DWQ-2024-005410

APPENDIX E
PROCESS WATER PIPELINE INSPECTION AND
PREVENTATIVE MAINTENANCE PLAN
KENNECOTT TAILINGS IMPOUNDMENT UGW350011
Kennecott Utah Copper
June 2017
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1.0 Introduction
The Process Water Pipeline Inspection and Preventative Maintenance Plan is developed in conjunction with the renewal of Permit No. UGW350011 (2017) and is captured here in
Appendix C of this groundwater discharge permit. This plan describes inspections,
maintenance, replacement, spill avoidance measures, and reporting requirements.
1.1 Facilities Description
The Tailing Impoundment is located on the northern end of the Kennecott Utah Copper (KUC) mining operation, immediately north of Magna, Utah and immediately south of the
Great Salt Lake. The impoundment consists of the 3,500 acre north impoundment and the
5,700 acre south impoundment as well as several adjacent pumping stations, wells, canals and
other facilities associated with mine tailings and water management.
1.2 General Guidance
The various aspects of managing process water at the Tailings Impoundment are detailed in
the Spill Prevention Management Standard Operating Procedure (Document
#TASOP300.0206). The SOP outlines KUC responsibilities, Health, Safety and
Environmental aspects, reference documents, facility description, and procedures related to activities, monitoring procedures, record keeping, and reporting requirements. KUC Tailings also maintains a critical pipeline inventory, spill prevention, control and countermeasures
(SPCC) documentation and an emergency response plan. The critical pipeline inventory
details pipe type, location length, substance conveyed, type of leak detection system and
potential environmental risk if a spill occurred.
2.0 Inspection and Maintenance
2.1 Inspection
Facilities that are in operation are monitored on a continuous basis electronically from the
Tailings control room. All operating Tailings facilities described in this plan are operated and
monitored 24 hours per day, 365 days per year. Process water pipelines, associated pumps, valves and sumps are visually inspected once per shift (twice per day) while areas of critical concern are inspected twice per shift. The assigned operators or inspectors are responsible for
correcting any problems discovered in a timely manner. Maintenance and repairs are
initiated in response to inspection results or according to preventive maintenance (PM)
schedules.
2.1.1 Protocol
A standard inspection protocol is followed for each inspection conducted. An inspection
report form is completed and signed by the inspector as well as reviewed and signed by the
supervisor. The operational status of each structure is noted along with any needed corrective
actions or maintenance items. Any necessary repairs or corrections will be completed within 45 days of the date inspected. A maintenance notification will be submitted and repairs will
be tracked and executed through maintenance work orders. KUC uses an electronic system
(SAP) to manage maintenance work. See section 2.2 of this Appendix for more detail
regarding maintenance protocol.

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2.1.2 Record Keeping
Copies of each inspection performed will be maintained on file to document compliance with this program as specified in Part II Section H of the permit for a period of three years.
Inspection reports will be available for review by UDWQ representatives during compliance
visits. A discussion of inspections, maintenance, replacements and spill avoidance measures
should be included in the semi-annual monitoring report required by the permit.
2.2 Maintenance
PM schedules at Tailings are tracked with a computerized maintenance program. Based upon
operator inspections and preset maintenance intervals, this program assists in scheduling and
planning PMs. Standard Operating Procedures (SOP) are used by the employee or group of
employees assigned the responsibility for completing the PM. After the PM is completed, a
signed PM checklist is returned to the maintenance scheduler. The maintenance planner notes any items identified during the inspection that require additional repair. A work order is then
written and the additional work scheduled. The work-order tracking system is intended to
ensure that proper and complete implementation of required repairs occurs in a timely
fashion. The system continues to remind maintenance planners periodically until the work-
order job is completed and closed out.
2.2.1 Spill Avoidance Measures
Spill avoidance is achieved through systematic monitoring, timely reporting, modification of
potential deficiencies and a preventative maintenance program. The monitoring program is
comprised of frequent visual inspections, electronic monitoring from the Tailing control room
as well as subsequent documentation. In addition, the following measures are employed to minimize the likelihood of process water spills:
1. Pipelines are used as per original intended design;
2. Buried pipeline is non-metallic or is provided with appropriate protective wrapping;
3. Buried pipeline is provided with cathodic protection as appropriate;
4. Cathodic protection is checked and documented at least every 2 years;
5. Pipelines carrying hazardous substances are double walled and have leak detection;
6. Pipeline exposed to potential traffic damage are adequately protected;
7. Pipe supports will be designed to minimize abrasion and corrosion and to allow for
expansion and contraction;
8. Pipelines subject to excessive settlement are re-surveyed to ensure pipelines are not
subject to excessive stress; and
9. Operational areas are fenced and gated with the goal of eliminating public access.
3.0 Spills and Overflows
Spills as a result of pipeline releases are identified by one or more of the following measures:
1. Visual observation by roving operators 2. Tailings control room monitoring of pump status, flows, sump levels and pipeline
pressures.
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Upon identification of a leak, compromised process water piping is de-energized, shutoff and
isolated for repair. In addition, the following plans will direct Tailings operations regarding spill protocol:
1. Tailings Spill Prevention Control and Countermeasures Plan (SPCC plan)
2. KUC Storm Water Pollution Prevention Plan (SWPPP)
3. Tailings Emergency Response Plan
Depending upon the specific circumstances of a particular pipeline release, KUC will refer to the following guidance:
1. Kennecott Tailings Impoundment Groundwater Discharge Permit No. UGW350011
2. Other various Utah Department of Environmental Quality reporting requirements
3. Other various U.S Environmental Protection Agency reporting requirements
4. Rio Tinto/Kennecott Utah Copper internal reporting requirements
4.0 Training
Each employee receives task specific training and mentoring related to job specific duties. In
addition, employees receive Standard Operating Procedure (SOP) Training on an annual
basis. The training includes the following areas:
1. Air Emissions Control (300.201)
2. Culinary Water Management (300.202)
3. Surface Water Management (300.203)
4. Groundwater Management (300.204)
5. Waste Management (300.205)
6. Spill Prevention Management (300.206)
7. Dam Failure Prevention (300.207)
8. Reclamation (300.208)
5.0 Reporting Requirements
5.1 Semi-annual Reporting
KUC will refer to Part I Section H with respect to reporting frequency and regarding content
included in the semi-annual reports.
5.2 Release Reporting
KUC will follow guidance outlined under Part II section I of this permit with respect to Spill Reporting and Part I Section G of this permit with respect to Non-Compliance of Best
Available Technology.