DRC-2019-013361 - 0901a06880b527e0

DRC-2019- 01331 Module Reviewer Name:
Phil Goble, Manager ?K 4 1 o/.13,D11
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2019
Inspection Date: October 15, 2019
Module Prepared by/Date Prepared:
Tom Rushing, P.G./October 21, 2019 :IP 10/2(/10)
DWMRC Staff Present: Tom Rushing
Energy Fuels Resources Staff Present: Garrin Palmer
Energy Fuels Resources Staff Interviewed: Garrin Palmer
Tanner Holliday
Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements
Inspected:
Part I.D.10 — Requires management of contact and non-contact storm water and control of
contaminant spills in accordance with the currently approved Storm Water Best Management
Practices Plan (SWBMPP), Spill Prevention Control and Countermeasures Plan (SPCC), and
applicable sections of the Utah Administrative Code.
Part I.D.11 — Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Area, including requirements for container integrity, storage on an engineered
impervious surface, and controls for storm water run-on and run-off.
Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm
Water Best Management Practices Plan (SWBMPP) for the White Mesa Uranium Mill:
Date: December 2016
Section I — Document Review
SWBMPP (Documentation Requirements):
SWBMPP Part 4.1.4. -- Diversion ditches, drainage channels and surface water control
structures in and around the Mill area will be inspected at least weekly. Areas
requiring maintenance or repair, such as excessive vegetative growth channel erosion or
pooling of surface water runoff, will be reported to appropriate departments and all
follow up actions are to be documented.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Findings:
The Utah Division of Waste Management and Radiation Control ("DWMRC") conducted an
inspection of upland diversion ditches 1, 2 and 3 and associated diversion berms.
Per the inspection, the ditches and berms appeared to be well maintained No excessive
debris or erosion was noted in the ditches.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DWMRC reviewed the March 4, 2019
monthly form and noted that the EFR Inspector (Tanner Holliday) noted that the Diversion
Ditches showed no signs of sloughing, erosion, undesirable vegetation or obstructions of
flow. Additionally the form notes that diversion berms show no stability issues or signs of
distress. The form notes that "Diversion ditches all look good."
SWBMPP Appendix 1 — Spill Prevention, Control, and Countermeasures Plan (SPCC)
(Documentation Requirements):
1.6.1. — Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DWMRC August 8, 2012 Request for Information which
stated as follows: "The EFR Spill Prevention, Control, and Countermeasures Plan, Part
1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include
the inspection findings with the daily inspection form used for storm water inspection
documentation within 30 days from your receipt of this letter," EFR has removed the daily
inspection requirement on the basis that the propane is a gas at ambient conditions and would
be immediately vaporized under all foreseeable leakage conditions at the Mill. DWMRC
concurred with this action and this item is no longer inspected as part of the documentation
review or included on the site walkthrough.
1.9.1. — External Notification of "reportable quantity" spills.
Findings: No reportable quantity spills were reported by EFR during the period reviewed,
DWMRC has no additional comments.
1.9.2. Internal Notification of incidents, spills, and significant spills.
The White Mesa Mill employees are using a formatted card to report the small quantity
spills; the card is titled "Non-Reportable Reportable Spillage." The card provides the
following information: Name, Date of Discovery, Approximate Amount Spilled, Time of
Discovery, LOcation of Incident, Description of Material Spilled, Cleanup Activities Taken
and Signature. The reports additionally include photographs of the spill and follow up
actions in most cases.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Small quantity spill reports were reviewed since the last inspection (Inspection range 9/25/18
through 10/15/19. A total of 14 small quantity spills and follow up actions were reported
during that time frame. Per DWMRC review it appears that the spills are being adequately
reported and follow up actions are described, and in many cases photos of the spill and clean-
up are included.
During 2019, EFR implemented the storm water training program with the annual
radiological refresher in two sessions (February 20, 2019 and February 22, 2019). A total of
54 employees were trained during 2019 as of the date of the inspection.
DWMRC notes that the internal spill reporting processes and SWBMPP training activities
are very effective. The spill reporting provides records of identification and follow-up
procedures thereby making the chemical management at the mill transparent and supports
employee involvement in spill identification, reporting, and follow-up.
