.0 Purpose
The purpose of this procedure is to assure that the receipt and storage of feed materials is
conducted in a manner so as to preclude the release of Mill feed material to the environment.
2.0 Scope
Feed materials delivered to the White Mesa Mill must be stored in a manner which precludes the
release of the materials to the environment. In the case of bulk materials, such as unrefined
natural ores and alternate feeds delivered in inter-modal containers, these materials are offloaded
from the truck or shipping container directly onto the approved ore pad where migration of
material is precluded by the pad's design and operating procedures (i.e. low permeability pad
material, dust control procedures and limited stockpile height). However, certain feeds are
received in drums or other containers which serve to effectively contain the material during
storage and, as such, are amenable for storage either on the ore pad or at locations other than the
ore pad. It is the intent of this procedure to describe the environmental safety precautions
utilized for contained feed storage.
3.0 Procedure
3.1 Feed Material Inspections
All feed materials received at the White Mesa Mill are inspected upon arrival,
prior to entering the Restricted Area, to determine that the containers and/or
conveyances are not leaking and to assure container integrity prior to placing the
material into storage. Each container and/or conveyance will be observed on all
sides for damage or leakage of contents. If any container and/or conveyance has
signs of leakage, the inspector must notify the RSO, or their designee,
immediately. The RSO, or their designee, will make the determination through
visual observation and radiological assessment if a leak has occurred. If a leak
has occurred, the RSO, or their designee, will make the proper notifications to
Corporate Management and regulatory agencies and complete page 2 of the Feed
Material Receipt form. All containers exhibiting signs of leakage will be re-
packed or placed in over-pack containers prior to placing the materials into
storage. Dented drums are acceptable if the dent is not located near a seam or
when the dent is not accompanied by a damage crease on the drum surface.
Drums damaged by dents near the seam, crease damaged drums or containers that
have been otherwise compromised during shipment are re-packed or placed in
over-pack containers prior to storage. Containers which are not damaged at the
time of receipt are transferred directly for placement at the storage location.
No.: PBL-19
Rev. No.: 3
Date: March 1,
2017
3.2
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 2 of 3
Title: Feed Material Receipt/Storage Procedure
Storage Localions
3.2.1 Defined Feedstock Storage
Feedstock materials stored at the defined storage location indicated on the
map attached hereto as Attachment A) the "Defined Feedstock Area" can
be stored in containers or in bulk form and are subject to the routine
inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT) Monitoring Plan of
the Mill's Environmental Protection Manual.
3.2.2 Storage of Contained Feeds in Location Other Than the Defined Feedstock
Area
a) Over-pack Container
Materials received or transferred into over-pack containers can be stored at
locations other than the Defined Feedstock Area absent a hardened ground surface
or containment berms due to the fact that the over-pack container provides a
secondary containment for the packaged material. Over-pack materials are
subject to the routine inspections described by the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT) Monitoring
Plan.
b) Hardened Surface Storage Locations
Contained feed materials, including materials in containers which have not been
provided with over-pack protection, can be stored at locations other than the
Defined Feedstock Area when a hardened ground surface storage location is used
and has been provided with containment berms. These materials are subject to the
routine inspections described by the White Mesa Mill Tailings Management
System Discharge Minimization Technology (DMT) Monitoring Plan.
c) Single Lined Containers Stored Outside the Defined Feedstock Area
Where Hardened Surfaces and Containment Berms Are Not Utilized
Contained feeds can also be stored in locations, other than the Defined Feedstock
Area, that have been selected to avoid impact by site drainage and/or pooling.
Prior to storage at these locations, planks or pallets are placed beneath the drum
storage locations in order to raise the container from the ground surface and avoid
corrosion from water which may accumulate during precipitation events ( despite
site selection) and from rusting due to soil moisture when drums are stored
directly on the ground. These contained materials are subject to the more
particular storage protocols and inspections outlined below.
