DRC-2014-006336 - 0901a068804ac38c

/
GE/i/;-..,
\ Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energ vfuels.com
\
i 2014
ENERGYFUELS \
October 20, 2014
VIA OVERNIGHT DELIVERY DRC-2014-006336
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
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 3rd Quarter of 2014
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell 4A
BAT Performance Standards Monitoring Report for the 3rd Quarter of 2014, as required under Parts
I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
3rd Quarter
July through September
2014
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
October 20, 2014
TABLE OF CONTENTS
1. 0 INTR 0 D U CTI 0 N ......................................................................................................................................... 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED ....................................................... 1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING ..................... _. ............ 2
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING ...................................................... 3
4 .1 GENERAL ................................................................................................................... -.................................. 3
4 .2 RESULTS FOR THE QUARTER ......................................................................................................................... 4
4 .3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION ..................................................................... 4
4.4 GRAPHIC COMPARISON TO PREVIOUS YEAR ................................................................................................ .4
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ............................................ 4
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS OF
FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE AREA ................ .4
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ................................................................ S
8.0 DECONTAMINATION PADS .................................................................................................................... 6
8.1 SUMMARY OF WEEKLY INSPECTIONS ............................................................. > ..... _ ........ -................................ 6
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ....................................................................... 6
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................................................. 7
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT ......................................... 7
9.1 LDS MONITORING ........................................................................................................................................ 7
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ........................................................... 7
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML ................................... 8
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS ................................................................. 8
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND4B ............................................. , ..... 9
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING ..................................................................................... " ... I 0
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING ......................................................................... 10
10.1 OPERATIONAL STATUS OF LDS PUMPING AND MONITORING EQUIPMENT ................................................. 10
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ....................................................... } 0
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1, 2, AND 3 ................................................. 10
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... II
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2014 .. 11
12.0 QUARTERLY PRECIPITATION DATA ................................................................................................ 11
13.0 SIGNATURE AND CERTIFICATION .................................................................................................... 12
1
LIST OF TABLES
Table 1-Summary of Waste Water Pool Elevations (In the Text)
Table 2 -New Decontamination Pad Inspection Portal Level (In the Text)
ATTACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to Part I.G.3 of the GWDP
C Quarterly Cell 2 Slimes Drain Monitoring Data
D Graph of Cell 2 Slimes Drain Water Levels Over Time
E Cell Liner Repair Reports and Notices
F Cell4A and Cell4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables lA and lB, Cell 4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.12)
H Weekly Feedstock Inspection Form-Feedstock Maps
I Quarterly Precipitation Data
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 3rd QUARTER OF 2014
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the third quarter of 2014 (the "quarter") prepared by Energy Fuels
Resources (USA) Inc. ("EFRI"), as required under Part I.F.2 of the White Mesa Mill's (the
"Mill's") State of Utah Groundwater Discharge Permit No. UGW370004 (the "GWDP"), and the
Routine Cell 4A and Cell 4B Best Available Technology ("BAT") Performance Standards
Monitoring Reports for the quarter, as required under Part I.F.3 of the GWDP.
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED
During the quarter, the following DMT monitoring was performed or addressed, as required
under Part I.D.3, I.E.7, and I.F.ll of the GWDP:
• Weekly tailings wastewater pool elevations for tailings Cells 1 and 3 (Part
I.E.7(a));
• Quarterly slimes drain water levels in Cell2 (Pmt I.D.3(b)(1) and (2));
• Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.ll);
• Weekly wastewater level measurements in Roberts Pond (Part I.D.3(e) and Part
I.E.7(c));
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part I.D.3(f) and Parts I.E.7(d); and
(e));
• Any tailings cell and pond liner system repairs (Part I.E.7 (f) and Part I.E.(8)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g)) and
• Annual Decontamination Pad Concrete Inspection (Part I.F.ll) (not required this
reporting period)
Also during the quarter, the following Cell 4A and 4B BAT performance standards monitoring
was performed, or addressed, as applicable and as required by Parts I.E.8 and I.E.12 of the
GWDP:
• Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.8.(a)), and Cell
4B (Part I.E.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.8 (a))
and Cell4B (Part I.E.12 (a)).
Attachments B, E, and G have been left blank because there were no notices, liner repair reports
or decontamination pad inspections this quarter.
1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in the Mill's tailings
cells during this quarter, to ensure compliance with the maximum wastewater elevation criteria
mandated by Parts I.E.7(a), I.E.8(a) and I.E.12(a) of the GWDP. The results of such
monitoring, reported as feet above mean sea level ("fmsl"), are included in Attachment A. Part
I.D.2 of the GWDP provides that under no circumstances shall the freeboard of any tailings cell
be less than three feet, as measured from the top of the flexible membrane liner ("FML"). The
top of the FML in Cell 1 is at 5,618.5 fmsl, and the top of the FML in Cell 4B is 5600.4 fmsl.
