Homestake Mining Company of California (nI-OMb4ESkitAKE · New Mexico Environment Department P.O. Box 5469 Santa Fe, New Mexico 87502-5469 ... Mr. Wayne Canon, New Mexico Office of

Homestake Mining Company of California(nI-OMb4ESkitAKE

Jesse R. ToepferGrants Project Closure Manager

18 September 2014

ATTN Mr. David L. MayersonMining Environmental Compliance SectionGround Water Quality BureauNew Mexico Environment DepartmentP.O. Box 5469Santa Fe, New Mexico 87502-5469

RE: Homestake's Responses to NMED's Comments Received 21 July 2014 Pertaining toHomestake's Zeolite Water Treatment System Submittal Package dated 7 July 2014

Dear Mr. Mayerson:

In a letter from the New Mexico Environment Department (NMED) dated 21 July 2014, entitledHomestake Mining Company of California millsite/DP-200 - Comments on DRAFT "1200 gpm zeolite-based uranium water treatment system design report" (July 2014), were several comments from NMEDpertaining to an earlier submittal (dated 7 July 2014) by Homestake Mining Company (HMC) to NMED.

Enclosed with this letter you will find HMC's responses to NMED's comments in the aforementioned letter.Also enclosed with this letter, you will find two "standalone" documents. The first document, entitled 300gpm zeolite treatment system operational data and notes, is intended to address the question you poisedin the second paragraph of the cover letter dated 21 July 2014, wherein you asked for the operationaldata following the initial four-week period. The second document is an updated and revised Gantt chart,which, per NMED's Comment on "Table 3," had not been identified in the original 7 July submittal. Pleaseaccept this new Gantt Chart, properly labeled as "Table 3" as a standalone page changeout to the 7 Julysubmittal. Lastly, for your convenience, NMED's 21 July letter and comments are also herein enclosed.

On behalf of Homestake, I hope this information is helpful to your department and will be of value to youduring the review process. Please feel free to contact me directly at 505.290.3067 if you have anyquestions or comments pertaining to this material.

Respectfully,

Jesse R. ToepferClosure ManagerHOMESTAKE MINING COMPANY OF CALIFORNIA

Coov To:

Mr. Jack Parrott, US Nuclear Regulatory Commission - Rockville, MarylandMr. Sai Appaji, US Environmental Protection Agency, Region 6 - Dallas, TexasMr. Wayne Canon, New Mexico Office of the State Engineer - Albuquerque, New MexicoMs. Deborah Barr, US Department of Energy, Office of Legacy Management - Grand Junction, ColoradoMr. David Shafer, US Department of Energy, Office of Legacy Management - Westminster, ColordadoMr. Bill Ferdinand, Barrick Gold - Salt Lake City, UtahMr. Patrick Malone, Barrick Gold - Salt Lake City, UtahMr. George Hoffman, Hydro Engineering - Casper, WyomingMr. Dale Shay, RIMCON - Rapid City, South Dakota

Homestake Mining Company P.O. Box 98, Grants, NM 87020 Tele: (505) 287-4456 Fax: (505) 287-9289

Responses to NMED Comments Received Regarding Zeolite Water Treatment System Submittal 18 September 2014

Page # Quoted Text NMED Comment Response

3 Without the pump-back 9 Please clarify that the scenarios presented are The scenarios presented are standard flow options.feature, the normal operation alternative modes of operational flow.of the cells would be as The sequence depends on the current regeneration cycle and cationfollows .... the pump-back * Please describe the functionality of the pump- loading status of the individual cells.feature is not part of the 1200 back feature in the 300 gallon per minutegpm full-scale system. (gpm) pilot zeolite. The pump-back feature in the 300 gpm system was intended to

allow operation of the three cells in any sequence during the pilottesting. This provided additional flexibility to test operationalprocedures and regeneration procedures and frequency. The testresults and operational experience gained from the 300 gpm pilotsystem allowed the design of the 1200 gpm to be simpler and morerobust with regard to plumbing and water transfer configuration.

While the pump-back system in the 300 gpm pilot was tested prior

to operation, it was not used during the pilot test run. This beingthe case, the pump-back system was not deemed necessary for the

1200 gpm zeolite system.

