DRC-2015-001889 - 0901a068805141d7

Department of
Environmental Quality
Amanda Smith
Executive Direclor
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
SPENCER J. COX
Lieutenant Governor DRC-2015-001889
May 23, 2015 D Kathy Weinel
Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd., Suite 600
Lakewood, CO 80228
Subject: Compliance: As-built Drawings for Concrete Cover for Nitrate Contaminated Soils and
Drawings for Additional Cover Beneath Ammonium Sulfate Crystal Tanks, Ground
Water Quality Discharge Permit UGW370004: Approval of Phase 1 As-Built
Drawings and Phase 1 Construction; Conditional Approval of Phase 2 Plans
Dear Ms. Weinel:
On October 16, 2014 the Utah Division of Radiation Control (DRC) approved drawings for a
concrete cover to prevent water from penetrating to nitrate-contaminated soils immediately east of
the main mill building. Representatives of the DRC inspected the concrete placed pursuant to that
plan approval on February 6, 2015 and on February 12, 2015. On March 13, 2015, the DRC
received as-built drawings for the construction of that concrete cover. The concrete placed to date
appears to satisfy the specifications detailed in the approved plans. Furthermore, the as-built plans
appear faithfully to reflect the construction completed to date. The construction completed thus
far, and the as-built plans are, therefore, approved.
Two items remain to be addressed with respect to the concrete cover. The first is curbing on the
perimeter of the concrete apron. As originally conceived, the concrete apron would have been
insufficient to control water flow and prevent flooding of a portion of the soil strata overlying the
contaminated zone. The approved plans extended the concrete cover beyond the originally
intended limits. The concrete as placed now provides protection of the areas the curbing would
have addressed. The curbing is, therefore, no longer necessary.
The concrete beneath the ammonium sulfate crystal tanks was to be addressed as part of the
concrete cover project. The DRC received plans for this phase of the construction (Phase 2 Plans)
on March 13, 2015. The existing, weathered concrete beneath the crystal tanks would be cleaned
of loose4ebris and a minimum of 6" of new concrete cap would-be placed over the prepared
surface. Following review of the Phase 2 Plans, the DRC received clarification of the intended
treatment of the joint between the Phase 1 and Phase 2 concrete placement; specifically, that the
Phase 2 concrete would overlie approximately 6 inches of the Phase 1 concrete. A water-resistant
barrier material of some kind would be placed in the construction joint. Waterstop previously
placed between the Phase 1 concrete and the existing concrete tank foundation would provide the
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
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Printed on 100% recycled paper
Kathy Weinel
Page 2
March 23. 2015
primary water barrier, with the joint filler between the two phases and a surface sealant providing
additional protection. This additional detail will be included on the as-built plans. The Phase 2
Plans are, therefore, approved, subject to the conditions detailed in this paragraph.
Please keep the DRC informed of the construction schedule for this project.
If you have any questions please contact at Russ Topham at [phone].
Sincerely,
Rusty Lundberg
Director
RI./RJT:rjt