This means that the maximum wastewater pool elevations in Cells 1 and 4B permitted under Part
I.D.2 of the GWDP are 5,615.50, and 5597.40 fmsl, respectively.
The maximum wastewater pool elevations in Cells 1 and 4B, as measured during the quarter, are
summarized in the following Table 1. The requirements to meet freeboard elevation limits in
Cell 3 and Cell 4A were eliminated. The solution elevation measurements in Cell 4A are not
required for compliance with freeboard limits but are required for the calculation of the daily
allowable volume of fluids pumped from Cell 4A LDS and are collected for this purpose. The
freeboard limits established by the GWDP and the Mill's State of Utah Radioactive Materials
License No. UT 1900479 (the "License") are slightly different; accordingly, the stricter of the
two limits represents the regulatory standard for each cell. As indicated in Table 1, the applicable
freeboard limits were not exceeded during the Quarter for any cell.
Table 1-Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measured During the Permitted Under Elevation Permitted
Quarter (fmsl) License Condition Under Part I.D.2 of
10.3 (fms1) the GWDP (fmsl)
Ce111 5612.58 5,615.40 5,615.50
Cell3 Not Measured-No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in Q 1 2011
Ce114A 5591.39-freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Q1 2011.
Ce114B 5584.46 5594.60 5597.40
* The Director approved the removal of the Cell 3 freeboard hrmt and authonzed the use of Cell 4B on January 27,
2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
**The Director granted a variance from the Cell4A freeboard limit on January 13, 2011, and approved the removal
of the Cell 4A limit and authorized the use of Cell 4B on January 27, 2011. The previous freeboard limit noted
above for Cell 4A was not set out in the License. The freeboard limit of 5,593.74 for Cell 4A was set out in a letter
from the Director dated November 20, 2008. The approved DMT Plan, Revision 11.1 dated January 2011, included
the removal of the freeboard limit for Cell 4A to be replaced by a freeboard limit for Cell 4B that will accommodate
the freeboard requirements of Cells 1, 4A, and 4B.
2
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b)(l) of the GWDP provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the DMT Plan. Part I.D.3(b)(3) of the GWDP
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Part I.D.6(c) of the GWDP provides that, after the Permittee initiates pumping conditions in the
slimes drain layer in Cell 4A, the Permittee will provide: 1) continuous declining fluid heads in
the slimes drain layer, in a manner equivalent to the requirements found in Part I.D.3(b), and 2) a
maximum head of 1.0 feet in the tailings (as measured from the lowest point of the upper FML)
in 6.4 years or less. Similarly, Part I.D.13(c) of the GWDP provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4B, the Permittee will provide: 1)
continuous declining fluid heads in the slimes drain layer in a manner equivalent to the
requirements found in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as
measured from the lowest point of the upper FML) in 5.5 years or less.
The GWDP, dated July 14, 2011, Part I.D.3 (b)(2) states "effective July 11, 2011, the Permittee
shall conduct a quarterly slimes drain recovery test. .. ". Monthly testing was conducted through
the second quarter of 2011. The frequency change dictated by the GWDP was implemented in
the third quarter 2011. The test ensures that each tailings cell meets the following minimum
requirements: 1) includes a duration of at least 90-hours, as measured from the time that
pumping ceases, and 2) achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements with no change in water level, as measured
to the nearest 0.01 foot.
At this time, dewatering operations have not commenced in Cell 3, Cell 4A, or Cell 4B. As a
result, the requirements in Part I.E.7(b) to monitor and record monthly the depth to wastewater in
the slimes drain access pipes as described in Part I.D.3 of the GWDP apply only to Cell 2 at this
time. Accordingly, this Report is limited to slimes drain recovery head information relating to
Cell2 only.
Pursuant to Parts I.E.7(b) and I.F.2 of the GWDP, Section 8.2 of the DMT Plan and
conespondence from DRC, dated February 7, 2008, the results of quarterly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Peiformance Standards Monitoring Report
and Cell 4A and Cell 4B BAT Performance Standards Monitoring Reports (the "DMT Reports").
Further, beginning in 2008, quarterly DMT Reports must include both the current year values
and a graphic comparison to the previous year. The annual slimes drain recovery head report for
2013, which addresses the requirements of Prut I.F.ll of the GWDP and Section 8.2 of the DMT
Plan, was submitted with the fourth quarter 2013 report.