4 ... flow rate and operational NMED infers that HMC intends this discussion to The 1200 gpm is essentially four separate 300 gpm zeolite trainssizing of the zeolite system reference individual zeolite treatment "units" or that share berms, plumbing, processing, and discharge features.achieves and optimal balance "trains" within an overall zeolite treatment system, However, each train can be operated independently, and as NMEDat approximately the 300 to as is described on page 9; if so, please clarify, has correctly inferred, the sizing criteria was applied for a single400 gpm capacity range. train.

4 et al. ... agreed upon site Applicable site ground water standards have been HMC believes the report is clear, and that the current agreed uponstandard... promulgated in HIMC's Source Material License, site standard for uranium, as promulgated by NRC, is 0.16 mg/L.

which is administered by the Nuclear RegulatoryAgency. Please change references throughout the HMC reaffirms that the NRC has primacy over the Grantsdocument accordingly. Reclamation Project, and that such site standards are explicitly

identified in HMC's Radioactive Materials License (RML).

HMC also acknowledges the support offered by NMED with regardto the site standards. Most recently this occurred during the 2014Public Hearing for DP-200, when NMED supported HMC'sobjection for Res Judicata el Collateral Esloppel after theopposition attempted to call the site standards into question.

Homestake Mining Company of California

2



9 The target retention time for Please provide a summary of testing that was Zeolite retention time determinations have been based on zeoliteoptimum uranium adsorption performed for these determinations, adsorption performance, zeolite mesh size, zeolite pore space,and optimum zeolite size zeolite purity and other factors. Determination of this informationfraction was determined is part of the proprietary aspects of the technology developed overthrough the testing process. years of zeolite performance research by RIMCON since 1997. AsThe zeolite tonnage such, the basis for such was beyond the scope of the HMC pilotnecessary to achieve the testing studies.target retention time wascalculated for each treatmentcell.

9 This additional flexibility The information that was provided in HMC, The plumbing and design features that allow a separate waterwould include.. .the ability to 11/21/2013 and reiterated on page 25 of this report supply to one of the trains are included as a contingency for futureincorporate other treatment indicates that only uranium concentrations were developments in the zeolite treatment process.parameters into a single reduced in the 4-week pilot zeolite system test

treatment train.., period. Please provide information about what No specific treatment modifications are under consideration at thispotential system modifications would be made "to time, but the inclusion of these minor design features to

incorporate other treatment parameters into a single accommodate any potential future modifications has beentreatment train", incorporated into the full-scale design.

9 . . pilot testing has shown that Please provide data from the pilot operation to The frequency of the regeneration cycle is based upon zeolite

the zeolite will likely require support this statement, loading curves and the operationally-derived performance dataregeneration approximately (which has been previously submitted to NMED). That data andevery 45 days... loading curves for the 50 gpm and 300 gpm systems have been

provided to NMED previously in the pilot testing report.

The loading rate will vary somewhat based upon flow rates anduranium concentrations in the feed water, but it is expected toaverage approximately 45 days for the north and south well fieldwater.

Scheduling of zeolite regeneration for tie zeolite cells will be basedon these loading curves. 45 days is a conservative estimate of therequired regeneration frequency. As such, a 45-day regenerationcycle will help ensure the zeolite is regenerated prior to thesystem's discharge reaching the 0.16 mg/L concentration limit.

Homestake Mining Company of California3


Page #L Quoted Text T NMED Comment Response

11 The manilbld is designed toallow the collected water tobe piped.. through either ofthe two 8 inch poly pipes or a6 in poly pipeline.

" Please explain why one of the zeolite supplypipelines is a 6-inch diameter, when the othertwo are 8-inch diameter.

" Please detail the design and/or processcontrols to monitor collection pipelines fromwells to the manifold for possible leakage.

Pipeline Sizing - The three pipelines supplying the 1200 gpmzeolite system were sized to provide a composite capacity of 1200gpm for the four trains and the six-inch pipeline was sized toprovide sufficient capacity to operate as a dedicated supply for asingle 300 gpm train. The ability to operate a single dedicated trainwill help ensure the continuity of water treatment is maximizedduring maintenance activities (e.g., mechanical repairs,regeneration evolutions in other cells, etc.). The capacity of anytwo of the three supply pipelines is sufficient to allow operation ofthe system at or near full capacity.

Pipeline Leak Detection - Routine inspections of all the pipelines

at the Grants Reclamation Site occur nearly every day. Operatorsand Contracted Personnel are provided continual training, nearlyweekly, to address upset and unexpected conditions. With regardto spills and leaks, all HMC and Contracted Personnel are familiarwith the "SWIMS" Emergency Response Procedure. SWIMS is anacronym that stands for:

0

0

6

S

S

Stop the leakWarn othersIsolate the AreaMinimize ExposureStandby for help to arrive

In addition to training, HMC has constructed artificial drainagepathways (via trenching and other earthwork activities) for most ofits major pipelines. This will help ensure any liquid spilled orleaked can be contained, to the best extent practical, within thecon•lnes of H-IMC property. Also, isolation valves are planned to beinstalled at key points along the major pipelines to allow operatorsto minimize leakage rates and volumes in the event of an upset orunexpected condition.

Lastly, prior to operation, Standard Operating Procedures will bedeveloped which will not only serve as an operating manual, butwill also provide direction on how to correct upset / unexpectedconditions (e.g., leaks, malfunctions, spills, etc.).

Homestake Mining Company ot Califtornia4



13 A berm is designed to Please include relevant calculations to support this The text quoted to which the NMED comment is referring, isenclose all four treatment assertion. simply a statement indicating that a perimeter berm surrounds thetrains around the facility area entire system and that the entire area within this perimeter berm isto provide complete lined. The perimeter berm and the emergency water storagecontainment of solution volume it provides is a contingency against temporary suspensionwithin the berms... of discharge from the zeolite system. A simplified calculation of

the approximate emergency storage is as follows:

" Plan area of top of zeolite in Cell #3 = 11,192 sq. ft. (for all 4trains)

" Elevation of top of zeolite in Cell #3 = 6666.1 ft-MSL" Plan area at elevation 6672.5 (2 ft. freeboard) = 66,315 sq. ft." Average plan area = (11192+66315)/2 = 38,754 sq. ft." Water depth with 2 feet freeboard = 6672.5 - 6666.1 = 6.4 ft." Storage volume = 38754 x 6.4 = 248,000 cu. ft." Storage volume = 1,855,000 gallon = 25.8 hours @ 1200

gpm

The plan areas were estimated using cell geometry and/or surfaceanalysis software. Because this is a simplified calculation and thetypical operating water level will be approximately 0.4 to 0.8 feetabove the zeolite, 20 hours of emergency storage at 1200 gpm isconsidered a more appropriate estimate. A more detailed analysisof earthen berm, zeolite and water storage volumes provided asimilar estimate of emergency storage capacity. It should be notedthat there is two feet of freeboard remaining to the crest of theperimeter berm beyond the emergency storage in this calculation.

13 The system is designed to Please describe any additional system safeguards or An emergency discharge system is included in the system design.operate at full capacity for processes that would alert operational personnel to In combination with the water level monitoring system connectedapproximately 20 hours the occurrence of an overflow situation. to the system controller, this provides redundancy and adequatewhile still providing protection against system overflow.freeboard within thecontaimnent.




14 ... acid metering tanks... * Please clarify whether the "acid metering The smaller acid tanks located adjacent to the process building aretanks" are the same as the tanks that are designated as the acid transfer or acid metering tanks.labeled as acid transfer tanks on Exhibit 9.

* Please confirm that the acid used for Sulfuric acid is used in the treatment process.regeneration is sulfuric acid as discussed inthe HMC, 11/21/2013.

18 The control point for the Please explain this statement. "Control point" in this sense does not refer to a physical location.system will be the... sitestandard of 0.16mg/1 (for In this context, "control point" was meant to-describe the maximumuranium). concentration limit for uranium, thus representing the "control" to

which the effluent concentrations will be compared. The 1200 gpm

zeolite system is designed to treat impacted water to such an extentthat its effluent uranium concentration will be less than 0.16 mg/l.

