DRC-2014-003181 - 0901a068804386e9

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ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.t^efc;,yfuels.com
May 12, 2014
VIA PDF AND EXPRESS DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850 DRC-2014-003181
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MAY
9f
Dear Mr. Lundberg:
Re: Utah Ground Water Discharge Permit No. UGW3700004
White Mesa Uranium Mill - Follow up to notice pursuant to Parts I.E.7 f) and I.G.3
and Action Plan for Roberts Pond Liner Damage
Reference is made to the Energy Fuels Resources (USA) Inc. ("EFRI") letter dated March 18,
2014 which provided notice pursuant to Parts I.E.7 f) and I.G.3 of the White Mesa Mill's (the
"Mill's") State of Utah Groundwater Discharge Permit No. UGW370004 (the "Permit"), that
EFRI, as operator of the Mill and holder of the Permit, identified damage to the Roberts Pond
Liner System. The EFRI March 18, 2014 letter committed to submitting an Action Plan in
response to the liner damage in Roberts Pond.
Pursuant to the March 18, 2014 letter, EFRI is submitting this Action Plan to address any
impacted soils that may be present beneath the liner.
Please contact me if you have any additional questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Attachment 1
Action Plan for Roberts Pond Liner System
Roberts Pond Action Plan
May 12, 2014
Attachment 1
Action Plan for Roberts Pond Impacted Soils
In May of 2002, the decision was made to clean out and re-line the White Mesa Mill ("Mill")
area retention basin, commonly referred to as Roberts Pond. The 2002 activities were completed
as described in the As-Built Report Mill Area Retention Basin ("Roberts Pond"), White Mesa
Mill (the "2002 Report") (IUSA 2002). The 2002 Report provided procedures and
documentation of the cleanup of the soils underlying Roberts Pond prior to the re-lining. This
Action Plan is based on the applicable procedures for removal and verification of soils during the
2002 refurbishment of Roberts Pond.
Roberts Pond is within the current area covered by the Mill reclamation plan. As such, the area
will be included in the cleanup activities for final Mill reclamation and will be subject to the
radiological cleanup criteria in effect at that time.
1.0 Notification of the Spill
Mill operations notified the EFRI Quality Assurance Manager on Thursday, March 13, 2014 at
12:30 pm, of liner damage to Roberts Pond that was noted, during routine operations, apart from
routine inspections. As contemplated by Parts I.E.7f) and I.G.3 of the Permit, EFRI provided
notification to Mr. Thomas Rushing of the Division of Radiation Control ("DRC") at 2:45 pm
and again to Mr. Russ Topham at 3:35 pm on March 13, 2014, within 24 hours of the Quality
Assurance Manager receiving information from Mill personnel regarding the incident. Written
notification was provided to the Director of the Utah Division of Radiation Control ("Director")
on March 18, 2014.
a) Part I.E.7 f) of the Permit requires that the licensee conduct daily inspections for each
of the tailings cells and weekly inspections of Roberts Pond. According to Part I.E.7
f):
"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."
b) Although Part I.G.3 of the Permit is stated to apply to circumstances where the
Permittee fails to maintain Discharge Minimization Technology ("DMT") or Best
Available Technology ("BAT") standards, Part I.E.7 f) requires that the notification
provisions of Part I.G.3 also apply to liner defects or damage, regardless of whether or
not the liner defect or damage constitutes a failure of DMT or BAT. Under Part I.G.3,
the Permittee is required to submit to the Director a notification and description of the
defect or damage orally within 24-hours of the Permittee's discovery, followed by
written notification within five calendar days. Verbal notification was provided to the
Director on March 13, 2014 and written notification was provided to the Director on
March 18, 2014.
1
Roberts Pond Action Plan
May 12, 2014
c) The liner damage was identified, at 12:30 pm during routine operations, on March 13,
2014, apart from a liner maintenance inspection.
2.0 Containment Procedures/Actions Taken to Date
Upon receipt of the initial identification, the Mill's Environmental Coordinator notified the Mill
Manager immediately. The following plan of action was immediately put into place:
a) Removal of residual fluids in Roberts Pond was immediately implemented by pumping
the fluids to the Cell 1.
b) Mill staffing was increased by 12 for manual removal of the sediments in Roberts Pond
to allow for a thorough inspection of the liner in Roberts Pond. Initially, sediment
removal was completed using only hand equipment to prevent further liner damage in
anticipation of repairing the liner currently in place. EFRI Management subsequently
determined that the liner currently in place is not salvageable and mechanical sediment
removal using a long-arm bucket excavator was employed.
c) Additional liner system damage discovered during the sediment removal has been
documented. Existing damage caused by the 2012 clean out activities was
documented. New damage resulting from the use of a long-arm bucket excavator in
2014 was also documented. Newly caused damage was not included when estimating
the spill volume.
3.0 Proposed Cleanup Activities and Radiological Verification
The clean out of sediments on the liner in Roberts Pond was completed initially by manual
methods (shovels). EFRI Management determined that the liner currently in place was not
salvageable and mechanical sediment removal using a long-arm bucket excavator was employed.
After sediment removal, the Roberts Pond Liner was thoroughly inspected for damage. Existing
damage caused by the 2012 clean out activities was documented and is shown on Figure 1. New
damage resulting from the use of a long-arm bucket excavator in 2014 was also documented.
Newly caused damage was not included when estimating the spill volume and is not included in
Figure 1.
The Roberts Pond Liner System will be removed. The soils underneath the liner will be visually
inspected for staining or other indications that they were impacted by the solutions. Visually
stained soils will be removed.
After the visual contamination is removed, a grid pattern of 10ft. by 10ft. will be established,
extending up beyond the liner anchor trench as shown in Figure 2. Each point on the grid will be
surveyed with a Ludlum Model 19 microR meter. An area will be deemed cleaned if the gamma
measurements are within 10% of background. Background will be established as described in
Section 4.0. Any area with a gamma measurement greater than 10% of background, will be
excavated until the grid point measurement is within 10% of background.
2
Roberts Pond Action Plan
May 12, 2014
After all impacted soils have been removed based on the gamma measurements, soil samples
will be collected and analyzed for uranium. Soil samples will be collected at 5% of the grid
points for verification by analysis for uranium. The uranium analysis will be completed in the
on-site laboratory. Because the solutions historically present in the pond were process fluids, it
is very unlikely that there would be other chemical constituents present in the Roberts Pond
subsoil unless they were accompanied by significantly higher uranium values; therefore, uranium
was chosen as the indicator for final clean up of the impacted soils. The soil verification samples
analyzed for uranium will be collected at 5% of the grid points used for the microR
measurements. Duplicate soil samples for each location will be collected and archived on site.
When a location is deemed clean based on the uranium limits described in Section 4.0, the
archived sample will be sent to an off-site laboratory for analytical verification of the results
obtained from the on-site laboratory. Archived soil samples will be stored in accordance with
the analytical method requirements for sample preservation and storage until analysis and/or
disposal.
Soils removed during cleanup activities will be disposed of in one of the on-site cells or may be
reprocessed if the uranium content makes this economically feasible.
DRC will be provided with notice 14 days prior to the commencement of field activities.
4.0 Establishment of Background and Cleanup Limits
4.1 Gamma Background
The gamma measurement background referenced in Section 3.0 above will be determined by
averaging gamma measurements collected from the four cardinal directions one mile from the
Mill Restricted Area.
4.2 Uranium Cleanup Limit
The 5% soil verification samples will be compared to the EPA Regional Screening Level
(formerly Preliminary Remediation Goals) for uranium as published in the "Regional Screening
Levels (RSL) for Chemical Contaminants at Superfund Sites"(EPA 2013). The MCL-based
Protection of Groundwater limit of 14 mg/kg will be used for the cleanup and excavation of
potentially impacted soils under Roberts Pond. The excavation will be considered complete if
the verification soil samples are at or below 14 mg/kg.
In the event that the full excavation of contaminated soils is not practical (i.e. the impacted soils
extend under existing Mill structures) during operation of the Mill, EFRI will produce a
conservative estimate of potentially impacted soils remaining. Removal of this remaining soil
will be completed at Mill reclamation and the associated costs will be included in the 2015 surety
estimate.