3
4.2 Results for the Quarter
In accordance with the requirements described above, the quarterly slimes drain recovery head
monitoring data for the quarter, which includes the date and time for the start and end of the
recovery test, the initial water level, and the final depth to stable water level for the quarter, are
included as Atta~hment C to this Report.
4.3 Quality Assurance Evaluation and Data Validation
EFRI management has evaluated all slimes drain data collected, data collection methods, and all
related calculations required by the GWDP, and have verified the accuracy and reliability of both
the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, EFRI has concluded
that the 2009, and 2010 monthly slimes drain tailings fluid elevation measurements, the 2011
monthly (through June) and quarterly (July forward), and the quarterly 2012, 2013, and 2014
slimes drain tailings fluid elevation measurements to date meet the test performance standards
found in Part I.D.3(b)(2) of the GWDP and can be used for purposes of determining compliance
with the requirements of Part I.D.3(b)(2) of the GWDP.
4.4 Graphic Comparison to Previous Year
A graph showing the final depth to stable water level readings for 2009 through the current 2014
period is included as Attachment D.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
When fluid is present, Mill personnel are required to monitor and record weekly the wastewater
levels at Roberts Pond to determine compliance with the DMT operations standards in Part
I.D.3(e) of the GWDP. Part I.D.3(e) of the GWDP provides that the water level in Roberts Pond
shall not exceed an elevation of 5,624 fmsl.
During the quarter, Robert's Pond was dry. As noted in the first quarter 2014 DMT report,
submitted on May 13, 2014, damage in the FML of Roberts Pond was identified during routine
operations, apart from routine inspections. As a result of the FML damage, no fluids have been
added to Roberts Pond since the first quarter of 2014.
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the GWDP and that all alternate feedstock located outside the defined
feedstock area is maintained in compliance with the requirements of Part I.D.11 of the
4
GWDP. The results of these inspections are recorded on the Weekly Mill Inspection forms,
which are available at the Mill for inspection.
In the closeout letter for the first quarter 2013 DMT Report, dated July 23, 2013, DRC wrote
"EFRI noted standing water in one of the feedstock storage areas. Language in the report referred
to the standing water as a "small amount." The DRC requests that in future quarterly reports,
EFRI be more complete in quantifying and describing the location of standing water discovered
in feedstock storage areas." To comply with this request, EFRI has attached the Feedstock
Storage Area Maps ("Feedstock Maps") completed during the weekly Feedstock Storage Area
inspections as Attachment H. The Feedstock Maps include the areal extent (in feet) and depth
(in inches) of any standing water noted during the weekly inspections. During the quarter,
standing water was noted during the weekly inspections of August 15, August 29, September 12
and September 19. Standing water noted was the result of precipitation received during the
reporting period.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, 3, 4A, and 4B were inspected on a daily basis. The results of
those inspections are recorded on the Mill's Daily Inspection Data sheets, which are available at
the Mill for review. A visual inspection of Roberts Pond was performed on a weekly basis. The
results of those inspections are recorded on the Weekly Mill Inspection forms, which are
available at the Mill for review.
Mill operations notified the EFRI Quality Assurance Manager on Thursday, March 13, 2014, of
a tear in the FML of Roberts Pond. The damage in the FML of Roberts Pond was identified,
during routine operations, apart from routine inspections. EFRI provided initial notification to
the DRC by telephone at approximately 2:45pm on Thursday, March 13, 2014, as contemplated
by Parts I.E.7 f) and I.G.3 of the Permit. Additionally, EFRI provided 5-day written notification
to DRC contemplated by Parts I.E.7 f) and I.G.3 of the Permit on March 18, 2014.
An Action Plan was submitted to DRC on May 12, 2014 and DRC approval was received by
letter dated June 16, 2014. EFRI started implementing the Action Plan on July 14, 2014. In
summary, 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. Following the removal of the stained soils, cleanup
procedures will be completed to the levels specified in the Action Plan.
Implementation of the Action Plan has progressed during the third quarter. Confirmation
sampling as specified in the Action Plan was completed during the third quarter. A separate
report detailing the cleanup activities and the associated confirmation data will be submitted to
DRC under separate cover.
5
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Inspections
Part I.F.7 (g) of the GWDP and Section 3.1 of the DMT Plan require that a weekly inspection of
the New Decontamination Pad be performed, and that the vertical inspection portals on the New
Decontamination Pad, which are located between the primary and secondary containments, be
visually observed on a weekly basis as a means of detecting any leakage from the primary
containment into the void between the primary and secondary containments. The BAT
performance standards for the New Decontamination Pad are set out in Part I.D.14 of the
GWDP. Table 2 below indicates the water level measurements in each portal measured during
the quarter.
