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Home My WebLink AboutDRC-2013-003351 - 0901a068803cffbdw *m/M ENE Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 ENERGY FUELS 303 974 2140 11 [^p^^—201 3~003351 " www.energyfu.els com October 18, 2013 Sent VIA OVERNIGHT DELIVERY Mr. Rusty Lundberg Division of Radiation Control Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4820 Re: Ore Pad Storm water Management Follow-up to Telephone Conversations with Utah Division of Radiation Control ("DRC") October 1 and October 2,2013 Dear Mr. Lundberg: This letter is a follow-up to telephone conversations between Utah DRC and Energy Fuels Resources (USA) Inc. ("EFRI") on October 1 and 2, 2013 regarding the existing ore pad storm water ditch and drain pipe at White Mesa Mill. DRC contacted EFRI on October 1, 2013 following DRC's September 27, 2013 DRC's inspection of at the Mill. The inspection followed the September 18 and 19, 2013 rain and hailstorm events which included a peak precipitation of 0.75 inch of rainfall within 10 minutes. In addition to conducting inspection modules, DRC inspectors Kevin Carney and Boyd Imai observed some of the storm related effects and post-storm cleanup and repair efforts underway on September 27. Mr. Phil Goble and Mr. Russ Topham of DRC contacted me on October 1, 2013 regarding an HDPE storm water transfer line at the bottom of a storm water ditch running along the southern edge of the administration building parking lot, which appeared to the inspectors to possibly be a temporary construction associated with post-storm repairs. Specifically, Mr. Goble asked EFRI to clarify the age and purpose of the pipeline and whether it was currently disconnected or connected to the concrete storm water catchment at the southwest corner of the ore pad. During an additional phone conversation on October 2, Mr. Goble requested that EFRI provide in writing: 1. A summary of the age and history of the drainage ditch and pipe, 2. Demonstration that its existence predated Utah's Agreement State Status and the Mill's DRC Radioactive Materials License, and £GE/|^ OCT 2013 W9 Sad 3. EFRI's proposal to minimize line damage and/or leakage. Letter to Mr. Rusty Lundberg October 18, 2013 Page 2 This letter responds to that request. History of the Ditch and Pipeline At the time of initial Mill construction in 1980, the ore pad was constructed with berms at the southwest corner of the pad inside the restricted area fence. The berms were intended to prevent the release of storm water that had been in contact with the ore pad or its contents. The berms resulted in collection of stagnant pools or ponding of standing water after heavy rainfall events. Ponded water from the ore pad gravity drained from the southwest corner of the ore pad via an open ditch which exited the restricted area and ran along the south side of the administration building parking lot. The ditch re-entered the restricted area at the west end of the parking lot and was sloped to drain its contents to Cell 1. In approximately 2000, the Mill voluntarily constructed an upgrade to the ore pad storm water management to eliminate the ponding at the southwest corner and enclose and improve transfer of storm water to Cell 1. At that time, the Mill installed a concrete catchment, approximately 5 feet in diameter and 2 feet deep, at the southwest corner of the ore pad, inside the restricted area. The catchment was connected via a closed system, specifically an HDPE storm water pipe buried near- surface at the bottom of the existing trench, which gravity drains to Cell 1. The berms remained in place. Both the storm water trench, and the catchment and pipeline upgrade, were part of the existing facilities in place prior to Utah's achievement of Agreement State Status and issuance of the Mill's State of Utah Radioactive Materials License in 2004. Storm Event of September 18,2013 As mentioned above, the Mill experienced several storm events during September 2013, which culminated in the September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary power outage which was resolved within 24 hours with no loss of environmental monitoring data. Following the September 18 storm, the Mill identified that the high volume and velocity of ore pad runoff ruptured the earthen berm at the southwest corner of the ore pad, carried ore pad soils beneath the fence, and deposited soils and silt into and along the trench containing the storm water pipe at the south end of the parking lot. The Mill was in the process of cleaning up the soils and silt at the time of the DRC inspection on September 27, 2013. The Mill cleaned up the discharged soils originating from the ore pad using practices consistent with those used for cleaning up spilled ores. The Radiation Department used a Ludlum MicroR Meter to establish background, and soils were excavated in and around the trench until the meter indicated that background levels were reached. Letter to Mr. Rusty Lundberg October 18, 2013 Page 3 To accommodate scanning and removal of potentially radiologically contaminated soils, Mill personnel had disconnected and removed sections of the pipe during the trench cleanout. The trench cleanout and confirmatory scanning was completed during the week of October 1, and the line reconnected to the concrete catchment. Commitments Requested by DRC EFRI agrees to make the following modifications to the operation of the storm water transfer line to minimize the potential for leakage of ore pad storm water from the line. 1. The formerly buried line, which has been reinstalled at the bottom of the trench, will remain uncovered for ease of inspection by environmental and/or maintenance personnel. 2. The line will be marked for visibility with yellow or other bright colored painted stripes. Flags or other markers will be added to the pipe or trench. 3. The pipeline will be inspected weekly and the inspection will be documented on the weekly ore storage inspection form. Clean and redlined copies of the revised weekly ore storage inspection form, showing the proposed inspection criteria, are provided in Attachment 1. If you should have any questions please contact me. Yours very truly, ENERGY FUELS RESOURCES (USA) INC. Jo Ann Tischler Manager, Compliance and Licensing cc: David Frydenlund Ronnie Nieves Harold R. Roberts Steve Snyder David Turk Katherine Weinel Dan Hillsten Central Files ATTACHMENT 1 I White Mesa Mill - Discharge Minimization Technology Monitoring Plan 3A310/13 Revision: Denison 12.24- Page 19 of 26 ATTACHMENT A-3 ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week of through Date of Inspection:. Inspector: Weather conditions for the week: Blowing dust conditions for the week: Corrective actions needed or taken for the week: Are all bulk feedstock materials stored in the area indicated on the attached diagram: yes: no: comments: Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained within water-tight containers: yes: no: comments (e.g., conditions of containers): Are all sumps and low lying areas free of standing solutions? Yes: No: If "No", how was the situation corrected, supervisor contacted and correction date? Is there free standing water or water running off of the feedstock stockpiles? Yes: No: Comments:. I White Mesa Mill - Discharge Minimization Technology Monitoring Plan 3A310/13 Revision: Denison 12.24- Page 20 of 26 Ore Pad Stormwater Transfer Line: Is the transfer line visible? Yes: Npj Comments: Is there free anv evidence of breakage, spillage or leakage? Yes: No: Comments: Other comments: White Mesa Mill - Discharge Minimization Technology Monitoring Plan 10/13 Revision: Denisonl2.2 Page 19 of 26 ATTACHMENT A-3 ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week of through Date of Inspection: Inspector: Weather conditions for the week: Blowing dust conditions for the week: Corrective actions needed or taken for the week: Are all bulk feedstock materials stored in the area indicated on the attached diagram: yes: no: comments:__ Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained within water-tight containers: yes: no: comments (e.g., conditions of containers): Are all sumps and low lying areas free of standing solutions? Yes: No: If "No", how was the situation corrected, supervisor contacted and correction date? Is there free standing water or water running off of the feedstock stockpiles? Yes: No: Comments: White Mesa Mill - Discharge Minimization Technology Monitoring Plan 10/13 Revision: Denisonl2.2 Page 20 of 26 Ore Pad Storm water Transfer Line: Is the transfer line visible? Yes: No: Comments: Is there free any evidence of breakage, spillage or leakage? Yes: No: Comments: Other comments: