DRC-2016-006847 - 0901a0688062ea0e

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State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
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MEMORANDUM
TO:Project File C-2016-38
THROUGH: Phil Goble, Section Manager P16 */<//£
Russell J. Topham, PEFROM:
DATE:
SUBJECT:
May 5, 2016
Engineering Module 75B, Review of the 1st Quarter 2016 (January-March, 2016) DMT
Performance Standards Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report (Report). Groundwater Discharge Permit (GWDP) UGW370004 - Energy
Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
This is a summary of Utah Division of Waste Management and Radiation Control (DWMRC) staff review of the
EFR DMT Performance Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards Monitoring
Report dated April 20, 2016, and covering the 1st Quarter 2016 (January-March, 2016) monitoring period
(Report). DWMRC received the Report on April 22, 2016 in both hard copy and CD formats. Discussions in this
document reference the White Mesa Mill Discharge Minimization Technology (DMT) Monitoring Plan, Revision
12.3 (DMT Plan), dated April, 2015.
After review of this report, DRC staff findings and recommendations are as follows:
Findings
1. Weekly monitoring of Cell 1 solution pool elevations occurred as required, and the solution pool
elevation remained below the specified limit.
2. Weekly monitoring of Cell 4A solution pool elevations occurred as required to calculate acceptable
leakage rates, and the leakage rate thus determined remained below the specified limit
3. Weekly monitoring of Cell 4B solution pool elevations occurred as required, and the solution pool
elevation remained below the specified limit.
4. Data provided in Attachment C to the Report supports a conclusion that EFR has generally met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable. However,
the data also supports a hypothesis that the effectiveness of the current practice may be at an end without
making changes in the cover system.
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Review Memorandum, Project C-2016-38
May 5, 2016
Page 2
5. Monitoring of the feedstock storage area occurred as required. The data support a conclusion that no
feedstock existed outside the designated feedstock storage areas.
6. EFR met the requirements for inspection of the liner systems. No damage was detected, and no repairs
were undertaken.
7. EFR has met the requirements for inspecting the New Decontamination Pad, finding no indication of
leakage from secondary containment or other indicators of substandard performance.
8. EFR has met the requirements for inspecting the Old Decontamination Pad, finding no indications of
substandard conditions.
9. EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and corrected all
mechanical failures the same day as detected.
10. The leak detection systems in Cells 1, 2, and 3 appear to have operated properly, and no fluids were
detected therein during the 1 st Quarter 2016.
11. EFR has met the requirements for inspection and crack/joint repair of the Ammonium Sulfate Pad.
Recommendations
1. The DRC should issue a closeout letter for the review of this report.
2. The DWMRC and EFR should continue jointly to pursue expedited revision, approval and
implementation of Reclamation Plan Revision 5 to provide a means of excluding as much precipitation
as possible from contributing to recharge of the slimes.
1.0 Tailings Wastewater Pool Elevation Monitoring
Part I.E.7(a) of the GWDP requires EFR to monitor and record weekly the elevation of the wastewater pool in
Tailings Cells 1 and 3 to ensure compliance with Condition 10.3 of the License. Part I.D.3(e) of the GWDP
requires EFR to operate Roberts Pond to provide a minimum two feet of freeboard at all times. Part 3.1(d) of the
DMT/BAT Plan requires EFR to measure the solution pool elevation in Cells 4A and 4B weekly, and the tailings
beach maximum elevation and area within Cells 4A and 4B monthly. The reference to Roberts Pond will be
removed at the next revision to the GWDP inasmuch as the DWMRC has approved plans to fill Roberts Pond and
regrade the area, eliminating the impoundment entirely.
Cell 1
Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with the prescribed
freeboard requirements.
Cell 3
Tailings have nearly completely filled Cell 3. Recognizing this, letters from the Director dated January 27, 2011
and March 14, 2011 formally eliminated the need for solution pool elevation measurement in Cell 3. The
previously cited January 27, 2011 letter and another letter from the Director dated March 15, 2011 concluded a
process ending the need for freeboard-related solution pool elevation monitoring in Cell 3. However, Part 3.1(a)
of the DMT/BAT Plan requires monitoring solution pool elevations in Cells 4A and 4B to facilitate determination
of compliance with FML leakage rate limitations.
Review Memorandum, Project C-2016-38
May 5, 2016
Page 3
As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed during the
monitoring period. Attachment A to the report reflects no measurements for the reported quarter.
Cell 4A
Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of calculating
acceptable leak rates for the liner system
CeU4B
Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance with the
prescribed freeboard requirements.
Roberts Pond
Roberts Pond has been taken out of service following discovery of tears in the pond liner on March 13, 2014.
