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HomeMy WebLinkAboutDRC-2024-007606Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 1 Inspection Year: 2024 Inspection Date: November 5, 2024 Module Reviewer Name: Heather Mickelson, P.E., P.G. Adam Wingate, Manager Module Prepared by/Date Prepared: Chris Leahy, P.G./November 22, 2024 Staff Present: Chris Leahy Adam Wingate Energy Fuels Resources (EFR) Staff Present: Garrin Palmer EFR Staff Interviewed: Garrin Palmer Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements Inspected: Part I.D.10 Requires management of contact and non-contact storm water and control of contaminant spills in accordance with the currently approved Storm Water Best Management Practices Plan (SWBMPP), Spill Prevention Control and Countermeasures Plan (SPCC), and applicable sections of the Utah Administrative Code. Part I.D.11 Requirements for Feedstock Material Stored Outside of the Mill Feedstock Storage Area, including requirements for container integrity, storage on an engineered impervious surface, and controls for storm water run-on and run-off. Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm Water Best Management Practices Plan for the White Mesa Uranium Mill: SPCC: September 8, 2023 (Approved by the Division on October 16, 2023). SWBMPP: April 14, 2022 (Approved by the Division on May 5, 2022). Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 2 Section I Document Review SWBMPP (Documentation Requirements): SWBMPP Part 4.1.4. -- Diversion ditches, drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair, such as excessive vegetative growth, channel erosion, or pooling of surface water runoff will be reported to appropriate departments, and all follow up actions are to be documented. Findings: The Division conducted an inspection of upland diversion ditches 1, 2, and 3 and associated diversion berms. Per the inspection, the ditches and berms appeared to be well maintained. No excessive debris or erosion was noted in the ditches and excessive vegetation growth was not present. EFR inspects the diversion ditches and berms monthly and fields are included on the monthly inspection data form. The Division reviewed the March 2024 monthly form, the EFR Inspector noted that the Diversion Ditches showed no signs of sloughing, erosion, undesirable vegetation, or obstructions of flow. SWBMPP Appendix 1 Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation Requirements): 1.6.1. Daily monitoring of propane tanks required. Findings: Per an EFR response to an August 8, 2012, Request for Information from the Division: The EFR Spill Prevention, Control, and Countermeasures Plan, Part 1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include the inspection findings with the daily inspection form used for storm water inspection documentation within 30 days from your receipt of this letter, has removed the daily inspection requirement on the basis that the propane is a gas at ambient conditions and would be immediately vaporized under all foreseeable leakage conditions at the Mill. The Division concurred with this action and this item is no longer inspected as part of the documentation review or included on the site walkthrough. Log, along with other areas and tanks (2024 Logs were inspected no comments regarding disrepair or inaccessibility of the tanks was noted). 1.9.1. Findings: No reportable quantity spills were reported by EFR during the period reviewed. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 3 1.9.2. Internal Notification of incidents, spills, and significant spills. The White Mesa Mill employees are using a formatted card to report the small quantity spills; the card is titled Non-Reportable Reportable Spillage. The card provides the following information: Name, Date of Discovery, Approximate Amount Spilled, Time of Discovery, Location of Incident, Description of Material Spilled, Cleanup Activities Taken and Signature. The reports additionally include photographs of the spill and follow up actions for all reported small quantity spills. Small quantity spill reports were reviewed between the date of the last inspection (11/8/2023) to the current inspection date (11/5/2024). A total of 11 small quantity spills and follow up actions were reported during that time frame. Per Division review it appears that the spills are being adequately reported and follow up actions are described, and in all cases, photos of the spill and clean-up are included. During 2024, EFR implemented the storm water training program with the annual SPCC refresher on 3/29/24. A total of 72 employees were trained. Any new employees hired after 3/29/24 were trained individually during onboarding. Per Division cross check, it appears all spill cards were filled out by personnel who had completed the SPCC and storm water training. The spill reporting provides records of identification and follow-up procedures thereby making the chemical management at the mill transparent and supports employee involvement in spill identification, reporting, and follow-up. 1.10 Records and Reports. Period of Records Examined During Inspection: Begin/Ending: 3/1/2024 through 3/31/2024 No. of On-site Records Required: Daily, Weekly, Monthly, and/or Quarterly Forms No. of On-site Records Found: All Stormwater Related Records/Reports Onsite No of Records Examined: July 2024 (31 days) How Selected: The Division inspected a random month of daily, weekly, monthly, and/or quarterly forms completed since the last annual Division Storm Water Inspection. Daily Tailings Inspection Data: Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-1 of the Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport system (Slurry pipeline, pipeline joints and supports, valves and point of discharge). 