Table 2 -New Decontamination Pad Inspection Portal Level for the Quarter
Portal 1 Portal 2 Portal3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
7/3114 0.00 0.00 0.00
7111/14 0.00 0.00 0.00
7118114 0.00 0.00 0.00
7/25/14 0.00 0.00 0.00
8/1114 0.00 0.00 0.00
8/8114 0.00 0.00 0.00
8115/14 0.00 0.00 0.00
8/22/14 0.00 0.00 0.00
8/29/14 0.00 0.00 0.00
9/5114 0.00 0.00 0.00
9/12/14 0.00 0.00 0.00
9119114 0.00 0.00 0.00
9/25114 0.00 0.00 0.00
As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the quarter.
Any soil and debris identified during the weekly inspections was removed from the wash pad of
the New Decontamination Pad, in accordance with part I.D.14 (a) of the GWDP and Section 3.1
(e)(i)(F) of the DMT Plan. No cracks greater than 118" were observed during any ·weekly
inspections.
8.2 Annual Inspection of Existing Decontamination Pad
As required by Part I.F.12 of the Permit, annual inspections of the existing decontamination pad
must be conducted during the second quarter of each year. The documentation for the 2014
annual inspections was reported in the Second Quarter DMT report submitted July 22, 2014. The
2015 annual inspection will be conducted during the second quarter of 2015.
6
8.3 Annual Inspection of New Decontamination Pad
Annual inspections of the new decontamination pad are conducted during the second quarter of
each year. The documentation for the annual inspections was reported in the Second Quarter
DMT report submitted July 22, 2014. The 2015 annual inspection will be conducted during the
second quarter of 2015.
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report for the quarter, as required under Part I.F.3 of the GWDP.
9.1 LDS Monitoring
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for both of Cell 4A and Cell 4B, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment,
operated continuously during the quarter except as noted below.
Cell 4A
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.8(a)(l) of the GWDP.
During the quarter there was one failure of the Cell 4A monitoring equipment which was made
operational within 24-hours of discovery, as required by Part I.E.8(a)(l) for Cell4A. On August
25, 2014 Mill Personnel noted that the transducer was not recording fluid head measurements.
Based on the daily fluid level measurements recorded by the Mill Personnel manually, no gallons
of fluid were pumped and no data were lost. The equipment was reset within several hours of
noticing the malfunction, and full function was restored. No notifications to DRC were required
as the issue was rectified within 24-hours as required by Part I.E.8(a)(l) for Cell4A.
It is important to note that these periodic malfunctions of the equipment are due to the super-
saturated nature of the fluids in the LDS system, which crystallize on the electronic components
and cause the components to malfunction and/or fail prematurely. EFRI inspects the equipment
daily to preclude data loss and maintains spare parts to replace the components on an as needed
basis.
Cell 48
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.l2(a)(l) of the GWDP.
7
During the quarter there was one failure of the Cell 4B monitoring equipment which was made
operational within 24-hours of discovery, as required by Part I.E.12(a)(l) for Cell 4B. On
September 17, 2014 Mill Personnel noted that the flow meter was malfunctioning. Based on the
daily fluid level measurements recorded by the Mill Personnel manually as well as the
computerized level recordings downloaded from the electronic data measurement system no
gallons of fluid were pumped and no data were lost. The flow meter was replaced within several
hours of noticing the malfunction, and full function was restored. On September 18, 2014 during
the daily check Mill Personnel noted that the new flow meter had recorded that 49,453 gallons of
fluid was pumped since the previous daily check. The electronic flow/pump data were
downloaded and reviewed. Review of the pump data showed that the electronic system recorded
that the entire 49,453 gallons were supposedly pumped in a 30 minute period. The flow meter
was recording a pump rate of 120 gallons per minute ("gpm"). Mill Personnel manually checked
the flow rate of the pump using a 5-gallon bucket and a stop watch. The measured flow rate was
approximately 34 -37 gpm. Review of the flow and pump data indicated that the electronic
system was malfunctioning and the data outputs were incorrect for both the flow rate and
volumes. Mill Maintenance Personnel disassembled the system, cleaned all of the components
and electronic connections, reinstalled the system and tested the functionality. The repairs
restored the system to full functionality and the flow rate was measured as 34 gpm. The total
gallons pumped, reported in Attachment F and below, was adjusted based on the corrected
pumping rate of 34 gpm. No official notifications to DRC were required as the issue was
rectified within 24-hours as required by Part I.E.12(a)(l) for Cell 4B. DRC was notified by
telephone that the issue was resolved within the 24-hour window and no further actions were
necessary.
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML
The measurements of the fluid head above the lowest point in the secondary FML for Cells 4A
and 4B are provided in Attachment F.