No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: 3 STANDARD OPERATING PROCEDURES Page 3 of 3
Date: March 1, Title: Feed Material Receipt/Storage Procedure
2017
3.3 Storage ProtocoJ Sfogle Lined Containers
3.4
3.5
In accordance with MSHA requirements, container storage must be implemented
in such a manner as to limit the potential for a container to tip or fall onto a
worker. For drummed materials, the agency limits such stacks to three drums in
height due to stability considerations. In keeping with these concerns, EFR will
configure single lined storage drums (stored off the Designated Feedstock Area)
in rows no more than two containers wide at the base and may place a one-
container row either on top of a single row or in the middle of a lower two-
container row, in each case so as to straddle the tops of drums in the lower
container row(s). This stacking configuration distributes the single upper row
across bottom row(s) of containers in such a manner as to hold the bottom row(s)
from leaning and allowing for limited stacking on top of these lower row(s).
accordingly, when stacking is necessary, this configuration minimizes the risk of
falling drums, limits stacking height for safety reasons and allows for a thorough
inspection of each of the individual containers from the outside of the container
row(s).
Single Lined Container Storage Area Inspections
The single lined container storage area(s) that are off of the Designated Feedstock
Area will be inspected on a weekly basis (and after significant precipitation
events) on both sides of any row in order to assure that the stored materials
remain intact, that standing water has not accumulated and that materials are not
leaking or migrating from the storage area.
Single Lined Container Storage Inspection Records
EFR will record all instances where single lined containers are received damaged
( or leaking) and require re-packing or the provision of an over-pack container.
This information will be recorded on a container receipt form (see Attachment B)
which documents the receipt of drummed materials to be stored in locations other
than the Defined Feedstock Area. Similarly, each weekly inspection shall be
recorded on the inspection form referred to in the White Mesa Mill Tailings
Management System Discharge Minimization Technology (DMT) Monitoring
Plan at Attachment A-3 and attached as Attachment C to this procedure. Such
inspections require the documentation of container condition, the drainage
conditions in the storage location, the presence of leakage, if any, and any
corrective actions taken due to leakage of containers or standing water at the
storage location.
Attachment A
(
..
)rftJi:I -, ---
)
:. )
•
le: l/T
Attachment B
(
•
j
! " ··~)
Feed Material Receipt
Inspection
Date: -------------------
j
Inspector: ----------
Is the shipment leaking? Yes or No
If Yes, complete the other side of this document.
Number of containers/drums in shipment: ________ _
Radiation Activity Levels: ----------
Location of Storage: -------------
Corrective Action Taken for Damaged Drums:
Observations (note dented or damaged drums)
Inspector:----------
(Print Name) (Signature)
Feed Material Receipt
Inspection
Name of generator of shipment: -----------
Bill of Lading#:---------------
Activity in Curies:----------------
Radionuclides: -----------------
The amount of material that leak out of the package (if known):
The amount of material that leak out of the conveyance (if known):
Can it be determined when the leak occurred?
Corrective Actions:
RSO: --------
(Print Name) (Signature)
Attachment C
•
/ •,
\
' ·,
_;,,'
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-3
12/16 Revision: EFRI 12.4
Page 19 of25
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:
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: __________________________________ _
•
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
Ore Pad Stonnwater Transfer Line:
Is the transfer line visible?
Yes: No: __ _
12/16 Revision: EFRI 12.4
Page 20 of25
Comments: __________________________________ _
Is there any evidence of breakage, spillage or leakage?
Yes: No: __ _
Comments: __________________________________ _
Other comments:
Ore Pad Southwest Stormwater Containment (Kiva):
Is there sediment or debris in the bottom of the Kiva?