20 Uranium samples will be Please provide the scheduling of this sampling and Sampling for the KPA analyses will likely be on a variablerequired to be taken analysis. programmed schedule depending on the stage of operation and zeolite loading.routinely... Sample will be While sampling of the discharge water is important, the volume andrequired to be analyzed on- nature of water processed through individual cells and trains aresite with a KPA. considerations that will afTect the appropriate sampling frequency.

Sampling frequency may increase for a cell as it gets closer to thedesired loading limit for that cell. While the sampling frequencywill be operationally detemined in the field, it is reasonable toassume the frequency would be every 3 to 5 days.

The Standard Operating Procedures, which will be developed priorto operating the full-scale system, will provide guidance on thesampling frequency.

20 ... as stipulated HMC's Please define "RML". RML is an acronym that stands for Radioactive Materials License.RML... RML is tantamount to, and interchangeable with, "Source Materials

License."

Hoinestake Mining Company of California6



20 The treated effluent will be * The list of analytes here should be the same as The list of analytes should also include molybdenum, vanadium,sampled.. .on a weekly basis that presented on page 24. thorium, and radium-226 and radium-228.for period of at least three * Analytical results for weekly samples that aremonths.. .For this period, submitted to an outside laboratory generally While the concentration of sulfate does increase slightly overtreated effluent will be would not be available until after the baseline levels, it has never been shown to approach dischargerequired to be sampled for discharge has already occurred. Since limits; thus, it is not deemed to be a critical parameter that warrantsanalysis of uranium... increased sulfate concentrations occur as a "real-time" or continuous monitoring.selenium.. sulfate.. chloride result of the zeolite treatment (p. 25) HMC.TDS .. and nitrate.., must monitor sulfate concentrations in "real- Note: The mass balance calculations for baseline sulfate plus

time" either through on-site analysis or a metered acid sulfate additions ensure that sulfate discharge limitscorrelation to a surrogate indicator (e.g., are not exceeded.conductivity). Additionally HMC mustpresent baseline concentration data for the HMC may measure field conductivity levels on the discharge waterother contaminants of concern from supply which serves as a useful surrogate to sulfate measurements.wells to the zeolite system.


Responses to NMED Comments Received Regarding Zeolite Water Treatment System Submittal 18 September' 2014


22 In addition, the third cell ofeach treatment train isdesigned to be equipped withan ultrasonic water levelindicator that can be read atthe control building or byremote computer... [which]will be programed [sic] toread when the water level inthe cells exceeds theoperational water level range.

According to the infonnation and inferred operationscenarios that are presented on page 3, a treatmenttrain would operate normally with only 2 cells.Therefore each cell should be equipped with anultrasonic water level indicator to precludeexceedances of the operational water level range.Additionally, please clarify whether these indicatorswould be equipped with high water level visualand/or audible alarms, or would automatically stopinfluent water flow to the malfunctioning cell.

Normal Operation Mode - Pertaining to the full-scale 1200 gpmsystem, the normal operational mode may include all three cells ineach train. However, as stated in the report, operational sequencesmay be Cell 1 to Cell 2, Cell 1 to Cell 3, Cell 2 to Cell 3, or Cell 1to Cell 2 to Cell 3 ("three-cell operation").

The three cell train design includes a pipe overflow from Cell 1 toCell 2 and from Cell 2 to Cell 3. These pipe overflows limit themaximum water levels in Cells 1 and 2 until the water level in Cell3 rises well above the normal operating level. Hence, themonitoring of levels in Cell 3 is sufficient to detect rising levels forthe entire system. Also note that the level indicator detects highwater within the cells before they exceed the crest of each cell andreach the emergency storage areas.

Water Level Alarms - The water level monitors may actuate anemergency discharge valve when the water level approaches theallowable freeboard for the system. An overflow spillway isattached to the discharge pipelines for each train so the system candischarge to the treated water pipelines under emergencyconditions. In addition, an audible, visual, or callout alarm can betriggered by a rising water level.

The system does not automatically stop the water supply to thesystem, but this can be done manually. Since the emergency waterstorage capacity is such that it would take approximately 20 hoursfor it to reach the maximum water level with two feet of freeboardin the event of a plugged discharge event, it is reasonable tosurmise that adequate response time by HIMC Operators orContracted Personnel is ensured.

