DRC-2018-000364 - 0901a068807a0478

Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADI-ATION CONTROL
Scott T. Anderson
Director
State of Utah
GARY R, HERBERT
Governor
SPENCERJ. COX
Lieutenant Governor
January 19.2018
David Frydenlund
Energy Fuels Resources (USA) Inc.
225 UnionBlvd., Suite 600
Lakewood, CO 80228
RE:Groundwater Discharge Permit No. UGW370004
Dear Mr. Frydenlund:
A signed copy of Groundwater Discharge Permit No. UGW3 70004 (Renewal) for the White Mesa
Uranium Mill is enclosed. Please ensure that all affected Energy Fuels Resources (USA) Inc. personnel
are familiar with the requirements of this renewed Permit.
If you have any questions, please call Phil Goble at [phone]
Sincerely,
Division of Waste Management and Radiation Control
STA/TR/ka
Enclosure: Groundwater Discharge PermitNo. UGW370004(DRC-2018-000363)
c: Kirk Benge, Health Officer, San Juan Public Health Department (WO Enclosure)
Rick Meyir, Environmental Health Director, San Juan Public Health Department (WO Enclosure)
Scott Hacking, P.8., DEQ District Engineer (WO Enclosure)
195 North 1950 West' Salt Lake City, UT
Mailing Address: P.O. Box 144880'Salt Lake City, UT 84114-4880
Telephonl [phone]. Fax [phone] 'T.D.D. (801) 5364284
ttnno.deq'utnh.gott
Printed on 100% recYcled PaPer
DRc-2018-000364
PermitNo. UGW370004
STATE OF UTAH
DIVISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALITY BOARD
SALT LAKE CITY. UTAH 84114-4870
GROUND WATER DISCHARGE PERMIT
In compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,
Energy Fuels Resources (USA) Inc.
225 Union Boulevard. Suite 600
Lakewood, CO 80228
is granted a ground water discharge permit for the operation of a uranium milling and tailings
disposal facility located approximately six miles south of Blanding, Utah. The facility is located
on a tract of land in Sections 28,29,32, and 33, Township 37 South, Range 22 East, Salt Lake
Base and Meridian, San Juan County, Utah.
The permit is based on representations made by the Permittee and other information contained in
the administrative record. It is the responsibility of the Permittee to read and understand all
provisions of this Permit.
The milling and tailings disposal facility shall be operated and revised in accordance with
conditions set forth in the Permit and the Utah Ground Water Quality Protection Regulations.
This Ground Water Quality Discharge Permit amends and supersedes all other Ground Water
Discharge permits for this facility issued previously.
This Permit shall become effective on January | ? ,2018.
This Permit shall expire on January /7 ,2023.
Signed this ESaV of January,2018.
Scott T. Anderson,
Division of Waste
Director
Management and Radiation Control
. Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS............ .............. I
A. GnouNu WereR CLlssmIcerloN.......... ....................... I
B. BncrcRoLrNDWarenQuelIrv ................. I
C. Penvtrl-tvns....... ....................2
l. Ground Water Compliance Limits ..........2
2. Tailings Cell Operations........... ...............2
3. Prohibited Discharges ...........2
D. DrscnaRGE MrNIMrzATroN eNp Besr Avert.est.e TpcnNor-ocv SreNoeRDS........... .......6
1. DMT Design Standards for Existing Tailings Cells 1, 2, and 3...................................... 6
2. Existing Tailings Cell Construction Authorized........... .............. 8
3. Existing Facility DMT Performance Standards............... ........... 8
4. Best Available Technology Requirements for New Construction................................ l0
5. BAT Design Standards for Tailings Cell4A. ............ ................ l0
6. BAT Perfoilnance Standards for Tailings CeII4A............ ...-.'. 13
7. Definition of 1le.(2) Waste....... ............ 13
8. Closed Cell Performance Requirements..... ..........'.. 13
9. Facility Reclamation Requirements.......... .............. 14
10. Stormwater Management and Spill Control Requirements........... ..............14
11. Requirements for Feedstock Material Stored Outside the Feedstock Storage Area..... 14
12. BAT Design Standards for Tailings CeII4B............. ................ 15
13. BAT Performance Standards for Tailings Cell 4B............. ....... 18
14. BAT Performance Standards for the New Decontamination Pad ............... 18
E. GnouNo Weren CovrplrnNcE AND TpcuNor-ocy PERFoRMANCE MoNIroRhlc ............ 19
1. Routine Groundwater Compliance Monitoring............. ............ 19
2. Groundwater Monitoring: General Monitoring Wells ........-.-...20
3. Groundwater Head Monitoring ..........-.-20
4. Groundwater Monitoring Well Design and Construction Criteria ..............21
5. Monitoring Procedures for Wells.. ...-....21
6. White Mesa Seep and Spring Monitoring ..-...-..-..--.21
7. DMT Performance Standard Monitoring .............-..22
8. BAT Perfonnance Standard Monitoring ...-.-.-.---..-..23
g. On-site Chemicals Inventory.. .........-.....24
10. Tailings Cell Wastewater Quality Monitoring ........24
11. Groundwater Monitoring Modifications...'.'....... ....25
12. BAT Performance Standard Monitoring .................25
F. ReponrrNc ReQuInEuENTS ......... -.-...---...-27
1. Routine Groundwater Monitoring Reports ...-.-.......27
2. Routine DMT Performance Standard Monitoring Report....... ....................28
3. Routine BAT Perfonnance Standard Monitoring Reports..... '...-.-..........."' 28
4. DMT and BAT Performance Upset Reports ...-.-...-.28
5. Other Information...........'... .""""""""" 28
6. Groundwater Monitoring Well As-Built Reports..... ..-...-.......-..29
7. White Mesa Seeps and Springs Monitoring Reports """"""""29
8. Chemicals Inventory Report....... """""' 30
g. Tailings Cell Wastewater Quality Reports..... ."""" 30
10. Revised Hydrogeologic Report """"""' 30
11. Annual Slimes Drain Recovery Head Report.......'.'..... """"""' 31
12. Decontamination Pads Annual lnspection Report """""""""" 3l
G. Our oF CoMPLIANCE Srarus ."""""""""32
i
l. Accelerated Monitoring Status... ...........32
2. Violation of Permit Limits ....................32
3. Failure to Maintain DMT or BAT Required by Permit.. ...........32
4. Facility Out of Compliance Status ........ 33
H. Covpt-IANCE ScHeoule RequrneuENTS. ...................34t. Slimes Drain Compliance Plan. ............34
2. Installation of New Groundwater Monitoring Wells ................34
3. Background Groundwater Quality Report for MW-38, MW-39, MW-40....................34
PART rr. REPORTTNG REQUIREMENTS ........36
A. RBpnesENTATrvE Savpr.rNc. .................... 36
B. ANer-yrrcAl PRocrpuRES.............. .......... 36
C. PeNer.rrES FoR TeNapenNc .....36
D. RsponrrNc oF MoNrroRnc Rrsulrs ......36
E. CovplnNcp ScsepuLES............ ..............36
F. AoorrroNer- MoNrronrNc By rHp PeRvrrrEE ........... .................. 36
G. Rpconos CoNreNrs ............. .................... 36
H. RpreNrroN oF REconos .........37I. Norlcs orNoNcotvtpLrANCE ReponrrNc ....................37J. OrHpnNoNCoMpLrANce RspoRrrNG........... ..............37
K. INspncrroN AND ENrny ..........37
PART III. COMPLIANCE RESPONSIBILITIES ................. 38
A. Dury ro CoMpLy .................... 38
B. PBNer-rrES FoR VrourroNs or PeRurr CoNorrroNs ............... .... 38
C. NBEp ro Halr oR Reouce Acrrvrry Nor A Derpxsp ................. 38
D. Dury ro MrrrcnrE ............. ...................... 38E. PRopsn OpeRarroN eNo MnNTeNANCE .................... 38
PART rV. GENERAL REQUTREMENTS ..........39
A. PlexNeo CueNcps................ ................... 39
B. ANrlcrpATEDNoNcotvtpt IANCE ................39
C. PpnvrrAcrroNs .....................39
D. DuryroRsnpply............... ....39
E. DuryroPRovroplNroRuarroN.......... ....39F. Orspn INronvnrroN ............ .................... 39
G. SrcNeronvRnqurREMENTS ....39
H. PeNeluES FoR FnlsrrrcnrroN oF RepoRrs ............... 40I. Averr.esrI.rry oF Rrponrs .....40J. PnopeRry Rrcurs ...................40K. SevnnnBrlrry .......40L. TReNsrERs ............40
M. Srare Llws .......... 41N. RnoppNpR PRovrsroNs........... ................... 4l
List of Tables
Table 1. Ground Water Classification............. ....... I
Table 2. Groundwater Compliance Limits... ...........3
Table 3. DMT Engineering Design and Specifications ............6
Table 4. Feedstock Storage Area Coordinates........ ..................9
Table 5. Approved Tailings Cell4,A' Engineering Design and Specifications ........... 10
Table 6. Approved Tailings Cell48 Engineering Design and Specifications...... ...... 15
Table 7. Groundwater Monitoring Reporting Schedule .............. .............27
lll
Part I.A
Permit No. UGW370004
PART I. SPECIFIC PERMIT CONDITIONS
A. Gnou.ro WereR CI-nsstncertoN - the groundwater classification of the shallow aquifer
under the tailings facility has been determined on a well-by-well basis, as defined in Table l,
below:
Footnotesl
l) N = Number of Samples2) Based on historic total dissolved solids (TDS) data provided by the Permittee for period between Octobet,1979 andseptember 2016. Thisdata was obtained from the Permittee's background groundwater quality reports..3) Background concentralions of uranium in well MW-I8 (55.1 pglL) and thallium in MW-I9 (2.1 1tg/L\ excend the GWeS, 30 1tglL 111,d2.0pgl]-, respectively. Therefore these wells have been classified as Class III groundwater rather than-Class II groundwater.4) Wells MW-I, Mw-18, Mw-19, MW-20, Mw-22, andTW4-24 are not point of compliance monitoring wells, but instead are generalmonitoring wells as per Part I.E.2. Average concentrations and standard deviations for wells MW-20 ;d MW-22 ,net" providid by thePermittee for the period betwe€n June, 2008 and February, 2010. This data was obtained from the Permittee's Background Groundwater
Quality Report for wells MW-20 and MW-22 dated June.2010.5) Background concentralion of manganese in well MW-25 (1,806 pgll-) exceeds the GWQS, therefore well MW-25 has been classified asClass III groundwater rather than Class II groundwater.6) Well MW-26 was originally named TW4-15 and was installed as part of the chloroform contaminant investigation at the facility. Under thisPermit MW-26 is defined as a Point of Compliance (POC) well for the tailings cells (see Part l.E.l).7) Background concentrations of uranium in well MW-27 Qa pg/L) and selenium in MW-31 (71 ttdL) exceed the GWeS, therefore thesewells have been classified as class III groundwater rather than class II groundwater.8) Well MW-32 was originally named TW4-17 and was installed us part oittre chloroform contaminant investigation at the facility. Under thisPermit it is included as a POC well for the tailings cells in part I.E. l.
B. BecrcRoLND Werpn Quellrv - based on groundwater samples collected through Jwre2007for existing wells (MW-l, Mw-2, Mw-3, Mw-5, Mw-l l, Mw-12, Mw-14, Mw-15, Mw-17,
I
Table 1. Ground Water Classification
Class II Groundwater
Average TDS (mg/L)
DUSA Data
Class III Groundwater
Average TDS (mg/L)
DUSA Data
Well ID 11(t)
Average
Concentration(2)
Standard
Deviation(2)Well ID y(t)
Average
Concentration(2)
Standard
Deviation(2)
MW-1 1.273 93 MW-2 77 3.050 252
MW-5 82 2.058 r70 MW-12 6l 3.894 241
MW-I1 71 l-844 178 MW-14 51 3.592 t76
MW-30 42 1601 100 MW-15 47 3.857 243
MW-17 22 4.444 321
MW-18,"l8 2.605 297
MW-lg(',/22 2.457 900
MW-20("'23 s,192 475
MW-221')23 7,633 656
MW-3A 40 5.684 184
MW-23 aaJJ 3.4r9 408
MW-24 32 4,080 268
MW-25("46 2,763 97
MW-26(o,60 3,106 23r
MW-27\',)45 r.067 56
MW-28 32 3.633 l0l
MW-29 40 4,332 118
MW-31(90 1.395 138
MW-32\"/32 3,703 r66
MW-35 24 3.725 354
MW-36 21 4.344 t54
MW-37 2l 3.881 108
Part I.B &I.C
Permit No. UGW370004
MW-18, MW-19, MW-26, and MW-32) and through December 2007 for new wells (MW-3A,
MW-23, MW 24, MW-25, MW-27, MW-28, MW-29, MW-30 and MW-31), the upper boundary
of background groundwater quality is determined on a well-by-well basis, pursuant to
Environmental Protection Agency (EPA) guidance, and documented in the Permittee's
background groundwater quality reports dated October 2007, April 30,2008, and May 1,2014.