Yes: No: __ _
CommeJ1ts: __________________________________ _
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes: No: __ _
Comments: __________________________________ _
Appendix 0
White Mesa Mill Chemical Inventory
Location Key
Chem Lab CL
Maintenance Shop/Warehouse MSW
Bulk Around the Mill Mill
Location
CL
CL
CL
CL
CL
CL
CL
CL
CL
CL
CL
CL
Chemical Name
Alcohol, Reagent
Aluminum Nitrate Solution
Compressed Gas (Argon)
Compressed Gas (Nitrogen)
Hydrochloric acid
Hydroflouric Acid
Isa-Octane
Mercuric Nitrate ( .1410 N)
Nitric Acid
Perchloric Acid
Phosphoric Acid
Sulfuric Acid
Appendix 0-1
Laboratory Chemical Inventory1
Historic volume
or mass used
Current Volume and Mass at the Mill (1978 -2013)
Density 1cm 3 -1
Quantity Unit g/cm3 Volume mL Quantity Unit
32 kg 0.79 40 L 4,156 L
291,685 g 1.401 55 gal 1457 L
74,400 cf * * * 497,364 cf
26,190 cf * * * 152,775 cf
23,000 g 1.15 20,000 mL 4,826 L
2,500 g 1.25 2,000 mL 231 L
17 kg 0.692 24 L 1,304 L
20,400 g 1.02 20,000 mL 274 L
35,500 g 1.42 25,000 mL 3,109 L
8,368 g 1.6736 5,000 mL 1,487 L
4,700 g 1.88 2,500 mL 1,665 L
18,300 g 1.83 10,000 mL 2,245 L
Total historic
Historic volume volume or mass
or mass used used (1978 -
(2014 -2022) 2022)
Quantity Unit Quantity Unit
1,712 L 5,868 L
240 L 1697 L
595,187 cf 1,092,551 cf
342,652 cf 495,427 cf
97 L 4,923 L
104 L 335 L
816 L 2,120 L
232 L 506 L
732 L 3,841 L
266 L 1,753 L
296 L 1,961 L
183 L 2,428 L
1 Part 1.E.9 states that "The Permittee shall monitor and maintain a current inventory of all chemicals used at the facility at rates equal to or greater
than 100 kg/yr." Previous chemical inventories inadvertantly included all chemical in the laboratory regardless of usage rate. This inventory has
been modified to include only those chemicals that meet the Part 1.E.9 usage rate. Inclusion in this inventory is based on the highest annual usage
from 2014 through May 2022 exceeding 100 kg/yr and/or more than 100 kg total usage for the period of 2014 -May 2022.
* Pursuant to Section I.E.9b) of the GWDP dated August 24, 2012, the Permittee shall provide "Determination of volume and mass of each raw
chemical currently held in storage at the facility." Both mass and volume are provided when specific gravity data are available.
Laboratory chemicals are stored in the laboratory or in the laboratory storage areas adjacent to the laboratory.
Abbreviations:
gal = gallons
cf= cubic feet
ml = milliliters
g = grams
kg = kilograms
L = liters
Appendix 0-2
Current Mill Chemical Inventory
Historic volume or Historic volume or Total historic volume
mass used (1978 -mass used (2014 -or mass used (1978 -
Current Volume and Mass at the Mill 4 2013) 2022) 2022)
Quantity Specific Gravity Approximate
Location Chemical Name (lbs) or Bulk Density Volume (gals) Quantity Unit Quantity Unit Quantity Unit
Alamine 336 Drums and
Mill Totes2 0 0.80 sp.g 0 1,538,782 lbs 134,109 lbs 1,672,891 lbs
Mill Ammonia (East and West) 183,662 5.68 lb/gal 32,335 34,861 ,910 lbs 6,258,243 lbs 41 ,120,153 lbs
Ammonium sulfate (North
Mill and South) 92,124 1.76 sp.g 6,284 44,266,008 lbs 6,305,875 lbs 50,571,883 lbs
Ammonium Sulfate Super
Mill Sacks 0 1.76 sp.g 0 :j: lbs 13,200 lbs :j: lbs
Mill Barium Chloride 27,000 3.86 sp.g 840 0 lbs 78,364 lbs 78,364 lbs
Boiler Salt (Sure Soft NaCl