1.10 Records and Reports.
Period of Records Examined During Inspection:
Begin/Ending: 2/1/2019 through 2/28/2019
No. of On-site Records Required: Daily, Weekly, and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: February 2019
How Selected: DWMRC Inspected a random month of daily, weekly and monthly
forms completed since the last annual DWMRC Storm Water Inspection.
Daily Tailings Inspection Data:
Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-1 of the
Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport
system (Slurry pipeline, pipeline joints and supports, valves and point of discharge); 2.
Operational systems (interior cell walls, water level, beach, liner and cover); 3. Dikes and
embankments (slopes and crest) to check for erosion and seepage; 4. Physical inspection of
the slurry lines, and; 5. Dust control and leak detection, are conducted daily and documented
on a daily inspection form. The forms additionally include fields for observations of
potential concerns and action required. Spills and clean up actions are noted in the text boxes
for these fields. Additionally, EFR inspects tank integrity daily (including fuel tanks) and
reports comments (e.g. odors or leaks) on the "Operating Foreman's Daily Inspection" log.
DWMRC randomly selected and reviewed the Appendix A-ldaily forms and foreman's log
for the month of February 2019 (daily forms) and 2/1/2019 (foreman's log). The forms and
log appeared to be appropriate and inspections were conducted on all days. There are no
additional comments regarding the forms or log.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection
Manual Section 3.1.). The forms include sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, 4B and
Roberts Pond, as well as slimes drain liquid levels in Cell 2, Existing Decontamination Pad
and general tailing area. The form also includes information regarding the leak detection
systems for Cells 1, 2, 3, 4A and 4B as well as the potential blowing of tailings, and
condition of concrete at the decontamination pad.
DWMRC inspected the February 2019 weekly forms (February 8, February 14, February 22
and March 1, 2019). Per the 2019 DWMRC storm water inspection, the inspection forms
reviewed appeared to be completed appropriately. There are no additional comments
regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness:
Findings: Monthly inspection data is documented on Appendix A-3 of the Environmental
Protection Manual, Section 3. DWMRC reviewed the EFR monthly inspection report dated
March 4, 2019. Note that the monthly inspection reports include comments related to the
slurry pipelines that "all pipelines are in good condition with no leaks." There are no
additional comments regarding the forms.
Quarterly Tailings Inspection, Embankments:
Findings: Quarterly inspection data is documented on Appendix A-4 of the Environmental
Protection Manual, Section 3. DWMRC reviewed the EFR quarterly inspection report dated
March 29, 2019. Regarding the embankment inspection it was noted `!few erosion channels
formed on south side at cell 2. Cell 4A, 4B dikes are all in good condition. Utility crew will
fix erosion channels when weather and ground conditions permit." There are no additional
comments regarding the forms.
Tank to soil potential measurements:
Findings: This item was included as part of a September 1, 2011 DWMRC Request for
Information ("RFI"), RFI # 2. DWMRC had concerns regarding on-grade tanks (tanks where
the bottom is in contact with soil). Per DWMRC communication with EFR it was clarified
that tanks which sit on the ground must have cathodic protection or sit on a concrete
foundation.
Per DWMRC inspection of the tank foundations during the 2019 inspection, no issues
regarding the concrete foundations were noted.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Tank and pipeline thickness tests:
Findings: During the inspection period, as noted on the EFR monthly inspection form, the
slurry pipelines were noted to be in good condition by EFR.
Spill Incident Reports:
Findings: This item is discussed above in the section related to reportable and small quantity
spills. DWMRC notes that an effective spill reporting and tracking system has been
implemented at the Mill.
1.11 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files):
Personnel training for spill prevention are discussed in the internal notification of spills
section of this module above. Per DWMRC findings the personnel training has been
implemented and appears to be effective. Mill 5taff attends annual training regarding the
small quantity internal spill notification process.
Section II -- Site Walk-through Inspection
Areas and Observations:
Ore Storage:
Berms and storm water detention tank (kiva) appeared well maintained. Pad appeared to be
graded, but no precipitation at the time of the inspection so potential ponding on the pad was
not inspected. No additional comments regarding the ore storage pad.
Reagent Yard:
Per DWMRC observations no issues were noted regarding reagent storage.