EFRI has redirected all fluid flows previously destined for Roberts Pond to Cell 1. EFR1 has completed cleanup of
contaminants released from the pond as a result of the breached liner. The pond has been completely backfilled,
with all storm water collected on the new surface directed to Cell 1.
Findings: The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the DMT/BAT plan in force during the quarter.
2.0 Slimes Drain Water Level Monitoring
Part I.F.2 of the GWDP requires EFR to include in the Report, all DMT performance standards monitoring
detailed in Parts I.D.3 and I.E.7 of the GWDP. Part I.D.3(b)(l) of the GWDP requires EFR to maintain the fluid
level in the slimes drain of Cells 2 and 3 as low as reasonably achievable at all times, and to demonstrate that
performance through adherence to the current DMT Monitoring Plan. Part I.E.7(b) of the GWDP requires
monthly monitoring and recording of the depth to wastewater in the slimes drain access pipe as described in Part
I.D.3 of the GWDP and the current DMT Monitoring Plan. Part 3.1(b)(v) of the DMT Monitoring Plan requires
EFR to monitor and record weekly the depth to wastewater in the Cell 2 slimes drain access pipe to determine
maximum and minimum head before and after a pumping cycle, respectively.
Section 4.1 of the Report asserts that the above discussed monitoring requirements only pertain to Cell 2 for the
reporting period, as dewatering operations have not commenced in Cell 3.1 concur with this assessment.
Weekly water level monitoring of the Cell 2 slimes drain is not required as part of the DMT plan, but is required
under Part I.D.3(b)(l) of the GWDP. EFR retains records of Cell 2 slimes drain monitoring at the mill.
Attachment C to the Report contains data from the quarterly recovery head measurements (discussed in the next
paragraph). The recovery head monitoring data provides indirect evidence that EFR has maintained the fluid level
in the Cell 2 slimes drain as low as reasonably achievable, as required in GWDP, Part I.D.3(b)(l). From the graph
of slimes drain recovery head data in Attachment D, it is apparent that the downward trend that has occurred since
May of 2011 has not continued apace. All measurements since the 2nd Quarter of 2014 are above the level
observed during the 2nd Quarter of 2014. It appears that the readings beginning with the 1st Quarter of 2014 are
roughly equivalent to each other, only varying by “noise,” or imperfection, in the measurement technique.
The remainder of this section repeats analysis from the 1st Quarter, 2015 Report review memorandum, as updated
during review of the 4th Quarter, 2015 Report.
More information is required to understand whether equilibrium has been reached with approximately 7.5 feet of
hydraulic head (approximately 22.5 feet from the surface of the temporary cover on the cell) at the pumping point
Review Memorandum, Project C-2016-38
May 5, 2016
Page 4
(Report, Appendix D). Table 2-1 on p. 7 of the Tailings Data Analysis Report (TDAR, April, 2015) presents a
water table at a depth of between 0.2 feet and 12.3 feet of the surface of the temporary cover. Likewise, Table 4-1
indicates the depth to top of saturated tailings varying from 3.92 feet to 11.58 feet below the temporary cover
surface, with the greater depths occurring closer to the slimes drain alignment (TDAR, p. 17). This indicates a
substantial volume of fluid yet to be removed from the cell.
The TDAR postulates the presence of gypsum in the interstices within the tailings mass (p. 11). This condition
would reduce hydraulic conductivity within the tailings. The temporary cover is composed of random fill, which
on visual inspection appears to be a sandy gravel or gravelly sand with cobbles and boulders. The porosity of this
cover would allow surface water to penetrate into the tailings below. While the region in which the mill is sited
has experienced drought conditions, significant storms have occurred. Those may have recharged the cell,
offsetting the withdrawal through the slimes drain. 2015 saw wet conditions through the spring and early summer
with normal-to-wet conditions prevailing through the end of the year.
Given the above hypotheses and the data presented in Attachment D to the report, I question whether the current
practice of withdrawing slimes will prove effective in reducing the fluid level in the cell. Installation of final
cover, with a liner system and grading to shed precipitation may be required in order to achieve the desired fluid
reduction.
One drawback has been identified to placing final cover at this time. With the amount of fluid remaining in the
cell, settlement may occur as fluid is withdrawn. This could compromise a clay radon barrier. An alternative to
placing final cover might be to place a less permeable layer to shed storm water. This could be augmented by
installing piezometers in a few well-chosen locations to monitor phreatic head in the cell, while keeping the pump
in the slimes drain active, and abandoning the practice of recovery head measurement in favor of monitoring the
piezometers.