* .L L


8



26 During the regeneration "Incoming feed water" would contain uranium The diluted acid regeneration solution is used to strip thecycles, the incoming feed concentrations in excess of applicable site accumulated uranium from the zeolite and has typicalwater is consumed by the standards. Please explain how contaminated water concentrations of 0.30 to 50 mg/i after passing through the zeolite.regeneration process. would be effective in the regeneration cycle.

Since acid is used to strip uranium from the zeolite, there is noconcern of using incoming feed water during regeneration, becausethe acidic environment is not conducive to adsorption. The pilottest work also supports these conclusions, and has proven thatinconing feed water can be used to effectively regenerate thezeolite material.

In addition, at only 27,000 gallons per regeneration, mass loadingof uranium during regeneration is negligible compared to full timeoperational loading. Thus, the relatively small uraniumconcentration (less thanl irg/I) in the feed water has no significantimpact on the regeneration process.

26 ... the dates of startup and Please explain this statement and include a brief Planned schedules for the implementation of the remedial activitiescompletion will slide as discussion of these permitting tasks. at the site have been previously submitted to NMED. Thepermitting tasks are statement was intended to indicate that the dates are not firmlycompleted established, and that due to the uncertainties associated with any

project, the dates may change somewhat depending on designreviews and/or other unforeseen circumstances.

Figure NMED Comment HMC ResponseNumber

Figures 1 Please include figure numbers in accordance with textual Figure numbers are located on the figures in the upper left hand comer of eachand 2 references. figure.



Figure NMED Comment HMC ResponseNumber

Figure 1 * The legend includes references to 3 types of wells, although Well Symbols in Legend - There are wells very near the 300 gpm system that hadnone are shown on this figure. to be preserved or avoided during construction, so the standard drawing legend

e The figure includes symbols comprising a red rectangle both included the well symbols. However, these well locations were not shown on thiswith and without an "X," which are not defined in the legend. particular drawing for simplicity.

Red Reclangles - The red rectangles indicate valve locations for the verysimplified plumbing schematic included on this drawing.

Figure 5 Please provide construction details for the "building or enclosure" The building or enclosure will likely be a simple pre-fabricated metal building.that will house the zeolite treatment system manifold, including but Any leaks will be detected visually and repaired promptly. Because the manifold isnot limited to secondary containment and leak detection. located within the hydraulic control area where the alluvial aquifer has been

profoundly affected by past tailings seepage, the water quality in the zeolite supplyis dramatically better than that in underlying alluvium. Hence, secondarycontainment is not necessary and standard inspection and repair procedures shouldbe sufficient to avoid degradation by leakage from the manifold.

TableNube NMED Comment ResponseNumber

Table 3 e Please show the table number on this page. Table Number - The Gantt Chart should be identified as Table 3.* Please explain the meaning of task #23, "Hexa Armour Install".

Hexa Armor - Hexa Armor is a trademark name for Rhombo Hexagonal shapedHDPE "balls" that will be placed on top of the water operating surface. The black"balls" help keep blowing dirt or dust out of the operating area, provide winterthermal protection, and will also lend themselves to protection against possiblealgae growth in the cells.



ExhibitNumber NMED Comment ResponseNumber

Exhibit I o Please show the location and components of the 300 gpm zeolite 300 gpim Zeolite System - The 300 gpm zeolite system was not constructed whensystem. the air photo was taken and the corresponding contour map was produced. Because

o Please define the meaning of the dashed relines on this figure. of this, the most recent base mapping does not include the 300 gpm system, and anadditional survey would be required to accurately locate the system.

Dashed Red Lines - The dashed red lines indicate roads for the available base mapof the site.

Exhibit 9 a Please show the location and components of the 300 gpm zeolite Leeend - The legend used for this drawing included several components that weresystem. not displayed to avoid clutter and unnecessary complexity. Since the more relevant

" Please identify the water source for the water tank that is shown features on the individual drawings are labeled, the general legend should only bein the lower 2 figures. used as a tangential reference.