C. Ppnun Lrurrs - the Permittee shall comply with the following permit limits:
l. Ground Water Compliance Limits - contaminant concentrations measured in each
monitoring well listed in Table 2 below shall not exceed the Ground Water Compliance
Limits (GWCL) defined in Table 2, below. Groundwater quality in the wells listed in
Table 2 below must at all times meet all the applicable GWQS and ad hoc GWQS
defined in R317-6 even though this permit does not require monitoring for each specific
contaminant.
2. Tailings Cell Operations - only 11.e.(2) by-product material authorized by Utah
Radioactive Materials License No. UT-2300478 (hereafter License) shall be discharged
to or disposed of in the tailings ponds.
3. Prohibited Discharges - discharge of other compounds such as paints, used oil, arfiifteeze,
pesticides, or any other contaminant not defined as 1le.(2) material is prohibited.
T able 2. Groundwater Compliance Limrts (GWCL
Upgradient
Well Down or Lateral Gradient Wells
MlV-27
(Class lll)
MW-2
(Class Ill)
MlV-3A
(Class lll)
MW-5
(Class Il)
MW-I1
(Class II)
M\il-12
(Class III)
MW-14
(Class III)
MlV-15
(Class lll)
MW-I7
(Class III)
MW-23
(Class III)
MW-24
(Class III)
MW-25
(Class
III)
Contaminant G\f,/OS(I)GWCL GWCLp)GWCL GWCL GWCL (,)GWCL GWCL GWCL GWCL GWCL CWCL GWCL
Nutfients (mg/L)
Ammonia (as N)25 l2.s t2.s 0.6 t.02 6.25 0.6 12.5 0.21 0.26 0.6 7 0.77
Nitrate + Nitrite (as N)10 5.6 0.t2 l.J 2.5 2.5 5 5 0.27 5 5 5
Heavy Metak (pg/L)
Arsenrc ]U 25 25 25 17 l5 25 25 25 25 25 t7 25
Bervllium ^2 2 2 I 2 2 2 z z 2 2
Cadmium 5 2.5 2.5 3.5 5 2 |.25 7 2.5 2.5 2.:2.5 6.43 l.)
Chromium 100 50 50 50 25 25 50 50 50 )(,50 50 50
Cobalt 730 36s 365 365 t82.5 l82.5 365 365 365 365 365 365 365
Copper 1.300 650 650 650 325 325 650 650 650 650 650 650 650
lron I 1.000 (5,500 t51.6 5.500 2.750 2.750 5,500 5.500 81.7 5.500 5.500 4.162 5-500
Lead 15 /.)7.5 7.5 4.1 J. IJ 7.5 I.i 7.5 7.5 7.5 7.5 I,J
Manganese 900 (*)400 378.76 383 376.74 164.67 2,088.80 2,230.30 400 915.4 550 7,507 1,806
Mercury 2 I I 0.5 I I I
Molvbdenum 40(20 20 20 l0 l0 20 25 30 20 20 20 20
Nickel 100 (')50 60 105 44.1 46.2 60 50 97 50 50 50 50
Selenium 50 25 26.6 109.58 12.5 12.5 5Y 25 t28.7 25 25 25 25
Silver 100 50 50 50 25 25 50 )U 50 {n 50 50 50
Thallium 2 I 1.4 0.5 0.5 I I 1.5 2.01 l.l
Tin 17.000 (')8,500 8.500 8.500 4.250 4.250 8,500 8.500 8.500 8.s00 8.500 8,500 8.500
Uranium 30 5+18.45 35 t.)7.5 23.5 98 65.7 46.66 32 I 1.9 I .Z)
Vanadium 60 ('30 30 30 l5 l5 30 30 40 30 30 30 30
Zinc 5.000 2,500 2.500 155 87.38 t.250 2.500 35.04 2.500 2.500 '74 2,500 2.500
Radiologics (pCi/L)
Gross Alpha 15 2 J.L 7.5 3.75 3.75 /.)7.5 7.5 2.8 2.86 7.5 7.5
Volatile Organic Compounds (pg/L)
Acetone 700 3s0 350 350 r75 175 3s0 350 350 350 350 J]U 350
Benzene 5 2.5 2.5 2.5 1.25 t.25 2.5 2.5 2.5 2.5 2.5 2.5 2.5
2-Butanone (MEK)4000(2.000 2,000 2,000 1.000 1.000 2.000 2,000 2.000 2.000 2.000 2.000 2,000
Carbon Tetrachloride 5 2.5 2.5 2.5 |.25 1.25 2.5 2-5 2.5 2.5 2.5 2.5 2.5
Chloroform 70 (o)35 35 35 17.5 t7.5 35 J)35 35 35 J)J)
Chloromethane 30(l5 15 9.4 7.5 7.5 l5 t5 t5 t5 5.7 t5 l5
Dichloromethane 5 2.5 2.5 2.5 l.25 1.25 2.5 2.5 2.5 2.5 2.5 2.:2.5
Naphthalene 100 v 50 50 50 25 25 50 50 50 50 50 )U 50
Tetrahvdrofuran 46Q)23 23 23 I 1.5 I l.)z)23 ZJ 23 23 23 L)
Toluene I "000 500 500 500 250 250 s00 500 500 500 500 500 500
Xvlenes (total)r 0.000 5,000 5,000 )00 2.500 2.500 s.000 5.000 5.000 5.000 5.000 5,000 5,000
Others
Field pH (S.U.)6.5 - 8.5 6.47 - 8.5 6.72 - 8.5 5.84 - 8.s 7.04 - 8.s 6.25 - 8.5 5.86 - 8.5 5.42 - 8.s 5.88 - 8.5 6.27 - 8.5 s.97 - 8.5 5.03 - 8.5 5.77 - 8.5
Fluoride (ms/L)4 0.85 0.43 1.6 |.42 z 0.2 2 2 2 0.47 0.42
Chloride (mgll)38 20 70 7l 39.t6 80.5 27 57.1 46.8 l0 7l 35
Sulfate (mdl)462 2.147 3.949.27 1.518 r.309 2,560 2,330 2.549.02 2.860 2.524 2,903 l,933
TDS (me/L)I " I 85.72 3.800 6.028 ) \1\2,528 4.323 4.062 4.530 5.085.42 3,670 4,450 2.976
J
ontmued.water Com lance Ltmlts
Down or Lateral Gradient Wells
MW-26
(Class III)
MW-28
(Class lll)
MW-29
(Class lll)
MW-30
(Class ll)
MW-31
(Class III)
M\ry-32
(Class III)
MW-35
(Class lll)
MW-36
(Class III)
MW-37
(Class III)
Contaminant GWQS
0)
GWCL GWCL CWCL GWCL CWCL GWCL (,)CWCL GWCL GWCL
Nutilents (mp/L)
Ammonia (as N)25 0.92 t2.5 1.3 0.14 12.5 t.l7 0. l4 t2.5 12.5
Nitrate + Nitrite (as N)10 0.62 5 5 2.5 5 5 5 5 2.22
Heavv Metals fus/L)
Arsenic 50 25 2l 25 t2.5 25 25 25 25 25
Bervllium 4 2 2 2 I 2 z z 2 2
Cadmium 5 2.5 5.2 2.5 t.25 2.5 i1a 2.5 2.5 2.5
Chromium 100 50 50 50 25 50 50 50 50 50
Cobalt 730 (')365 47 365 t82.5 365 75.21 36s 365 36s
Copper 1.300 650 650 650 32s 650 650 650 650 bfu
Iron l r-000 2.67s.83 299 l.869 2.750 5.500 r 4.060 330.08 5.500 5.500
Lead l5 7.5 7.5 7.5 3.75 7.5 '7.5 t.)t.>
Manganese 800 1.610 1.837 5.624 6l 400 5.594.90 290.68 400 400
Mercurv 2 I 0.5
Molvbdenum 40 (r)20 20 20 l0 20 20 20 20 20
Nickel 100,50 )U 50 25 50 94 50 50 50
Selenium 50 25 il.1 z)47.2 86.8 I 25 25 307.42 25
Silver 100 50 50 50 25 50 50 )U 50
Thallium 2 I 1.2 0.5 1.35
Tin I 7.000 8.500 8,s00 8,500 4.250 8.500 8.500 8,500 8,500 8.500
Uranium 30(1t9 4.9 l5 8.32 9.1 5.26 26.76 26.42 18.08
Vanadium 60 30 30 30 t<30 30 30 30 30
Zinc 5.000 2.s00 83 30 I.250 2.500 230 t00 2,s00 4t.25
Rodioloeics (pCi/L)
Gross Aloha l5 4.69 2.42 2 J. /)7.5 7 7.5 7.5 4.2
Vo I atil e O rganic C o mp ounds
tue/L)
Acetone 700 (*)350 350 3s0 t75 350 3s0 350 350 350
Benzene 5 z.)2.5 2.5 1.25 2.5 2.5 2.5 2.5 2.5
2-Butanone (MEK)4,000 (2.000 2.000 2.000 1.000 2.000 2,000 2,000 2.000 2.000
Carbon Tetrachloride 5 5 2.5 2.5 1.25 2.5 2.5 2.5 2.5 2.5
Chloroform '70 J)35 17.5 J)35 35 35 JJ
Chloromethane 30 {'z 30 4.t)l5 7.5 6.1 l5 l5 l5 l5
Dichloromethane 5u)5 2.5 2.5 t.25 2.5 2.5 2.5 2.5 2.5
Naohthalene 100 50 50 50 25 50 50 50 50 50
Tetrahvdrofuran 46 \.)L)z)L'I 1.5 23 23 z3 LJ 23
Toluene r.000 500 500 500 250 s00 500 500 500 s00
Xvlenes (total)r 0.000 5.000 5,000 s.000 2.500 5.000 5.000 5.000 5.000 5.000
Others
Field oH (S.U.)6.5 - 8.5 5.61 - 8.5 5.58 - 8.5 s.94 - 8.5 6.4't - 8.s 6.23 - 8.5 5.31 - 8.5 6.15 - 8.s 6.49 - 8.s 6.61 - 8.5
Fluoride (me/l)4 2 0.73 t.l 0.51 2 2 0.42 0.3s 0.31
Chloride (mell)58.31 105 4l 128 t43 35.39 69.12 t)57.3
Sulfate (mey'l)2.082.06 ? s1?2.946 972 697.60 2.556.70 2.400 3.146.21 2.927.65
TDS (me/l)3.284.19 3.852 4,570 l.918 1.700 3.960 4.821.88 5.470 4,866.25
Table 2 C ued Ground C Li GWCL
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Part I.D
Permit No. UGW370004
D. DrscHaRGE MrNrMrzATroN AND BEST Aveu,eglr TncnNolocy STANDARDS - the tailings
disposal facility must be built, operated, and maintained according to the following
Discharge Minimization Technology (DMT) and Best Available Technology (BAT)
standards:
l. DMT Design Standards for Existing Tailings Cells l, 2, and 3 - shall be based on existing
construction as described by design and construction information provided by the
Permittee, as summarized in Table 3 below for Tailings Cells 1,2, and3:
Footnotes:l) D'Appolonia Consulting Engineers, Inc., June, 1979, "Engineers Report Tailings Management System White Mesa Uranium Project
Blanding, Utah Energy Fuels Nuclear, trnc. Denver, Colorado", unpublished consultants report, approximately 50 pp., 2 figures, 16 sheets,2
appendices.2) D'Appolonia Consulting Engineers, Inc., February, 1982, "Construction Report Initial Phase - Tailings Management System White Mesa
Uranium Project Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado", unpublished consultants report, approximately 7 pp.,6
tables, 13 figures,4 appendices.3) D'Appolonia Consulting Engineers, Inc., May, 1981, "Engineer's Report Second Phase Design - Cell 3 Tailings Management System
White Mesa Uranium Project Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado", unpublished consultants report approximately
20 pp., | figure, 5 sheets, and 3 appendices.4) Energy Fuels Nuclear, lnc., March, 1983, "Construction Report Second Phase Tailings Management System White Mesa Uranium Project
Energy Fuels Nuclear, Inc.", unpublished company report, 18 pp., 3 tables,4 figures, 5 appendices.
a) Tailings Cell 1 - consisting of the following major design elements:
l) Cross-valley Dike and East Dike - constructed on the south side of the pond of
native granular materials with a 3:l slope, a 20-foot crest width, and a crest
elevation of about 5,620 ft above mean sea level (amsl). A dike of similar design
was constructed on the east margin of the pond, which forms a continuous earthen
structure with the south dike. The remaining interior slopes are cut-slopes at 3:1
grade.