3
Roberts Pond Action Plan
May 12, 2014
5.0 Estimation of Seepage Volume
DRC requested during the initial verbal notification on March 13, 2014, that EFRI estimate the
volume of seepage resulting from the liner damage in Roberts Pond. EFRI has completed a
thorough inspection of the liner, documented all damage arising from the 2012 clean out
activities, visually inspected the underlying soils in areas with liner damage, and completed a
vertical assessment of moisture content (percent moisture) of the underlying materials in order to
estimate the seepage volume. The seepage volume was calculated using the two methodologies
described below. The associated calculations, assumptions and inputs for the calculations are
included in Appendix 1.
The first method for estimating seepage volumes used moisture data from samples collected
under the liner immediately adjacent to two of the larger areas of liner damage. Moisture analysis
was conducted in both areas on samples collected every six inches to a maximum depth of 42
inches or refusal, whichever came first.
The second method for estimating the seepage volume used the total calculated area of liner
damage, site soil/geology data, published hydraulic conductivity values, average depths of fluids
in the pond during the time the liner is estimated to have leaked, and Darcy's Law. This
estimation of seepage was completed for conservatism.
Using the above two methodologies resulted in the following estimated seepage volumes:
• Seepage based on moisture analysis - 43,791 gallons
• Seepage based on Darcy's Law - 213,400 gallons
The seepage volume calculated using Darcy's Law likely overestimates the total volume of
fluids that seeped from Roberts Pond. This estimate was completed for conservatism and EFRI
does not believe that this estimate accurately reflects the seepage volume based on both
empirical data and visual observations conducted during the sediment removal. The depth of
penetration (as shown in Appendix 1) for the Darcy's Law estimate would likely be greater than
2 feet, which is not supported by the moisture content data. Furthermore, visual observations
regarding soil saturation were made throughout the sediment removal. The visual observations
indicated that only the top 3 inches of underlying materials were saturated, but below 3 inches
the underlying materials were not saturated, suggesting that the volume of fluids seeped is
significantly less than the Darcy's law estimate.
One factor contributing to the retardation of the fluid seepage is the presence of sediments in
Roberts Pond. The sediment within Roberts Pond fully covered the bottom of the pond and
extended partway up the sides. The sediment thickness varied between 4 inches on the northern
end and 29 inches on the southern end and the averaged 11 inches. The fine grained and tightly
compacted sediment likely acted as a partial low-permeability barrier to seepage within the areas
where the liner was damaged, thus limiting seepage rates.
4
Roberts Pond Action Plan
May 12, 2014
5.1 Location and Extent of Liner Tears
The liner tears were measured as the sediment was removed and recorded on Figure 1 - Roberts
Pond Liner Tear Locations. These tears varied in size, location failure type (i.e. slit, wide tear,
tear with liner material still in original place, punctures). There were 114 liner tears ranging in
size from 2 inches to 30 feet by 15 feet. The liner tears appear to be indicative of damage from
the bucket of a hydraulic excavator. An estimate of the total damaged area is included in
Appendix 1.
6.0 Root Cause Analysis
As previously stated in the March 18, 2014 letter, EFRI believes the damage incident occurred as
a result of maintenance activities, during the planned maintenance outage in July 2012.
The 2012 chronology is as follows:
a) Roberts Pond was out of service in June 2012 for routine maintenance and preparation
for Mill startup. Roberts Pond underwent cieanout of accumulated sediment during the
month of July 2012. The long-arm bucket excavator used for solids removal created a
tear in the flexible membrane liner ("FML") of Roberts Pond at approximately 1:30 pm
on July 5, 2012. Residual sediments/slurry several inches thick were left in place by the
heavy equipment used during the July 2012 maintenance activities. The 2012 liner
tears and repairs were above the sediment/slurry levels and therefore were easily seen
and no seepage was possible and/or documented in 2012.
b) Repairs to the 2012 liner tear were performed and completed during the weeks of July 5
and July 12, 2012, in accordance with the Mill's Liner Maintenance Provisions. The
Mill returned Roberts Pond to service during the week of August 6, 2012, and it
received process fluids, as necessary, thereafter.
c) EFRI estimates that the liner damage discovered in March 2014 most likely was caused
by heavy equipment contact with the liner itself during the July 2012 maintenance
outage or was a result of stresses to the liner caused by the maintenance activities in
July 2012. The July 2012 maintenance activities are believed to be the source of the
liner damage because no other maintenance activities, involving the use of heavy
equipment, have been performed in the interim.
d) The liner damage or liner stress was not noted at the time of the July 2012 maintenance
outage because residual sediments/slurry, several inches thick, were left in place by the
heavy equipment used during the July 2012 maintenance activities.