As can be seen from a review of Attachment F, at no point in the quarter did the fluid head in the
Cell 4A LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring, this 1-foot distance equates to 2.28 feet
[27 .36 inches] above the LDS system transducer), as stipulated by Part I.E.8(a)(2) of the GWDP.
During the quarter, the fluid head in the Cell4A LDS sump did not exceed 13.2 inches above the
LDS transducer.
As can be seen from a review of Attachment F, at no point in the quarter did the fluid head in the
Cell 4B LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor, as stipulated by Part I.E.12(a)(2) of the GWDP. For the purposes of compliance
monitoring, this 1-foot distance equates to 2.25 feet (27 inches) above the LDS system. During
the quarter, the fluid head in the Cell4B LDS sump did not exceed 14.75 inches above the LDS
transducer.
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS
The measurements of the volume of fluids pumped are provided in Attachment F.
8
Cell4A
As can be seen from a review of Attachment F, 11,332 gallons of fluid were pumped from the
Cell 4A LDS for the quarter. Accordingly, the average daily LDS flow volume in Cell 4A did
not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the GWDP.
The daily allowable volume of fluids pumped from the Cell 4A LDS have also been calculated
based on weekly tailings cell fluid measurements using the calculations provided in the Cell 4A
BAT Operations and Maintenance Plan. A letter from the Director dated January 27, 2011 that
approved the use of Cell4B, and a subsequent letter dated March 15, 2011, stated approval of the
DMT and Cell 4A O&M Plans, which effectively eliminated the former freeboard elevation
requirements for tailings Cell4A. Pursuant to the receipt of the March 15, 2011 letter, freeboard
limits in Cell 4A were no longer required. However, the weekly wastewater elevations are
documented in order to calculate the maximum daily allowable flow volume, in accordance with
the Cell 4A BAT Operations and Maintenance Plan. Based on the wastewater pool elevation
surveys conducted during the quarter, and the maximum head recorded on the FML during the
quarter of 35.84 feet, the allowable flow rate would be approximately 587.5 gallons/acre/day
(23,500 gallons/day for the cell), as determined by Table 1A of the Mill's Cell 4A and 4B BAT
Operations and Maintenance Plan, and assuming a liner elevation of 5555.55 feet and
approximately 40 acres of liquid area. The average daily flow volume in Cell4A did not exceed
the calculated flow volume of 23,500 gallons/day. As mentioned above, a total of 11,332 gallons
of fluid were pumped from the Cell 4A LDS during the quarter and did not exceed the calculated
maximum allowable daily flow volume. The allowable flow rate calculation for the quarter for
Cell 4A along with Table 1A is included in Attachment F of this report.
Cell4B
As can be seen from a review of Attachment F, 23,066 gallons of fluid were pumped from the
Cell 4B LDS for the quarter. Accordingly, the average daily LDS flow volume in Cell 4B did
not exceed the 26,145 gallons/day limit, as stipulated by Part I.E.12(a)(3) of the GWDP.
Based on the wastewater pool elevation surveys conducted during the quarter, the maximum
head recorded on the FML during the quarter was 26.96 feet. The allowable flow rate would
therefore be approximately 528.4 gallons/acre/day (19,958 gallons/day for the cell), as
determined by Table 1B of the Mill's Cell 4A and 4B BAT Operations and Maintenance Plan,
and assuming a liner elevation of 5557.5 feet and approximately 37.77 acres of liquid area. The
average daily flow volume in Cell 4B did not exceed the calculated flow volume of 19,958
gallons/day. The allowable flow rate calculation for the quarter for Cell 4B is included along
with Table 1B in Attachment F of this report.
9.2 Measurement of Weekly Wastewater Fluids in Cells 4A and 4B
Weekly fluid elevations for Cells 4A and 4B for the quarter are provided in Attachment A along
with elevations for Cell 1 and Roberts Pond.
9
9.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping of the Cell4A or Cell4B slimes drain systems at this time,
monthly recovery head tests and fluid level measurements are not required at this time pursuant
to Part I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING
The requirement in Section 3.1(a) of the DMT Plan to monitor the LDS for Cells 1, 2, and 3 is a
requirement of the License, and not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP. However, DRC has requested that the LDS monitoring for Cells 1,
2, and 3 be included on the DMT inspection forms and that the results of the monitoring be
reported in the quarterly DMT reports. The Cells 1, 2, and 3 LDS monitoring data are included
in Attachment F.
10.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 1, Cell 2, and Cell 3, including,
but not limited to, the submersible pump, pump controller, head monitoring, and flow meter
equipment, operated continuously during the quarter except as noted below.