2) Liner System - including a single 30 mil PVC flexible membrane liner (FML)
constructed of solvent welded seams on a prepared sub-base. Top elevation of the
FML liner was 5,618.5 ft amsl on both the south dike and the north cut-slope. A
protective soil cover layer was constructed immediately over the FML with a
thickness of l2-inches on the cell floor and 18-inches on the interior sideslope.
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch
thick layer of crushed sandstone was prepared and rolled smooth as a FML sub-
base layer. Beneath this underlay, native sandstone and other foundation materials
were graded to drain to a single low point near the upstream toe of the south
Table 3. DMT neen and rcatrons
Tailings
Cell
Report
Tvpe Ensineerins Report Desien Fieures
Construction
Specifications
Cell I Design June,1979 D'Appolonia
Consultins Ensineers, lnc (r)
Appendix A, Sheets 2,4,8,
9. t2-15
Appendix B
Cell2 Design June, 1979 D'Appolonra
Consulting Engineers. lnc (l)
Appendix A, Sheets 2,4,7-
10. 12-15
Appendix B
As-Built February, 1982 D'Appolonia
Consultins Ensineers. lnc (2)
Figures 1,2, and ll N/A
Cell3 Design May, l98l D'Appolonia
Consultins Ensineers. Inc (3)
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear- Inc. (a)
Figures l-4 N/A
b)
Part I.D
PermitNo. UGW370004
cross-valley dike. Inside this layer, an east-west oriented pipe was installed to
gather fluids at the upstream toe of the cross-valley dike.
Tailings Cell2 - which consists of the following major design elements:
1) Cross-valley Dike - constructed at the south margin of Cell 2 of native granular
materials with a 3:1 slope, a 2D-foot crest width, and crest elevation of about
5,615 ft amsl. The east and west interior slopes consist of cut-slopes with a 3:1
grade. The Cell I south dike forms the north margin of Cell 2, with a crest
elevation of 5,620 ft amsl.
2) Liner System - includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell2 is 5,615.0 ft and 5,613.5 ft amsl
on the north and south dikes, respectively. Said Cell2 FML liner is independent
of all other disposal cell FML liners. Immediately above the FML, a nominal 12-
inch (cell floor) to l8-inch (inside sideslope) soil protective blanket was
constructed of native sands from on-site excavated soils.
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch
thick layer of crushed sandstone was prepared and rolled smooth as a FML sub-
base layer. Beneath this underlay, native sandstone and other foundation materials
were graded to drain to a single low point near the upstream toe of the south
cross-valley dike. Inside this layer, an east-west oriented pipe was installed to
gather fluids at the upstream toe of the cross-valley dike.
4) Slimes Drain Collection System immediately above the FML a nominal l2-inch
thick protective blanket layer was constructed of native silty-sandy soil. On top of
this protective blanket, a network of l.5-inch PVC perforated pipe laterals was
installed on a grid spacing interval of about 50-feet. These pipe laterals gravity
drain to a 3-inch diameter perforated PVC collector pipe which also drains toward
the south dike and is accessed from the ground surface via a 24-inch diameter,
vertical non-perforated HDPE access pipe. Each run of lateral drainpipe and
collector piping was covered with a 12 to l8-inch thick berm of native granular
filter material. At cell closure, leachate head inside the pipe network will be
removed via a submersible pump installed inside the 24-inch diameter HDPE
access pipe.
Tailings Cell 3 - consisting of the following major design elements:
1) Cross-valley Dike - constructed at the south margin of Cell 3 of native granular
materials with a 3:l slope, a 2O-foot crest width, and a crest elevation of 5,610 ft
amsl. The east and west interior slopes consist of cut-slopes with a 3: I grade. The
Cell2 south dike forms the north margin of Cell 3, with a crest elevation of 5,615
ft amsl.
2) Liner System - includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell 3 is 5,613.5 ft and 5,608.5 ft amsl
on the north and south dikes, respectively. Said Cell 3 FML liner is independent
of all other disposal cell FML liners.
c)
aJ.
Part I.D
PermitNo. UGW370004
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch
thick layer of crushed sandstone was prepared and rolled smooth as a FML sub-
base layer. Beneath this underlay, native sandstone and other foundation materials
were graded to drain to a single low point near the upstream toe of the south
cross-valley dike. Inside this layer, an east-west oriented pipe was installed to
gather fluids at the upstream toe of the cross-valley dike.
4) Slimes Drain Collection Layer and System - immediately above the FML, a
nominal l2-inch (cell floor) to l8-inch (inside sideslope) soil protective blanket
was constructed of native sands from on-site excavated soils (70%) and dewatered
and cyclone separated tailings sands from the mill (30%). On top of this
protective blanket, a network of 3-inch PVC perforated pipe laterals was installed
on approximately 50-foot centers. This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a l2-inch diameter, inclined HDPE trccess
pipe. Each run of the 3-inch lateral drainpipe and collector pipe was covered with
a 12 to 18-inch thick berm of native granular filter media. At cell closure, leachate
head inside the pipe network will be removed via a submersible pump installed
inside the l2-inch diameter inclined access pipe.
Existing Tailings Cell Construction Authorized - tailings disposal in existing Tailings
Cells 1, 2, and 3 is authorizedby this Permit as defined in Table 3 and Part I.D.1, above.
Authorized operation and maximum disposal capacity in each of the existing tailings cells
shall not exceed the levels authorized by the License. Under no circumstances shall the
freeboard be less than three feet, as measured from the top of the FML. Any modification
by the Permittee to any approved engineering design parameter at these existing tailings
cells shall require prior Director approval, modification of this Permit, and issuance of a
construction permit.
Existing Facility DMT Performance Standards - the Permittee shall operate and maintain
certain mill site facilities and the existing tailings disposal cells to minimize the potential
for wastewater release to groundwater and the environment, including, but not limited to
the following additional DMT compliance measures:
a) DMT Monitoring Wells at Tailings Cell 1 - at all times the Permittee shall operate
and maintain Tailings Cell I to prevent groundwater quality conditions in any nearby
monitoring well from exceeding any Ground Water Compliance Limit established in
Table 2 of this Permit.
b) Tailings Cells 2 and 3 - including the following performance criteria:
l) 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 9O-hours, as measured from the time that
pumping ceases, and
8
c)
d)
e)
Part I.D
PermitNo. UGW370004
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 Compliance - The Permittee shall submit an annual report
on or before March 1 following the reporting year which includes but is not
limited to; l) Monthly volumes of fluid pumped from the slimes drain for each
applicable tailings disposal cell; 2) The results of all quarterly slimes 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.
Maximum Tailings Waste Solids Elevation - upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation of the tailings waste solids does
not exceed the top of the FML liner.
DMT Monitoring Wells - at all times the Permittee shall operate and maintain
Tailings Cells 2 and 3 to prevent groundwater quality conditions in any nearby
monitoring well from exceeding any Ground Water Compliance Limit established in
Table 2 of this Permit.
Feedstock Storage Area - open-air or bulk storage of all feedstock materials at the
facility awaiting mill processing shall be limited to the eastem portion of the mill site
area described in Table 4, below. Storage of feedstock materials at the facility outside
this area, shall meet the requirements in Part I.D.l l. At the time of mill site closure,
the Permittee shall reclaim and decommission the Feedstock Storage Area in
compliance with an approved Reclamation Plan. The Permittee shall maintain a
minimum 4-foot wide buffer zone on the inside margin of the Feedstock Storage Area
between the storage area fence and the Feedstock which shall be absent of feed
material in order to assure that materials do not encroach on the boundary of the
storage area.
oordinates (l)Table 4. Feedstock Storaee Area C
Corner Northine (ft)Eastine (ft)
Northeast 323.59s 2-s80.92s
Southeast 322.140 2-580.920
Southwest 322.140 2.580.420
West I 322.815 2.580.410
West 2 323.040 2.580.085
West 3 323,120 2,580,085
West 4 323.315 2-s80-28s
West 5 323.415 2,579,990
Northwest 323.600 2.s79.990
Footnote:l) Approximate State Plane Coordinates beginning from the extreme northeast comer and progressing clockwise around
the feedstock are a(from6/22101 DUSA Response, Attachment K, Site Topographic Map, Revised June,200l.)
Mill Site Chemical Reagent Storage - for all chemical reagents stored at existing
storage facilities and held for use in the milling process, the Permittee shall provide
secondary containment to capture and contain all volumes of reagent(s) that might be
released at any individual storage area. Response to spills, cleanup thereof, and
9
4.
Part I.D
Permit No. UGW370004
required reporting shall comply with the provisions of the approved Emergency
Response Plan as found in the currently approved Stormwater Best Management
Practices Plan. For any new construction of reagent storage facilities, said secondary
containment and control shall prevent any contact of the spilled or otherwise released
reagent or product with the ground surface.
Best Available Technology Requirements for New Construction - 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 Best Available Technology (BAT) requirements
stipulated by the Utah Ground Water Quality Protection Regulations (UAC R317-6).
Upon Director approval this Permit may be re-opened and modified to include any
necessary requirements.
BAT Design Standards for Tailings Cell 4,{ - the BAT design standard for Tailings Cell
44 shall be defined by and construction conform to the requirements of the Jvne25,2007
Director design approval letter for the relining of former existing Tailings Cell No. 4,{,
and as summarized by the engineering drawings, specifications, and description in Table
5. below:
fications
5.
Table 5. Aooroved Tai inss Cell4,A.ring Design an,I
Engineering Drawings
Name Date Revision No.Title
Sheet I of7 June.2007 Title Sheet
Sheet 2 of7 June 15,2007 Rev. I Site Plan
Sheet3 of7 June 15.2007 Rev. I Base Gradins Plan
Sheet 4 of7 June 1 5.2007 Rev. I Pioe Lavout Plan
Sheet 5 of7 June 15,2007 Rev. I Linins System Details I
Sheet 6 of 7 June 15.2007 Rev. 1 Linine System Details II
Sheet 7 of7 June I 5.2007 Rev. I Linine Svstem Details III
Fieure 1 Aueust.2008 Spillway Splash Pad Anchor
Engineeq4g llggrfig4lqn!
Date Document Title Prepared by
June,2007 Revised Technical Specifications for the
Construction of Cell4A Lining System
Geosvntec Consultants
June.2007 Revised Construction Quality Assurance Plan for
the Construction of Cell4,{ Lining System
Geosyntec Consultants
March 27.2007 Revised Geosynthetic Clay..l-iner Hydration
Demonstration Work Plan (')
Geosyntec Consultants
November 27.2006 Cell Seismic Study (')MFG Consulting Scientists
and Engineers
October 6,2006 Calculation of Action Leakage Rate Through the
Leakage Detection System Underlying a
Geomembrane Liner
Geosvntec Consultants
June22,2006 Slope Stability Analysis Cell44' - Interim
Conditions
Geosyntec Consultants
June 23.2006 Settlement Evaluation of Berms ('Geosvntec Consultants
Ausust 22,2006 Pine Strensth Calculations Geosvntec Consultants
September 27,2007 DMC Cell4'A. - GCL HYdration Geosvntec Consultants
Footnotes:
l0
r)
2)
Part I.D
PermitNo. UGW370004
As qualified by conditions found in May 2,2007 Division of Radiation Confol letter.