" Please identify the destination for water contained in the "drainpipe from sink and shower" shown in the figure in the lower Water Source for Tank - The water for the emergency shower and sink is expectedright comer, to be potable water hauled to the system and pumped into the storage tank.

Drain Pipe - The drain pipe from the emergency shower and sink is intended todischarge in the adjacent zeolite cell. The quantity of water used for incidentalwashing in the sink is expected to be very small, and the shower is intended only tobe used for emergencies.

Exhibit 10 This exhibit is not referenced in the text. Exhibit 10 is referenced in paragraph 2 on page 14 of the report.


11

300 GPM Zeolite Treatment System Operational Data and Notes Addendum to 11/23/2013 Report

Sample Name Date Sampled Time Sampled pH I Bicarbonate Dissolved U Total U NotesIIIME/L mg/L mg/L I

300 Z-1 Regen 1

300 Z-1 Regen 2

300 Z-1 Regen 3

Feed

300 Z-1

300 Z-2

Feed

300 Z-1

300 Z-2

Feed

300 Z-1

300 Z-2

300 Feed - KPA

CE - Comp - KPA

300 Z-1 - KPA

300 Z-2 - KPA

Feed

Z-1

Z-2

Z-3

Feed

Z-1

Z-2

Z-3

Feed

Z-1Z-2

Z-3

10/22/2013

10/23/2013

10/23/2013

10/28/2013

10/28/2013

10/28/2013

10/31/2013

10/31/2013

10/31/2013

11/4/2013

11/4/2013

11/4/2013

10/21/2013

10/21/2013

10/21/2013

10/21/2013

4/28/2014

4/28/2014

4/28/2014

4/28/2014

5/1/2014

5/1/2014

5/1/20145/1/2014

5/6/2014

5/6/2014

5/5/2014

5/5/2014

8/4/2014

thru

9/8/2014

10:20 AM

9:20 AM

11:20 AM

11:10 AM

11:15 AM

11:15 AM

9:05 AM

9:10AM

9:15 AM

10:30 AM

10:35 AM

10:40 AM

12:00 PM

1:00 PM

12:30 PM

1:00 PM

7:00 AM

7:00 AM

7:00 AM

7:00 AM

8:00 AM

8:05 AM

8:05 AM

8:05 AM

7:35 AM

7:40 AM

7:45 AM

7:48 AM

1.66

1.69

1.68

5.51

6.11

6.19

5.33

6.226.17

5.99

6.22

6.15

0.94

7.69

6.47

8.04

5.78

5.92

6.38

6.75

5.55

6.15

6.44

6.33

5.65

6.11

6.32

6.23

13.1

15.1

10.9

0

0

0

0

10.20

21.5

0

0

0

495

113

170

55.6

76.2

80.1

138

21.5

40.2

22.5

0

10.3

22.9

10.8

0

0.489

0.021

0.011

0.476

0.045

0.033

0.455

0.055

0.044

2.83

2.82

0.322

1.37

0.375

0.241

0.135

0.247

0.399

0.056

0.049

0.039

0.401

0.078

0.072

0.056

Regeneration Data

Acid metering issues resolved by pH electrode calibration orreplacement and pump metering adjustments

Winter shut down

Non-operational samples taken for KPA analyzer

Spring start up to evaluate water flow characteristics of all

three cells.

Summer startup.

Shut down due to lightning in well fields. Re-start pending

regeneration of system and maintenance.

RECEIVED JUL 2NEW MEXICO

ENVIRONMENT DEPARTMENT

Harold Runnels Building1190 St. Francis Drive

P.O. Box 5469, Santa Fe, New Mexico 87502-5469Phone (505) 827-2855 Fax (505) 827-2965

www.nmenv.state.nm.us

4 2014

RYAN FLYNNSecretary

BUTCH TONGATEDeputy Secretary

SUSANA MARTINEZGovernor

JOHN A. SANCHEZLieutenant Governor

CERTIFIED MAIL-RETURN RECEIPT REQUESTED

July 21, 2014

Jesse Toepfer, Closure ManagerHomestake Mining Company of CaliforniaP.O. Box 98Grants, NM 87020

RE: Homestake Mining Company of California millsite/DP-200-Comments onDRAFT "1200 gpm zeolite-based uranium water treatment system design report"(July 2014)

Dear Mr. Toepfer:

The New Mexico Environment Department (NMED) has reviewed the above-referenceddraft report that was submitted by Homestake Mining Company of California (HMC) on July8, 2014.