For Cell 1, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 2, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 3, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
10.2 Measurement of the Volume of Fluids Pumped from the LDS
No fluids were pumped from the Cells 1, 2 or 3 LDSs during the quarter because no fluids were
detected in the Cells 1, 2 or Cell 3 LDSs.
10.3 Measurement of Weekly Wastewater Fluids in Cells 1, 2, and 3
A summary of the fluid elevations for the Cells 1, 2 and 3 LDSs for the quarter are provided in
Attachment F. The LDS for Cells 1, 2, and 3 were dry during the quarter.
10
10.4 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping in the Cell 1 or Cell 3 slimes drain system at this time,
monthly recovery head tests and fluid level measurements are not required at this time.
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2014
The annual slimes drain recovery head report for Cell 2 for calendar year 2014 (the "Period"), as
required under Parts I.D.3 (b) and I.F.11 of the GWDP and Section 8.2 of the DMT Plan will be
included with the fourth quarter 2014 DMT report which will be submitted on or before March 1,
2015.
12.0 Quarterly Precipitation Data
Pursuant to a verbal request from DRC personnel, EFRI is providing the quarterly precipitation
data in the quarterly DMT reports. The data are collected at the Mill, by the EFRI Field Staff,
using an on-site rain gauge. The data are included as Attachment I to this report.
11
13.0 SIGNATURE AND CERTIFICATION
This document was prepared by Energy Fuels Resources (USA) Inc. on October 20, 2014.
Energy Fuels Resources (USA) Inc.
By:
~~~--
Scott A. Bakken
Director, Permitting and Environmental Affairs
12
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Scott A. Bakken
Director, Permitting and Environmental Affairs
Energy Fuels Resources (USA) Inc.
13
Attachment A
Date Celll Cell3 1 Cell4A 2 Cell4B 3 Roberts Pond
Freeboard 5615.40-RML 5593.74-RML 5594.60 -RML
Limit 5615.50-GWDP 5595.50-GWDP 5597.40 -GWDP 5624.00 -GWDP
7/3/2014 5611.79 No Longer Required 5591.39 5584.46 DRY
7/11/2014 5611.98 No Longer Required 5591.02 5584.27 DRY
7118/2014 5611.95 No Longer Required 5590.83 5584.09 DRY
7/25/2014 5612.07 No Longer Required 5590.47 5584.03 DRY
811/2014 5612.05 No Longer Required 5590.24 5583.87 DRY
8/8/2014 5612.00 No Longer Required 5590.24 5583.82 DRY
8/15/2014 5612.29 No Longer Required 5590.16 5583.81 DRY
8/22/2014 5612.44 No Longer Required 5589.88 5583.60 DRY
8/29/2014 5612.52 No Longer Required 5589.79 5583.56 DRY
9/5/2014 5612.50 No Longer Required 5589.83 5583.41 DRY
9/12/2014 5612.58 No Longer Required 5590.34 5583.90 DRY
9/19/2014 5612.49 No Longer Required 5589.90 5583.34 DRY
9/25/2014 5612.40 No Longer Required 5589.87 5583.29 DRY
1Cell 3 is nearly full of solids, and is undergoing pre-closure steps. The freeboard limit is no longer required and the weekly measurements are no
longer required per the January 27 and March 14, 2011letters from DRC.
2 The previous freeboard limit of 5,593.74 for Cell4A is set out in a letter from the Director dated November 20, 2008. EFRI proposed in the DMT
Plan revision dated November 12, 2010 the removal of the freeboard limit for Cell4A to be replaced by a freeboard limit for new Cell4B that will
accommodate the freeboard requirements of Cells 2, 3, 4A, and 4B. The Director granted a variance from the Cell4A freeboard limit on January 13,
2011 and approved the removal of the Cell 4A limit and the use of Cell 4B on January 27, 2011. The weekly measurements are no longer required for
compliance with freeboard limts, but are required for the calculation of the daily allowable volume of fluids pumped from the Cell 4A LDS.
3 The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A pool surface area of 40 acres is used
because there are no beaches present in Cell4B at this time.
Attachment B
This attachment has been deliberately left blank.
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 9/23/14 -9/29/14
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
9/23/14 9/24/14 9/25/14 9/26/14 9/27/14 9/28/14 9/29/14
600 33.98 25.50
700 33.64 27.50 25.46 24.47 22.62
800 32.96 27.40 25.43 24.44 22.61
900 32.27 27.29 25.40 24.40 23.01 22.60
1000 31.84 27.18 25.35 24.36 22.58
1100 31.38 27.08 25.27 24.33 22.56
1200 31.01 26.96 25.23 24.29 22.54
1300 30.72 26.85 25.19 24.23 22.52
1400 30.40 26.73 25.15 24.18 22.50
1500 30.23 26.62 25.10 24.12 23.36 22.50
1600 29.91 26.52 25.04 24.09 22.50
Comment Final reading was 22.50.