As clarified by February 8,2007 Division of Radiation Control Round 6 Intenogatory.
Tailings Cell 44 Design and Construction - approved by the Director will consist of the
following maj or elements :
Dikes - consisting of existing earthen embankments of compacted soil, constructed by
the Permittee between 1989 andl990, and composed of four dikes, each including a
l5-foot wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has an interior slope of 2H to lV.
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 2ll-feet at the west dike.
Foundation - including existing subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90Yo. Floor of Cell 44 has an average
slope of IVo that grades from the northeast to the southwest corners.
Tailings Capacity - the floor and inside slopes of Cell 44 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).
Liner and Leak Detection Systems - including the following layers, in descending
order:
l) Primary Flexible Membrane Liner (FML) - consisting of impermeable 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 4,A' 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 4,{, and drains to a leak
detection sump in the southwest comer. Access to the leak detection sump is via
an l8-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 l0 feet by 2 feet deep. In tum, the gravel filter layer will be enclosed
in an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
3) Secondary FML - consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends across the
entire Cell 4,{ floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
4) Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay liner(GCL) composed of O.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile. Prior to disposal of any wastewater in
Cell 44, the Permittee shall demonstrate that the GCL has achieved a moisture
a)
b)
c)
d)
tl
e)
Part I.D
PermitNo. UGW370004
content of at least 50% by weight. This item is a revised requirement per DRC
letter to DUSA dated September 28,2007.
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 pattem across the
floor of Cell 44. 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 5O-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'obackbone" 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 southwest comer of Cell 4A where it joins the slimes drain
access pipe.
3) Slimes Drain Access Pipe - consisting of an l8-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell 4,A. 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
l8-inch pipe with the 4-inch SDC pipe. At some future time, a pump will be set in
this l8-inch pipe and used to remove tailings wastewaters for purposes of de-
watering the tailings cell.
Cell 44 North Dike Splash Pads - three 20-foot wide splash pads will be constructed
on the north dike to protect the primary FML from abrasion and scouring by tailings
slurry. These pads will consist of an extra layer of 60 mil HDPE membrane that will
be installed in the anchor trench and placed down the inside slope of Cell 44, 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.
Cell 44 Emergency Spillway - a concrete lined spillway will be constructed near the
western comer of the north dike to allow emergency runoff from Cell 3 into Cell44.
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. No other spillway or overflow
structure will be constructed at Cell 4A. All stormwater runoff and tailings
t2
g)
6.
Part I.D
Permit No. UGW370004
wastewaters not retained in Cells 2 and 3, will be managed and contained in Cell 44,
including the Probable Maximum Precipitation and flood event.
BAT Perforrnance Standards for Tailings Cell 4,A. - the Permittee shall operate and
maintain Tailings Cell 4,A' so as to prevent release of wastewater to groundwater and the
environment in accordance with the currently approved Cell 4,{ BAT, Monitoring,
Operations and Maintenance Plan. Any failure to achieve or maintain the required BAT
performance standards shall constitute a violation of the Permit and shall be reported to
the Director in accordance with Part I.G.3. Performance standards for Tailines Cell 44
shall include the following:
a) Leak Detection System (LDS) Maximum Allowable Daily Head - the fluid head in
the LDS shall not exceed 1 foot above the lowest point on the lower flexible
membrane liner on the cell floor. For purposes of compliance this elevation will
equate to a maximum distance of 2.28 feet above the LDS transducer. At all times the
Permittee shall operate the LDS pump and transducer in a horizontal position at the
lowest point of the LDS sump floor.
b) LDS Maximum Allowable Daily Leak Rate - shall not exceed 24,160 gallons/day.
c) Slimes Drain Annual Average Recovery Head Criteria - after the Permittee initiates
pumping conditions in the slimes drain layer in Cell 44, the Permittee 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), and2) a maximum head of 1.0 feet in the
tailings (as measured from the lowest point of upper flexible membrane liner) in 6.4
years or less.
d) Maximum Weekly Wastewater Level - under no circumstance shall the freeboard be
less then 3-feet in Cell 44, as measured from the top of the upper FML.
Definition of 11e.(2) Waste - for purposes of this Permit, 1le.(2) waste is defined as: "...
tailings or wastes produced by the extraction or concentration of uranium or thorium
from any ore processed primarily for its source material content", as defined in Section
l1e.(2) of the U.S. Atomic Energy Act of 1954, as amended; which includes other
process related wastes and waste streams described by a March 7,2003 NRC letter from
Paul H. Lohaus to William J. Sinclair.
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 liner elevation internal to any disposal cell,
i.e. create a "bathfub" effect. and
7.
8.
13
Part I.D
PermitNo. UGW370004
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.
9. Facility Reclamation Requirements - upon commencement of decommissioning, the
Permittee shall 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 in an approved Reclamation Plan. The Director reserves the
right to require modifications of the 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.
10. Stormwater Management and Spill Control Requirements - the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices Plan.
Said plan includes the following minimum provisions:
a) Protect groundwater quality or other waters of the state by design, construction,
and/or active operational measures that meet the requirements of the Ground Water
Quality Protection Regulations found in UAC R317-6-6.3(G) and R3l7-6-6.4(C),
b) Prevent, control and contain spills of stored reagents or other chemicals 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.
Reconstruction of stormwater management and/or chemical reagent storage facilities,
existing at the time of original Permit issuance, may be required by the Director after
occurrence of a major spill or catastrophic failure, pursuant to Part IV.N.3 of this Permit.
I l. BAT Requirements for Feedstock Material Stored Outside the Feedstock Storage Area -
the Permittee shall store and manage feedstock materials outside the 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 ofeach 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:
1) A storage areacomposed of a hardened engineered surface of asphalt or concrete,
and
2) A storage area designed, constructed, md 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.
T4
Part I.D
PermitNo. UGW370004
3) A storage area that provides containment berms to control stormwater run-on and
run-off, and
4) Stormwater drainage works approved in advance by the Director, or
5) Other storage facilities and means approved in advance by the Director.
12. BAT Design Standards for Tailings Cell 48 - the BAT design standard for Tailings Cell
48 shall be defined by and constructed in accordance with the requirements as
summarized by the engineering drawings, specifications, and description in Table 6,
below:
able 6.Ta I Cell48 En rins Desisn and Soecifications
Ensineerinp Drawinss
Name Date Revision No.Title
Sheet I of8 Januaw 2009 Rev. I Cover Sheet
Sheet 2 of 8 Januarv 2009 Rev. I Site Plan
Sheet 3 of8 Januarv 2009 Rev. I Base Gradins Plan
Sheet 4 of 8 Januarv 2009 Rev. I Pipe Layout and Details
Sheet 5 of8 December 2007 Rev.0 Linins Svstem Details I
Sheet 6 of 8 Januarv 2009 Rev. I Linins System Details II
Sheet 7 of 8 January 2009 Rev. I Lining System Details III
Sheet 8 of8 Januarv 2009 Rev. I Linine System Details IV
Fisure I Januarv 2009 Mill Site Drainage Basins (supportine reference)
Ensineerins Snecifications
Date Document Title Prepared by
Januarv 2009 Slope Stabilitv Analvsis Ca ulation Packase Geosvntec Consultants
January 2009 Seismic Deformation Analysis Calculation
Packase
Geosyntec Consultants
January 2009 Revised Pipe Strength Analysis Calculation
Packase
Geosyntec Consultants
January 2009 Revised Comparison of Flow Though Compacted
Clay Liner and Geosynthetic Clay Liner
Calculation Packase
Geosyntec Consultants
January 2009 Revised Action Leakase Rate Calculation
Packaee
Geosyntec Consultants
Ausust 2009 Blasting - Locations and Profiles, Attachment:
Fisures I and2
Geosyntec Consultants
August 2009 (Revised) Technical Specifications, with the
exception of Section 02200 (Earthwork)
Geosyntec Consultants
Aueust 2009 Cell 48 Capacity Calculations Geosyntec Consultants
Aueust 2009 Revised Cushion Fabric Calculations
August 2009 Construction Quality Assurance Plan for the
Construction of Cell48 Linins Svstem
Geosyntec Consultants
September 2009 (Revised) Technical Specification Section 02200
(Earthwork)
Geosyntec Consultants
August 6,2009
Blast Plan, KGL and Associates and Blast Plan
Review, Geosyntec Consultants letter dated
September 10,2009
KGL and Associates and
Geosyntec Consultants
September 2009 Probable Maximum Precipitation (PMP) Event
Computation
Geosyntec Consultants
Januarv 2009 Slope Stability Analysis Calculation Packase Geosyntec Consultants
l5
Part I.D
PermitNo. UGW370004
Tailings Cell 48 Design and Construction - approved by the Director will consist of the
following major elements:
a) Dikes - consisting of newly constructed dikes on the south and west side of the cell,
each including a 2O-foot wide road at the top (minimum) to support an access road.
The grading plan for the Cell 48 excavation includes interior slopes of 2H to lV. The
exterior slopes of the southern and westem dikes will have typical slopes of 3H to lV.
Limited portions of the Cell 48 interior sideslopes in the northwest corner and
southeast corner of the cell, (where the slimes drain and leak detection sump will be
located will also have a slope of 3H to lV. The base width of the southem dikes
varies from approximately 92 feet at the western end to approximately 190 feet at the
eastem end of the dike, with no exterior embankment present on any other side of the
cell.
b) Foundation - including existing subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90oh at a moisture content between *3olo
and -3o/o of optimum moisture content, as determined by ASTM D-1557. The floor of
Cell 48 has an average slope of loh that grades from the northwest corner to the
southeast comer.
c) Tailings Capacity - the floor and inside slopes of Cell 48 encompass about 44 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 48 floor area. In other locations, the primary FML
will be in contact with the slimes drain collection system (discussed below).
Leak Detection System - includes a permeable HDPE geonet that extends across
the entire area under the primary FML in Cell 48, and drains to a leak detection
sump in the southeast corner. Access to the leak detection sump is via an l8-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 a sump having dimensions of 15 feet by 10 feet by 2 feet deep
ihat contains a leak detection system sump area. 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.
Secondary FML - consisting of a 60-mil HDPE membrane found immediately
below the leak detection geonet. Said FML also extends across the entire Cell 48
floor, up the inside side-slopes and is also anchored in a trench at the top of all
four dikes.
Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay liner
(GCi) composed of 0.2-inch of low permeability bentonite clay centered and
t6
2)
3)
4)
e)
Part I.D
PermitNo. UGW370004
stitched between two layers of geotextile. Prior to disposal of any wastewater in
Cell 48, the Permittee shall demonstrate that the GCL has achieved a moisture
content of at least 50%by weight.
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:
l) Horizontal Strip Drain System - is installed in a herringbone pattern across the
floor of Cell 48 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 5O-foot centers, where they conduct fluids downgradient in a
southwesterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
fabric filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC)
pipe found at the downgradient end of the strip drain lines. This pipe is in tum
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve as
an additional filter material. This perforated collection pipe seryes as the
"backbone" to the slimes drain system and runs from the far northwest corner
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 l8-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell48 at the southeast comer, above the primary
FML. Said pipe then merges with another horizontal pipe of equivalent diameter
and material, where it is enveloped by gravel and 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.
Cell 48 North and East Dike Splash Pads - Nine 2O-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 60 mil HDPE
membrane that will be installed in the anchor trench and placed down the inside slope
of Cell 48, from the top of the dike, under the inlet pipe, and down the inside slope to
a point at least 5 feet onto the cell 48 floor beyond the toe of the slope.
Cell 4B Emergency Spillway - a concrete lined spillway will be constructed near the
southeastem corner of the east dike to allow emergency runoff from Cell44 into Cell48. This spillway will be limited to a 6-inch reinforced concrete slab. with a welded
s)
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Part I.D
PermitNo. UGW370004
wire fabric installed within it at 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 membrane splash pad will be installed beneath the emergency spillway.