The weekly liner inspections and freeboard measurements specified by the GWDP were
conducted as required. The weekly inspections did not note the liner damage due to the residual
sediments left after the 2012 maintenance activities and because additional sediments have
accumulated during use.
5
Roberts Pond Action Plan
May 12, 2014
7.0 Compliance with the SPCC
The Mill's Spill Prevention Controls, and Countermeasures ("SPCC") Plan, in Section 1.8,
"Spill Discovery and Remedial Action" requires the following steps be completed in response
to a spill. Each step is listed in italics followed by confirmation of how the step was
implemented during the Roberts Pond investigation.
"Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, if possible, to limit further
releases."
• The influent flows were shut off after the damage was identified. Removal of residual
fluids in Roberts Pond was immediately implemented by pumping to Cell 1.
"The Shift Foreman will also secure help if operators are requiring additional assistance to
contain the spill."
• The Mill Manager and Corporate Environmental Health and Safety Manager mobilized
a multiple operator crew for sediment removal.
"The Shift Forman is also obligated to initiate reporting procedures. Once control measures
have begun and personal danger is minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager. "
• Internal reporting to the Mill Manager and Quality Assurance Manager occurred
immediately. The Corporate Environmental Health and Safety Manager discovered the
damage and participated in the notifications.
"The Production or Maintenance Superintendent will notify the Mill Manager, who in turn will
notify the Department Head ofEA/HS and/or the Environmental Coordinator. "
• The Mill Manager delegated notification duties to the Corporate Environmental Health
and Safety Manager. The Corporate Environmental Health and Safety Manager
contacted Corporate Environmental management (the Quality Assurance Manager).
Notification to the Quality Assurance Manager occurred within one hour of the
incident.
"The Mill Manager will assess the spill and related damage and direct remedial actions. The
corrective actions may include repairs, cleanup, disposal, and company notifications.
Government notification may be necessary in some cases. "
• Corrective actions were implemented or are in process as described in Section 2.0, 3.0
and 4.0 above. Notification of the Director occurred as described in Section 1.0, above.
6
Roberts Pond Action Plan
May 12, 2014
8.0 Reclamation and Surety
As previously stated, Roberts Pond is within the current area covered by the Mill reclamation
plan. As such, the area will be included in the cleanup activities for final Mill reclamation and
will be subject to the radiological cleanup criteria in effect at that time.
EFRI assumes that we can remove the contamination resulting from the liner damage during the
planned cleanup event. In the event that the full excavation of contaminated soils is not practical
(i.e. the impacted soils extend under existing Mill structures) during operation of the Mill, EFRI
will produce a conservative estimate of potentially impacted soils remaining. Removal of this
remaining soil will be completed at Mill reclamation and the associated costs will be included in
the 2015 surety estimate.
9.0 Reporting
A report will be submitted to DRC 90 days after the completion of the excavation work. The
report will include a summary of the gamma data, uranium data and locations of the individual
pond and background sample locations.
7
Appendix 1
Seepage Calculations
Seepage Estimate Based on Moisture Content Analysis
South*
Depth (inches)
0-6
6- 12
12- 18
18-24
24-30
30-36
36-42
Moisture %
20.08
11.98
12.16
12.08
13.49
14.61
15.29
East*
Depth (inches)
0-6
6- 12
12-18
18-24
24-30
30-36
36-42
Moisture %
20.39
13.97
13.12
16.71
15.65
15.46
refusal
* Samples were collected under undisturbed liner adjacent to large tears
to conservatively estimate maximum moistue from seepage resulting
from the adjacent tear.
The following calculation was used to calculate the total seepage based on the above percent
moisture data:
Solution leaked (gals) =
Area X Gallons/Cubic foot X Saturated Soil Depth (feet) X % Water
Where:
Area = 0.64 acres
Square Feet/Acre = 43,560
Gallons/Cubic Feet = 7.48
Water by Volume (%) = 21
Wet Soil Depth = 1 foot - Actual depth is 6 inches, however, for conservatism this
depth was doubled.