Shop/Vehicle Maintenance Area:
DWMRC notes that areas inside of the vehicle maintenance shop and surrounding area drain
through the pipeline to Cell 1. DWMRC noted that hydraulic fluid and oil drums were stored
on pallets with secondary containment. The secondary containments looked dry and the
pallets appeared to be in good condition.
Mill Processing Areas:
SX Building Roof Drainage:
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
It was noted that the area around the SX building had been stabilized with rock riprap and
that the drainage channel had been improved. No comments during the 2019 inspection.
Alternate Feed Circuit South of the SX Building:
Observations: Per DWMRC observations it appeared that all concrete pad areas and berms
used for storage of alternate feed storage and staging was being maintained. No concerns
regarding concrete integrity or drainage were noted.
Old Decontamination Pad:
Observations: No observations noted during the 2019 inspection.
New Decontamination Pad:
Observations: Pump had been moved to the top of the decontamination pad. Any leaks from
the pump will re-enter the water circuit. This was in response to comments documented
during the 2018 inspection. Onsite EFR staff reported that the new decontamination pad will
be taken out of service during the winter and that all decontamination activities will be at the
old decontamination pad. It was noted that a discharge of wash water had occurred during
the inspection period, onsite staff stated that the water from the overflow was fully contained
in the eastern lined ditch and that no water discharged out of the restricted area. Per
DWMRC inspection findings no evidence of a discharge outside of the restricted area was
noted.
Reagent Tanks:
Sodium Chloride Tanks — Per past agreements between DWMRC and EFR (Agreements
made in 2005) the secondary containment for these tanks is earthen. Per the agreement, all
reagent tanks that pre-existed the Ground Water Permit (3/05) would be acceptable as is —
and that as upgrades or replacements were installed, EFR would work to meet BAT
requirements. More detail regarding this agreement is in the December 2004 Statement of
Basis for the site Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit.
No issues were noted during the 2019 inspection.
Kerosene Tanks (West of Shop) — The kerosene tanks and concrete platforms appeared in
good condition.
Ammonia Tanks — Secondary containment is earthen per the same agreement as the sodium
chloride tanks. Per observations no comments were noted.
Ammonium Sulfate Crystal Tanks — Per the previous 2018 inspection "powder was noted
around the tank storage. The powder needs to be cleaned up per good housekeeping
requirements." Per the 2019 inspection it was noted that the powder had been cleaned up,
and that reasonable efforts to keep the area clean were being implemented.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Used Oil Tank (shop) — The used oil tank and secondary containment appeared in good
condition. A leak/overflow from the tank had occurred and was contained within the
secondary containment. At the time of the inspection the oil had been removed from the
containment and cleaned with absorbents. No additional comments.
Kerosene Tank (shop) — The shop kerosene tank sits in the same secondary containment as
the used oil tank. DWMRC did not note any problems regarding taps and valves on the tank.
No additional comments.
Fuel Tanks — Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks — No comments were noted.
Vanadium Pregnant Liquor (VPL) Tanks — No comments were noted.
Clean Water Tank — No standing water was noted around the tank. The tank appeared in
good condition. No comments were noted.
Sulfuric Acid Tank — The tank, concrete platform appeared in adequate condition. The
berm around the tank was in good condition. No comments noted.
Caustic Soda Tank — Tank and secondary containment appeared to be in adequate
condition. No comments noted.
Soda Ash Tanks — Per the previous 2018 inspection "powder material was noted around the
soda ash tanks, outside of the secondary containment. This material needs to be swept up to
prevent storm water contamination." Per the 2019 inspection it appeared that the powder
material had been cleaned up and that reasonable efforts to keep the area clean were being
implemented.
Tailings Cells Areas (Note that upland drainage was included in comments above) —
DWMRC toured the tailings cell areas (Cells 4A and 4B) and observed the condition of the
outer toe areas of the dikes to ensure that excessive erosion or damage (e.g. burrowing
animal intrusion or rooting damage) was not present. No areas of excess erosion were noted
during the inspection.
Summary of Onsite Closeout Meeting:
Date/Time: October 15, 2019/3:00 P.M.