No other spillway or overflow structure will be constructed at Cell 48. All
stormwater runoff and tailings wastewaters not retained in Cells 2 and 3, and 4A will
be managed and contained in Cell48, including the Probable Maximum Precipitation
and flood event.
13. BAT Performance Standards for Tailings Cell 48 - the Permittee shall operate and
maintain Tailings Cell 48 so as to prevent release of wastewater to groundwater and the
environment in accordance with the currently approved Cell 48 BAT, Monitoring,
Operations and Maintenance Plan. Any failure to achieve or maintain the required BAT
performance standards shall constitute a violation of the Permit and shall be reported to
the Director in accordance with Part I.G.3. Performance standards for Tailings Cell 48
shall include the following:
a) Leak Detection System (LDS) Maximum Allowable Daily Head - the fluid head in
the LDS shall not exceed I foot above the lowest point on the lower flexible
membrane liner on the cell floor. At all times the Permittee shall operate the LDS
pump and transducer in a horizontal position at the lowest point of the LDS sump
floor.
b) LDS Maximum Allowable Daily Leak Rate - shall not exceed 26,145 gallons/day.
c) Slimes Drain Annual Average Recovery Head Criteria - after the Permittee initiates
pumping conditions in the slimes drain layer in Cell48, the Permittee 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 upper flexible membrane liner) in 5.5
years or less.
d) Maximum Weekly Wastewater Level - under no circumstance shall the freeboard be
less than 3-feet in Cell48, as measured from the top of the upper FML.
14. BAT Performance Standards for the New Decontamination Pad - the Permiuee shall
operate and maintain the New Decontamination Pad (NDP) to prevent release of
wastewater to groundwater and the environment in accordance with the currently
approved DMT Monitoring Plan. Any failure to achieve or maintain the required BAT
performance standards shall constitute a violation of the Permit and shall be reported to
the Director in accordance with Part I.G.3. Performance standards for the NDP shall
include, but are not limited to, the following:
a) NDP LDS Access Pipes - the water level shall not exceed 0.10 foot above the
concrete floor in any LDS access pipe, at any time. Compliance will be defined 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).
b) Soil and debris will be removed from the wash pad of the NDP, in accordance with
the currently approved DMT Monitoring Plan. Cracks in the wash pad gteater than
1/8 inch (width) witl be repaired within five working days of discovery.
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Part I.E.
Permit No. UGW370004
E. GnouNIo WarpR CoupltaNcE AND TpcnNolocy PERFoRMANCE MoNrroRruc - beginning
with the effective date and lasting through the term of this Permit or as stated in an approved
closure plan, the Permittee shall sample groundwater monitoring wells, tailing cell
wastewaters, seeps and springs, monitor groundwater levels, monitor water levels of process
solutions, and monitor and keep records of the operation of the facility, as follows:
l. Routine Groundwater Compliance Monitoring - the Permittee shall monitor upgradient,
lateral gradient, and downgradient groundwater monitoring wells completed in the
shallow aquifer in the vicinity of all potential discharge sources that could affect local
groundwater conditions at the facility, as follows:
a) Ground Water Monitoring Quality Assurance Plan - all groundwater monitoring and
analysis performed under this Permit shall be conducted in accordance with a Quality
Assurance Plan (QAP) cunently approved by the Director. 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
groundwater monitoring report pursuant to Part I.F.1.
b) Quarterly Monitoring - the Permittee shall monitor on a quarterly basis all monitoring
wells listed in Table 2 of this Permit where local groundwater average linear velocity
has been found by the Director to be equal to or greater than l0 feet/year. For
purposes of this Permit, quarterly monitoring is required at the following wells:
1) Upgradient Wells: none
2) Lateral or Downgradient Wells: MW-11, MW-14, MW-25, MW-26 (formerly
TW4-15), MW-30, MW-31, MW-36.
c) Semi-annual Monitoring - the Permittee shall monitor on a semi-annual basis all
monitoring wells listed in Table 2 of this Permit, where local groundwater average
linear velocity has been found by the Director to be less than l0 feetlyear, and all
general monitoring wells. For purposes of this Permit, semi-annual monitoring is
required at the following wells:
l) Monitoring Wells Listed on Table 2:
i. Upgradient Well: MW-27.
ii. Lateral or Downgradient Wells: MW-2, MW-3A, MW-5, MW-12, MW-
15, MW-17, MW-23, MW-24, MW-28, MW-29, and MW-32 (formerly
TW4-17), MW-35, and MW-37.
2) General Monitoring Wells:
i. Upgradient Wells: MW-l, MW-18, and MW-19.
ii. Lateral or Downgradient Wells: TW4-24, MW-20 and MW-22.
d) Compliance Monitoring Parameters - all groundwater samples collected shall be
analyzed for the following parameters:
1) Field Parameters - depth to groundwater, pH, temperature, specific conductance,
and redox potential (Eh).
2) Laboratory Parameters
t9
2.
Part I.E.
PermitNo. UGW370004
i. GWCL Parameters - all contaminants specified in Table 2.
ii. General Inorganics - chloride, sulfate, carbonate, bicarbonate, sodium,
potassium, magnesium, calcium, and total anions and cations.
e) Special Provisions for Groundwater Monitoring - the Permittee shall ensure that all
groundwater monitoring conducted and reported complies with the following
requirements:
l) 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 Ground
Water Compliance Limit concentration defined in Table 2.
3) Gross Alpha Counting Variance - all gross alpha analysis shall be reported with
an effor 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 thrrn2O%
of the reported activity concentration. An error term may be greater than 20o/o 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.
Groundwater Monitoring: General Monitoring Wells - Upgradient wells MW-l, MW-l8,
and MW-19;Lateral Monitoring Well TW4-24; and Downgradient wells MW-20 and
l.dW-22 The Permittee shall monitor wells MW-I, MW-18, MW-19, TW4-24, MW-20
and MW-22 on a semi-annual basis. Said sampling shall comply with the following
Permit requirements, but shall not be considered compliance monitoring for the purposes
of Pan G:
a) Routine groundwater compliance monitoring requirements of Part I.E.l.
b) Groundwater head monitoring requirements of Part I.E.3
c) Well monitoring procedure requirements of Part I.E.5.
Groundwater Head Monitoring - on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.l, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers:
a) Point of Compliance Wells - identified in Table 2 andPart I.E.1 of this Permit-
b) Piezometers - P-l,P-2, P-3, P-4, and P-5.
c) Head Monitoring Well - MW-34.
d) General Monitoring Wells - Upgradient wells MW-l, MW-18, and MW-19;Lateral
well TW4-24; and Downgradient wells MW-20 andMW-22.
e) Contaminant Investigation Wells - any well required by the Director as a part of a
contaminant investigation or groundwater corrective action.
0 Any other wells or piezometers required by the Director.
aJ.
20
4.
Part I.E.
Permit No. UGW370004
Groundwater Monitoring Well Design and Construction Criteria - all new groundwater
monitoring wells installed at the facility shall 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(D(6), including the
EPA RCRA Ground Water Monitoring Technical Enforcement Guidance Document,
1986, OSWER-9950.1.
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
Monitoring Procedures for Wells - beginning with the date of Permit issuance, all
monitoring shall be conducted by the Permittee 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 within the well casing has been performed.
b) Sampling Plan - all sampling shall be conducted to ensure collection of representative
samples, and reliability and validity of groundwater monitoring data.
c) Laboratory Approval - all analyses shall 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 pu{pose, 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 guidelines. 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 shallidenti$ the manufacturer's and model number of each piece of freld equipment used
and calibration.
White Mesa Seeps and Springs Monitoring - the Permittee shall conduct annual
monitoring of all seeps and springs identified in the currently approved Sampling Plan for
Seeps and Springs in the Vicinity of the White Mesa Uranium Mill. Said monitoring shall
include, but is not limited to:
a) Field Measurements - including: pH, temperature, and specific conductivity.
b) Water Quality Sampling and Analysis - the Permittee shall collect grab samples andperform laboratory analysis of all water quality parameters identif,red in Table 2 of
this Permit.
c) Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified laboratory.
d) Analytical Methods - all laboratory analysis shall be conducted using analytical
methods listed in the currently approved QAP pursuant to Part I.E.1 of this permit.
2T
5.
6.
Part I.E.
PermitNo. UGW370004
e) Minimum Detection Limits - all seeps or springs water quality analyses reported shall
have a minimum detection limit or reporting limit that is less than or equal to the
respective:
l) Ground Water Quality Standards concentrations defined in Table 2 of this Permit,
and
2) For TDS, Sulfate, and Chloride, the Minimum Detection Limit for those
constituents for seeps and springs monitoring will be as follows: 10 mg/L, I
mglL, and I mg/L, respectively.
f) Quality Control Samples - the Permittee will conduct quality control (QC) sampling
and analysis as a part of all seeps and springs sampling, in accordance with the
requirements of Section 4.3 of the currently approved QAP; pursuant to Part I.E.l of
this Permit. Said QC samples shall include, but are not limited to: trip blanks,
duplicate samples, and equipment rinse blanks.
g) Prior Notification - at least 15 calendar days before any fieldwork or water quality
sample collection, the Permittee shall provide written notice to allow the Director to
observe or split sample any or all seeps or springs.
7. DMT Performance Standards Monitoring - the Permittee shall perform technology
performance monitoring in accordance with the currently approved DMT Monitoring
Plan to determine if DMT is effective in minimizing and controlling the release of
contaminants pursuant to the provisions of Parts I.D.1 and I.D.3 of this Permit, including,
but not limited to the following activities:
a) Weekly Tailings Wastewater Pool Elevation Monitoring: Cells I and 3 - the Permittee
shall monitor and record weekly the elevation of wastewater in Tailings Cells 1 and 3
to ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the License. Said measurements shall be made from a wastewater
level gauge or elevation survey to the nearest 0.01 foot.
b) Quarterly Slimes Drain Water Level Monitoring: Cells 2 and 3 - the Permittee shall
monitor and record quarterly the depth to wastewater in the slimes drain access pipes
as described in Part I.D.3 of this Permit and the currently approved DMT Monitoring
Plan at Tailings Cells 2 and 3 to determine the recovery head. For purposes of said
monitoring, the Permittee shall at each tailings cell:
l) Perform at least I separate slimes drain recovery test at each disposal cell in each
quarterly period of each calendar year that meets the requirements of Part I.D.3,
2) Designate, operate, maintain, and preserve one water level measuring point at the
centerline of the slimes drain access 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.
22
Part I.E.
PermitNo. UGW370004
c) Weekly Feedstock Storage Area Inspection - the Permittee shall conduct weekly
inspections of all feedstock storage to: l)Confirm the bulk feedstock materials are
maintained within the approved Feedstock Storage Area defined by Table 4, and 2)
Verify that all alternate feedstock materials located outside the Feedstock Area
defined in Table 4, are stored in accordance with the requirements found in Part
I.D.11.
d) Feedstock Material Stored Outside the Feedstock Storage Area Inspections
a) Weekly Inspection - the Permittee will conduct weekly inspections to verifu 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 materials, pursuant to Part I.D.11, prior Director
approval will be secured for the following:
i. Engineering Design and Specifications - in accordance with the requirements
of Part I.D.4, and
ii. Operation and Maintenance Plan.
e) Inspections of Tailing Cell and Pond Liner Systems - the Permittee shall inspect the
liner system at Tailing Cells l, 2, and 3 on a daily basis pursuant to the requirements
of Sections 2.I and 2.2 of the currently approved DMT Monitoring Plan. In the event
that any liner defect or damage is identified during a liner system inspection, the
Permittee shall: 1) report and repair said defect or damage pursuant to Part I.G.3 by
implementation of the currently approved Liner Maintenance Provisions, and 2)
report all repairs made pursuant to Part I.F.2.
f) Weekly New Decontamination Pad Inspection - the Permittee shall conduct weekly
inspections of the New Decontamination Pad as described in Part I.D.14 of this
Permit and the currently approved DMT Monitoring Plan.