NMED previously had requested an update to the information on the initial 4-weekoperation of the pilot zeolite treatment system that HMC provided to NMED (HMC,11/21/2013, "RE: Update on treatment activities at Homestake"). As was discussed, thisupdate was to include information and data on system operation and efficacy after the acidmetering issue, which was detailed in the latter report, was resolved. The period of time forwhich HMC provided data in that report ended at the point at which the acid metering issuehad been identified; however no operational data after that time has been provided. Inaddition to addressing the following tabulated comments in the final draft of this currentreport, NMED requests HMC to provide a summary of, and data for, pilot zeolite systemoperations following the initial 4-week period.

Reportpage Quoted text NMED comments

number

Without the pump-back feature, the e Please clarify that the scenarios

normal operation of the cells would be presented are alternative modes of

3 as follows....the pump-back feature is operational flow.

not part of the 1200 gpm full-scale 9 Please describe the functionality of

system. the pump-back feature in the 300gallon per minute (gpm) pilot zeolite

Jesse Toepfer. Homestake Mining Company of California Closure ManagerRE: Homestake Minina Company of California milleitelDP-200--Comments on DRAFT "1200 gpm zeolite-based uranium

water treatment system design report" (July 2014)July 21, 2014


number treatment system, and why it is notproposed for inclusion in the 1200

gpm zeolite treatment system.NMED infers that HMC intends this

... flow rate and operational sizing of inferenc intedua eoitthe eolte sste acheve andiscussion to reference individual zeolite

4the zeolite system achieves an treatment "units" or "trains" within anoptimal balance at approximately the overall zeolite treatment system, as is300 to 400 gpm capacity range. described on page 9; if so, please clarify.

Applicable site ground water standardshave been promulgated in HMC's SourceMaterial License, which is administered4 et al. .... agreed upon site standard...byteNcarRgloyAen.by the Nuclear Regulatory Agency.Please change references throughout thedocument accordingly.

The target retention time for optimumuranium adsorption and optimumzeolite size fraction was determined Please provide a summary of testing that

9through the testing process. The9throuith tonae tinepcessay Tochiee was performed for these determinations.zeolite tonnage necessary to achieve

the target retention time wascalculated for each treatment cell.

The information that was provided inHMC, 11/21/2013 and reiterated on page25 of this report indicates that only

This additional flexibility would uranium concentrations were reduced ininclude.. .the ability to incorporate the 4-week pilot zeolite system testother treatment parameters into a period. Please provide information aboutsingle treatment train.., what potential system modifications

would be made "to incorporate othertreatment parameters into a singletreatment train."

... pilot testing has shown that the9 zeolite will likely require regeneration Please provide data from the pilot

approximately operation to support this statement.

The manifold Is designed to allow the * Please explain why one of the zeoliteTsupplynpipelinesdisian6-inchadiametercollected water to be piped.. .through whensupplythe pipother twois are 6-inch8diameter,

either of the two 8 inch poly pipes or a diameter.

6 inch poly pipeline. dPasedets9 Please detail the design and/or

Page 2/5

Jesse Toepfer, Homestake Mining Company of California Closure ManagerRE: Homestake Minina Company of California mUlsite/DP-200--Comments on DRAFT "1200 gpm zeolite-based uranium



numberprocess controls to monitor collectionpipelines from wells to the manifold forpossible leakage.

A berm is designed to enclose all four

13 treatment trains around the facility Please include relevant calculations toarea to provide complete containment support this assertion.of solution within the berms...The system is designed to operate at Please describe any additional system

13 full capacity for approximately 20 safeguards or processes that would alerthours while still providing freeboard operational personnel to the occurrencewithin the containment, of an overflow situation.

" Please clarify whether the "acidmetering tanks" are the same as thetanks that are labeled as acid transfer

14 ... acid metering tanks... tanks on Exhibit 9.* Please confirm that the acid used for

regeneration is sulfuric acid asdiscussed in the HMC, 11/21/2013.