Attachment D
Feet Below Top of Standpipe
N N N ...... ...... ...... ~ N 0 00 0'1 ~
0 0 0 0 0 0 0 0 0 0 0 0
,_ 1/30/2009
3/30/2009
5/30/2009
. 7/30/2009
9/30/2009
11/30/2009
1/31/2010 n
t1) -3/31/2010 --.• 5/31/2010
N
~ 7/31/2010 --· 9/30/2010
3 II' Ill .....
t1) 15' "' (/) N
11/30/2010
1/31/2011
c
""'
. 3/31/2011
Q) -. 5/31/2011
~ 7/31/2011
I
N -9/30/2011
0 0 c: U) ::J .. Ill Ql
. 11/30/2011
1/31/2012
N .....
Vi 0 Ill
~ ..... 15' 0 "' N .. ~
3/31/2012
5/31/2012
7/31/2012
N
0
~
9/30/2012
11/30/2012
~ .. 1/31/2013
N 0 3/31/2013
~ N 5/31/2013 .. 7/31/2013
N
0 9/30/2013
~ w -11/30/2013
RO 1/31/2014
N 3/31/2014
0
~ . 5/31/2014
~ 7/31/2014
Attachment E
Th is attachment has been deliberately left blank.
Attachment F
July 2014
Date
7/3/2014
711112014
7118/2014
7/25/2014
Cell 4A LDS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
10.3
12.0
9.6
10.7
Flow Meter in Gallons
344994
344994
348238
348238
Highest level for the month based on the daily data was 13.0 inches and the lowest level for the
month was 6.6 inches. Total number of gallons pumped was 3,244.
August 2014
Weekly measurements in
inches from transducer at
the bottom of the LDS
Date sump. Flow Meter in Gallons
8/112014 7.0 348238
8/8/2014 9.9 348250
8/15/2014 11.3 348250
8/22/2014 11.1 349691
8/29/2014 7.0 352940
Highest level for the month based on the daily data was 13.2 inches and the lowest level for the
month was 5.4 inches. Total number of gallons pumped was 4,702.
September 2014
Weekly measurements in
inches from transducer at
the bottom of the LDS
Date sump. Flow Meter in Gallons
9/5/2014 10.2 352940
9/12/2014 11.9 352940
9/19/2014 7.6 356326
9/25/2014 10.1 356326
Highest level for the month based on the daily data was 12.9 inches and the lowest level for the
month was 4.9 inches. Total number of gallons pumped was 3,386.
For the 3rd Quarter 2014, the highest level was 13.2 inches and the lowest level was 4.9 inches and
11,332 gallons were pumped.
July 2014
Date
7/3/2014
7111/2014
7/18/2014
7/25/2014
Cell 4B LDS Monitoring Information
Weekly measurements in inches
from transducer at the bottom
of the LDS sump.
4.73
4.72
5.55
5.55
Flow Meter in Gallons
4066
4066
4066
4066
Highest level for the month based on the daily data was 5.55 inches and the lowest level for the
month was 4.72 inches. No gallons were pumped.
August 2014
Weekly measurements in inches
from transducer at the bottom
Date of the LDS sump. Flow Meter in Gallons
8/1/2014 5.55 4066
8/8/2014 5.55 4066
8/15/2014 7.22 4066
8/22/2014 5.55 13123
8/29/2014 7.22 13123
Highest level for the month based on the daily data was 8.09 inches and the lowest level for the
month was 5.30 inches and 9,057 gallons were pumped.
September 2014
Date
9/5/2014
9/12/2014
9/19/2014
9/25/2014
Weekly measurements in inches
from transducer at the bottom
of the LDS sump.
10.56
13.92
8.08
11.40
Flow Meter in Gallons
13123
13123
'6251764!,t
62576
*On Septemb~r I 2014 the ~le · t:ronie!c~nweo, nts (!.nQ W flow meter malfu.nctioned and
ecord~ un-incorreet pump rate of 110.gallan per minute(~m ·and an incerrecL t tal lume
pumped. The e' malfi.IOG!Jons' re ~red in m_€} e-J~-9t1;e)liC t9talizer -:; rem erron:eou ly-re:cording
4~ 4'53 g-allon gumped in a . '(:) minute period on eptembev 18, 201 ~ Repair ef electtonic
·onnectic::m corrooted rhe: i •l(e .and res~-,.the pump lo tl:l.~eorteetrat ·ef -~ gpu.1. l'h .total gallan,
ptllt}J>"e:d r~pQ.r ,l't b:elQ , wa ;adju· ted bru~ed en the t!;,9Ia:ect&J pumping J1nte ofi :.a-4 g~rn.
tHighest level for the month based on the daily data was 14.75 inches and the lowest level for the
month was 8.08 inches and 14,009 gallons were pumped.
