DRC-2013-005842 - 0901a06880a3d918

SWBMPP Training - General Employee Training
Outline
o Potential Chemical Spill Sources
o Potential Petroleum Spill Sources
. Spill Discovery and Remedial Action
o Spill Incident Notification' *'i,il:ixl:
lx i: *l*',;l:m'. Discuss the timeliness of receiving the cards
o Extemal - Who is responsible for reporting
Training will be conducted during the 2nd Quarter Radiation Refresher training session
Traimimg Attendanee Reeord
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FullName Social Securitv No.Job Classification-I-a,vrvr- ELr^.t )tA tt+{ tih^5r..-*rvLr..r..l lvte .". * r rr S.Jt 1 61 4Elh Lornthua tllll'*n7;lf Y,'71<,\l\*Cot/l4ll-.f,Z.),"//t t ,tJl /E-a.- I --Wcd-1 t-r0e c W.9t,bv .{Ja*-a.,a-1!/I ^. I .1,,- jff ,raes {e^ fD. .r^ -6srz 4f.frrllr V)*rct*,)*.L,4-vTr.if orr-ttl a bLr,.,r.dL.\H.i /f,rYi1;rra,1'fartv 6[adc-&ur.[.]v ranr:Fpl(L.f'rftElt .f,A -*im-S.a lu-€- b\n-r R<-r drAt'arnr.trr -Cl r'.no.r^lt1.i^ Otvc*, Et*t-C ulldnir JoE l -.J-\r*.FF-iWV (/Am A-t. u*zLlryrrrt^-.n GEt I-al.l.a'ilMf - )ldmnhz*( -Ll.JTho I AAf,crr Aflir.rr tfir- griaiF
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Outline Somments
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Outline 3omments
1i<- ,. il.zrL- I
Stom lilater Best Mrnagement Prrcticrs Plm {$SWBMPP'} Training -
Environmentel $trlf Tmining
0utline
. Line of Authority
r Potential Chemicol Spill $ourcesr Potential Petroleum Spill Soureesr Contaiument Areas. Spill Discovery and Remedial Actionr Spill IncidentNatificatiou
o Iniernal - $pill Cardsr Dircuss how to fill out the cardsr Disews who is t0 get the cards. Discuss the timeliness of receiving the cardso Extemal - rffho is responsible for reportirgr Records and Reports '
r Prcteetion ofgroundwater qualityr Prevent, conhol and containment of spillsr R*mediation of spills of reagents and chemicalsr Rsporting dritsria
Schedule
SWBMPP Environmental $taffTraining will be conducted in January of cach year.
SWBMPP Ceneral Employee Training will be conducted during th€ 2nd Quarter Radiarion
Refresher training s&ssior, except in 2012, when it will be couduct€d during the third quartcr.
t-/
O
eekly Mill Inspectio
To
From :
Energy Fuels Supervisors
Ronnie Nieves
Date : Apri|3,2013
For the week of: 03/3lll3 - 04106113
The following areas of the White Mesa Mill were inspected. A description of the potential safety hazards,
housekeeping, operational and radiological conditions are described. The color code breakdown is for those
departments I feel are responsible, but not limited to for repair of said items:
Red - Maintenance Green - Safety Blue - Operations/Utility Crew
lf an item is underlined, that item must be corected immediately.
Leach Tank Area: Continue clean of ore sands in between tanks and walkway.
Ore Storage: Tyrone, that flat bed with all the alamine tots need their labels removed.
CCD Area: Again, continue clean up on that north side impound. All the sands and diluted acid water.
Administration Building: No Problems Identifi ed.
Reagent Tanks: On the back side of the soda ash area needs washed and cleaned up.
Labor Change Room: No Problems Identified.
SX: Make sure that any hoses not being used gets put up and out of the way to eliminate any potential tripping
hazards.
Vanadium: The ground level floors need to be washed, as well as outside on the asphalt. Also in between the
VPL storage tanks outside there is a lot of liquor on the dirt. This needs to be cleaned up as soon as possible.
Yelloweake: The Re-pulp area needs washed down, especially the lines and pumps. All that yellowcake needs
to be removed.
Maintenance: No Problems Identified.
Warehouse: No Problems Identified.
Alternate Feed: No Problems Identified.
Sag MilI: The north side of the sag mill needs cleaned up. The still balls and rocks need to be rcmoved from
the walkways. Please keep on top of this to prevent any trippinghazards.
Miscellaneous:
Tails: Tyrone, there are two blue drums out at the bone yard that need removed. They are filled with trash and
black material.
RSO il{ill Superintendent/ Fo""-", k
David Turk
From: N. Tanner HollidaySent Tuesday, April09,2013 3:30 PMTo: David Turk
Subject: vpl spill
On a/9/2O13 Garrin Palmer was performing the annual inspection on the old Decon pad when he noticed a spill from the
vpltanks. The compound caught a lot of the material but not all of it. lt went around the tanks and saturated the soil.
According to Tyrone Blackhorse this spill happened 1 week ago. He reported it to Ronnie Nieves and Ronnie reported it
to Scott Christensen, No information was ever passed on to Garrin and l. Tyrone was never told to clean up the Tanks
but he took it in his own hands to have his crew clean it up. Tyrone's crew is cleaning up around the vpl tanks cleaning
up all the saturated dirt. We do know the Spill came from a leaking pump and now is reported as 400 gallons.
irelh, Energy FuetsFesources(usA,,,nc.
N. Tanner Holliday
{nviranm*nlat T*ch
t: 435-678-2221 | I: 435-67 8-2224
6425S. Highway 191 PO Box 809
Blanding, UT, US, 84511
http :/lwww.enerqvfu els.com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and any atbched files with it are confidential and may
contain privileged or proprietary information. lf you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute
print or copy this message if you are not the intended recipient(s).
David Turk
From:
Sent:
To:
David,
Garrin Palmer
Tuesday, April 09, 2013 3:29 PM
David Turk
Today I was performing the annual inspection on the old decon pad with Tyrone Blackhorse. During my inspection of the
Kiva I notice a spillaround the VPLtanks. Tyrone told me that it had been there for a while and that Ronnie had notified
Scot a couple of days ago. I took some pictures of the spill and asked for a cleanup. Tyrone's crew came over
immediately with equipment and started the clean up. I had Tanner add the spill to his daily mill inspection for today.
The issue was then reported further. I asked Ronnie when he found the spill and reported it to Scot. The spill was found
by Ronnie on April 3'd and reported during his mill inspection print out. Clean up is still in progress but it is unknown the
amount of solution spilled.
Garrin Palmer
i.:.' i i,r' t r,.; r i ii ! t: t t L t ! !',,: r; I r r; i i: t,.t i i
6425S. Highway 191 PO Box 809
Blanding, UT, US, 845'l"l
http:/ /vww.enerqvfu els.com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and any attached files with it are confidential and may
contain privileged or proprietary information. lf you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute
print or copy this message if you are not the intendd recipient(s).
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White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
7/12 Revision: Denison 2.1
Page 26 of 37
APPENDIX A.3
MONTHLY INSPECTION DATA
Inspector: Gnr,,, P" l,r..e r
oatez sl?ilt3
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Diversion Ditch 1
yes L/ no
-]eS
..2 nO
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Diversion Ditch 2
VeS .-/ nO
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Diversion Ditch 3
VeS . t flO
ves ^-/ no
-yes
.-/ no
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Diversion Berrn 2
4. Overspray Dust Minimization:
E:Mill SOP Master Copy\Book I l_Environmental Procedues\07 License Renewal\Tailings Management System Rev 2 I June 2012.doc
White Mesa Mill - Standar.d Operating procedures
Book I 1: Environmental Protection Manual, Section 3.1
Overspray systeil -----yeS___-no
Overspray carried more than 50 feet from the ceill
If "yes", was system immediately shut off?
--yes-.-noComments:
7/12 Revision: Denison 2.1
Page27 of37
Cell2W5-N:
Cell2 W6N:
Cell2 W4N:
Cell2 W5C:
Cell 2 W5S:
Cell3-3N:Cell3-3S:
Cell3-4N:
Cell3-7C:
Cell3-BC:
Cell3-3C;
Cell3-6N:
Cell3-7N:
Cell3-8N:
Cell2El-2S:
Cell2 East:
Cell2 W7S:
Cell2 W6S:
Cell2 W4S:
Cell3-2S:
Cell3-7S:
Cell3-8S:
7' Movement Monitors: (Is there visible damage to any movement monitor or to adjacentsurfaces)?
8. Summary of Daily, Weekly and euarterly Inspections! Faur ,r....t i.r.-tl_r .Jr-rL i,$+&llc-r..
a,a, Jr-lc- te Jta.oo+ L Zlu,r**tt*s oS €-o,r vt +l a"*^ "A^^'S c*APPENDIX A.4
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6. Settlement Monitors
Cell2 W1: Cell2W3-S:
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E:\N{ill soP Master copy\Book I I Environmental Procedures\07 Liceuse Renewal\Tailirigs Management system Rev 2 I June z;lz.doc
Location Trans. Shot Base Applied Elevation
Cell44 3.87 5574.5 5576.99 Garrin Palmer, Tanner
lntitial 6.3€5580.86
: 312712013
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czw2 0.48 5612.27 5620.82
C2W3 3.71 5612.27 s617.5S
c2w4 1.07 5612.27 5620.23
2W5-C 3.29 5612.27 5618.01
2W4-N 2.32 5612.27 5618.9€
2W4-S 2.95 5612.27 5618.35
2W5-N 2.80 5612.27 s618.5C
2W3.S 2.10 5612.27 5619.2C
2W-5S 5.51 5612.27 5615.7S
lnitial 9.03 5621.30
5623.14 5623.82
[: 1 -il,l .:..1 5623.14 5627.3t
rl 5623.14 5622.84
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,:1ii )'.i ri.4 5623.14 5622.18