The control point for the system will be18 the.. site standard of 0.16 mg/L (for Please explain this statement.

uranium).Uranium samples will be required tobe taken routinely.. Sample will be Please provide the scheduling of thisrequired to be analyzed on-site with a sampling and analysis.KPA.

20 ... as stipulated in HMC's RML... Please define "RML."" The list of analytes here should be the

same as that presented on page 24.* Analytical results for weekly samples

The treated effluent will be that are submitted to an outsidesampled.. .on a weekly basis for a laboratory generally would not beperiod of at least three months.. .For available until after discharge has

20 this period, treated effluent will be already occurred. Since increasedrequired to be sampled for analysis of sulfate concentrations occur as auranium.. selenium... sulfate... chloride result of the zeolite treatment (p. 25)...TDS... and nitrate... HMC must monitor sulfate

concentrations in "real-time" eitherthrough on-site analysis or acorrelation to a surrogate indicator

Page 315

Jesse Toepfer, Homestake Mining Company of California Closure ManagerRE: Homestake Minina Company of California mililsite/DP-200--Comments on DRAFT "1200 gpm zeolite-based uranium



number(e.g., conductivity). Additionally HMCmust present baseline concentrationdata for the other contaminants ofconcern from supply wells to thezeolite system

According to the information and inferredoperational scenarios that are presented

In addition, the third cell of each on page 3, a treatment train wouldtreatment train is designed to be operate normally with only 2 cells.equipped with an ultrasonic water Therefore each cell should be equippedlevel indicator that can be read at the with an ultrasonic water level indicator to

22 control building or by remote preclude exceedances of the operationalcomputer... [which] will be programed water level range. Additionally, please[sic] to read when the water level in clarify whether these indicators would bethe cells exceeds the operational equipped with high water level visualwater level range. and/or audible alarms, or would

automatically stop influent water flow tothe malfunctioning cell."Incoming feed water" would contain

During the regeneration cycles, the uranium concentrations in excess of26 incoming feed water is consumed by applicable site standards. Please explain

the regeneration process. how contaminated water would beeffective in the regeneration cycle.

...the dates of startup and completion Please explain this statement, and26 will slide as permitting tasks are include a brief discussion of these

completed permitting tasks.

Figure NMED commentsnumberFigures Please include figure numbers in accordance with textual references.1 and 2

" The legend includes references to 3 types of wells, although none are shown

1 on this figure." The figure includes symbols comprising a red rectangle both with and without

an "X," which are not defined in the legend.Please provide construction details for the "building or enclosure" that will house

5 the zeolite treatment system manifold, including but not limited to secondarycontainment and leak detection.

Page 415

Jesse Toepfer, Homestake Mining Company of California Closure ManagerRE: Homestake Mining Company of California millslte/DP-200 Comments on DRAFT "1200 gpm zeolite-based uranium


Table NMED commentsnumber

* Please show the table number on this page.0 Please explain the meaning of task #24, "Hexa Armour Install."

Exhibit NMED commentsnumber

1 Please show the location and components of the 300 gpm zeolite system.* Please define the meaning of the dashed red lines on this figure.* The legend for the figure in the lower left of this exhibit references components,

such as acid supply plumbing, zeolite level, discharge pipe bench, and acidsupply tank, which are not shown on any figure in this exhibit.

9 a Please identify the water source for the water tank that is shown in the lower 2figures.

* Please identify the destination for water contained in the "drain pipe from sinkand shower" shown in the figure in the lower right corner.

10 This exhibit is not referenced in the text.

Please respond to the comments herein in the final submittal within 60 days from the date of thisletter. You may contact me by telephone at (505) 476-3777 or by email atdavid. mayerson ,state.nm .us if you have any questions.

f

L. Maydrson I /Mining Environmental Compliance SectionGround Water Quality BureauNew Mexico Environment Department

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Homestake Mining Company of California (nI-OMb4ESkitAKE · New Mexico Environment Department P.O. Box 5469 Santa Fe, New Mexico 87502-5469 ... Mr. Wayne Canon, New Mexico Office of