8. Cell 4A BAT Perfonnance Standards Monitoring and Maintenance - in accordance with
the currently approved Cell4,A, BAT, Monitoring, Operations and Maintenance Plan, the
Permittee shall immediately implement all monitoring and recordkeeping requirements
therein. The Cell4,A. BAT monitoring includes the following:
a) Weekly Leak Detection System (LDS) Monitoring - including:
1) Leak Detection System Pumping and Monitoring Equipment - the Permittee shall
provide continuous operation of the leak detection system pumping and
monitoring equipment, including, but not limited to, the submersible pump, pump
controller, head monitoring, and flow meter equipment approved by the Director.
Failure of any LDS pumping or monitoring equipment not repaired and made
fully operational within 24-hours of discovery shall constitute failure of BAT, and
a violation of this Permit.
2) Maximum Allowable Head - the Permittee shall measure the fluid head above the
lowest point on the secondary flexible membrane 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 l-foot level above the lowest point in the
lower flexible membrane liner on the cell floor. For purposes of compliance
23
Part I.E.
PermitNo. UGW370004
monitoring this l-foot distance shall equate to 2.28 feet above the leak detection
system transducer.
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS. Under no circumstances shall the
average daily LDS flow volume exceed 24,160 gallons/day.
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 44. Said measurements shall be made to the nearest 0.1 foot.
Quarterly Slimes Drain Recovery Head Monitoring - immediately after the Permittee
initiates pumping conditions in the Tailings Cell 4,A. slimes drain system, quarterly
recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of this Permit and the currently approved
Cell4,A. BAT, Monitoring, Operations and Maintenance Plan.
Liner Maintenance and Repair - all repairs to the liner shall be completed in
accordance with Section 9.4 of the approved June 2007 Geosyntec Consultants Cell
4A Construction Quality Assurance Plan (CQAiQC Plan) as found in Table 5 of this
Permit. Repairs shall be performed by qualified liner repair personnel and shall be
reported in a Liner Repair Report, certified by a Utah licensed Professional Engineer.
The Liner Repair Report shall be submitted to for Director approval in accordance
with Part I.F.3 of the Permit. Any leak, hole, or other damage to the liner will be
reported to the Director pursuant to the requirements found in Part I.G.3.
9. 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 kglyt.
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.
10. Tailings Cell Wastewater Quality Monitoring - on an annual basis, the Permittee shall
collect wastewater quality samples from each wastewater source at each tailings cell at
the facility, including, but not limited to:
a) One surface impounded wastewater location at each of Tailings Cells 1, 3,4A, and
48.
One slimes drain wastewater access pipe at each of Tailings Cells 2, 3, 4A, and 48.
For Cells 3,4A, and 48, this requirement shall apply immediately after initiation of
de-watering operations at these cells, and
One leak detection wastewater access pipe at Tailings Cells 44 and 4B'.
All such sampling shall be conducted in August of each calendar year in compliance
with the currently approved White Mesa Uranium Mill Tailing and Slimes Drain
Sampling Program. Said annual monitoring shall include, but is not limited to:
1) Water Quality Sampling and Analysis - the Permittee shall collect grab samples
and perform laboratory analysis of all:
i. Water quality parameters identified in Table 2 of this Permit, and
24
b)
c)
b)
c)
d)
Part I.E.
PermitNo. UGW370004
ii. Semi-volatile compounds identified in EPA Method 8270D.
2) Certified Laboratory Analysis - all laboratory analysis will be conducted by a
Utah certifi ed laboratory.
3) Analytical Methods - all laboratory analysis shall be conducted using analytical
methods listed in the currently approved QAP pursuant to Part I.E.l of this
Permit.
4) Minimum Detection Limits - all water quality analyses reported shall have a
minimum detection limit or reporting limit that is less than or equal to the
respective:
i. Ground Water Quality Standards concentrations defined in Table 2 of this
Permit,
ii. For TDS, Sulfate, and Chloride, the Minimum Detection Limit for those
constituents for Tailing Cell wastewater monitoring will be as follows: 1,000
mg/L,1,000 mg/L, and 1 mg/L, respectively, and
iii. Lower limits of quantitation for groundwater for semi-volatile organic
compounds listed in Table 2 of EPA Method 8270D, Revision 4, dated
February, 2007.
5) Quality Control Samples - the Permittee will conduct quality control (QC)
sampling and analysis as a part of all tailings wastewater sampling, in accordance
with the requirements of Section 4.3 of the currently approved QAP; pursuant to
Part I.E.l of this Permit. Said QC samples shall include, but are not limited to:
trip blanks, duplicate samples, and equipment rinse blanks.
6) Prior Notification - at least 30 calendar days before any water quality sample
collection, the Permittee shall provide written notice to allow the Director to
observe or split sample any tailings cell, slimes drain, or leak detection
wastewaters.
7) Sample Omission - in the course of each annual sampling event, the Permittee
shall sample and analyze all tailings cell, slimes drain, and leak detection
wastewater sources identified in the currently approved Tailings and Slimes Drain
Sampling Program (pp. 1-3), or as required by this Permit, whichever is greater.
The Permittee shall not omit sampling of any of tailings cell wastewater source
during said annual event, without prior written approval from the Director.
ll.Groundwater Monitoring Modifications - before any modification of groundwater
monitoring or analysis procedures, methods, or equipment, the Permittee must obtain
prior written approval from the Director.
12. Cell 48 BAT Performance Standards Monitoring and Maintenance - immediately
following Director approval of the Cell 4B BAT, Monitoring, Operations and
Maintenance Plan, the Permittee shall immediately implement all monitoring and
recordkeeping requirements therein. The Cell 4B BAT monitoring shall include the
following:Weekly Leak Detection System (LDS) Monitoring - including:
1) Leak Detection System Pumping and Monitoring Equipment - the Permittee shall
provide continuous operation of the leak detection system pumping and
25
b)
c)
Part I.E.
PermitNo. UGW370004
monitoring equipment, including, but not limited to, the submersible pump, pump
controller, head monitoring, and flow meter equipment approved by the Director.
Failure of any LDS pumping or related monitoring equipment not repaired and
made fully operational within 24-hours of discovery shall constitute failure of
BAT, and a violation of this Permit.
2) Maximum Allowable Head - the Permittee shall measure the fluid head above the
lowest point on the secondary flexible membrane by the use of procedures and
equipment approved by the Director. Under no circumstance shall fluid head in
the leak detection system (LDS) sump exceed a l-foot level above the lowest
point in the lower flexible membrane liner on the cell floor. Any occurrence of
leak detection system fluids above this l-foot limit shall constitute failure of
BAT, and a violation of this Permit.
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS. Under no circumstances shall the
average daily LDS flow volume exceed 26,145 gallons/day.
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 Cell48. Said measurements shall be made to the nearest 0.1 foot.
Quarterly Slimes Drain Recovery Head Monitoring - immediately after the Permittee
initiates pumping conditions in the Tailings Cell 48 slimes drain system, quarterly
recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of this Permit and the currently approved
Cell48 BAT, Monitoring, Operations and Maintenance Plan.
Liner Maintenance and Repairs - all repairs to the liner shall be completed in
accordance with Section 10.4 of the approved August 2009 Geosyntec Consultants
Cell 48 Construction Quality Assurance Plan (CQA/QC Plan) as found in Table 6 of
this Permit. Repairs shall be performed by qualified liner repair personnel and shall
be reported in a Liner Repair Report, certified by a Utah licensed Professional
Engineer. The Liner Repair Report shall be submitted for Director approval in
accordance with Part I.F.3 of the Permit. Any leak, hole, or other damage to the liner
will be reported pursuant to the requirements found in Part I.G.3.
26
Part I.F.
PermitNo. UGW370004
F. RrponrrNc RequnevENTS - The following reporting procedures for routine and compliance
reports must be met.
l. Routine Groundwater Monitoring Reports - the Permittee shall submit quarterly
monitoring reports of field and laboratory analyses of all well monitoring and samples
described in Parts I.E.l, I.E.2, I.E.3, and I.E.5 of this Permit for Director review and
approval. Reports shall be submitted according to the following schedule:
Table 7. Ground Moni Schedulewater Momto
Ouarter Period Due Date
First Januarv - March June I
Second April - June September I
Third Julv - Seotember December I
Fourth October - December March I
Failure to submit the reports by the due date shall be deemed as noncompliance with this
Permit. Said monitoring reports shall include, but are not limited to, the following
minimum information:
a) Field Data Sheets - or copies thereof that provide the following: well name, date and
time of well purging, date and time of well sampling, type and condition of well
PumP, depth to groundwater before purging and sampling, calculated well casing
volume, volume of water purged before sampling, volume of water collected for
analysis, types of sample containers and preservatives.
b) Laboratory Results - or copies thereof that provide the following: date and time
sampled, date received by laboratory, and for each parameter analyzed, the following
information: laboratory result or concentration, units of measurement, minimum
detection limit or reporting limit, analytical method, date of analysis, counting error
for radiological analyses, total cations and anions for inorganic analysis.
c) Water Table Contour Map - which provides the location and identity of all wells
sampled that quarter, the measured groundwater elevation at each well measured in
feet above mean sea level, and isocontour lines to delineate groundwater flow
directions observed during the quarterly sampling event.
d) Quality Assurance Evaluation and Data Validation - including a written description
and findings of all quality assurance and data validation efforts conducted by the
Permittee in compliance with the currently approved Groundwater Monitoring
Quality Assurance Plan. Said report shall verify the accuracy and reliability of the
groundwater quality compliance data, after evaluation of sample collection techniques
and equipment, sample handling and preservation, analytical methods used, etc
e) Non-confonnance disclosure - with each quarterly groundwater monitoring report the
Permittee shall fully and completely disclose all non-conformance with requirements
of the currently approved QAP, mandated by part I.E.l(a).
0 Electronic Data Files and Format - in addition to written results required for every
sampling report, the Permittee shall provide an electronic copy of all laboratory
results for groundwater quality monitoring conducted. Said electronic files shail
27
J.
Part I.F.
Permit No. UGW370004
consist of Comma Separated Values (CSV) format, or as otherwise approved by the
Director.
g) Time Concentration Plots - with each quarterly groundwater monitoring report the
Permittee shall submit time concentration plots for each monitoring well for the
following constituents: chloride, fluoride, sulfate, and uranium.
Routine DMT Performance Standards Monitoring Report - the Permittee shall provide
quarterly monitoring reports of all DMT performance standards monitoring required by
Parts I.D.3 and 1.E.7 of this Permit. DMT monitoring shall be conducted in compliance
with this Permit and the currently approved DMT Monitoring Plan. When a liner repair is
performed at any DMT impoundment, a Repair Report is required by the Liner
Maintenance Provisions. This Repair Report shall be included with the next quarterly
DMT Report. Said monitoring reports and results shall be submitted for Director
approval on the schedule provided in Table 7, above.
Routine Cell4,A' and 48 BAT Perfonnance Standards Monitoring Reports - the Permittee
shall provide quarterly monitoring reports of all BAT performance standards monitoring
required by Parts I E.8 and l.E.l2 of this Permit. BAT Monitoring at Cells 4,A. and 48
shall be conducted in compliance with the currently approved BAT Monitoring,
Operations and Maintenance Plan. When a liner repair is performed at Tailings Cell 4,A'
or 48, a Repair Report is required by Parts I.8.8(c) and I.E.12(c) of the Permit. This
Repair Report shall be included with the next quarterly BAT Report. Said monitoring
report and results shall be submiued for Director approval on the schedule provided in
Table 7 above. At a minimum, reporting of BAT monitoring for Cells 4,{ and 48 will
include:
a) LDS Monitoring - including:
1) Report on the operational status of the LDS pumping and monitoring equipment
during the quarter, including identification of any intervals of non-operational
status and repairs.
2) Measurement of the weekly fluid head at the lowest point of the secondary
membrane.
3) Measurement of the volume of all fluids pumped from the LDS.
b) Measurement of the weekly wastewater fluids elevation in the Cells 4,A' and 48 to
determine freeboard.
c) Slimes Drain Recovery Head Monitoring as per the requirements of Parts I.D.6 and
r.E.8(b).