Area
(acres)
0.64
sq ft/acre
43,560
gal/cuft
7.48
% water by vol
21.0%
wet soil depth
1.0
Gallons
43,791
BACKGROUND AND ASSUMPTIONS:
- The anchor trench of Roberts Pond is approximately 12 to 15 feet lower in elevation than the ammonium
sulfate investigation area on the west side of the Mill building.
- Roberts pond is approximately 10 feet deep.
- Percent moisture data collected from the deep soil borings (> 18 feet) during the ammonium sulfate
investigation ranged from 7.7% to 16.4%.
- The deep soil boring percent moisture data are considered applicable because they are approximately
equivalent in depth to the bottom of Roberts Pond due to the elevation differences on the west and east side
of the Mill building. The 10-foot depth of Roberts Pond was added to the elevation difference.
- Visual observations regarding saturation were made during sediment removal. Visual observations noted
that the elevated saturation levels across Roberts Pond do not extend deeper than approximately 6 inches.
- Moisture contents in the 15% to 20% range are considered consistant with optimum moisture content for
fill placement using on-site soils and therefore inplace moisture contents in this range are not abnormal.
- The percent moisture values greater than 20% were considered to be caused by seepage. Percent moisture
values less than 20% are considered to be unaffected by seepage and representative of site conditions.
Seepage Estimate Based on Darcy's Law
BACKGROUND AND ASSUMPTIONS:
- This calculation of seepage from Roberts Pond takes into account the area of the liner that was undamaged
that would prevent seepage.
- The total area of the tears was estimated. Areas for tears reported with both a length and width were
calculated as the product of length and width, for example, 2ft x 3ft (= 6 ft2). Slits in the liner were reported
as only a length without a width. In these cases, it was assumed that the tears were 1 inch wide in order to
estimate an area.
- A total torn area of 1,445 square feet, or approximately 5% of the total pond area of 28,000 square feet.
1,445 was the total calculated area through which seepage occurred.
- The solution levels within Roberts Pond vary with mill activities. During the timeframe that the liner is
estimated to have been torn, the levels varied from 0 to 5.5 feet with an average level of 1.7 feet.
- Sediment was removed in July 2012. Thisdate has been assumed as the initial date of the liner damage
identified in March 2014. Damage to the Roberts Pond Liner was noted on March 13, 2014 and was assumed
as the final date of use. This results in a total timeframe of 658 days. Roberts Pond was dry for 147 days
during this timeframe, allowing for 511 days of possible solution seepage.
- The hydraulic conductivity estimate is based on the default values for moderately compacted silt provided
in the HELP3 manual.
Using the following, and conservatively assuming that fully saturated conditions developed beneath the pond
bottom:
area through which seepage occurs = 1,445 ft ,
flow path length = pre-Ieakage depth to perched water = 28 ft,
average depth of water in pond = 1.7 ft,
head difference = 29.7 ft (28 ft + 1.7 ft),
hydraulic gradient = 29.7/28 = 1.06 ft/ft,
hydraulic conductivity = 1.3 x 10"5 cm/s (0.0364 ft/day),
By Darcy's Law, the seepage rate is calculated as 0.0364 ft/day x 1445 ft2 x 1.06 ft/ft = 55.7 ft3/day or 0.29
gpm. Over 511 days, the total seepage would be 213,400 gallons.
Seepage from tears in the liner distributed over the 28,000 ft2 pond bottom can be assumed to spread out in
the soils beneath the pond. Assuming seepage spreads out uniformly over the area ofthe pond bottom, and:
1) full saturation develops,
2) the porosity of the soils underlying the pond is 0.44 (for a moderately compacted silt),
3) 'plug flow' occurs, and
4) the total seepage = 213,400 gal or 28,500 ft3,
Then the average depth of penetration would be 28,500 ft3/(0.44)(28,000 ft2) =2.3 feet
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Energy Fuels Resources (USA)
REVISIONS
Date By
Project: White Mesa Mill
County: San Juan State:
Location: Roberts Pond
Figure 1
Roberts Pond
Liner Tear Loactions
Date:4/.50/14 | Drafted By: w.
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REVISIONS
Date By
Project: White Mesa Mill
County: San Juan State:
Location: Roberts Pond
Figure 2
Roberts Pond
Cleanup Grid
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