2. Operational systems (interior cell walls, water level, beach, liner, and cover). 3. Dikes and embankments (slopes and crest) to check for erosion and seepage. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 4 4. Physical inspection of the slurry lines. 5. Dust control and leak detection are conducted daily and documented on a daily inspection form. The forms additionally include fields for observations of potential concerns and actions required. Spills and clean up actions are noted in the text boxes for these fields. Additionally, EFR inspects tank integrity daily (including fuel tanks) and reports comments (e.g. odors or leaks) The Division randomly selected and reviewed the Appendix A-1 daily forms log for the month of March 2024 (daily forms). The forms and log appeared to be appropriate and inspections were conducted on all days. There are no additional comments regarding the forms or log. Weekly Tailings Inspections and Survey: Findings: Weekly tailings inspections were done and documented on weekly tailings inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection Manual Section 3.1. The forms include sections to document pond elevations (solution elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, and 4B, as well as slimes drain liquid levels for Cell 2. The form also includes information regarding the leak detection systems for Cells 1, 2, 3, 4A, and 4B as well as the potential blowing of tailings and condition of concrete at the decontamination pad. The Division inspected the March 2024 weekly forms. All forms were filled out and identified the individuals completing the inspections. Per the 2024 Division storm water inspection, the inspection forms reviewed appeared to be completed appropriately. There are no additional comments regarding the forms. Monthly Tailings Inspection - Pipeline Thickness: Findings: Monthly inspection data is documented on Appendix A-3 of the Environmental Protection Manual, Section 3. The Division reviewed the EFR monthly inspection report dated March 28, 2024. The monthly inspection reports include sections related to the slurry pipelines and also diversion ditches which stated that no issues occurred during the month. There are no additional comments regarding the forms. Quarterly Tailings Inspection - Embankments: Findings: Quarterly inspection data is documented on Appendix A-4 of the Environmental Protection Manual, Section 3. The Division reviewed the EFR quarterly inspection report dated March 29, 2024. Regarding the embankment inspection it was noted that all embankments were in good condition. There are no additional comments regarding the forms. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 5 Tank to soil potential measurements: This item was included as part of a September 1, 2011 Division Request for Information RFI , RFI # 2. The Division had concerns regarding on-grade tanks (tanks where the bottom is in contact with soil). Per Division communication with EFR it was clarified that tanks which sit on the ground must have cathodic protection or sit on a concrete foundation. Findings: Per Division inspection of the tank foundations during the 2024 inspection, no issues regarding the concrete foundations were noted. Tank and pipeline thickness tests: Findings: During the inspection period, as noted on the EFR monthly inspection form, and - the slurry pipelines were noted to be in good condition by EFR. Spill Incident Reports: Findings: This item is discussed above in the section related to reportable and small quantity spills. The Division notes that an effective spill reporting and tracking system has been implemented at the Mill. 1.11 Personnel training and Spill Prevention Procedures (records of training required to be maintained in the general safety training files): Personnel training for spill prevention are discussed in the internal notification of spills section of this module above. Per Division findings, the personnel training has been implemented and appears to be effective. Mill staff attend an annual SPCC training regarding the small quantity internal spill notification process. If new employees are hired after the annual SPCC training, they are trained individually during onboarding. Section II -- Site Walk-through Inspection Areas and Observations: Ore Storage: Due to a recent rain event, some small areas of storm water ponding were noted on the ore pad. Areas around the detention tank (kiva) were not accessible yet for contractors to remove the water due to muddy conditions persisting. Per an Energy Fuels White Mesa internal memo supplied to the Division, this will be completed as soon as conditions allow. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 6 Photo 1: Ore storage area surrounding the Kiva. Muddy conditions still present due to recent rain events. Photo 2: Storm water detention tank (kiva). Storm water will be removed as soon contractor crews can access. Reagent Yard: Per observations, no issues were noted regarding reagent storage. Shop/Vehicle Maintenance Area: Areas inside of the vehicle maintenance shop and surrounding area drain through the pipeline to Cell 1. The Division noted that hydraulic fluid and oil drums were stored on secondary containment. The secondary containments were generally free of standing water. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 7 Photo 3: Secondary containments under oil and hydraulic fluid drums Mill Processing Areas: Alternate Feed Circuit South of the SX Building: The tanks and concrete containment appeared in good condition. No additional comments were noted. Photo 4: Alternate feed circuit tanks and secondary containment Storage Area West of the SX Building: All drums/containers of alternate feed were stored on the concrete impervious surface areas and the concrete staging pads also appeared to be in good condition. No additional comments were noted during the 2024 inspection. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 8 New Decontamination Pad: The new decontamination pad is currently under repair and not in use during the time of inspection. Per inspection findings, no evidence of a discharge outside of the pad area was noted and no additional comments were noted during the 2024 inspection. Photo 5: New decontamination pad containment Old Decontamination Pad: While repairs are made to the new decontamination pad, the old decontamination pad will be used. It was in use at the time of inspection and no evidence of a discharge outside of the pad area was noted. No additional comments were noted during the 2024 inspection. Reagent Tanks: Sodium Chloride Tanks Per observations, no comments were noted during the 2024 inspection. Photo 6: Sodium chloride tanks and secondary containment Kerosene Tanks (West of Shop) Per past agreements between the Division 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 Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 9 Statement of Basis for the site Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit. The kerosene tanks and concrete platforms appeared in good condition. Photo 7: Kerosene tanks Ammonia Tanks Secondary containment is earthen per the same agreement as the kerosene tanks. Per observations, no comments were noted. Photo 8: Ammonia tanks Ammonium Sulfate Crystal Tanks The secondary containment and the surrounding impervious pad for the nitrate corrective action plan were in good condition. Minimal concrete spalling was observed. Kerosene Tank (shop) The shop kerosene tank sits in the same secondary containment as the used oil tank. No comments were noted. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 10 Photo 9: Kerosene and used oil tanks and associated containment. Fuel Tanks No comments were noted. The tanks and concrete containment appeared in good condition. Photo 10: Fuel tank area Uranium Liquor Tanks No comments were noted. Vanadium Pregnant Liquor (VPL) Tanks No comments were noted. Clean Water Tank The tank appeared in good condition. No comments were noted. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 11 Sulfuric Acid Tank The tank and concrete platform appeared in adequate condition. The berm around the tank was in good condition. No other comments were noted. Photo 11: Sulfuric Acid Tank. Caustic Soda Tank Spalling and some minor cracks were observed in the secondary containment. Per EFR, these tanks are not currently filled or in operation. Crews were cleaning dirt and debris in the containment at the time of inspection. No other comments were noted. Photo 12: Caustic soda tank containment Soda Ash Tanks Spalling was observed in the secondary containment for the soda ash. Per EFR, these tanks are not currently filled or in operation. No other comments were noted. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 12 Photo 13: Soda ash tank receiving area. HCL Tanks Spalling was observed on the surface of the concrete in the secondary containment. Some storm water remained in the containment from recent storms. Per EFR, the storm water will be pumped out by utility crews in the coming days. No other comments were noted. Photo 14: Spalling of concrete in HCL tank containment. Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004 13 Summary of Onsite Closeout Meeting: Date/Time: November 5, 2024/03:00 P.M. EFR Representatives Present Garrin Palmer (RSO) Tanner Holliday Division Representatives Present Adam Wingate Chris Leahy Dean Henderson An onsite close-out meeting took place to discuss findings of the storm water. Specifically, the following items were discussed by the Division: Documentation: The Division discussed that the documentation review appeared to be fully filled out and to address the requirements of the permit. No specific issues were identified. Site Walkthrough: The Division discussed that during the site walkthrough no specific violations were noted. The findings of spalling on the concrete surface under the soda ash tanks, caustic soda tanks, and HCL tanks was discussed. The concrete will be monitored to ensure that it is providing an impervious barrier, and if necessary, a concrete slurry will additionally be added on top. The Division is currently reviewing a proposed revision of the Discharge Minimization Technology Monitoring Plan (Revision 13.1 submitted by EFR in September 2024). Conclusions A close-out letter will be sent to EFR regarding the 2024 storm water inspection at the White Mesa Uranium Mill.