Mill or equivalent) 45,790 63 lbs/cu ft 727 cu ft 0 lbs 136,910 lbs 136,910 lbs
Mill Cyanex 801 397 0.96 sp.g 50 0 lbs 13,889 lbs 13,889 lbs
Sodium Hydroxide 50%
Mill (Caustic) 84,496 1.50 sp.g 6,762 42,332,116 lbs 9,154,782 lbs 51,486,898 lbs
Sodium Hydroxide (Solid
Mill caustic) 898,415 2.13 sp.g 50,635 0 lbs 942,771 lbs 942,771 lbs
De-Scaler (ChemTreat BL
Mill 122 or equivalent) 232 1.16 sp.g 200 3,960 lbs 0 lbs 3,960 lbs
Mill Armeen 380 Totes 0 0.82 sp.g 0 0 lbs 83,531 lbs 83,531 lbs
Diatomaceous Earth Filter
Mill Aid 12,480 2.30 sp.g 651 1,000,000 lbs 6,240 lbs 1,006,240 lbs
Mill DEHPA 0 0.98 sp.g 0 0 lbs 31,676 lbs 31,676 lbs
Mill Flocculant 6551 23,100 0.80 sp.g 3,466 1,149,225 lbs 44,550 lbs 1,193,775 lbs
Mill Flocculant 314 8,150 0.80 sp.g 1,223 0 lbs 0 lbs 0 lbs
Hydrochloric Acid (Tanks
Mill and Totes) 1,143 9.83 lb/gal 116 98,300 lbs 2,201 ,060 lbs 2,299,360 lbs
Mill Hydrogen Peroxide 50% 1,000 1.20 sp.g 100 537,973 lbs 135,432 lbs 673,405 lbs
Mill Hyper Floe 757 Coagulant 0 0.80 sp.g 0 1,395 lbs 0 lbs 1,395 lbs
Mill Hyperfloc 624 2,300 0.80 sp.g 345 0 lbs 4,600 lbs 4,600 lbs
Mill Kerosene 123,392 6.80 lb/gal 18,146 15,067,139 lbs 5,243,276 lbs 20,310,415 lbs
Appendix 0-2
Current Mill Chemical Inventory
Historic volume or Historic volume or Total historic volume
mass used (1978-mass used (2014 -or mass used (1978 -
Current Volume and Mass at the Mill4 2013) 2022) 2022)
Quantity Specific Gravity Approximate
Location Chemical Name (lbs) or Bulk Density Volume (gals) Quantity Unit Quantity Unit Quantity Unit
Mill Liquified Natural Gas 65,739 0.55 sp.g 14,245 23,371,465 lbs 16,241,163 lbs 39,612,628 lbs
Mill Perlite Filter Aid 3,888 2.30 sp.g 203 604,158 lbs 156,669 lbs 760,827 lbs
Mill Propane 75,182 0.50 sp.g 17,908 7,309,158 lbs 1,286,955 lbs 8,596,113 lbs
Mill Salt 149,634 2.16 sp.g 8,316 63,111,955 lbs 13,230,595 lbs 76,342,549 lbs
Mill Soda ash silo 131,544 0.99 sp.g 15,951 76,472,417 lbs 20,210,604 lbs 96,683,021 lbs
Mill Soda ash Super Sacks 2,000 0.99 sp.g 243 :j: lbs 188,000 lbs 188,000 lbs
Sodium chlorate Tanks 1-3
Mill (50% Solution) 95,649 1.45 sp.g 7,919 30,978,629 lbs 3,572,595 lbs 34,551,224 lbs
Sodium Chlorate Super
Mill Sacks 0 1.32 sp.g 0 :j: lbs 0 lbs :j: lbs
Mill Sulfuric Acid 94% 5,734,000 1.84 sp.g 374,106 757,297,581 lbs 96,146,376 lbs 853,443,956 lbs
Mill Tertiary amine 2 8,818 0.80 1,323 0 lbs 61,729 lbs 61,729 lbs sp.g
Mill Tri-decyl alcohol 3 26,484 0.83 sp.g 3,831 967,383 lbs 222,535 lbs 1,189,918 lbs
1The Mill uses a number of comparable polymer flocculants depending on the specific feed.
2 The Mill has and may continue to use other tertiary amines with comparable chemical properties.
3Current alcohol used as modifier. Alternatively, the Mill has and may continue to use other secondary and tertiary alcohols, including isodecanol, among others, to improve
tertiary amine/U/kerosene solubility.
4 Pursuant to Section I.E.9b) of the GWDP dated August 24, 2012, the Permittee shall provide "Determination of volume and mass of each raw chemical currently held in storage
at the facility." Both mass and volume are provided when specific gravity data are available.
:j: -Historic values reported are the total quantity used at all locations. The historic quantities are reported as a single total for the first location listed.