For the 3rd Quarter 2014, the highest level was 14.75 inches and the lowest level was 4.72 inches
and 23,066 gallons were pumped.
Geoqnttc CDnsultJJnts Table 1A
Calculated Action Le1kqe Rates for VlrlouJ Head Conditions
Ceii4A, White Mesa MJII
Blandfns, Utah
Head Above Uner CitlcUIIt8d Aclfan Lukap Rate
System (feet) (plans/acnt/dly)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
Geosyntec Consulttlnts Table 18
calculated AttJon Leakage Rates for Various Head Conditions
Ceii4B, Wblte Mua Mill
Blandtns, Utah
Head Above Uner System C:.lcullted Action Leakap Rate
(feet) (pllans/acre/dayJ
5 211.4
10 317~0
15 369.9
20 422.7
25 475.6
30 528.4
35 570.0
37 581.2
Max head on Ceii4A FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table lA (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4A-Q3 2014
5591.39
5555.55
35.84
587.5
40
23,500
Max head on Ceii4B FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1B (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B-Q3 2014
5584.46
5557.50
26.96
528.4
37.77
19,958
Calculation of Maximum Daily Allowable LDS Flow Volume for Varying Head Conditions in
Cells 4A and 4B
The equation for the calculation of maximum daily allowable flow volume in Cells 4A and 4B is
as follows:
Step 1)
Where:
Step 2)
Step 3)
Step 4)
Elevation !-Elevation 2 =Head (ft.)
Elevation 1 is the maximum elevation in feet measured during the reporting
period.
Elevation 2 is the FML elevation in feet.
Determine Calculated Action Leakage Rate from Table 1A (for Cell 4A) or Table
lB (for Cell4B) using the head calculated in Step 1 above. If the head calculated
in step 1 above falls between two values in the Head Above Liner System (feet)
column, then the closer of these two values will be used to determine the
Calculated Action Leakage Rate.
Calculate the acres of tailings cell fluids based on the area of the base of the cell,
the head, and the angle of the sideslopes of the cell.
Action Leakage Rate (from Table 1A or lB) X Acres of Tailings Cell Fluids=
Maximum Daily Allowable Flow Volume
Celll, Cell 2, and Cell 3 LOS Monitoring Information-Third Quarter 2014
Celll Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches '
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the lDS sump.
7/3/2014 Dry 7/3/2014 Dry 7/3/2014 Dry
7/11/2014 Dry 7/11/2014 Dry 7/11/2014 Dry I
7/18/2014 Dry 7/18/2014 Dry 7/18/2014 Dry .
7/25/2014 Dry 7/25/2014 Dry 7/25/2014 Dry
Celll Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the I
bottom of the LDS sump. bottom of the LDS sump. bottom of the LDS sump.
8/1/2014 Dry 8/1/2014 Dry 8/1/2014 Dry
8/8/2014 Dry 8/8/2014 Dry 8/8/2014 Dry
8/15/2014 Dry 8/15/2014 Dry 8/15/2014 Dry
8/22/2014 Dry 8/22/2014 Dry 8/22/2014 Dry
8/29/2014 Dry 8/29/2014 Dry 8/29/2014 Dry
Celll Cell2 Cell3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the LDS sump.
9/5/2014 Dry 9/5/2014 Dry 9/5/2014 Dry
9/12/2014 Dry 9/12/2014 Dry 9/12/2014 Dry
9/19/2014 Dry 9/19/2014 Dry 9/19/2014 Dry
9/25/2014 Dry 9/25/2014 Dry 9/25/2014 Dry
----
Attachment G
This attachment has been deliberately left blank.
Attachment H
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
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Attachment I
(
(
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014 Month July
Rain Snow Rain Snow
17
18
19
20
21
• /'1 22
23
24
25
.. i3 26
27
28
29
.. ld 30
31
Combined
Total: ,37
(
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014 Month August
Rain Snow Rain Snow
1 17 .f!.bl
• i3 2 18
3 19
4 20 ..
5 21 go i-::,
6 22
7 23
8 24
9 25
10 26 .Sl
11 27
12 28
13 29 I. qJ
14 30
15 31
16
Combined
Total: 3 .oq
(
1
2
3
4
5
6
7
8
9
10
1 1
12
13
14
15
16
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014
Rain Snow
• I\
. l)E.
L@ -\ ()-.
Combined
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Month September
Rain Snow
.rl
,,g
Total: 2.. .12