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3-1N 1.20 5613.04 5616.62
3-1C 5.04 5613.04 5612.7E
3-1S 2.70 5613.04 561 5.1 2
3-2N 4.80 5613.04 5613.02
3-2C 4.28 5613.04 5613.54
3-2S 5.71 5613.04 5612.11
lnitial 4.7t 5617.82
c3-3S 5.9€5613.04 561 1.84
c3-3C 6.87 5612.27 5610.95
C3-3N 6.88 5612.27 5610.93
c3-4N 7.23.5612.27 5610.58
lnitial 4.9t 5612.655
c3-6N 2.42 5607.675 5610.24
C3-7S 2.O3 5607.675 5610.63
c3-7C 2.67 5607.675 5609.9e
C3-7N 1.96 5607.675 5610.7C
C3-8S 1.29 5607.675 5611.37
c3-8C 1.58 5607.675 5611.08
C3-BN 1.24 5607.675 5611.42
Location Trans. Shot Base Applied Elevation
Cell 4A \ f41 5574.5 5574.50 Name: Garrin Palmer, Tanner Hol
lntitial 6.3L 5574.5
Date: 312712013
c2w1 2 3-7 5612.27 56 2.27
c2w2 o;+g 5612.27 56 2.27
C2W3 '3.7r 5612.27 56 2.27
c2w4 1,07 5612.27 56 2.27
2W5.C 3Zq 5612.27 56 2.27
2W4.N 2,3t 5612.27 56 2.27
2W4-S 2.q5 5612.27 56 2.27
2W5.N z.8a 5612.27 56 2.27
2W3-S ?.lb 5612.27 56 2.27
2W-5S 5.51 5612.27 56 2.27
lnitial cl.o"'5612.27
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I. ?4,5623.14 5623.14
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lnitial ItJft 5613.04
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3-1C 5.0q 5613.04 5613.04
3-1S z:76 5613.04 5613.04
3-2N 1.80 5613.04 5613.04
3-2C q Z,(5613.04 5613.04
3-2S 5,7 t 56'13.04 5613.04
lnitial 5613.04
C3-3S 5.qg 5613.04 5613.04
c3-3C a.8',5612.27 5613.04
C3-3N 6,8q 5612.27 5613.04
C3.4N 1.23 5612.27 5613.04
lnitial 5 5607.675
c3-6N ".'{z 5607.675 5607.68
C3-7S .z,Oj 5607.675 5607.68
c3-7C z.L7 5607.675 5607.68
C3-7N i,qL 5607.675 5607.68
C3.8S lLq 5607.675 5607.68
c3-8C r.5,5607.675 5607.68
C3-8N i.z"t 5607.675 5607.68
White Mesa Mill - Standard O|}ur,n, Procedures
Book I 1: Environmental Protection Manual. Section 3.1
12112 Revision: Denison 2.2
Page 25 of 37
APPENDIX A.2
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: j/l/zolj
l. Slimes Drain Liquid Levels Cell2
2. Existing Decontamination Pad (concrete) Luoks Goo)..
3. Tailings Area Inspection (Note dispersal of blowing tailings):
lnspectors: -f.^nn.. il,il')^'{ Go"i^ P^J-"
Pump functioning properly V"t
35.-7 f Depth to Liquid pre-pumpjL.8L Depth to Liquid posr-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37 .97'-Depth to Liquid Pre-
pump = z'21
Post-pump head is 37.97'-Deprh to Liquid Post-
pump= t'll
5o\^\io^ +^tr so... sa^Ls e:<areA ccA ,rr'rpo*^J. n... raL 8. B*
*r\ln wi"trs Llao ^ 1i|1. or.. on oc. F,). Ammon.^na 5..1.Qr4. ,fi*^,L <pill e-Jrq pltl,
4. C.ontrol Methods Implemented:
Anr^ori'* 5;$fra
uilt
Lort\$ncunl oa}<. sa,qpka[.'1 r.rRI ll€Z !6als f)*ar1ce
n '-f1.0*ro uil\ I.l
\Y on Z/zL/26'15.
Designated Disposal Area,for Non-Tailings Mill Waste (awaiting DRC approval)
Loo]*s *A- aoo)
White Mesa Mill - Standa.a fiu,ing Procedures
Book 1 l: Environmental Protection Manual, Section 3.1
l2112 Revision: Denison 2,2
Page 25 of 37
APPENDIX A.2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: alSfzotS
1. Slimes Drain Liquid Levels Cell2
2. Existing Decontamination Pad (concrete) LooLr ('col.
3. Tailings Area Inspection (Notq dispersal of blowing tailings):
Q.^-rlcs o*o1.;*hrn ).jlL) ul .r.- z.l't^..f)-- r..r,tr(
4. Control Methods
!
on litc *. lbto.u. n.,
5.
Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
Lrakr. 6-I
Inspectors: 4nqu ll"tl;L,), D ^ut)(^.L
Pump functioning property tlcs
35.Sq Deprh to Liquid pre-pumpj6.73 Depth to Liquid Posr-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37 .97'-Depth to Liquid Pre-
pump = 2.3(
Post-pump head is 37.97' -Depth to Liquid Posr-
PumP = I Z'l
aa. r,
,r,rrrit oO <co. lrrt
quts b<I
White Mesa Mill - StandarO Ot ring Procedures
Book I l: Environmental Protection Manual, Section 3.1
12112 Revision: Denison 2.2
Page 25 of 37
APPENDIX A.2
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: -1 /l\/zail
1. Slimes Drain Liquid Levels Cell2
2. Existing Decontamination Pad (concrete)
3. Tailings Area Inspection (Note dispersal
Pump functioning properly VrS
35.71 Depth to Liquid pre-pump
-e-7{ Depth to Liquid Posr-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37.97'-Depth to Liquid Pre-
pump = L'2J-
Post-pump head is 37.97'-Depth to Liquid Post-
pump = t, 16
},-ook5 G,"J.
of blowing tailings):
4. Control Methods Implemented:
.];^
.r^L sanples *.r-]-f-.^ rF f,H*.-..d.
Disposal Areqfor Non-Tailings Mill Waste (awaiting DRC approval)LioV* (*,1,
.,t};l,ll
S*rliq.
Designated
."J i^*
,t 4f 0,., so*fl ,* r0*.,t4*-
White Mesa Mill - Standara f,ru,irg Procedures
Book I l: Environmental Protection Manual. Section 3.1
12112 Revision: Denison 2.2
PageZ5 of 37
Date: \/Z-L/2.b\\
1. Slimes Drain Liquid Levels Cell2
APPENDIX A.2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors:
Pump functioning properly te-S
unab)c- +" p-.Ery4;*. Bq*r.+-fr1 g-^*td
r@ls\){
3. Tailings Area Inspection (Note dispersal of blowing tailings):R"J. n,.I 1," b" bloJr). cu3 n,.., *n)ls.TrnJLl-28 areco\s Sla.t co.si.4 ar^A lourtrfc Po<ts
pth to Liquid pre-pump
pump
(all measurements
is 37.97'-Depth to Liquid Pre-
pump head is 37 .97' -Depth to Liquid Post-
DUMD =
2. Existing Decontamination Pad (concrete) L.o\<s kro).,
4. Control Methods Implemented:
1-uL1 - 21 r30ri,slca\ aasings L*r+pr po:-.
5. Remarks:Rt 'T:.+ on sl:h€s 'rt
uxlcr saf4 {,9^/ *^i";, r'a). tl'a ,e';t or"l lhc Slorrnvr^J<r fnspqclrLl
Designated Disposal
l-*vq (r*),Area for Non-Tailings Mill Waste (awaiting DRC approval)
r3
6.
White Mesa Mill - Standa.A Qru,irg Procedures
Book I 1: Environmental Protection Manual, Section 3.1
12112 Revision: Denison 2.2
Page 25 of 37
APPENDIX A.2
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
oarc:3lLX [z,on
1. Slimes Drain Liquid Levels Cell2 Pump functioning properly ?:
3L.6b Depth to Liquid pre-pump'>L-'Tl Oepth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37.97'-Depthto Liquid Pre-
pump = ".31Post-pump,headis 37 .97' -Depth to Liquid Post-
DUmD = I Ll-
P^l,a.r
2. Existing Decontamination Pad (concrete; Lo'ks 6-I'
3. Tailings Area Inspection (Note dispersal of blowing tailings):
4. Control Methods Implemented:
Disposal,{rea
2Bs aood.
for Non-Tailings Mill Waste (awaiting DRC approval)
tlt^:ep P/accd
White Mesa Mill - Standard Operating Procedures
Book t1: Environmental Protection Manual' Section 3'1
7/12 Revision: Denison 2' l
Page28 of37
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector: 6 r-r.;.- Polr^^'n
Date: =laqlv
1. Embankment InsPection:
3. Construction Activities:
4. Estimated Areas:
Bstimatea percent of bqqqtrlgrfugg :{e
of solution Pool area
Estimated Percent of 99f9I 3I9q
4ert A it'i,,t.c.l il *out ?u*?;9 i"*ta
to 4A ?;l,trA oilL"- c+fSlo-Lr'
L1.ll 3 bec^c.u'Sc- lLe- t i-''C'
E:\Ir4ill SOp Master copy\Book 1r_Environmental procedures\O7 Lice,se Renewal\Taiti.gs Management Syste.r Rev 2 1 J,ne 2012'doc
White Mesa Mill - DischaL-eeoimization Technolo-qy Monitoring Plan O l2l12 Revision: Denisonl2.2
Pa-ee l8 of 26
ATTACHMENT A.2
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: i / t ,/ zo rf Inspectors: '4,,^, r frnil;),.i. (ru ' r ,^ ?,^1,-.rIt
1. Pond and Beach elevations Cell 1: (a) Pond Solution Elevation
(msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b11 tr1.'LZ
Cell4,A.: (a)Pond Solution Elevation \\1tl,Oi
(b)FML Bottom Elevation 55s5.14
(c)Depth of Water above FML ((a)-(bD 58.6q
Cell4B: (a)Pond Solution Elevation 5580"06'
V-iL.zz
(b)FML Bottom Elevation _5557.5Q
(c)Depth of Water above FML ((a)-(b>f--..p1
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Roberls
Pond: (a)Pond Solution Elevation ]5Gq )L
(b)FML Bottom Elevation _s612.3_
(c)Depth of Water above FML ((a)-(b)) 5 . 0!
2. Leak Detection Systems
Observation:
New Decon Pad.
Portal 1
New Decon Pad.
Portal2
New Decon Pad
Portal3
Is LDS (Portal)
wet or dry?
-wet
./ dry
-wet
,/dry _wet -dry
If wet, Record
liquid level:
_Ft to
Liouid
Ft to
Liquid
Ft to
Liquid
If wet, Report to
RSO* Does Level exceed 12 inches above the lowest point on the bottom fle*itte mernlrane liner (solution
elevation of 5556.14 amsl for Cell 4,{ and 5558.50 for Cell 4B)? / no _ yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete): L ooks f,-oo)'
White Mesa Mill - Dischargfni,rirution Technology Monitoring plan a
ATTACHMENT A.2
DENISON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
oate: 3/8lzol\
1. Pond and Beach elevations
(msl, ft)
Inspectors:d
(c) Depth of Water above FML ((a)-(b)) l(. f,{
5555.14_
(c)Depth of Water above FML ((a)-(b)) 55,71
Cell 48: (a)Pond Solution Elevation s5trO.1?-
(b)FML Bottom Elevation _5557.50
(c)Depth of Water above FML ((a)-(b)) z3.Lrt
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
561?.{g
5612.3
s.ltr
2. Leak Detection Systems
Observation:
New Decon Pad.
Portal I
New Decon Pad.