Abbreviations:
lbs= pounds
lb/gal -pounds per gallon
sp.g = specific gravity
Appendix 0-3
Cleaners and Maintenance/Miscellaneous Chemicals1
Total historic volume
Historic volume or mass Historic volume or mass or mass used (1978-
Current used (1978 -2013) used (2014 -2022) 2022)
Location Cleaners Quantity Units Quantity Unit Quantity Unit Quantity Unit
MSW #2 EP Grease Shell Retinax LXZ 0 lbs 3300 lbs 796 lbs 4,096 lbs
MSW #5182 Pyroshield Grease / oil 240 lbs 21660 lbs 840 lbs 22,500 lbs
MSW 150 Gear Oil 110 gal 4312 gal 220 gal 4,532 gal
MSW 15-40w Motor Oil 165 gal 8435 gal 1265 gal 9,700 gal
MSW 220 Gear Oil 91 gal 26000 gal 1943 gal 27,943 gal
MSW 30w motor oil Rotella T 55 gal 2805 gal 385 gal 3,190 gal
MSW 460 Gear Oil 267 gal 6718 gal 613 gal 7,331 gal
MSW 5w-30 synthetic blend oil 55 gal 421 gal 275 gal 696 gal
MSW 680 gear oil 165 gal 17514 gal 770 gal 18,284 gal
MSW Acetylene bottle 1,173 cf 141008 cf 6701 cf 147,709 cf
MSW Anti-Freeze 165 gal 4,377 gal 495 gal 4,872 gal
MSW Argon mixed gas 660 cf 63,114 cf 6,930 cf 70,044 cf
MSW Argon T-large 331 cf 27,074 cf 3,972 cf 31,046 cf
MSW Bredel hose lubricant 98 gal 2,857 gal 522 gal 3,379 gal
MSW Fantastik 2.5 gal 1,777 gal 229 gal 2,006 gal
MSW Ferric Chloride 0 gal 660 gal 304 gal 964 gal
MSW Go-Jo hand cleaner 0 lbs 4,004 lbs 243 lbs 4,247 lbs
MSW Grease tubes 0.65625 lbs 6,874 lbs 1,480 lbs 8,354 lbs
MSW Hydraulic oil #68 165 gal 18,467 gal 1,650 gal 20,117 gal
MSW Laundry Soap 330 lbs 72,996 lbs 8,760 lbs 81,756 lbs
MSW Lysol 1.875 gal 1,543 gal 258 gal 1,801 gal
MSW Methyl Ethyl Ketone #366 0 gal 3,286 gal 165 gal 3,451 gal
MSW Oil absorbent floor dry 100 lbs 31,800 lbs 5,925 lbs 37,725 lbs
MSW Oxygen Cylinder TOX 2,310 cf 303,600 cf 21,450 cf 325,050 cf
MSW Sullair Coolent 40 gal 2,259 gal 345 gal 2,604 gal
MSW Sweeping compound oil base 25 lbs 29,066 lbs 975 lbs 30,041 lbs
MSW T-Chlor liquid chlorine 12% 40 gal 96 gal 765 gal 861 gal
MSW Windshield washer fluid 6 gal 1,053 gal 252 gal 1,305 gal
Appendix 0-3
1 Part 1.E.9 states that "The Permittee shall monitor and maintain a current inventory of all chemicals used at the facility at rates equal to or greater than 100 kg/yr."
Previous chemical inventories inadvertantly included all chemical in the laboratory regardless of usage rate. This inventory has been modified to include only those
chemicals that meet the Part 1.E.9 usage rate. Inclusion in this inventory is based on the highest annual usage from 2014 through May 2022 exceeding 100 kg/yr
and/or more than 100 kg total usage for the period of 2014 -May 2022.
Abbreviations:
lbs= pounds
gal = gallons
cf = cubic feet
Location of
Storage or
Use
Leach circuit
UraniumSX
UraniumSX
Appendix 0-4
Historic/Formerly Used Chemicals
Chemicals Formerly Used at Mill/No Longer Used or Present on Site 1
Time Period of Total Quantity
Chemical Form Use Used 2
Several months
Dry solid in during 1997 or No more than several
Ammonium Bi-fluoride SuperSaks 1998 thousand lbs.
Several months
during 1997 or No more than 2,000
J-Mt primary amine Drummed Liquid 1998 gallons
Several months
Tri octyl phosphine during 1997 or No more than 2,000
oxide ("TOPO") Drummed liquid 1998 gallons
Current Status
None on site
since 1998
None on site
since 1998
. None on site
since 1998
1. These reagents were used during processing of one alternate feed for 6 months in 1997 /1998, and have not been
used before or since.
2. Total quantities used are also the total quantities purchased over life of the alternate feed project, that is, total on
site was this quantitiy or less.
3. Unused residual consumed from 1997 to 1999 for cleaning purposes.