DMT and BAT Performance Upset Reports - the Permittee shall report any non-
compliance with the DMT or BAT performance criteria of Part I.D in accordance with
the requirements of Part I.G.3 of this Permit.
Other Information - when the Permittee becomes aware of a failure to submit any
relevant facts in the permit application or submittal of incorrect information in a permit
4.
5.
28
Part I.F.
PermitNo. UGW370004
application or in any report to the Director, the Permittee shall submit such facts or
information within l0 calendar days of discovery.
6. Groundwater Monitoring Well As-Built Reports - as-built reports for new groundwater
monitoring wells shall be submitted for Director approval within 60 calendar days of well
completion, and at a minimum will 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 shall be prepared by a
Professional Geologist licensed by the State of Utah, or otherwise approved
beforehand by the Director.
b) Well Completion Diagram - that detail all physical attributes of the well construction,
including:
l) Total depth and diameters of boring,
2) Depth, type, diameter, and physical properties
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.
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.
7. White Mesa Seeps and Springs Monitoring Reports - a seeps and springs monitoring
report shall be submitted for Director review and approval with the 3'o Quarter Routine
Groundwater Monitoring Report due on December 1, of each calendar year. Said report
shall include, but is not limited to:
a) Field Measurement Results and Worksheets - for each sample collected that comply
with the requirements of Part I.F.1(a) of this Permit,
b) Laboratory Results - for each sample collected that comply with the requirements of
Part I.F.1(b) of this Permit,
c) Water Table Contour Map - that includes groundwater elevations for each well at the
facility and the'elevations ofthe phreatic surfaces observed at each ofthe seeps and
springs sampled. The contour map will include all water level data measurements
from seeps, springs, and monitoring wells at the site from the 3'd Quarter Routine
Groundwater Monitoring event of each year. The contour map shall be at a map scale,
such that, all seeps and springs listed in the approved Sampling Plan for Seeps and
Springs in the Vicinity of the White Mesa Uranium Mill and the monitoring wells on
site may be seen on one map,
d) Data Evaluation - and interpretation of all groundwater quality data collected,
of well casing and screen,
29
Part I.F.
PermitNo. UGW370004
e) Quality Assurance Evaluation and Data Validation - for the seeps and springs water
quality datathat meets the requirements of Part I.F.1(d),
0 Electronic Data Files and Format - that meet the requirements of Part I.F.l(e) of this
Permit, and
g) Survey data for the seeps and springs shall be based on an elevation survey,
conducted under the direction of and certified by a Utah licensed professional
engineer or land surveyor. The survey will include State Plan Coordinates (northings
and eastings) and vertical elevations. The surveyed coordinates and elevations of the
seeps and springs shall be within 1 foot of the highest point of the saturated seepage
face on the day of the survey. This survey data must be obtained before any samples
are collected.
8. 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
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.
9. Tailings Cell Wastewater Quality Reports - all annual wastewater quality sampling and
analysis required by Part I.E.10 shall be reported to the Director with the 3'd Quarter
groundwater quality report due on December 1, of each calendar year. Said report shall
include:
a) Data evaluation and interpretation of all wastewater quality samples collected,
b) All information required by Part I.F.1(a), (b), (d), and (e) of this Permit, and
c) For slimes drain samples, the Permittee shall report depth to wastewater
measurements from the water level measurement point. Said wastewater level shall be
measured immediately before sample collection.
l0.Revised Hydrogeologic Report - pursuant to Part IV.D of this Permit, and at least 180
calendar days prior to Permit expiration, the Permittee shall submit for Director approval
a revised hydrogeologic report for the facility and surrounding area. Said report shall
provide a comprehensive update and evaluation of:
a) Local hydrogeologic conditions in the shallow aquifer, including, but not limited to:
local geologic conditions; time relationships and distribution of shallow aquifer head
measurements from facility wells and piezometers; local groundwater flow directions;
and distribution of aquifer permeability and average linear groundwater velocity
across the site, and
b) Well specific groundwater quality conditions measured at facility monitoring wells
for all groundwater monitoring parameters required by this Permit, including, but not
limited to: temporal contaminant concentrations and trends from each monitoring
well; statistical tests for normality of each contaminant and well, including univariate
30
Part I.F.
PermitNo. UGW370004
or equivalent tests; calculation of the mean concentration and standard deviation for
each well and contaminant.
ll.Annual Slimes Drain Recovery Head Report - on or before March 1 of each year the
Permittee shall submit for Director approval an annual slimes drain recovery head report
for Tailings Cells 2 and 3. Said report shall conform to the requirements of Part I.D.3(b),
I.E.7(b), and II.G of this Permit, and:
a) Provide the individual slimes drain recovery head monitoring data for the previous
calendar year, including, but not limited to: date and time for the start and end of
recovery test, initial water level, final depth to stable water level and equivalent
recovery water level elevation.
b) Calculate the average slimes drain recovery head for the previous calendar year.
c) Include a time series chart to show trends of the recovery water level elevations at
each slimes drain.
d) Include the results of a quality assurance evaluation and data validation. Said
examination shall provide written descriptions and findings that:
1) Evaluate all data collected, data collection methods, and all related calculations
required by this Permit, and
2) Verify the accuracy and reliability of both the data and calculations reported.
e) Demonstrate compliance status with the requirements of Part I.D.3(b) and I.E.7(b) of
this Permit.
12. Decontamination Pads Annual Inspection Report - the New Decontamination Pad and
Existing Decontamination Pad will be taken out of service and inspected annually during
the second quarter of each year, to ensure integrity of the concrete wash pad surfaces. If
physical defects in the wash pad as defined by Part I.D.14 of the Permit are identified
during the inspection, repairs shall be made prior to resuming the use of the facility. Said
defects include, but are not limited to concrete deterioration, cracking, subsidence, etc.
The results of the annual inspection and all repairs will be documented on inspection
forms in accordance with the currently approved DMT Monitoring Plan. The inspection
forms and documentation of all repairs completed shall be included in the 2no Quarter
DMT Monitoring Report due September 1, of each calendar year.
3l
Part I.G
PermitNo. UGW370004
G. Our oF CoMPLTANCE Srerus
l. Accelerated Monitoring Status - is required if the concentration of a pollutant in any
compliance monitoring sample exceeds a GWCL in Table 2 of the Permit; the facility
shall then:
Noti$ the Director in writing (the Exceedance Notice) within 30 calendar days of
receipt of the last analytical data report for samples collected within a quarter,
including quarterly and monthly samples, but no later than 60 days after the end of
the quarter, and
Initiate accelerated sampling of the pollutant as follows:
1) Quarterly Baseline Monitoring Wells - for wells defined by Part I.E.l(b) the
Permittee shall initiate monthly monitoring. Monthly monitoring shall begin the
month following the month in which the Exceedance Notice is provided to the
Director.
2) Semi-annual Baseline Monitoring Wells - for wells defined by Part I.E.l(c) the
Permittee shall initiate quarterly monitoring. Quarterly monitoring shall begin the
quarter following the quarter in which the Exceedance Notice is provided to the
Director.
3) Said accelerated monitoring shall continue at the frequencies defined above until
the compliance status of the facility can be determined by the Director.
Violation of Permit Limits - out-of-compliance status exists when the concentration of a
pollutant in two consecutive samples from a compliance monitoring point exceeds a
GWCL in Table 2 of this Permit.
Failure to Maintain DMT or BAT Required by Permit
Permittee to Provide Information - in the event that the Permittee fails to maintain
DMT or BAT or otherwise fails to meet DMT or BAT standards as required by the
Permit, the Permittee shall submit to the Director a notification and description of the
failure according to R317-6-6.16(CXl). Notification shall be given orally within24-
hours of the Permittee's discovery of the failure of DMT or BAT, and shall be
followed up by written notification, including the information necessary to make a
determination under R317-6-6.16(C)(2), within five calendar days of the Permittee's
discovery of the failure of best available technology.
The Director shall use the information provided under R3l7-6-6.16.C(1) and any
additional information provided by the Permittee to determine whether to initiate a
compliance action against the Permittee for violation of Permit conditions. A
compliance 4ction shall not be initiated, if the Director determines that the Permittee
has met the standards for an affirmative defense, as specified in R317-6-
6.16(cX3)(c).
Affirmative Defense - in the event a compliance action is initiated against the
Permittee for violation of Permit conditions relating to best available technology or
DMT, the Permittee may affirmatively defend against that action by demonstrating
the following:
l) The Permittee submitted notification according to R317-6-6.13,
2.
J.
a)
b)
a)
b)
c)
32
Part I.G
PermitNo. UGW370004
2) The failure was not intentional or caused by the Permittee's negligence, either in
action or in failure to act,
3) The Permittee has taken adequate measures to meet Permit conditions in a timely
manner or has submitted to the Director, for the Director's approval, an adequate
plan and schedule for meeting Permit conditions, and
4) The provisions of UCA l9-5-107 have not been violated.
4. Facility Out of Compliance Status - if the facility is out of compliance, the following is
required:
a) The Permittee shall notifu the Director of the out of compliance status within 24-
hours after detection of that status, followed by a written notice within 5 calendar
days of the detection.
b) The Permittee shall continue accelerated sampling pursuant to Part I.G.l, unless the
Director determines that other periodic sampling is appropriate, until the facility is
brought into compliance.
c) The Permittee shall prepare and submit to the Director within 30 calendar days
following the date the Exceedance Notice is submitted to the Director, 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
groundwater quality to insure that Permit limits will not be exceeded at the
compliance monitoring point and that DMT or BAT will be reestablished.
d) The Director may require immediate implementation of the currently approved
contingency plan in order to regain and maintain compliance with the Permit limit
standards at the compliance monitoring point or to reestablish DMT or BAT as
defined in the Permit.
e) Where it is infeasible to reestablish DMT or BAT as defined in the Permit, the
Permittee may propose an altemative DMT or BAT for approval by the Director.
aaJJ
Part I.H
Permit No. UGW370004
H. CovplrANcE Scupoulr ReeuInevENTS. The Permittee will comply with the schedules as
described and summarized below:
1. Slimes Drain Compliance Plan - Within two (2) years after the effective date of this
Permit, the Permittee shall submit a Slimes Drain Compliance Plan for Director Review
and Approval. The Plan shall include measures to ensure that wastewater removal from
the tailings cell slimes drain is effectively dewatering the tailings to the extent practicable
in order to allow placement of final cover within specified time frames. The Plan may
incorporate multiple methods to evaluate the effectiveness of tailings cell dewatering and
projected timelines for placement of final tailings cell cover, including, but not limited to;
1. Demonstration of decreasing fluid elevation trends as measured by slimes drain
recovery tests; 2. Evaluations of head data from piezometers installed in the affected
tailings cell demonstrating net dewatering, and 3. Demonstration of decreasing trends in
cell settlement monitoring. The Plan shall include specific measures for Tailings Cell 2
and will incorporate Tailings Cell 3 after initiation of dewatering operations.
2. Installation of New Groundwater Monitoring Wells - the Permittee shall install three new
groundwater monitoring wells within 90 calendar days of issuance of the Permit,
designated MW-38, MW-39 and MW-40, located southeast of the tailings cells between
monitoring wells MW-17 andMW-22. Specifically, the monitoring well locations shall
include the three locations identifred by the Permittee in Figure I attached to the January
2018 License/?ermit Statement of Basis. These monitoring wells shall be drilled and
installed in accordance with the following requirements:
a) All new monitoring wells must be properly designed, installed,
screened/completed, and developed in accordance with Part I.E.4 of the Permit.
b) All new monitoring well screens will fully encompass the Burro Canyon
Formation saturated zone.
c) All new monitoring wells will be designed to be monitored for the full suite of
monitoring parameters listed in the Permit Table2.
d) On or before August 31, 2018 or as otherwise approved by the Director, the
Permittee shall submit a monitoring well As- built report for the monitoring wells
installed to document the well construction. The As-built report shall comply
with the requirements of Part I.F.6.
e) The Permittee shall provide at least a 14 calendar day written notice prior to field
drilling and construction of the monitoring wells to allow the Director to observe
all drilling and well installation activities.
