DRC-2017-008181 - 0901a0688076d9a7

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State of Utah
Department of
Environmental Quality
Alan Matheson
Executive Director
GARY R. HERBERT
Governor
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director DRC-2017-00 e>lS lSPENCERJ COX
Lieutenant Governor
MEMORANDUM
TO:Project File C-2017-24
THROUGH: Russell J. Topham, PE
Phil Goble, Uranium Mill S Manager P^> ^
/o/ti/n
FROM: Heather Mickelson, PE Hk\ lo\ I FV
DATE: October 19,2017
SUBJECT: 2017 BAT/DMT Field Inspection; Radioactive Materials License Number UT1900479
VAC R317-6-4 Issuance of a Discharge Permit
“A. The Director may issue a ground water discharge permit for a new facility if the Director
determines, after reviewing the information provided under R317-6-6.3, that:...3. the applicant is using
best available technology to minimize the discharge of any pollutant;...”
VAC R313-15-406(2) Minimization of Contamination
“Licensees shall, to the extent practical, conduct operations to minimize the introduction of residual
radioactivity into the site, including the subsurface, in accordance with the existing radiation protection
requirements in Section R313-15-101 and radiological criteria for license termination in Sections R313-
15-1401 through R313-15-1406.”
Permit and License Conditions
The data collected during the BAT/DMT inspections is used to generate reports for the quarterly DMT
Performance Standards Monitoring Report and Cell 4A BAT Performance Standards Monitoring Report
and Annual Technical Evaluation Report of the White Mesa Tailings Management System. These
reports are used to show compliance with the following conditions in the Radioactive Materials License
and the Ground Water Discharge Permit.
and Ground Water Discharge Permit UG37004; Energy Fuels Resources White Mesa
Mill, Blanding, Utah
Authority
195 North 1950 West • Salt Lake City. UT
Mailing Address: P O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
umnu.deq.uttih.gov
Printed on 100% recycled paper
Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.3
“The licensee shall implement a monitoring program of the leak detection systems for disposal Cells 4A
and 4B in accordance with requirements of the Ground Water Discharge Permit. The licensee shall
implement a monitoring program of the leak detection systems for disposal Cells 1,2, and 3...”
Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.7
“Settlement Monitoring Standard Operating Procedure - the licensee shall submit for Director approval a
written Settlement Monitoring Standard Operating Procedure (SOP) on or before December 1, 2010.
The proposed SOP shall describe methods for monitoring vertical settlement in the tailings management
cell areas and for recording and documenting settlement monitoring data and comparing such data to
previous data to track potential settlement. All data collected by the Licensee for these purposes shall be
included in an annual report to be submitted to the Director, pursuant to License Condition 12.3....”
Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.8
“Movement (Displacement Monitoring Standard Operating Procedure - the licensee shall submit for
Director approval a written Movement Monitoring Standard Operating Procedure (SOP) on or before
December 1, 2010. The proposed SOP shall describe methods for monitoring potential vertical and
horizontal movements in the constructed dike portions of the tailings management cells, and for
recording and documenting displacement monitoring data and comparing such data to previous data to
track potential movement (displacement)....”
Ground Water Discharge Permit #UGW370004, Part I.E. 7
“DMT Performance Standards Monitoring - the Permittee shall perform technology performance
monitoring in accordance with the currently approved DMT Monitoring Plan to determine if DMT is
effective in minimizing and controlling the release of contaminants ...”
Ground Water Discharge Permit #UGW370004, Part I.E.8
“Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the currently
approved Cell 4A BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall immediately
implement all monitoring and recordkeeping requirements therein...”
Ground Water Discharge Permit WGW370004, Part I.E. 12
“Cell 4B BAT Performance Standards Monitoring and Maintenance - immediately following Director
approval of the Cell 4B BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall
immediately implement all monitoring and recordkeeping requirements therein...”
Observations
Heather Mickelson, PE of the Utah Division of Waste Management and Radiation Control (the
Division), with Phil Goble, Uranium Mill Section Manager, inspected the White Mesa Uranium Mill
during data collection activities on October 2 to 3, 2017. The mill is owned and operated by Energy
Fuels Resources (the Licensee).
This inspection was specific to the Licensee’s Standard Operating Procedures, Discharge Minimization
Plan (DMP), dated December 2016, and Tailings Management System (TMS), dated March 2017, for
the time period since the previous inspection last performed by Russ Topham on April 27, 2016. The
Licensee provided copies of the current revision of the field report forms used to perform the daily,
2017 Annual BAT/DMT Inspection
October 19, 2017
Page 2
2017 Annual BAT/DMT Inspection
October 19,2017
Page 3
weekly, and annual inspections for the DMP and the daily, weekly, monthly and quarterly inspections
for the TMS.