Recent activity on amendment of Reclamation Plan Revision 5.0 appears focused, in part, on resolving the
questions presented above. I expect the Licensee will commence placement of additional platform fill prior to the
end of this month, providing an opportunity to evaluate the potential for surcharge to accelerate fluid withdrawal
capability. The new fill, if properly contoured at the surface, may also shunt storm water aside, preventing much
of the recharge that may occur in the slimes due to percolation.
Finding: Data provided in Attachment C to the Report supports a conclusion that EFR has generally met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable. However, the data
also supports a hypothesis that the effectiveness of the current practice may be at an end without making changes
in the cover system.
Recommendation: The DWMRC and EFR should continue jointly to pursue expedited revision, approval and
implementation of Reclamation Plan Revision 5 to provide a means of excluding as much precipitation as
possible from contributing to recharge of the slimes.
3.0 Feedstock Storage Monitoring
This section addresses both bulk conventional feedstock (ore) and alternate feed stored onsite. Ore is stored on the
ore pad. Part I.D.l 1 of the GWDP anticipates and governs storage of alternate feed outside the confines of the ore
pad.
Weekly inspection revealed no evidence of ore beyond the boundaries of the ore pad. Storage practices for
alternate feeds appeared compliant with GWDP requirements.
The current report highlighted no example of significant amounts of standing water persisting on the ore pad after
storms.
Review Memorandum, Project C-2016-38
May 5,2016
Page 5
Finding: Monitoring of the feedstock storage area occurred as required. The data support a conclusion that no
feedstock existed outside the designated feedstock storage areas. Standing water problems were addressed during
the quarter.
Recommendation: Efforts to address the storm water issue should be monitored over several inspections and
report review cycles to see that changes made by the licensee are effective and lasting. Inasmuch as this is not a
failure in monitoring, but in operations, this follow through activity should not prevent closing out the review of
the Report.
4.0 Tailings Cells and Pond Liner System Repairs
Inspection of all cells occurred weekly during the period covered in the report. The report indicated no case of
liner damage in the tailings cells discovered or repaired during the quarter.
Finding: EFR met the requirements for inspection of the liner.
5.0 Decontamination Pads
Weekly inspection of the New Decontamination Pad occurred as required under Part I.F.12 of the GWDP. The
monitoring portals were dry during all inspections, indicating no leakage from primary containment. Cracks were
repaired during the Report period.
Finding: EFR has met the routine and annual requirements for inspecting both the Old and New
Decontamination Pads, finding no indication of leakage from secondary containment.
6.0 Ammonium Sulfate Pad
Phase 1 of the Nitrate Corrective Action Plan required installation of a concrete pad to prevent water penetrating
to nitrate-containing soils in the area of the ammonium sulfate crystal tank. This pad was installed and inspected
by DWMRC during the Report quarter. The DWMRC approved the construction by letter on June 26, 2015, near
the end of the Report period. Plant personnel inspected the pad and applied sealant to joints and cracks as
required. Inspections are required quarterly for eight consecutive quarters, and annually thereafter thereafter.
Finding: EFR has met the routine requirements for inspecting the Ammonium Sulfate Pad, and has sealedjoints
and cracks therein.
7.0 Cells 4A and 4B BAT Performance Standards Monitoring
Requirements for measuring BAT performance for Cells 4A and 4B include verifying that leak detection system
equipment operates appropriately, verifying that fluid head in the leak detection system sumps does not exceed 1
foot above the lowest point in the secondary (lower) flexible membrane liner, and recording the volume of fluid
pumped from the leak detection systems for the two cells. EFR must also record the fluid head in Cell 4B for
compliance purposes, and in Cell 4A for computation of acceptable leakage rate in Cell 4A. The data provided in
the report and its attachments provide evidence of compliance with the Cells 4A and 4B BAT performance
monitoring standards in place during the monitoring period.
Cell 4A
No failures were noted in the Cell 4A leak detection system during the Report period.
Review Memorandum, Project C-2016-38
May 5, 2016
Page 6
Cell 4B
No failures were noted in the Cell 4B leak detection system during the Report period.
Finding: EFR has met the monitoring requirements for Cell 4A and 4B BAT performance. No mechanical failures
were noted during the quarter.
8.0 Cells 1,2 and 3 Leak Detection System Monitoring
Leak detection system monitoring requirements for Cells 1, 2 and 3 appear in the Radioactive Materials License
rather than the GWDP. For consistency, the DRC requested that this monitoring be included as part of the
quarterly report and EFR has consented to do so.
The report and its attachments contain weekly monitoring data for the operational status of the leak detection
system equipment, fluid levels detected in the leak detection systems, and volumes of fluid pumped. From the
data, EFR represents that no failures of the monitoring equipment occurred that were not corrected within 24
hours. Leak detection systems for the three cells measured dry; therefore, no fluids were pumped therefrom.
Finding: The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids were
detected therein during reporting period.