Portal2
New Decon Pad
Portal3
Is LDS (Portal)
wet or dry?
wet /drv--v-wet / drv _wet___:1dry
If wet, Record
liquid level:- Ftto
Liquid
- Ftto
Liquid
- Ftto
Liquid
If wet, Report to
RSO* Does Level exceed 12 inches above the lowest point on the bottom nexlUte merUUrane liner (solution
elevation of 5556.14 amsl for Cell 4,{ and 5558,50 for cell 4B)? / no yes
If Cell 44 leak detection system level exceeds 12 inches above the lowest point on the bottom flexiblemembrane liner (elevation 5556.14 amsl), notify supervisor or Mill *unugir immediately.
3. New Decontamination pad (concrete): Looks (i*4.
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation
Cell 44: (a)Pond Solution Elevation
(b)FML Bottom Elevation
I 2/1 2 Revision: Denisonl 2.2
Page 18 of26
:4"{r,.
561 \ xq
5597
ssqi.13
White Mesa Mill - Discha.g"li*lrurion Technology Monitoring plan O
ATTACHMENT A.2
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: -.. /iS/Zo,.a
1. Pond and Beach elevations
(msl, ft)
Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
lnspectors:
I 2/12 Revision: Denison I 2.2
Page l8 of26
P.l^..
sr 15,\-1
_5597
I 'd..1f
ssq3"79
(b)FML Bottom Elevation _5555.14_
(c)Depth of Water above FML ((a)-(b)) 36 t5
Cell 48: (a)Pond Solution Elevation ssl z "31
(b)FML Bottom Elevation _55s7.50
(c)Depth of Water above FML ((a)-(b11 2q.91
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
sLrg 16
5612.3--zl 6s -
2. Leak Detection Systems
Observation:
New Decon Pad.
Portal 1
New Decon Pad.
Portal2
New Decon Pad
Portal3
Is LDS (Portal)
wet or dry?
wet - drv
-wet--.-1dry
wet 4rv
If wet, Record
liquid level:
Ft to
Liquid
Ft to
Liouid
Ft to
Liquid
If wet, Report to
RSO* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4,{ and 5558.50 for Cell 4B)?'- no _ yes
If Cell 44 leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):i-aoks (*.'.-{
White Mesa Mill - Dischargl.,irrirurion Technolo-qy Monitoring PIal I l2l12 Revision: Denisonl2.2
Page 18 of26
ATTACHMBNT A.2
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: 3 /zz/zca
1. Pond and Beach elevations Cell 1: (a) Pond Solution Elevation 5A l5 ,a/
(msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b)) 16,'Z I
Cell 4.A: (a)Pond Solution Elevation 55q3 c3
(b)FML Bottom Elevation _5555.14
(c)Depth of Water above FML ((a)-(b)) 38,']g
Cell48: (a)Pond Solution Elevation -1582 q i
(b)FML Bottom Elevation _5557.50
(c)Depth of Water above FML ((a)-(b)) "5 ,tt I
(d)Elevation of Beach Area with Highest Elevation
(monthly)
lnspectors: '4^,v1or l"!ll,t . Go,,;^ A1,-n
Roberts
Pond: (a)Pond Solution Elevation
-
,'/
{u)FML Bottom Elevation
-6w_
D.\
(c)Depth of Water above FML ((a)-(b)) ,/ -\-)
2. Leak Detection Systems
Observation:
New Decon Pad.
Portal I
New Decon Pad.
Portal2
New Decon Pad
Portal 3
Is LDS (Portal)
wet or dry?
_wet__a dry
-wet
/ dry wet /dry
If wet, Record
liquid level:
- Ftto
Liquid - Ftto
Liquid - Ftto
Liquid
If wet, Report to
RSO* Does Level exceed 12 inches above the lowest point on the bottom RexiUte memUTane liner (solution
elevation of 5556.14 amsl for cell 44 and 5558.50 for cell 4B)? ,./ no _ yes
If Cell 44 leak detection system level exceeds 12 inches above the lowest point on the bottom flexiblemembrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete): Lr.y.r G,-r,c\
White Mesa Mill - Dischar-qfni,rirurion Technolo-ey Monitoring plan O
ATTACHMENT A.2
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: 3/zq/ Zota
L Pond and Beach elevations
(msl, ft)
12i 12 Revision: Denison 12.2
Page 18 of26
lnspectors: 4J,.. lloll,)1 ,k,.:^ P^l^n
_ LLiq 77
s597
(c) Depth of Water above FML ((a)-(b)) i-l 1\
5555.14
(c)Depth of Water above FML ((a)-(bD 3fr.2:l-
Cell 4B: (a)Pond Solution Elevation
(b)FML Bottom Elevation _5s57.50
(c)Depth of Water above FML ((a)-(bD ZL'114
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
2. Leak Detection Systems
Observation:
New Decon Pad.
Portal 1
New Decon Pad,
Portal2
New Decon Pad
Portal 3
Is LDS (Portal)
wet or dry?
_wet__:1dry
-wet-jdry
wet - drv
If wet, Record
liouid level:
- Ftto
Liquid
' Ftto
Liouid
- Ftto
Liquid
If wet, Report to
RSO
Does Level exceed 12 inches above the lowest point on the bottom flexible memgrane liner (solution
elevation of 5556.14 amsl for Cell 44 and 5558.50 for Cell 4B)? ,,/ no _ yes
If Cell 44 leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane Iiner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation
Cell 4,{: (a)Pond Solution Elevation
(b)FML Bottom Elevation
55fli".t t
(CI-7 \D_5612.3_LI.A
3. New Decontamination Pad (concrete):Loorrg G,uA.
o
lJ RC- 20fr-001844
En*gg Fuels Flwaurre {trffi} bl*.
September 7,2012
VIA E-MAIL AI{D OVERI\IIGHT DELTYERY
Mr. Rusty Lundberg
Director, Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Response to Utah Division of Radiation Control (*DRC") August 8, 2012 Request for
lnformation, Notice of Enforcement Discretion and Confirmatory Action regarding June2l,2012
Storm Water Inspection at White Mesa Uranium Mill
Dear Mr. Lundberg:
This letter responds to DRC's above-named letter dated August8,20l2, which Enerry Fuels Resources
(USA) Inc. ("EFR") received on August I0,2012, regarding the June 21,2012 storm water inspection
at White Mesa Mill.
For ease of review, this letter provides each of DRC'S comments verbatim in italics, below, followed by
EFR's response.
Re q u e s t fo r Info r moti o n
DRC Comment
1. Standing water was observed in the area of the clean water tanh from an over/low or line break
at a shed (purnp house?) south of the tanlc Please provide an explanation of the cause of the
standing water ond verification that the issue is resolved and that the stonding watel is
eliminatedfrom that locationwithin 30 calendar daysfromyour receipt of this letter.
EFR Response:
The standing water which DRC observed outside a shed in the area near the clean water (service water)
tank resulted from drainage from the potable water treatment shed. Overflow water from vessels in the
potable water building is channeled outside the building through a floor drain pipe which discharges at the
bottom of the west wall of the building. The small volume of standing water was removed (evaporated)
within 24 hours of DRC' s Junre 2012 inspection. EFR proposes to construct an extension to the drain pipe
to gravity drain any overflow water to the concrete channel adjacent to the service water tank, which
flows to the tailings area.
d*ihfl Para i
W':kj
The pipe extension will be completed on
DRC's inspection letter).
Energy Fuels Resources (USA) Inc.
Lakewood, CO 80228
or before September 9, 2012 (within 30 days of receipt of
225 Union Boulevard, Suite 600
Phone: [phone]
Letter to Rusty Lundberg
September 7,2012
Page2ofll
DRC Comment
2. The DUSA 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
fromyour receipt ofthis letter.
EFR Response:
Section 1.5 through 1.6.1 of EFR's Spill Prevention Control and Countenneasures ("SPCC') Plan was
intended to identiff liquid reagent chemicals and solutions which contents would require management or
cleanup of liquids if spilled or leaked from the storage vessel. Per the Hondbook of Thermodynamic
Tables and Charts (K. Raznjevic,lg76),the boiling temperature of propane at760 mm of Hg is -42.6'C
(-45T), that is, propane is a gas at ambient conditions and would be immediately vaporized under all
foreseeable leakage conditions at the Mill. Moreover, no spill reportable quantrty ("RQ") has been
identified for propane.
Since it is not meaningful to inspect the propane storage area for signs of liquid spills, EFR proposes as
agreed to in EFR's August 2,2012 telephone conversation with DRC, to remove the requirement from the
Spill Prevention Control and Countermeasures Plan.
The propane storage area will continue to be inspected each shift, as are other process equipment and
process areas, and any observations will continue to be recorded in the shifter's inspection report.
A revised version of the SPCC Plan in redline/strikeout format along with a clean copy are provided as
Attachment 1. The revisions include:
. the removal of propane from the SPCC Plan,o minor grammatical changes to the SPCC Plan for clarity, and. update of the plan to reflect the current operator of the Mill, Enerry Fuels Resources (USA) Inc.,
along with current names and titles of responsible personnel.
Following DRC approval of the proposed revisions, EFR will provide a signed copy certified by a Utah
Registered Professional Engineer.
EFR has also identified an inconsistency in the Storm Water Best Management Practice Plan
(*SWBMPP"). As discussed in Section 2 of the SWBMPP, the SWBMPP identifies practices to
prevent spills of chemicals and hazardous materials and minimize spread of particulates from
stockpiles and tailings management areas; and the requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are not part of the SWBMPP and
are addressed separately in other documents, specifically, the Spill Prevention Control and
Countermeasures (*SPCC") Plan, the Emergency Response Plan ("ERP"), and the housekeeping
procedures within Mill SOPs. Previous versions of the SWBMPP incorrectly included the SPCC
Plan and ERP as appendices. For clarity and consistency, EFR proposes removing those
documents from the SWBMPP appendices and maintaining them as stand-alone documents. This
also eliminates the need to revise the SWBMPP when revisions are made to the SPCC or ERP.
Letter to Rusty Lundberg
September 7,2012
Page3ofll
A revised version of the SWBMPP in redline/strikeout format along with a clean copy are provided in
Affachment 2. Therevisions include:
o The removal of the SPCC and ERP appendices, and
o update of the plan to reflect the current operator of the Mill, Energy Fuels Resources (USA) Inc.,
along with current names and titles of responsible personnel.
Notice of Enforcement Discretion
DRC Comment
1. The (Jtah Grotmd Water Permit, Permit No. UGW370004, Pmt 1.D.10 requires that "the Permittee
will monage all contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices Plan." The approved
Best Management Practices Plan, Appendix l, Part l-ll Personnel Training and Spill Prevention
Procedures requires thot "all new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and control. They are informed that
leaks in piping, valves, and sudden discharges from tanks should be reported immediately. Abnormal
flows from ditches or impoundments are of immediate concern. In addition, a safety meeting is presented
annually by the Environmental Health mtd Safety Mmtager to review the SPCC plan." Additionally, Part
1.11.1 Training Records requires that "Employee training records on chemical and petroleum spill
prevention are maintained in the general safety trainingfiles."