Mr. Garrin Palmer and Mr. Tanner Holiday conducted the daily and weekly inspections of the DMP and
the TMS. The monthly inspection for the TMS was also executed. As the quarterly inspection for the
TMS is a summary of the quarter’s activities and overall status of the tailings cells, this inspection was
not performed during this visit. The annual inspection for the decontamination pad and the ammonium
sulfate cover area for the DMP had been completed previously in the 2nd Quarter of 2017, as required.
All of the individual inspections components of the inspection are not reviewed in this narrative.
However, the inspection forms are attached to this memo for the record. During the collection of the
data, I agreed with the data collected and the staffs evaluation of the status of the Mill’s components.
The Licensee’s staff demonstrated an appropriate understanding the data collected and its further use.
Specific components of the onsite inspection are discussed further.
• The diversion ditches and berm were visited in their entirety. The vegetation growing in the
diversion ditches (1, 2, and 3) had recently been removed (Photos 1, 2, and 3) as requested
during a previously inspection performed by Division staff the week of September 25, 2017.
The ditches are clear of vegetation and direct rain water away from the plant.
• Cells 2 and 4B were visited to review the repairs made to the embankments (Photos 4, 5, and 6).
Erosion from 2017 rainfall events created rills in the embankments. Additional erosional
resistivity was achieved by placing road base material over the original cover (Photo 5).
• Pictures showing the methods used by Mill staff to measure the liquid elevation in Cells 1 and
4B are shown in Photos 7 and 8.
• The monthly inspection form for TMS includes Section 4 - Overspray Dust Minimization. The
overspray system is no longer installed at the site. It was recommended to the Licensee’s staff
that this section be removed with the forms next revision.
A records review of the data collected since the last inspection was performed following the site
inspection. The records showed similar conditions for the previous months. Quarterly inspections
performed for the previous year were reviewed for the TMS. The Annual UsedAVaste Oil and Fuel Tank
Inspection forms in the DMP were also reviewed.
In addition to appropriate data collection techniques and site evaluation, the records review
demonstrated ongoing maintenance to protect human health and the environment. For example,
Division Staff observed that when cracks in the concrete pad for the Used/Waste Oil and Fuel Tanks
were identified, the cracks were filled to prevent contamination of the sediments below. Other examples
of maintenance activities were: repair of the acid tank containment berm, removal and replacement of
soil contaminated with hydraulic oil, clearing of ditches of vegetation, and weed clearing throughout the
mill site.
A close out meeting to discuss observations from the inspection included with Heather Mickelson; Phil
Goble; Logan Shumway, Plant Manager; David Turk, Site Radiation Safety Officer; Garrin Palmer and
Tanner Holiday.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements with respect to
DMT/BAT data collection and evaluation. The Licensee’s personnel appear to understand the
significance of the data being collected and provide accurate and comprehensive records. In addition,
the correct forms, updated in 2017, are being used to record the data.
No new recommendations were identified during this inspection.
2017 Annual BAT/DMT Inspection
October 19, 2017
Page 4
Attachments: 2017 Annual BAT/DMT Inspection Photolog
Discharge Minimization Plan Inspection Forms dated December 2016
Tailings Management System Forms dated March 2017
Photo 2. Diversion Ditch 2 looking south. Photo taken on October 2, 2017.
5‘., ~ •-
■ .'l ' ' ■ '
Photo 4. Cell 2 embankment erosion repair with road base. Photo looking east and
taken on October 2, 2017.
Photo 5. Road base material placed on Cell 2’s embankment. Photo taken on October
2, 2017.
Photo 7. Measuring the pond solution elevation in Cell 4B. Photo looking northwest
and taken on October 3, 2017.
Photo 6. Erosional repair to Cell 4B’s embankment. Photo taken on October 3, 2017.
Photo 8. Measuring the pond solution elevation in Cell 1. Photo looking west and
taken on October 3, 2017.
Tailings Management System Forms
While Mesa Mill - Standard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual, Section 3.1 Page 21 of 37
APPENDIX A-l
DAILY INSPECTION DATA
Inspector:______
Date;__________
Accompanied by:
Time:__________
Any Item not “OK” must be documented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM 1
Inspection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Location or Orientation
II. OPERATIONAL SYSTEMS and INTERIOR of CELLS
Inspection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3 (:ei 4A Cell 4B
N S | E W N S E W W
Interior Cell Walls 1 1
Liner Observable Liner Damage TT
Water Level Greater Than Operating Level, Large
Change Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
Presence of Sediments Sediments should be saturated YorN N/A N/A N/A YorN
Notes:.
While Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 22 of 37
III. DIKES AND EMBANKMENTS
Insnection Items Conditions of Potential
Concern
Dike l-I Dike 1-
1A
Dike 2 Dike 3 Dike
4A-S
Dike
4A-E
Dike
4B-S
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
Crest Cracks, Subsidence, Severe
Erosion
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
No
visible
extenor
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
IV. FLOW RATES _____1
Slurrv Linefsl Pond Return S-X Tails Sprav Svstem
CPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point _____________Yes ___________> No
Observed Entire Discharge Line _____________Yes ______________No
VI. DUST CONTROL
Cell 2 Cell 3 Cell 4A Cell 4B
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
Slimes
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 23 of 37
General Meteorological conditions:.