3. Background Groundwater Quality Report for Wells MW-38, MW-39, MW-40 - within
30 calendar days of Director approval of the new monitoring well As-built Report,
required by Part I.H.z, above, the Permittee shall corrmence a quarterly groundwater
sampling program that will comply with the following Permit requirements:
a) Routine gloundwater compliance monitoring requirements of Part I.E.l.
34
b)
c)
Part I.H
Permit No. UGW370004
Well monitoring procedure requirements of Part I.E.5.
After completion of eight consecutive quarters of groundwater sampling and
analysis of wells MW-38, MW-39, MW-40 required by Part I.H.2, the Permittee
shall submit a Background Report for Director approval, that will include:
1) Data preparation and statistical analysis of groundwater quality data,
including, but not limited to, evaluation of data characteristics and intemal
data consistency, treatment of non-detectable values, and statistical methods
used. These statistics shall be calculated using the Decision Tree/Flowchart
used for the previous Background Reports that was conditionally approved by
the DRC on August 24,2007.
2) Shallow aquifer average linear groundwater velocity calculated for the new
wells, based on well specific hydraulic conductivity, hydraulic gradient, and
effective aquifer porosity.
If after review of the report, and the Director determines that additional
information is required, the Permittee shall provide all requested information,
resolve all issues identified, and re-submit the report for Director review and
approval within a timeframe approved by the Director. After approval of this
report, the Director will re-open this Permit and establish an appropriate
monitoring frequency with the criteria found in Part I.E.1(b). Designation of these
wells as "compliance" or "general" monitoring wells will be determined after
analysis of the Background Quality Groundwater Report. If the new wells are
determined to be compliance wells, the Director will establish Groundwater
Compliance Limits in Table 2 for wells MW-38, MW-39, MW-40.
d)
35
A.
B.
Part II
Permit No. UGW370004
PART II. REPORTING REQUIREMENTS
RppRespNrATrvE Snupr-rNc. Samples taken in compliance with the monitoring requirements
established under Part I shall be representative of the monitored activity.
ANel,yucel PRocEDURES. Water sample analysis must be conducted according to test
procedures specified under UAC R3l7-6-6.3.I2 unless other test procedures have been
specified in this Permit.
PBNer,rms FoR TAMIERING. The Act provides that any person who falsifies, tampers with, or
knowingly renders inaccurate, any monitoring device or method required to be maintained
under this Permit shall, upon conviction, be punished by a fine of not more than $10,000 per
violation, or by imprisonment for not more than six months per violation, or by both.
RrpoRuNc or MoNrroRrNG RESULTS. Monitoring results obtained during reporting periods
specified in the Permit, shall be submitted to the Director at the following address, no later
than the date specified following the completed reporting period:
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
The quarterly due dates for reporting are: June 1, September l, December 1, and March I .
CouplnNcp ScupouLES. Reports of compliance or noncompliance with, or any progress
reports on interim and final requirements contained in any Compliance Schedule of this
Permit shall be submitted no later than 14 calendar days following each schedule date.
AoplrroNel MoNrroRrNG By rHE PERMITTEE. If the Permittee monitors any pollutant more
frequently than required by this Permit, using approved test procedures as specified in this
permit, the results of this monitoring shall be included in the calculation and reporting of the
data submitted. Such increased frequency shall also be indicated.
Rrconps CoNreNrs.
1. Records of monitoring information shall include:
a) The date, exact place, and time of sampling, observations, or measurements:
b) The individual(s) who performed the sampling, observations, or measurements;
c) The date(s) and time(s) analyses were performed;
d) The name of the certified laboratory which performed the analyses;
e) The analyical techniques or methods used; and,
f) The results of such analYses.
D.
C.
F.
G.
E.
36
H.
I.
J.
K.
Part II
PermitNo. UGW370004
RerpNrroN oF RECoRDS. The Permittee shall retain records of all monitoring information,
including all calibration and maintenance records and copies of all reports required by this
Permit, and records of all data used to complete the application for this Permit, for a period
of at least five years from the date of the sample, measurement, report or application. This
period may be extended by request of the Director at any time.
Norrce or NoNcoupLrANCE RrpoRrrNc.
l. The Permittee shall verbally report any noncompliance which may endanger public
health or the environment as soon as possible, but no later than 24-hours from the time
the Permittee first became aware of the circumstances. The report shall be made to the
Utah Department of Environmental Quality 24-hotn number, [phone], or to the
Division of Water Quality, Ground Water Protection Section at [phone], during
normal business hours (8:00 am - 5:00 pm Mountain Time).
2. A written submission shall also be provided to the Director within five calendar days of
the time that the Permittee becomes aware of the circumstances. The written submission
shall contain:
a) A description of the noncompliance and its cause;
b) The period of noncompliance, including exact dates and times;
c) The estimated time noncompliance is expected to continue if it has not been
corrected; and,
d) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
3. Reports shall be submitted to the addresses in Part II.D, Reporting of Monitoring Results.
OrHpnNoNcovplIANCE RepoRrrNc. Instances of noncompliance not required to be reported
within 5 calendar days, shall be reported at the time that monitoring reports for Part II.D are
submitted.
INspecrtoN nxo EurRv. The Permittee shall allow the Director, or an authorized
representative, upon the presentation of credentials and other documents as may be required
by law, to:
1. Enter upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of the Permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this Permit;
3. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this Permit; and,
4. Sample or monitor at reasonable times, for the purpose of assuring Permit compliance or
as otherwise authorized by the Act, any substances or parameters at any location.
37
A.
Part III
PermitNo. UGW370004
PART III. COMPLIANCE RESPONSIBILITIES
Dury ro CoMpLy. The Permiffee must comply with all conditions of this Permit. Any Permit
noncompliance constitutes a violation of the Act and is grounds for enforcement action; for
permit termination, revocation and re-issuance, or modification; or for denial of a permit
renewal application. The Permittee shall give advance notice to the Director of the Division
of Water Quality of any planned changes in the permitted facility or activity which may
result in noncompliance with Permit requirements.
PeN,q.r-rrps FoR VToLATToNS oF PERMIT CoNptrtoNs. The Act provides that any person who
violates a Permit condition implementing provisions of the Act is subject to a civil penalty
not to exceed $10,000 per day of such violation. Any person who willfully or negligently
violates Permit conditions is subject to a fine not excee$ing $25,000 per day of violation.
Any person convicted under Section l9-5-115 of the Act a second time shall be punished by
a fine not exceeding $50,000 per day. Nothing in this Permit shall be construed to relieve the
Permittee of the civil or criminal penalties for noncompliance.
Nppo ro HALT oR REDUCE Acrrvlry Nor A Dprpusn. It shall not be a defense for a Permittee
in an enforcement action that it would have been necessary to halt or reduce the permitted
activity in order to maintain compliance with the conditions of this Permit.
Dury ro MrrrcAre. The Permittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this Permit which has a reasonable likelihood of adversely affecting
human health or the environment.
PnopeR OpeRarroN AND MATNTENANCE. The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which
are installed or used by the Permittee to achieve compliance with the conditions of this
Permit. Proper operation and maintenance also includes adequate laboratory controls and
quality assurance procedures. This provision requires the operation of back-up or auxiliary
facilities or similar systems which are installed by a Permittee only when the operation is
necessary to achieve compliance with the conditions of the Permit.
B.
C.
D.
E.
38
A.
B.
D.
E.
C.
Paft IV
Permit No. UGW370004
PART IV. GENERAL REQUIREMENTS
PlaNupo CunNcps. The Permittee shall give notice to the Director as soon as possible of
any planned physical alterations or additions to the permitted facility. Notice is required
when the alteration or addition could significantly change the nature of the facility or
increase the quantity of pollutants discharged.
ANttcrparED NoNCoMPLIANCE. The Permittee shall give advance notice of any planned
changes in the permitted facility or activity which may result in noncompliance with Permit
requirements.
Ppnvlr Acrtous. This Permit may be modified, revoked and reissued, or terminated for
cause. The filing of a request by the Permittee for a permit modification, revocation and re-
issuance, or termination, or a notification of planned changes or anticipated noncompliance,
does not stay any permit condition.
Durv ro Rpepplv. If the Permittee wishes to continue an activity regulated by this Permit
after the expiration date of this Permit, the Permittee must apply for and obtain a new permit.
The application should be submitted at least 180 calendar days before the expiration date of
this Permit.
Durv ro PRovIDE INFoRMATIoN. The Permittee shall fumish to the Director, within a
reasonable time, any information which the Director may request to determine whether cause
exists for modiSing, revoking and reissuing, or terminating this Permit, or to determine
compliance with this Permit. The Permittee shall also furnish to the Director, upon request,
copies of records required to be kept by this Permit.
Orspn lNroRuertoN. When the Permittee becomes aware that it failed to submit any
relevant facts in a permit application, or submitted incorrect information in a permit
application or any report to the Director, it shall promptly submit such facts or information.
F.
G. SrcNnroRY REQUIREMENTS. All applications, reports or information submitted to the
Director shall be signed and certified.
1. All permit applications shall be signed as follows:
a) For a corporation: by a responsible corporate officer;
b) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively.
c) For a municipality, State, Federal, or other public agency: by either a principal
executive officer or ranking elected official.
2. All reports required by the Permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that
person. A person is a duly authorized representative only if:
a) The authorization is made in writing by a person described above and submitted to
the Director. and-
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PermitNo. UGW370004
b) The authorization specified either an individual or a position having responsibility for
the overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or a well field, superintendent, position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus
be either a named individual or any individual occupying a named position).
3. Changes to Authorizalion.If an authorization under Part IV.G.2. is no longer accurate
because a different individuat or position has responsibility for the overall operation of
the facility, a new authorization satisfuing the requirements of Pan IV.G.2 must be
submitted to the Director prior. to or together with any reports, information, or
applications to be signed by an authorized representative.
4. Certification. Any person signing a document under this section shall make the following
certification:
"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 persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of
my knowledge and beliel true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations."
PBNer-rrcs FoR FALSTFTcATToN oF REeoRTS. The Act provides that any person who
knowingly makes any false statement, representation, or certification in any record or other
document submitted or required to be maintained under this Permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction be punished by a
fine of not more than $10,000 per violation, or by imprisonment for not more than six months
per violation, or by both.
Averles[rry oF Reponrs. Except for data determined to be confidential by the Permittee,
all reports prepared in accordance with the terms of this Permit shall be available for public
inspettion at the offices of the Director. As required by the Act, permit applications, permits,
effluent data, and groundwater quality data shall not be considered confidential.
pRopeRry RrcHrs. The issuance of this Permit does not convey any property rights of any
sort, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion oipersonal rights, nor any infringement of federal, state or local laws or regulations.
SevrRRsrr-rry. The provisions of this Permit are severable, and if any provision of this
permit, or the applica-tion of any provision of this Permit to any circumstance, is held invalid,
the application of such provision to other circumstances, and the remainder of this Permit,
shall not be affected therebY.
TnaNspens. This Permit may be automatically transferred to a new Permittee if:
1. The current Permittee notifies the Director at least 30 calendar days in advance of the
proposed transfer date;
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2. The notice includes a written agreement between the existing and new Permittee
containing a specific date for transfer of permit responsibility, coverage, and liability
between them; and,
3. The Director does not notiff the existing Permittee and the proposed new Permittee of his
or her intent to modify, or revoke and reissue the permit. If this notice is not received, the
transfer is effective on the date specified in the agreement mentioned in paragraph 2
above.
M. Srers Lews. Nothing in this Permit shall be construed to preclude the institution of any
legal action or relieve the Permittee from any responsibilities, liabilities, penalties established
pursuant to any applicable state law or regulation under authority preserved by Section 19-5-
115 of the Act.
N. RpopeNER PRovISroNs. This Permit may be reopened and modified (following proper
administrative procedures) to include the appropriate limitations and compliance schedule, if
necessary, if one or more of the following events occurs:
1. If new ground water standards are adopted by the Board, the Permit may be reopened and
modified to extend the terms of the Permit or to include pollutants covered by new
standards. The Permittee may apply for a variance under the conditions outlined in R3l7-
6-6.4(D).
2. changes have been determined in background groundwater quality.
3. The Director determines permit modification is necessary to protect human health or the
environment.
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