During the Jme 21, 2012 White Mesa Mill stormwater inspection, the DRC inspectors requested copies
of the training records required by the SWPPP as well as a cowse outlinefor the material presentations,
in response they received;
A. Copies of certificationformsfrom the Environmental Protection Manual, Section 3.1, Appendix C
regarding certification that the undersigned received instruction of the tailings system including
documentation of daily tailings inspections, analysis of potential problems and notification
procedures and safety (3forms total), and,
B. A Copy of Appendix B of the Environmental Protection Manual, Section 3.1 "Tailings Inspector
Training" which includes qn outline of the training program.
Per review of the provided documents DRC noted thot the training did not provide instruction for items
required by the Permit Part 1.D.10 or dny other topics related to spill prevention, control or storm water
pollution prevention. Additionally, it was noted that no records for new employees were provided, only
threeforms were providedfor thefollowing employees: David Turk, Tmtner Holliday and Garrin Palmer.
DUSA is in violation of the Permit Part I.D. 10 for failing to provide employee training as required by the
SWPPP,
DRC is extending enforcement discretion regording this violation based on:
A. This was thefirst time that DRC has reviewed the training syllabus, and,
B. DUSA will comply with the Confirmatory Action section, item 2 below which requires the
development of a training program in compliance with the Permit within the specified time-line.
Letter to Rusty Lundberg
September 7,2012
Page4ofl1
EFR Response:
EFR has developed a training program in response to item B, above. EFR's response and description of
the training program are provided in our response to DRC Confirmatory Action Comment 2, below.
ConJirmalory Actions:
Per an August 2, 2012 telephone close-out conference call, the following conJirmatory actions and
timelines were agreed to:
DRC Comment
l. Storm Water Best Management Practices Plan (SWBMPP) -- DRC notes that a complete copy of
the October, 201I Revised SYITBWP (including all appendices) in both hard copy and text
searchable electronicformat (PDF) has not been received. This was requested per a DRC March
7, 2012 Request for Information Letter, which also provided approval of the October, 2011
SWBMPP. A full copy wcts requested since the attachments were not included; DRC noted that
the Spill Prevention, Control and Counteflneasure Plan (Appendix I of the SWBMPP) was under
review; and tlat the Emergency Response Plan was not submitted due to there being no choryes.
DUSA will submit a complete revised SWBMPP for DRC Files within 30 days of receipt of this
letter.
EFR Response
A complete copy of the SWBMPP as requested on March 7, 2011, including the SPCC Plan and
Emergency Response Plan appendices was submitted to DRC in hard copy and on CD ROM which were
delivered to DRC on April 12,2012. EFR's duplicate copy of the printed document and of the CD ROM
indicates that all appendices and attachments were included. A copy of the UPS receipt indicating DRC's
signed acceptance of the document package is provided as Attachment 3.
An additional hard copy and CD ROM of the SWBMPP, with all attachments, was again transmitted by
UPS on August 28,2012.
DRC Comment
2. Storm Water Inspector Training - DUSA will implernent a training program in compliance with
the SWBMPP Appendix 1, Part 1.11 and will provide DRC a copy of the course syllabus, training
calendar, and commitrnent to maintain training logs/certficates at the Mill within 60 calendar
days of receipt of this letter.
DRC also notes that per a letter submitted to the Director by DUSA (dated October 17, 2011) in
response to a DRC RFI (dated September 1,2011), page 2ltem 3. DUSAprovides infurmation
regarding the newly implemented internal notification process for small quqntity spills and
commits that "all Mill employees will be tained to advise Mill environmental personnel of any
spills that they observe during the doy, and these will also be noted in the daily inspectionform."
Although the DUSA letter does not specify how the information will be provided to the Mill
employees, DUSA has agreed that this information will be provided during the newly
implemented SWBMPP training.
Letter to Rusty Lundberg
September 7,2012
Page5ofll
EFR Response
EFR has implemented a training program in compliance with the SWBMPP Appendix 1, Part 1.1I (Spill
Reporting Requirements), as discussed below.
General Employee SWBMPP training will be provided to all employees as one of the topics addressed
each year during one of the quarterly employee refresher training sessions. All employees, other than
Mill Environmental Personnel, will be instructed regarding the Mill's requirement to comply with the
SWBMPP, and that their reporting responsibilities require them to alert Mill Environmental Personnel
immediately regarding any spills, leaks, failures of storage or process equipment, or abnormal flows from
ditches or impoundments. A copy of the outline for SWBMPP General Employee Training is provided in
Attachment 3. Documentation of haining topics and attendance is maintained with'existing quarterly
refresher training records. SWBMPP training will be conducted during the second quarter refresher
training each year, except 2012, when it will be conducted during the third quarter refresher training
session.
Mill Environmental Personnel will receive an additional level of SWBMPP training as well as the general
Employee SWBMPP Training. Mill Environmental Personnel will be trained to meet the requirements of
Part I.D.l0 of the Permit, and to perform the reporting required for reportable quantity ("RQ') spills, as
well as the internal documentation of non-RQ spills. A copy of the course outline and training calendar
for Environmental StaffTraining has been provided in Attachment 4. EFR will maintain training records
for the Mill Environmental Personnel at the Mill. Environmental Staff SWBMPP Training will be
conducted in January ofeach year.
DRC Comment
3. Solvent Extraction (SX) Building Roof Drainage Improvements - Comments regarding needed
improvements to the SX building roof drain system have been ongoing since 2009. Per the 2012
inspection, issues related to the roofdrainage and discharges into the alternatefeed circuit have
not been addressed. DUSA agrees to upgrade the SX building roof drainage to prevent potential
standingwater on the groundwithin 60 calendm days of receipt of this letter. Specifically, DUSA
will provide appropriate drainage control for roof areas depicted in photograph j0 of the Memo
(north-west section of the building) and will provide documentation to DRC regardingfollow-up
actions tmdertaken.
EFR Response
As requested, EFR agrees to construct modifications to the SX building roof drainage within 60 days of
receipt of DRC's letter. EFR plans to install a concrete trench system to collect the water runofffrom the
SX building roof and transfer it to the tailings cell area.
The roof edges of the Mill buildings in the SX area are subject to high winds. EFR expects that any
rainwater collection system built on the roof (such as a gutter and downspout) would be subject to the
same recurrent wind damage as currently affects other roof materials. Therefore EFR has chosen to
minimize construction of rooftop elements, in lieu of the proposed trench at ground level.
The trench will be designed large enough to ensure ease of access for sediment removal, and will be
constructed by October 9,2012 (within 60 days of EFR's receipt of DRC's inspection letter).
Letter to Rusty Lundberg
September 7,2012
Page6ofll
DRC Comment
4. Based on DRC review of the DUSA May 4, 2012 letter "Response to Claricone Solution Spill" it
was noted that confirmation soil samplingwas not conducted to ensure that all contaminated soil
had been removed. Excavation of contaminated material was based on visual examination and
gamma surveying (microRmeter) only. DUSAwill submit to DRC either:
A. A work planfor the collection of confirmation soil somples to be collected and analyzed
for appropriate radiological parameters and total uranium within 45 days from DUSA
receipt of this letter. The work plan will detail the teclmiques to be used for sample
collection, number and locations of samples to be collected, methods to be used for soils
analysis, and will propose confirmation sample concentration thresholds to be used for
the evaluation. DUSA will propose applicable concentration stdndards to be used for
radiological pqrameters (per applicable guidonce/regulations); and will propose a study
evaluotion to determine an appropriate background concentration for total traniutn
within the restricted area of the Mill. The total uranium soil concentration threshold to
be used for con/irmation samples will be based on 2 times the average measured
backgroutd concentrations for total uronium as determined through the work plan study,
or;
B. A conservative basis for a larger three dimensional area of potentially contaminated soil
due to the claricone solution spill, in lieu of confirmation soil sampling, which will
include a calculated soil excavation vohtme (beyond the previous excavated soil volume).
DUSA will provide a Report which describes the justification for the calculated soil
volume and includes a sudace map of the Mill and cross sections clearly depicting the
ultimate area of soil for excavation, removal and disposal (at site closure). DUSA will
provide a surety estimate, for Director review and approval, which includes line items for
all work associated with excayation, removal and disposal of the proposed soil volume.
The Report ond Surety Estimate will be submitted within 45 days from DUSA receipt of
this letter.
EFR Response
EFR proposes to produce a conservative estimate of potentially contaminated soil resulting from the
Claricone spill, and calculation of additional soil excavation volume to be removed at reclamation,
consistent with Item B, above. EFR will provide a Report which describes the justification for the
calculated soil volume and includes a surface map of the Mill and cross sections clearly depicting the
ultimate area of soil for excavation, removal and disposal (at site closure). EFR will provide a surety
estimate, for review and approval by the Director of the Division of Radiation Conhol, which includes
line items for all work associated with excavation, removal and disposal of the proposed soil volume. As
agreed to in our telephone conversation of August 28,2012, and confirmed by DRC's letter of August 30,
2012, EFR will provide the required report by October 26,2012.
Letter to Rusty Lundberg
September 7,2012
PageTofll
Please contact me ifyou have any questions or require any further information.
Yours very truly,
ENERGv FUELs I{EsouRcEs (USA) INC.
Attachments
O*C,,"-fu
4,
^rrrischlerDirector, Compliance
David C. Frydenlund
Daniel C. Hillsten
HaroldR. Roberts
David E. Turk
KathyA. Weinel
Department of
Environmental Quality
Amanda Smith
Executive Direclor
DTVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARYR. HERBERT
Governor
GREG BELL
Lieutendnt Governor
"DRC-2013-002791"
rll I
\--l
June2l,2013
Jo Ann Tischler
Director Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 17th St. Suite 950
Denver, Colorado, 80265
Subject: Transmittal of Findings of the Utah Division of Radiation Control June 4,2013 Storm
Water Inspection at the White Mesa Uranium MilL DRC Close-out
Dear Ms. Tischler:
This is to transmit the findings of the Utah Division of Radiation Control (DRC) 2013 storm water
inspection which took place on June 4,2013 at the White Mesa Uranium Mill (MiX). A copy of
the DRC modular inspection memo (DRC Groundwater Module 65) is attached for your records.
Based on the inspection findings, it appears that EFR is in compliance with Utah Ground Water
DischargePermit,PermitNo.UGW370004PartsI.D.l0andI.D.ll. The2013MillStormWater
Inspection is therefore closed-out.