EFR Representatives Present — Garrin Palmer
Logan Shumway (Plant Manager)
Tanner Holliday
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Terry Slade (Radiation Safety Officer)
DWMRC Representatives Present — Tom Rushing
An onsite close-out meeting took place to discuss findings of the storm water inspection and
follow up regarding the previous year comments. Specifically, the following issues were
presented by DWMRC:
Previous Request for Information Items: DWMRC discussed the following items included in
an October 5, 2018 letter regarding findings of the previous storm water inspection at the
White Mesa Mill:
1. The previous issue regarding the need to repair berms was discussed. All berms were
repaired and in good condition per the 2019 inspection findings.
2. The previous issue regarding the storm water detention tank (kiva) on the south side
of the ore storage pond was discussed. The tank had been cleaned out and onsite EFR
representatives stated that the tank would not be used for other activities besides
storm water management. It was discussed that the main issue regarding maintaining
the detention tank was to avoid potential discharge line clogs of the discharge to the
tailings cells. A clog of the discharge line would likely result in a discharge of storm
water out of the restricted area.
3. The leaking pumps at the decontamination pads were discussed. It was noted that the
pump at the new decontamination pad had been relocated to discharge back into the
system. The old decontamination pad pump sits on an impervious pad. DWMRC
discussed that the relocation of the pump appeared adequate to address the issues.
4. The solid powder noted on the ground around the soda ash tanks and ammonium
sulfate tanks during the previous storm water inspection were discussed. DWMRC
discussed that adequate measures were being undertaken to keep the powder off of
the ground.
Documentation: DWMRC discussed that the documentation review appeared to be fully
filled out and to address the requirements of the permit. No specific issues were identified.
Site Walkthrough: DWMRC discussed that during the site walkthrough no specific
issues/deficiencies were noted. It appeared that previous identified issues had been
addressed.
Conclusions
A close-out will be sent to EFR regarding the 2019 storm water inspection at the White Mesa
Uranium Mill.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
2019 Ground Water Module 65, DWMRC Annual Storm Water Inspection
Appendix 1 — Photo Pages
Pictures Taken October 15, 2019
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 1 — Southwest area of ore storage pad looking south, margin berm in good condition.
7.4
Photo 2 — Southwest ore pad detention basin •-.-"kiva") cleaned out in good condition.
Photo 3 — Southwest ore pad corner berm in good condition.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 4 — South margin of ore pad, berm in good condition.
Photo 5 — Closed pump out sump on the southeast corner of the ore storage pad.
Photo 6 — Lined containment ditch on the south eastern margin of the ore storage pad, below
the new decontamination pad.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 7 — Pump at new location at the new decontamination pad, leakage will return to the
water storage for the pad.
Photo 8 — Eastern margin of the ore storage pad, berm in good condition and maintained.
Photo 9 — Northeastern margin of the ore storage pad, berm in good condition.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 10 — Northern margin of the ore storage pad, looking west, berm in good condition.
Photo 11 — Northern margin of the ore storage pad, looking west, berm in good condition.
Photo 12 — Clean water tank discharge, dry at discharge and around the tank.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 13 — Sulfuric acid tank, berm in good condition.
Photo 14, Sulfuric acid tank berrn, containment and pad in good condition.
Photo 15 — Alternate feed storage area, note drums stored on engineered impermeable pads.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 16 — Berm below CCD circuit and mill building, in good condition.
Photo 17 — Photo looking east towards SX building, note curbed drainage to bermed area in
photo 16 (discharge to Cell 1.
Photo 18 — Caustic soda tank and secondary containment, area has been swept clean.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 19 — Soda ash tank and secondary containment, no issues.
Photo 20 — Soda ash load out, powder has been cleaned from ground and is being swept.
Photo 21 — Ammonium sulfate crystal tank, housekeeping appeared adequate.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 22 — Used oil tank and secondary containment, overflow into containment had recently
occurred.
Photo 23 — Kerosene tank secondary containment.
Photo 24 — Chemical storage on secondary containment pallets.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Photo 25 — Cells 4A/4B Southern dike, in reasonable condition, no excessive erosion rills.
Photo 26 — Cells 4A/4B Southern Dike.
Photo 27 — Upland Diverstion Ditch 1 free of debris and well graded.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
.111•MIMM
Photo 28 — Upland Diversion Ditch 2 in good condition.
Photo 29 — Upland Diversion Ditch 3 in good condition.