DRC-2013-003031 - 0901a068803b2919

Department of
Environmental Quality
Amanda Smith
Executive Director
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
ll
DRC-2013-003031 II
July 2,2013
JoAnn Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO, US 80228
[phone]
Subject: Review of Energy Fuels Resources (USA) Inc. White Mesa Mill Tailings
Characterization and Analysis Work Plan, June 2013: DRC Request for Information
Dear JoAnn:
This review presents concerns and questions that the Utah Division of Radiation Control (DRC)
has concerning Energy Fuels Resources (USA) Inc. (EFRI) White Mesa Mill Tailings
Characterization and Analysis Work Plan, dated June 2013. The following items present these
questions and concerns, with relevant page numbers specified.
P4 EFRI Statement in Section 2.2:
"Maximum acceptable probe depths are shown on Figure 3 and discussed in Section 3.2."
DRC Comment:
Please change "Figure 3" to "Figure 2." Only Figure 2 shows "Maximum CPT Probe
Depth" as indicated in the Figure 2 legend. Figure 3, by contrast, shows the entire "Depth
of Interim Cover and Tailings," as is indicated in the Figure's legend, which is generally
three to five feet greater than the maximum acceptable probe depth.
P7 EFRI Atterberg Limits Reference in Table 1 in Section 2.6:
The ASTM standard for Atterberg Limits is given as '#'ASTM D4218."
DRC Comment:
Please change "ASTM D4218" to "ASTM D4318." Only the latter refers to the ASTM
Atterberg Limits standard.
195 North 1950 West • Salt Lake City, UT
Mailing Address P.O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax(801) 533^097-TDD [phone]
www deq Utah gov
Pnnted on 100% recycled paper
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FIG 2 EFRI Proposed CPT Locations:
Only seven proposed CPT locations are shown for each of Cells 2 and 3.
DRC Comment:
Please justify the proposing of only seven CPT locations for each of Cells 2 and 3. With a
total of 14 locations over 135 acres, this results in a total of only approximately one CPT
sounding per 10 acres of cell, on average. Please justify why this relatively low CPT-
sounding density should be considered to provide adequate, representative subsurface soil
and tailings information for the cells, both for the coarse-grained tailings materials
expected to be dominant near cell edges, and fine-grained tailings materials expected to be
dominant in cell interiors. It is noted that, for Cell 3, a total of six CPT locations are
proposed near the cell edges, but only one CPT location (3-2C) is proposed in the cell
interior. Please propose a program that, based on geostatistical analysis, offers a
reasonable level of confidence in the final results.
FIG 3 EFRI Existing and Proposed Settlement Monitoring Points:
Figure 3 shows settlement Monitoring Point 2W3 having a "total measured settlement" (as
described in the legend) of -1.80 feet, whereas Page 11 states that "Measured settlement
from July 2012 to [sic] present ranges from 0 to 1.4 inches" (0.12 feet)."
DRC Comment:
Settlement Monitoring Point 2W3 in Figure 3, which is said to be based on July, 2012
data, shows a "Total Measured Settlement (ft)" (as described in the legend) of-1.80 feet.
However, the text on Page 11 claims a different number, saying, "Measured settlement
from July 2012 to [sic] present ranges from 0 to 1.4 inches" (0.12 feet). Please explain the
apparent large discrepancy between these two numbers.
PI 1 EFRI Statement in Section 3.2:
"Figure 2 provides the estimated depth to liner for all the existing settlement monuments in
Cells 2 and 3."
DRC Comment:
Please change "Figure 2" to "Figure 3." Figure 2 provides "Maximum CPT Probe Depth."
It is only Figure 3 that provides "Depth of Interim Cover and Tailings," which is
comparable to "estimated depth to liner."
AppA MWH Statement on Page 14 of Appendix A:
". .. should be considered if insects are a prevalent."
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Page 3
DRC Comment:
Please change the above statement to the following: "... should be considered if insects
are prevalent." Elimination of grammatical errors leads to better understandability and thus
to improved safety.
AppE EFRI Statement on Page 91 of 101:
"whenever, work is performed in an environment, which requires special protection, such
as respirators, hearing protection, goggles or face shield, wet suits, etc. this protection must
be worn."
DRC Comment:
Please fix grammatical errors to improve readability, comprehension, and, thus, safety.
The sentence should read, "Whenever work is performed in an environment that requires
special protection, such as respirators, hearing protection, goggles or face shield, wet suits,
etc., this protection must be worn."
AppE EFRI Statement on Page 93 of 101:
"Persons taking medication will not be permitted to work it is affects their performance or
judgment."
DRC Comment:
Please change to "Persons taking medication will not be permitted to work if it affects
their performance or judgment."
Please address the concerns or discrepancies identified and provide the justification or rationale
regarding the CPT sampling size of seven locations. If you have any concerns regarding this letter,
please feel free to call me at 801-536-4263.
Sincerely,
tfohn Hultquist/Licensing Manager
Division of Radiation Control
JH/DE
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