If you have any questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
mffi
Director
RL:TR:tr
Enclosure: DRC Groundwater Module 65 Memo
F:\Energy Fuels\Storm Water ManagementV0l3 SW Inspection\White Mesa Mill 2013 SW Inspection Close-out Ltr.docx
195 North 1 950 West . Salt Lake City, UT
Mailing Address: P.O. Box 144850 . Salt l-ake City, UT 841l4-4850
Telephone [phone]'Fax [phone] 'T.D.D. (801) 5364414
w.deq.ulah.gov
Printed on I 007o recycled paper
Utah Division of Radiation Control (DRC)
Ground Water Module 65, DRC Annual Storm Water Inspection
Denison Mines, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2013
Inspection Date: June 4, 2013
Module Reviewer Name/Initials :
Phil Goble, Compliance Section Manager PZ6 e/Z/"",1
Module Prepared bv/Date Prepared:
Tom Rushing, P.G./Jun e 17,2Or3 1 ( 6 - l1 - 2c>t3
DRC Staff Present:
Tom Rushing
Denison Mines Staff Present: David Turk
Tanner Holliday
Denison Mines Staff fnterviewed: David Turk
Tanner Holliday
Garrin Palmer
Currently Approved Storm Water Best Management Practices PIan (SWBMPP) for the
White Mesa Uranium Mill:
Date: Sept ember,2072
Revision No. 1.5
Section I - Document Review
Part 4.1.4. -- Diversion ditches, drainage channels and surface water control structures
in and around the Mitl 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.
Findings:
The Utah Division of Radiation Control ("DRC") conducted an inspection of upland
Diversion Ditch 1 and Berms as shown on the Energy Fuels Resources ("EFR") Storm Water
Best Management Practices Plan, Figure 2. DRC found Ditch I and berms to be well
maintained. Photos of Ditch 1, taken during the day of the inspection are included the memo
appendix 1, photos 39 and 40.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DRC reviewed the March 29,2013 monthly
form and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion Ditches 1,2
and 3 showed no sloughing, erosion, undesirable vegetation or obstructions of flow, and that
"diversion ditches are in good condition."
Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
Findings: Per the EFR response to an August 8,2012 request for information which stated as
follows: "The EFR Spill Prevention, Control, and Countermeasures Plan, Part 1.6.1 requires
tlte documentation of a daily inspection of the propane tanl<s. Please include the inspection
findings with the daily inspectionform usedfor storm water inspection documentation within
30 days from your receipt of this letter," EFR has removed the removed the daily inspection
requirement on the basis that the propane is a gas at ambient conditions and would be
immediately vapoized under all foreseeable leakage conditions at the Mill. DRC concurred
with this action and this item has been removed from the storm water inspection at the mill.
1.9.1. - External Notification of "reportable quantity" spills.
Findings: No reportable quantity spills occurred during the period reviewed, DRC has no
additional comments.
1.9.2. Internal Notification of incidents, spills, and significant spills.
Performance Standards (list):
ln response to a DRC Request for Information item by letter dated September l,2OLI,
regarding the findings of the DRC 2010 storm water inspection, EFR provided a change to
the small quantity spills protocols in the October 17,2011 response letter, as follows:
"EFR has implanted an internal notification process for small quantity spills Qess than
reportable quantities), with the following steps :
1) Mitl environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size. .Theform will be amended to add spaces for this item.
2) In addition, all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day, and these will also be noted in the daily
inspectionform.
3) If the spill is of a reportable quantity, enyironmental personnel willfollow the procedures
in the Mill's SWMPP plan.
4) For spills smaller than reportable quantities, the environmental inspector will record
information regarding the spill, and the nature and type of cleanup, on the form.
5) The information on the inspectionform will be added to a database maintained at the Mill.
The database will be updated and maintained on site indefinitely. Cards are maintainedfor
no longer than one year."
These corrective actions were reviewed during the DRC June 21, 2012 storm water
inspection as well as the current June 4, 2013 inspection. Per the reviews DRC noted that a
process for intemal reporting of spills less than reportable quantities was instituted during
2012 andunderwent additional improvement during 2073.
The White Mesa Mill employees are using an orange 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. Per the 2013 orange cards, the following spills were recorded during 2013 atthe
date of the inspection (61412013).
Date of
Discovery
Material Spilled Quantity Spilled
1/2712013 CCD F1uid 200 eallons
217120t3 Soda Ash
31112013 Ore Process Solution
3t6t2013 oil 3 sallons
4/t/2013 Yellow Cake Liquor 1-600 sallons
4t3/2013 VPL Liquor 400 sallons
412212013 Decant Material 5 sallons
s1212013 Soda Ash Yzbas
s/1712073 Sulfuric Acid 10 eallons
sl20l20t3 Vanadium Material 4 eallons
5/23/2013 Product Retum Solution 500-1,000 gallons
5t26t2013 Uranium Hexafluoride lzbtcket
s/27/20t3 Ore Slurrv 1,000 gallons
s131l20t3 Hvdraulic Fluid 10+ eallons
DRC sees the new spill reporting process as very effective. EFR has additionally started
attaching photographs of the spill and clean-up activities to the orange card when deemed
appropriate and per DRC review of the follow up actions it is noted that mill personnel are
taking responsibility to clean-up spills.
DRC notes that the spill reporting training program required under the requirements of the
Spill Prevention, Control, and Counterneasures Plan for Chemicals and Petroleum Product,
Section 1 .1 1., and also outlined in the EFR response as a corrective action, has been
implemented since the last inspection findings and confirmatory'action letter (August 8,
2012).
EFR has implemented the training program in two parts, one training is required for the
environmental personnel at the mill and a second has been required of all employees at the
mill. Per the attendance logs, all environmental personnel attended the training on llll20l3
and all other mill employees received the training as follows:
412612013 - 25 employees
4l29l2\l3 - 24 employees
51112013 - 66 employees
51312013 - 31 employees
51812013 - i0 employees
Total employees trained - 156
The employee training is 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/End ing: IO/l/2012 to lOl3lDnD and 3/112013 through 3l3ll2Il3
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: l0%o (Percent of Total)
How Selected: DRC lrspected two full months of daily, weekly and monthly forms
requested at random
Daily Tailings Inspection Data:
Findings:
EFR inspection of: 1. Tailings slurry transport system (Slurry pipeline, pipeline joints and
supports, valves and point of discharge); 2. Operational systems (water level, beach, liner
and cover); 3. Dikes and embanl<ments (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 ofpotential concerns and action required. Spills and clean up actions are noted
in the text boxes for these fields.
DRC randomly selected and reviewed all of the daily forms for the months of October 2012
and March 2013. The forms appeared to be appropriate and inspections were conducted on
all days. There are no additional comments regarding the forms.
Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 andAttachment 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 7,3,44,48 and
Roberts Pond, as well as slimes drain liquid levels in Cell2, Existing decontamination Pad
and general tailing area. The form also includes information regarding the leak detection
systems for Cells l,2,3,4Aand,4B as well as the potential blowing of tailings.
Per the 2013 DRC storm water inspection, the inspections were completed, there are no
additional comments regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness:
Findings:
The monthly inspection report includes; 1. A summary of the slurry pipeline condition and
measurement of pipe thickness, which is applicable only when the Mill is operational; 2.
Inspection protocols and observations related to the diversion ditches, berms, sedimentation
pond, dust control, settlement monitors, and slimes drain static head measurements for Cells
2 and3.
DRC reviewed the monthly inspection report dated March 29,2Ol3.Note that the monthly
inspection reports include comments related to the upland diversion ditches which noted that
the"ditches are in good condition." Per inspection findings DRC confirmed that the ditches
were well maintained. DRC has no additional comments related to the reviewed monthly
inspection report.
Tank to soil potential measurements:
Findings:
This item was included as part of the September 1,2011 RFI, RFI # 2. DRC had concems
regarding on-grade tanks (tanks where the bottom is in contact with soil. Per DRC
communication with EFR it was clarified that tanks which sit on the ground must have
cathodic protection or sit on a concrete foundation.
Per DRC inspection of the tank foundations during the2Ol3 inspection, all concrete
foundations appeared in good condition.
Annual bulk oil and fuel tank visual inspections:
Findings:
ln response to a DRC request for information, EFR reviewed the White Mesa Mill Spill
Prevention Countermeasure and Control ("SPCC") Plan for the mill to ensure that all
inspection processes and oil containers are in conformance with those Federal (40CFR112)
regulations. In response (EFR September 7 ,2012letter), EFR removed the SPCC Plan as an
appendix to the SWBMPP. EFR additionally removed the Emergency Response Plan as an
appendix to the SWBMPP. The removal of these documents was done in order to maintain
each plan as a stand-alone document. EFR states in the September 7,2012letter that"the
requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are not part of the SWBMPP and are addressed separately in other
documents, specffically, the Spill Preyention control and Countermeasures Plan, the
Emergency Response Plan, and the housekeeping procedures within Mill SOP's." Per
comments related to inspection of the propane tanks and applicability of those requirements
in the SPCC Plan, a revised copy was submitted with the September 7,2012letter (SPCC
Plan dated September, 2012).
DRC has no additional comments regarding the SPCC Plan, and future storm water
inspections will focus on insuring that the SWBMPP adequately addresses all requirements
of the Permit, including spill reporting requirements in Part I.D.10, which specifically
requires actions for identification and cleanup of reagent and chemical spills for non-
reportable quantities and procedures for reportable quantity spills in conformancewith Utah
Administrative Code 1 9-5- I 1 4.
Tank and pipeline thickness tests:
Findings: During the inspection period the slurry pipelines were noted to be in good
condition. DRC has no additional comments related to the pipeline tests.
Quarterly and annual PCB transformer inspections (currently PCB only):
Findings: The Mill currently does not currently inspect the transfofiners based on all
transformers containing non-PCB based oil.
Spill Incident Reports :
Findings: This item is discussed above in the section related to reportable and small quantity
spills. DRC notes that an effective spill reporting and tracking system has been implemented
at the Mill.
Latest revision of SPCC plan (onsite and available?):
Findings: The SPCC plan was not requested during the inspection.
1.11 Personnel training and Spitl 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 DRC findings the liersonnel training has been
implemented and appears to be effective. All Mill staff received training regarding the small
quantity spill notification process. DRC has no additional comments related to personnel
training.
Section II -- Site Walk through Inspection
Areas and Observations:
Ore Storage:
Observations: All berms appeared to be in good condition, there was no ore stored on the
pad at the time of the inspection @hotos 3, 5 and 6). There are no additional comments
regarding the ore storage area.
Reagent Yard:
Observations: Per DRC inspection of the reagent yard and storage building, it appeared that
drum storage was appropriate. No degraded or tapped drums were noted in those areas.
Shop/Yehicle Maintenance Area:
Observations:
Oil Drum Storage Rack:
Per the 2013 inspection all drums were stored on the pallets and no observable fluid
accumulation was seen in the pallet secondary containments. (Photo 13)
Shop Building Drain to Bffie Box:
Per DRC inspection of the shop baffle box, no comments were noted @hoto 16).
Used Oil/Kerosene Tank North of Shop Building:
Per DRC inspection of the used oil tank and kerosene tank containment, it appeared that
previous violatidns concerning spills outside of the containments were addressed; no
additional issues/comments were noted. @hoto 14,15)
Mill Processing Areas:
SX Building Roof Drainage:
Per the 2013 inspection, issues related to the roof drainage and discharges into the alternate
feed circuit have been addressed. DRC communicated to the EFR staff that the drainage
needs to be inspected during a storm event to ensure that all roof drainage is diverted in the
directions intended. Specifically, the roof drainage is intended to divert either to cell 1 (south
side of building drainage) or to Roberts Pond (roof north side of building). (Photos 31
through 35)
Alternate Feed Circuit South of SX Building:
Observations:
All feedstock at the alternate feed circuit was stored and managed on the new concrete pads.
The concrete pads appeared to be in good condition. DRC has no additional
comments/observations regarding the altemate feed area. @hotos 26 through 30)
Old Decontamination Pad:
DRC has no cofirments regarding the old decontamination pad.
New Decontamination Pad:
Observations:
The pump back system and east apron drainage appeared to be in good condition (Photos 7,
8). DRC staff had no additional comments.
Reagent Tanks:
Sodium Chloride Tanks - Per past agreements between DRC 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, and in Part
I.D.3(g). No issues were noted during the 2013 inspection.
Kerosene Tanks (West of Shop) - Appeared in good condition, no additional comments.
Note: Secondary containment is earthen under the same agreement as the sodium chloride
tanks.
Ammonia Tanks - DRC noted that the tank was undergoing maintenance/refurbishing at the
time of the inspection (sandblasting and re-painting). Secondary containment is earthen per
the same agreement as the sodium chloride tanks. (Photo 4)
Used Oil Tank (shop) - Appeared in good condition, no additional comments.
Kerosene Tank (shop) - Appeared in good condition, no additional comments.
Fuel Tanks - Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks - Secondary containment appeared to be in good condition (Photo
22).DRC had no additional comments regarding tanks or secondary containment.
Vanadium Pregnant Liquor (YPL) Tanks - The VPL tank steam condensate containment
area, tanks and foundations appeared to be in good condition. (Photo l7)
Clean Water Tank - DRC noted that a new water treatment house is being constructed
which should eliminate the leaks previously observed at the old chlorination house (Photos
23,24). No additional comments.
Sulfuric Acid Tank - The tank and berm appeared in good condition. No additional
comments.
Caustic Soda Tank - Per the 2013 inspection it was noted that, in response to Confirmatory
Actions, the caustic acid secondary containment area has been re-poured and that anew tank
has been installed @hoto 36). No additional comments.
Soda Ash Tanks - The Soda Ash Tanks and Secondary Containment appeared to be
maintained. DRC noted that water from the chloroform pump system was being discharged
into the containment area drain. DRC has no comments regarding this area. (Photos 37, 38)
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC toured the tailings cell areas (Celis 4A and 48 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. The dikes appeared to be in overall good
condition. (Photos 41, 42, 43)
Summary of Onsite Closeout Meeting:
Date/Time: June 21, 20l2ll1 :30 P.M.
EFR Representatives Present --Daniel Hillsten, Mill Manager
David Turk
Tarurer Holiday
DRC Representatives Present - Tom Rushing
An onsite close-out meeting took place amongst Tom Rushing (DRC), Dan Hillsten (EFR
Mill Manager), David Turk (EFR) and Tanner Holliday (EFR). During this meeting, DRC
informed the EFR representative of the inspection findings above.
Conclusions
A close-out letter regarding the 2013 storm water inspection will be sent to EFR. DRC notes
that overall, the Mill facility storm water management and spill training and reporting has
significantly improved in recent years.
F:\Energy Fuels\Storm Water ManagementVOl3 SW Inspection\White Mesa Mill 2013 SW Inspection Memo.docx
Ground WaterModule 65, DRC 2013 Annual Storm Water Inspection
Appendix 1-PhotoPages
Utah Division of Radiation Control
2013 Annual Storm Water lnspection
lnspection Date June 4,2013
Photo Pages
Photo 1- Kerosene tanks on cement platforms
Photo 2 - Sodium chlorate tanks in cement containment
a,t
Photo 3 - Berm along the western margin of the ore pad
Photb 4 - Storm water detention southwest corner of ore pad - drains to cell L
Photo 5 - Ore pad and south berm, photo looking southeast
Photo 6 - Ore pad, No ore Piles
Photo 7 -southeast ore pad berm and lined drainage ditch
Photo 8 - New Decontamination pad pump back system in cement containment
*€e n,a: ,ry.Ei;_:
li t i;P}.ffi;i in,;,; !,.. :,,:l,r$t' i:ri. r',j€t'., :, ". ri*ffi. # ;: , . . . '::.i. ::rlq -. -d.. .:."1r;.,] r:,1:", i,.:.ai;,;t*1f'ai':,:i:ni--._,i1q't'i,aitr:i-4l {*:r* - s?'r .-'*.:t,ii__t ''ai. rmr're
Photo 9 - Ore Pad east side (note that the ore pad is graded to drain to the west)
Photo 10 - Ore pad east margin berm looking north
Photo 1,1- Ore pad looking northwest
Photo 12 - Drum storage at maintenance shop (drums on containment pallets)
Photo 13 - Containment under drum storage at the maintenance shop
Photo 14 - Used oil and kerosene tanks and containment (north side of maintenance shop)
containment area since that time)
i. ];
Photo 16 - North side of maintenance building baffle box containment (box is pumped to Roberts Pond)
Photo 15 - Kerosene tank valve (note stain was from previous noted leak, tank has been moved further into
Photo 17 - Vanadium Pregnant Liquor (VPL) Tanks on concrete platforms
Photo 18 - Mill building looking southwest
Photo t9 - Grizzly (Ore in drums to be used for stack tests)
Photo 20 - Mill building east side (foreground corner marker for Phase lll ammonium sulfate crystal. tank geoprobe
investigation)
Photo 21- Chemical storage building
Photo 22-Tank containment east side of Mill Building
Photo 23 - New water treatment building (clean water treatment and chlorination)
Photo 24 - Old clean water chlorination building will be removed
Photo 26 - Alternate feed storage pad
Photo 27 - Alternate feed processing area
Photo 28 -Alternate Feed storage pad looking southeast
low spot on pad)
Photo 30 - Alternate feed pad, drums waiting to go on processing rack
Photo 31 - SX building roof drainage gutter, drains to cell 1
Photo 32 , undergrourid pipe for roof drainage from SX building
Photo 33 - SX building roof drainage, west side of building drains to Roberts Pond
Photo 34 - Drainage from SX roof to Roberts Pond
Photo 37 - Soda ash tank containment, note that containment has been patched. Water in containment is from
groundwater pumping well for chloroform ground water contamination
Photo 38 - Caustic soda tank containment drainage into SX building
Photo 39 - Upland diversion ditch 1 well maintained
Photo 40 - Upland diversion ditch 1
Photo 41- Berm and toe for cell 4A well maintained, note vegetation
Photo 42 - Cell 4A well maintained, note vegetation
Photo 43 - Cell 44 berm well maintained
Photo 44 - Cell 4Al4B spillway
Photo 45 - Surplus storage area, note berm in background
Photo 46 - Surplus storage area, note berm in background
Utah Division of Radiation Control (DRC)
Ground Water Module 65, DRC Annual Storm Water Inspection
Denison Mines, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2013
Inspection Date: June 4, 2013
Module Reviewer Name/Initials:
Phil Goble, Compliance Section Manager PZ6 A/r/.", I
Module Prepared bv/Date Prepared:
Tom Rushing, P.G./June 17,2013 1 (e 6 - 11 - 2r:i3
DRC Staff Present:
Tom Rushing
Denison Mines Staff Present: David Turk
Tanner Holliday
Denison Mines Staff Interviewed: David Turk
Tanner Holliday
Garrin Palmer
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the
White Mesa Uranium Mill:
Date: September,2012
Revision No. 1.5
Section I - Document Review
S WB MPP (D o cum entation Req uirem entil :
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.
Findings:
The Utah Division of Radiation Control ("DRC") conducted an inspection of upland
Diversion Ditch 1 and Berms as shown on the Energy Fuels Resources ("EFR") Storm Water
Best Management Practices Plan, Figure 2. DRC found Ditch I and berms to be well
maintained. Photos of Ditch 1, taken during the day of the inspection are included the memo
appendix 1, photos 39 and40.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DRC reviewed the March 29,2013 monthly
form and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion Ditches 1, 2
and 3 showed no sloughing, erosion, undesirable vegetation or obstructions of flow, and that
"diversion ditches are in good condition."
Spill Prevention, Control, and Countermeasures Plan (SPCCI (Documentation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
Findings: Per the EFR response to an 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 tanl<s. Please include the inspection
findings with the daily inspectionform usedfor storm water inspection documentation within
30 days from your receipt of this letter," EFR has removed the 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. DRC concurred
with this action and this item has been removed from the storm water inspection at the mill.
1.9.1. - External Notification of "reportable quantity" spills.
Findings: No reportable quantity spills occurred during the period reviewed, DRC has no
additional comments.
1.9.2. Internal Notification of incidents, spills, and significant spills.
Performance Standards (list) :
In response to a DRC Request for Information item by letter dated September 1,2011,,
regarding the findings of the DRC 2010 storm water inspection, EFR provided a change to
the small quantity spills protocols in the October 17,2011 response letter, as follows:
*EFR has implanted an internal notification process for small quantity spills (less than
reportable quantities), with the following steps :
1) Mill environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size. The form will be amended to add spaces for this item.
2) In addilion, all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day, and these will also be noted in the daily
inspection form.
3) If the spill is of a reportable quantity, environmental personnel will follow the procedures
in the Mill's SWBMPP plan.
4) For spills smaller than reportable quantities, the environmental inspector will record
information regarding the spill, and the nature and type of cleanup, on the form.
5) The information on the inspectionform will be added to a database maintained at the Mill.
The database will be updated and maintained on site indefinitely. Cards are maintainedfor
no longer than one year."
These corrective actions were reviewed during the DRC June2I,2012 storm water
inspection as well as the current June 4, 2013 inspection. Per the reviews DRC noted that a
process for internal reporting of spills less than reportable quantities was instituted during
2012 and underwent additional improvement during 2073.
The White Mesa Mill employees are using an orange 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. Per the 2013 orange cards, the following spills were recorded during 2013 atthe
date of the inspection (61412013).
Date of
Discovery
Material Spilled Quantity Spilled
t/2712013 CCD Fluid 200 eallons
21712013 Soda Ash
3/t/2013 Ore Process Solution
3/6/2013 oil 3 sallons
4lt/20t3 Yellow Cake Liouor 1,600 eallons
413/20t3 VPL Liouor 400 eallons
4t22t20t3 Decant Material 5 sallons
5/2/20t3 Soda Ash Yzbas
5/17/2013 Sulfuric Acid l0 eallons
5t20t2013 Vanadium Material 4 eallons
sl23l20r3 Product Return Solution 500-1,000 gallons
sl26l2013 Uranium Hexafluoride Yzbwket
sl27l20t3 Ore Slurrv 1.000 eallons
sl3y20t3 Hvdraulic Fluid 10+ gallsrt
DRC sees the new spill reporting process as very effective. EFR has additionally started
attaching photographs of the spill and clean-up activities to the orange card when deemed
appropriate and per DRC review of the follow up actions it is noted that mill personnel are
taking responsibility to clean-up spills.
