DRC-2016-012282 - 0901a068806992ec

IM#
State of Utah
GARY R HERBERT
Governor
SEENCCR J COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMEN T
AND RADIATION CONTROL
Scott T Anderson
Director
MEMORANDUM
TO:File C-2016-42
THROUGH:Phil Goble, Section Manager
M
FROM:Russell J. Topham, P.E. fy'
DATE:December 6, 2016
SUBJECT: Compliance: 2016 Engineering Module 76.
Materials License UT1900479 (RML)
DRC-2016-0IZ2SZ
tty/u/k
Annual Technical Evaluation Report; Radioactive
On November 14, 2016, the Utah Division of Waste Management and Radiation Control (DWMRC) received the
2016 Annual Technical Evaluation Report (ATER) dated November 11,2016 and covering the November 1, 2015
to October 31.2016 monitoring period. DWMRC received the Report in both hard copy and CD formats.
Summary
After review of the ATER, DWMRC staff findings and recommendations are as follows:
The DWMRC should monitor performance of the tailings management system closely as Cell 4A fills, and
Energy Fuels Resources (EFR) closes Cell 3 and begins depositing tailings in Cell 4B, looking for recurrence of
historic problems maintaining freeboard. This comment repeats a notation in the ATER reviews for 2012 through
2015.
General Requirements
Condition 12.3 of the RML requires preparation of the ATER, specifies the content, and fixes the date by which
the DWMRC must receive the ATER. The Tailings Management System (TMS) document guides much of the
work reviewed and reported in the ATER. EFR used TMS revision 2.1, dated July, 2012 (the most recent
revision) in the preparation of the 2016 ATER. The report as prepared and submitted meets the requirements for
content and timeliness.
Maintaining Freeboard
The 2011 ATER contained.detail of instances where EFR failed to maintain appropriate freeboard in the various
cells involved in the TMS. The reports for 2012 through 2016 contain data showing that EFR successfully
maintained fluid levels without exceeding freeboard during from 2012 through 2016. Thus, EFR appears to have
resolved the problems that historically caused the fluid level to exceed established limits. As processing of ore
DWMRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address PO Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] •TDD [phone]
. mirw.deq.utnh.gov
Printed on 100% recycled paper
Page 2
and alternate feeds continues, the tailings beach in Cell 4A expands. Given the problems maintaining freeboard
during the 201 1 monitoring period, the DWMRC should monitor freeboard performance closely as Cell 4A fills.
Monitoring of Lateral Displacement
Movement monitors for Cells 4A and 4B showed no evidence of disturbance.
Monitoring of Vertical Displacement
Settlement monitors for Cell 2 show acceleration of settlement with the addition of the Radon barrier material, as
expected.
Cell 3 has sufficient fluid in interstices in the tailings mass that areas receiving fill, i.e., placement of waste and
cover, are settling, while areas that are not receiving fill are heaving. This is not surprising, inasmuch as the
saturated tailings are behaving like a fluid, rather than a solid. Once dewatering of the cell commences, this
situation should stabilize.
Monitors at the toe of the Cell 4A embankment toe reveal no motion. The toe is stable.
lle.(2) Waste Disposal
The Licensee disposed 838.5 cubic yards of 1 le.(2) waste from in-situ leach facilities during the reporting period.
Inspection of this activity and an audit of paperwork have been performed separately from the review of this
report. The disposal has been conducted and documented according to Standard Operating Procedure PBL-10.
Tailings Transport System
The licensee uses HOPE pipe to carry tailings slurry to the active cell, in this case Cell 4A. Identical solution
lines run between the mill and Cells 1 and 4B for fluid management. These pipelines are inspected daily for
leakage and repaired as required to prevent releases. No releases were reported.