VII. DAILY LEAK DETECTION CHECK
Daily Leak Detection Checks are recorded on the Daily Inspection Data form included
as Attachment A-l of the DMT Plan
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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While Mesa Mill - Slandard Operating Procedures 03/17 Revision: EFR 2.5
Book 11: Environmental Protection Manual, Section 3.1 Page 24 of 37
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 25 of 37
APPENDIX A-2
WHITE MESA MILL
WEEKLY TAILINGS INSPECTION
Date:__________________ Inspectors:
1. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
Depth to Liquid pre-pump
Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 43.41 ’-Depth to Liquid Pre­
pump =
Post-pump head is 43.41’ -Depth to Liquid Post­
pump -
2. Existing Decontamination Pad (concrete):
3. Tailings Area Inspection (Note dispersal of blowing tailings):
4. Sediments visible in: Cell 1: Y OrN Cell 4B: Y Or N If yes, are they saturated? YOrN
5. If no, note corrective actions:
6. Control Methods Implemented:
7. Remarks:
8. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 26 of 37
APPENDIX A-3
MONTHLY INSPECTION DATA
Inspector:
Date:___
1. Slurry Pipeline:
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Ditch 1
ves no
ves no
ves no
ves no
Diversion Ditch 2
ves no
ves no
ves no
ves no
Diversion Ditch 3
ves no
ves no
ves no
ves no
Diversion Berm 2
Diversion Berm:
Stability Issues _____yesno
Signs of Distress _____yesno
Comments:.
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 27 of 37
4. Overspray Dust Minimization:
Overspray system functioning properly: _______yesno
Overspray carried more than 50 feet from the cell: _____yesno
If “yes”, was system immediately shut off? yesno
Comments:__________________________________________________
5. Remarks:
6. Settlement Monitors:
Attach the Settlement monitor monthly survey data (spreadsheet). Note any unusual observations
below.
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections:
9. Monthly LDS Pump Checks in Cells 4A and 4B:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
03/17 Revision: EFR 2.5
Page 28 of 37
APPENDIX A-4
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:________________
Date:____________________
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activities:
4. Estimated Areas:
Cell3 Cell 4A Cell 4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments:
Discharge Minimization Technology Monitoring Plan Forms
While Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 17 of 25
ATTACHMENT A-l
DAILY INSPECTION DATA
Inspector:______
Date:__________
Accompanied by:.
Time:__________
Any Item not “OK” must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked Checked
Wet Drv Wet Drv Wet Drv Wet Drv Wet Drv
Initial level Initial level Initial level Initial level Initial level
Final
level
Final
level
Final
level
Final
level
Final
level
Gal. pumned Gal. pumoed Gal. pumned Gal. pumned Gal. pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-l)
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 18 of 25
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date:__________________ Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation ___________
elevations (msl, ft)
(b) FML Bottom Elevation 5597_
(c) Depth of Water above FML ((a)-(b))___________
Cell 4A: (a)Pond Solution Elevation __________
(b) FML Bottom Elevation 5555.14.
(c) Depth of Water above FML ((a)-(b))__________
Cell 4B: (a)Pond Solution Elevation __________
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))__________
(d) Elevation of Beach Area with Highest Elevation
(monthly) ___________
2. Leak Detection Systems
Observation:
New Decon Pad. Portal 1 New Decon Pad. Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
wet drv wet drv wet drv
If wet. Record liquid
level:
Ft to Liquid Ft to Liquid Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)7 _____no _____yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFR1 12.4
Page 19 of 25
ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week ofthroughDate 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 12/16 Revision: EFRI 12.4
Page 20 of 25
Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes:______No:
Comments:____________
Is there any evidence of breakage, spillage or leakage?
Yes:______No:
Comments:____________________________________
Other comments:
Ore Pad Southwest Stormwater Containment (Kival:
Is there sediment or debris in the bottom of the Kiva?
Yes:______No:
Comments:___________________________________
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes:______No:
Comments:.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 21 of 25
ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the pad surface?___Yes____No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank?____Yes____No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September
1 of each calendar year.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 22 of 25
ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection:
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the pad surface?____Yes____No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the asphalt surface?____Yes____No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 23 of 25
ATTACHMENT A-6
ANNUAL USED/WASTE OIL AND FUEL TANK INSPECTION
Date of Inspection:
Are there any anomalies on tanks including dents or rusty areas?
__Yes___No
Comments:_____________________________________________________________________
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:+
Valves:
Point(s) of Discharge:
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
____Yes____No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 24 of 25
ATTACHMENT B
FEEDSTOCK STORAGE AREA
DATE:
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 25 of 25
ATTACHMENT C
TABLES
Table 1A
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20