DRC notes that the spill reporting training program required under the requirements of the
Spill Prevention, Control, and Counterrneasures Plan for Chemicals and Petroleum Product,
Section 1.1 1., and also outlined in the EFR response as a corrective action, has been
implemented since the last inspection findings and confirmatory action letter (August 8,
2012).
EFR has implemented the training program in two parts, one training is required for the
environmental personnel at the mill and a second has been required of all employees at the
mill. Per the attendance logs, all environmental personnel attended the training on ll7l20l3
and all other mill employees received the training as follows:
4126/2013 - 25 employees
412912013 - 24 employees
5lll20l3 - 66 employees
51312013 - 31 employees
51812013 - 10 employees
Total employees trained - 156
The employee training is 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/End ing: 1 0 / I / 2Ol2 to I O I 3 1 / 2Ol2 and 3 I | 12013 through 3 I 3 I I 2013
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: l0o/o (Percent of Total)
How Selected: DRC Inspected two full months of daily, weekly and monthly forms
requested at random
Daily Tailings Inspection Data:
Findings:
EFR inspection of: 1. Tailings slurry transport system (Slurry pipeline, pipeline joints and
supports, valves and point of discharge); Z. Operational systems (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 ofpotential concerns and action required. Spills and clean up actions are noted
in the text boxes for these fields.
DRC randomly selected and reviewed all of the daily forms for the months of October 2012
and March 2013. The forms appeared to be appropriate and inspections were conducted on
all days. There are no additional comments regarding the forms.
Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 andAttachment 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 I,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 48 as well as the potential blowing of tailings.
Per the 2013 DRC storm water inspection, the inspections were completed, there are no
additional comments regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness:
Findings:
The monthly inspection report includes; 1. A summary of the slurry pipeline condition and
measurement of pipe thickness, which is applicable only when the Mill is operational; 2.
Inspection protocols and observations related to the diversion ditches, berms, sedimentation
pond, dust control, settlement monitors, and slimes drain static head measurements for Cells
2 and3.
DRC reviewed the monthly inspection report dated March 29,2013. Note that the monthly
inspection reports include comments related to the upland diversion ditches which noted that
the"ditches are in good condition." Per inspection findings DRC confirmed that the ditches
were well maintained. DRC has no additional comments related to the reviewed monthly
inspection report.
Tank to soil potential measurements:
Findings:
This item was included as part of the September L,2011 RFI, RFI # 2. DRC had concerns
regarding on-grade tanks (tanks where the bottom is in contact with soil. Per DRC
communication with EFR it was clarified that tanks which sit on the ground must have
cathodic protection or sit on a concrete foundation.
Per DRC inspection of the tank foundations during the 2013 inspection, all concrete
foundations appeared in good condition.
Annual bulk oil and fuel tank visual inspections:
Findings:
In response to a DRC request for information, EFR reviewed the White Mesa Mill Spill
Prevention Countermeasure and Control ("SPCC") Plan for the mill to ensure that all
inspection processes and oil containers are in conformance with those Federal (40CFR1l2)
regulations. In response (EFR September 7,2012letter), EFR removed the SPCC Plan as an
appendix to the SWBMPP. EFR additionally removed the Emergency Response Plan as an
appendix to the SWBMPP. The removal of these documents was done in order to maintain
each plan as a stand-alone document. EFR states in the September 7,20L2letter that"the
requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are not part of the SWBMPP and are addressed separately in other
documents, specifically, the Spill Prevention control and Countermeasures Plan, the
Emergency Response Plan, and the housekeeping procedures within Mill SOP's." Per
comments related to inspection of the propane tanks and applicability of those requirements
in the SPCC Plan, a revised copy was submitted with the September 7,2}lzletter (SPCC
Plan dated September, 20).2).
DRC has no additional comments regarding the SPCC Plan, and future storm water
inspections will focus on insuring that the SWBMPP adequately addresses all requirements
of the Permit, including spill reporting requirements in Part I.D.10, which specifically
requires actions for identification and cleanup of reagent and chemical spills for non-
reportable quantities and procedures for reportable quantity spills in conformance with Utah
Administrative Code I9-5-I I4.
Tank and pipeline thickness tests:
Findings: During the inspection period the slurry pipelines were noted to be in good
condition. DRC has no additional comments related to the pipeline tests.
Quarterly and annual PCB transformer inspections (currently PCB only):
Findings: The Mill currently does not currently inspect the transfoffners based on all
transformers containing non-PCB based oil.
Spill Incident Reports:
Findings: This item is discussed above in the section related to reportable and small quantity
spills. DRC notes that an effective spill reporting and tracking system has been implemented
at the Mill.
Latest revision of SPCC plan (onsite and available?):
Findings: The SPCC plan was not requested during the inspection.
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 DRC findings the personnel training has been
implemented and appears to be effective. All Mill staff received training regarding the small
quantity spill notification process. DRC has no additional comments related to personnel
training.
Section II -- Site lValk through Inspection
Areas and Observations:
Ore Storage:
Observations: All berms appeared to be in good condition, there was no ore stored on the
pad at the time of the inspection (Photos 3, 5 and 6). There are no additional comments
regarding the ore storage area.
Reagent Yard:
Observations: Per DRC inspection of the reagent yard and storage building, it appeared that
drum storage was appropriate. No degraded or tapped drums were noted in those areas.
ShopA/ehicle Maintenance Area :
Observations:
Oil Drum Storage Rack:
Per the 2013 inspection all drums were stored on the pallets and no observable fluid
accumulation was seen in the pallet secondary containments. (Photo 13)
Shop Building Drain to Baffle Box:
Per DRC inspection of the shop baffle box, no comments were noted (Photo 16).
Used Oil/Kerosene Tank North of Shop Building:
Per DRC inspection of the used oil tank and kerosene tank containment, it appeared that
previous violations concerning spills outside of the containments were addressed; no
additional issues/comments were noted. (Photo T4, L5)
Mill Processing Areas:
SX Building Roof Drainage:
Per the 2013 inspection, issues related to the roof drainage and discharges into the alternate
feed circuit have been addressed. DRC communicated to the EFR staff that the drainage
needs to be inspected during a storm event to ensure that all roof drainage is diverted in the
directions intended. Specifically, the roof drainage is intended to divert either to cell 1 (south
side of building drainage) or to Roberts Pond (roof north side of building). (Photos 31
through 35)
Alternate Feed Circuit South of SX Building:
Observations:
All feedstock at the alternate feed circuit was stored and managed on the new concrete pads.
The concrete pads appeared to be in good condition. DRC has no additional
comments/observations regarding the altemate feed area. (Photos 26 through 30)
Old Decontamination Pad:
DRC has no comments regarding the old decontamination pad.
New Decontamination Pad:
Observations:
The pump back system and east apron drainage appeared to be in good condition (Photos 7,
8). DRC staff had no additional comments.
Reagent Tanks:
Sodium Chloride Tanks - Per past agreements between DRC 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, and in Part
I.D.3(g). No issues were noted during the 2013 inspection.
Kerosene Tanks (West of Shop) - Appeared in good condition, no additional comments.
Note: Secondary containment is earthen under the same agteement as the sodium chloride
tanks.
Ammonia Tanks - DRC noted that the tank was undergoing maintenance/refurbishing at the
time of the inspection (sandblasting and re-painting). Secondary containment is earthen per
the same agreement as the sodium chloride tanks. (Photo 4)
Used Oil Tank (shop) - Appeared in good condition, no additional comments.
Kerosene Tank (shop) - Appeared in good condition, no additional comments.
Fuel Tanks - Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks - Secondary containment appeared to be in good condition (Photo
22).DPIC had no additional comments regarding tanks or secondary containment.
Vanadium Pregnant Liquor (VPL) Tanks - The VPL tank steam condensate containment
area, tanks and foundations appeared to be in good condition. (Photo 17)
Clean Water Tank - DRC noted that a new water treatment house is being constructed
which should eliminate the leaks previously observed at the old chlorination house (Photos
23,24). No additional comments.
Sulfuric Acid Tank - The tank and berm appeared in good condition. No additional
comments.
Caustic Soda Tank - Per the 2013 inspection it was noted that, in response to Confirmatory
Actions, the caustic acid secondary containment area has been re-poured and that a new tank
has been installed (Photo 36). No additional comments.
Soda Ash Tanks - The Soda Ash Tanks and Secondary Containment appeared to be
maintained. DRC noted that water from the chloroform pump system was being discharged
into the containment area drain. DRC has no comments regarding this area. (Photos 37, 38)
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC toured the tailings cell areas (Cells 4,A. and 48 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. The dikes appeared to be in overall good
condition. (Photos 41, 42, 43)
Summary of Onsite Closeout Meeting:
Date/Time: June 21, 20l2ll1 :30 P.M.
EFR Representatives Present -- Daniel Hillsten, Mill Manager
David Turk
Tanner Holiday
DRC Representatives Present - Tom Rushing
An onsite close-out meeting took place amongst Tom Rushing (DRC), Dan Hillsten (EFR
Mill Manager), David Turk (EFR) and Tanner Holliday (EFR). During this meeting, DRC
informed the EFR representative of the inspection findings above.
Conclusions
A close-out letter regarding the2013 storm water inspection will be sent to EFR. DRC notes
that overall, the Mill facility storm water management and spill training and reporting has
significantly improved in recent years.
F:\Energy Fuels\Storm Water ManagementV0l3 SW Inspection\White Mesa Mill 2013 SW Inspection Memo.docx
Ground Water Module 65, DRC 2013 Annual Storm Water Inspection
Appendix 1-PhotoPages
10
Utah Division of Radiation Control
2013 AnnualStorm Water lnspection
lnspection Date June 4,2OL3
Photo Pages
Photo 1.- Kerosene tanks on cement platforms
Photo 2 - Sodium chlorate tanks in cement containment
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Photo 4 - Storm water detention southwest corner of ore pad - drains to cell 1
Photo 5 - Ore pad and south berm, photo looking southeast
Photo 5 - Ore pad, No ore piles
Photo 7 -southeast ore pad berm and lined drainage ditch
Photo 8 - New Decontamination pad pump back system in cement containment
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Photo 9 - Ore Pad east side (note that the ore pad is graded to drain to the west)
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Photo 11- Ore pad looking northwest
Photo 10 - Ore pad east margin berm looking north
Photo 12 - Drum storage at maintenance shop (drums on containment pallets)
Photo 13 - Containment under drum storage at the maintenance shop
Photo 14 - Used oil and kerosene tanks and containment (north side of maintenance shop)
containment area since that time)
Photo 16 - North side of maintenance building baffle box containment (box is pumped to Roberts Pond)
Photo 15 - Kerosene tank valve (note stain was from previous noted leak, tank has been moved further into
Photo 17 - Vanadium Pregnant Liquor (VPL) Tanks on concrete platforms
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Photo 18 - Mill building looking southwest
Photo 19 - Grizzly (Ore in drums to be used for stack tests)
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Photo 20 - Mill building east side (foreground corner marker for Phase lll ammonium sulfate crystal tank geoprobe
investigation)
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Photo 21- Chemical storage building
Photo 23 - New water treatment building (clean water treatment and chlorination)
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Photo 24 - Old clean water chlorination building will be removed
Photo 25 - Clean water tank overflow drains to underground pipe system
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Photo 26 - Alternate feed storage pad
Photo 27 - Alternate feed processing area
Photo 28 - Alternate Feed storage pad looking southeast
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Photo 29 -Alternate feed storage pad looking northeast (note puddle low spot on pad)
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photo 30 - Arternate feeJpal, drunis waiti"r,m#sing rack
Photo 31 - SX building roof drainage gutter, drains to cell 1
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Photo 33 - SX building roof drainage, west side of building drains to Roberts Pond
Photo 35 - SX building and drainage
Photo 34 - Drainage from SX roof to Roberts Pond
Photo 36 - Caustic Soda Tank containment (new containment)
Photo 37 - Soda ash tank containment, note that containment has been patched. Water in containment is from
groundwater pumping well for chloroform ground water contamination
Photo 38 - Caustic soda tank containment drainage into SX building
Photo 39 - Upland diversion ditch 1 well maintained
Photo 40 - Upland diversion ditch 1
Photo 41- Berm and toe for cell4A well maintained, note vegetation
Photo 42 - Cell 4A well maintained, note vegetation
Photo 43 - Cell 44 berm well maintained
Photo 44 - Cell 4A/48 spillway
Photo 46 - Surplus storage area, note berm in background
State of Utah
GARY R. HERBERT
Goveraor
GREG BELL
Lieutenont Governor
THROUGH:
FROM:
File
Phil
Department of
Environmental Quality
Amanda Smith
Execalive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
Goble, Compliance Section Manager pL6 t/r/,-rs
rom Rushing, P.G. Je S / ra f tj
DArE: Marchts,2ot3 []RC-2Afi_00L649
SUBJECT: Environmental Protection Agency March 14,2013 Storm Water Inspection at the
White Mesa Uranium Mill
Summary:
Ort Marchl4,2013 representatives of the Utah Division of Radiation Control ("DRC") (Tom
Rushing and Boyd Imai) accompanied Region VIII Environmental Protection Agency ("EPA")
inspectors (Natasha Davis, Emilio Llamozas and Terry Brown) during an EPA inspection of the
White Mesa Uranium Mill, Blanding, Utah. The purpose of the DRC accompaniment was to
document activities during the inspection. Additionally, DRC took photos of the site areas
inspected during the day, with exception of upland diversion ditch 1. Copies of the photos are
attached to rhis memo.
Opening Meeting:
Present: Natasha Davis (EPA), Emilio Llamozas (EPA), Terry Brown (EPA), David Turk,
Energy Fuels Resources (USA) Inc. ("EFR"), Garin Palmer (EFR), Tom Rushing
(DRC), Boyd Imai (DRC)
Natasha Davis opened the meeting and summarizedthatthe EPA inspection was the result of a
complaint received from the Ute Mountain Ute Tribe. She reported that the Tribe was concerned
that contaminated storm water was being discharged from the White Mesa Facility. She also
wanted to see the location of Entrance Spring.
Terry Brown stated that his purpose was to inspect items related to the Tribe complaint.
Specifically, he was concerned with potential contamination from wind blown dust off of the ore
pad, high historical concentration of parameters at groundwater monitoring well MW-22, and the
location of the liner tear and repair of Cell 1.
195 North 1950 West. Salt take City, UT
Mailing Address: P,O. Box 144850 . Salt hke City, UT 841144850
Telephone [phone] . Fax [phone] . T.D.D. (801) 5364414
w.deq.utah.gn
Printed on l00o/o recycled paper
Page2
Tom Rushing stated that the purpose of the DRC was to accompany the EPA inspection and
clarified that a DRC inspection was not being undertaken.
Document Review:
Natasha Davis requested copies of the Stormwater Best Management Practices Plan (SWBMPP),
the most recent DRC inspection report (2012) and the EFR response to the DRC inspection. The
documents were provided by EFR. Natasha Davis reviewed the SWBMPP and Emilio Llamozas
reviewed the DRC inspection during the report review.
Terry Brown requested a copy of the historic data for monitoring well MW-22. EFR provided a
table of the data.
Site Walkthrough (Ore Storage Pad and Processing Area):
Present:Natasha Davis (EPA), Emilio Llamozas (EPA), Terry Brown (EPA), David Turk,
Energy Fuels Resources (USA) Inc. ("EFR"), Garrin Palmer (EFR), Tom Rushing
(DRC), Boyd Imai (DRC)
The ore storage pad was toured starting at the southwest margin. EPA inspectors (Natasha Davis
and Emilio Llamozas) were specifically looking at the diversion berm around the pad, the storm
water drainage system, and grading. EPA inspector (Terry Brown) was specifically looking at
dust mitigation measures undertaken by EFR on the ore storage pad.
It was noted that the ore storage pad was graded to the west and that storm water drainage was
primarily diverted toward the facility and was routed to Cell 1. EPA asked for clarification
regarding a past DRC Notice of Violation regarding the discharge of process water from the new
decontamination pad ditch out of the restricted arca at the southeast corner of the facility.
EP,'^ asked for clarification regarding dust mitigation from the Ore Storage Pad. EFR responded
that dust mitigation was conducted according to requirements by the Utah Division of Air Quality.
The ore piles were sprayed with water several times per day, and alternate feed that was not
drummed or otherwise containerized was covered with topsoil to avoid the blowing of material
offsite.
The south, east and north margins of the ore storage pad were walked during the inspection.
Conference Call 1:
Present:David Frydenlund (EFR, via telephone), Harold Roberts (EFR, via telephone), Jo
Ann Tischler (EFR, via telephone), Kathy Weinel (EFR, via telephone), Natasha
Davis (EPA), Emilio Llamozas (EPA), Terry Brown (EPA), David Turk, Energy
Fuels Resources (USA) lnc. ("EFR"), Garrin Palmer (EFR), Tom Rushing (DRC),
Boyd Imai (DRC)
After the processing area site walkthrough a telephone conference was held. The call was
initiated by EFR.
Page 3
David Frydenlund communicated the following during the call:
1. It is his understanding that the EPA does not have jurisdiction at the facility regarding
water management issues since the Atomic Energy Act defines by-product materials under
part 1le.(z) and outlines the primary regulating entity as the Nuclear Regulatory
Commission.
2. EFR will not allow the EPA inspectors to keep the documents that were provided.
In response, Natasha Davis stated that she had not heard that EPA did not have jurisdiction at
Uranium Mill Facilities and that it was her understanding that EPA had authority to inspect any
industrial facility regardless of the facility process.
David Frydenlund stated that this issue needed to be resolved and requested that the EPA
attorneys contact him to clarify the legal jurisdiction. It was agreed that the site walkthrough
inspection could continue.
After the conference call Natasha Davis contacted EPA attorney Jim Eppers (sp?) who agreed to
contact David Frydenlund directly.
Site Walkthrough (Water Management Ponds, Tailings Cells, Upland Diversion Ditch 1 and
Boneyard):
Present: Natasha Davis (EPA), Emilio Llamozas (EPA), Terry Brown (EPA), David Turk,
Energy Fuels Resources (USA) [nc. ("EFR"), Garrin Palmer (EFR), Tom Rushing
(DRC), Boyd Imai (DRC)
The upland diversion ditch I was inspected. It was noted that the ditch was well maintained and
designed for a very large storm event volume.
Cell I (Evaporation Pond) was inspected. EPA inspector (Terry Brown) request to specifically
observe the location at Cell I where the liner was breached and repaired.
Tailings Cells 4A and 4B were observed. It was noted that only Cell4A was receiving tailings
and that Cell 48 was crurently used as an evaporation pond.
The boneyard was toured. It was noted that a large (approx. 20 ft. high) berm surrounded the
boneyard area.
Conference Call2:
Present: David Frydenlund (EFR, via telephone), Harold Roberts (EFR, via telephone), Jo
Ann Tischler (EFR, via telephone), Kathy Weinel (EFR, via telephone), Natasha
Davis (EPA), Emilio Llamozas (EPA), Terry Brown (EPA), David Turk, Energy
Fuels Resources (USA) Inc. ("EFR"), Garrin Palmer (EFR), Tom Rushing (DRC),
Boyd Imai (DRC)
Page 4
After the site inspection of the boneyard a second conference call took place. David Frydenlund
communicated the following:
l. He had an initial conversation with the EPA attorney
2. The issue of EPA jurisdiction was not fully resolved and additional conversation was
needed
3. He would allow Natasha Davis and Emilio Llamozas to take the documents they requested
with the provision that the documents be logged and signed for
4. He would not allow Terry Brown to take the data table for monitoring well MW-22
It was agreed that the inspection close-out meeting would be delayed until further determination
of EPA legal jurisdiction at the mill facility. Natasha Davis reported that she would arrange a
close-out conference to be held via conference call for the following week.
Entrance Spring Inspection :
Present: Natasha Davis (EPA), Emilio Llamozas (EPA), Terry Brown (EPA), David Turk,
Energy Fuels Resources (USA) Inc. ("EFR"), Garrin Palmer (EFR), Tom Rushing
(DRC), Boyd Imai (DRC)
The group inspected Entrance Spring located east of the mill facility. No specific observations
were noted.
Utah DRC Accompaniment with EPA Storm Water lnspection
lnspection Date, March L4,2073
Photo Log of Areas Toured
1-. Berm on Southwest side of Ore Pad
2. Ore Pad looking east toward new decontamination facility (upward slope)
3. Southwest corner ore pad storm drain and berm
4. East ore pad berm (photo looking north toward Abajo Mountains)
5. Standing water (puddle) at northeast ore pad area
6. North ore pad berm (Photo looking west towards Bears Ears, Black Mesa)
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7. Area around sulfuric acid tank where storm water had accumulated. EFR had pumped standing
water in this area
8. Photo looking west (towards Black Mesa) of Cell 1 and restricted area berm (foreground)
9. Cell 1 looking east toward mill facility
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10. Cell 1 northeast corner where liner repair was undertaken (area of past liner tear)
11. Cell48
12. Cell44
13. Berm above boneyard
14. Entrance Spring