The URL can be used to link to this page

Home My WebLink AboutDRC-2012-002069 - 0901a06880315115State of Utah GARY R HERBERT Govemor GREG BELL Lieutenant Govemor Department of Environmental Quahty Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rusty Lundberg Director DRC-2012-00206 MEMORANDUM TO File THROUGH Phil Goble, Section Manager FROM Russell J Topham, P E DATE September 17,2012 SUBJECT Review ofthe 2"" Quarter, 2012 (Apnl - June, 2012) DMT Perfonnance Standards Monitonng Report and Cell 4A and Cell 4B BAT Performance Standards Monitonng Report (Report) Groundwater Discharge Permit (GWDP) UG370004 - Energy Fuels Resources, Inc (EFR) White Mesa Mill, Blanding, Utah This IS a summary of Utah Division of Radiation Control (DRC) staff review ofthe EFR DMT Performance Momtonng Report and Cell 4A and Cell 4B BAT Performance Standards Monitoring Report dated August 22, 2012, and covenng the 2"** Quarter (Apnl-June) 2012 monitormg penod (Report) DRC received the Report on August 27, 2012 in both hard copy and soft copy CD formats Discussions in this document reference the White Mesa Mill Tailings Management System and Discharge Minimization Technology (DMT) Monitoring Plan, Revision 11 1 (DMT/BAT Plan) The DMT/BAT Plan in force dunng the Penod in question was executed on January 20, 2011 Revision 12 1 of the DMT Plan and Revision 2 1 of the Tailings Management System Plan received approval July 25,2012 Review of the 3'** Quarter Report will reflect the requirements approved on July 25, 2012 After review of this report, DRC staff findings and recommendations are as follows 1 EFR has provided the weekly slimes drain maximum/minimum fluid level monitonng data in support of compliance with Part IF 2 ofthe GWDP and Part 3 l(b)(v) ofthe DMT Momtonng Plan 2 EFR has provided the data required in Part ID 3(b)(2) of the GWDP The data demonstrate comphance with the requirements ofthe GWDP for slimes dram head recovery testing 3 The data presented in the report demonstrate EFR compliance with the solution pool operational requirements of the License and the DMT/BAT plan in force dunng the quarter 4 EFR momtored the Cell 4B solution pool elevation as required to demonstrate compliance with the fi-eeboard requirement 5 EFR included in the Report data from tailings beach elevation and area surveys 195 North 1950 West • Salt Lake City, UT Mailing Address F O Box 144850 • Salt Uke City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801) 533-4097 'TDD (801) 536-4414 www deq utali gov Printed on 100% recycled paper Page 2 6 EFR included in the Report leak detection system momtonng data and leakage rate calculations for Cell 1 and Cell 3 7 EFR performed solution pool elevation monitonng in Cell 4A to facilitate determination of allowable FML leak rate Cell 4A solution pool monitonng data and the numencal determination of compliance with FML leak rate standards for Cell 4A and Cell 4B appear in the Report Attachments 8 EFR completed work on the approved Cell 1 liner repair plan dunng the Report penod The required liner repair report appears in the Report, but will receive treatment under a separate review In summary, excepting a pair of typographical enors which cloud the timeline, the report appears to meet expectations, and the repairs appear successfiil 9 Data presented in the report demonstrate EFR compliance with the decontamination pad inspechon and maintenance requirements of the DMT/BAT Plan 10 EFR has met the provisions of the DMT/BAT Plan with regard to feed matenal stockpiles 1.0 Slimes Drain Water Level Monitoring Part IF 2 ofthe GWDP requires EFR to include m the Report, all DMT performance standards monitonng detailed m Parts ID 3 and IE 7 ofthe GWDP Part ID 3(b)(1) ofthe GWDP requires EFR to maintain the fluid level m the slimes drain of Cells 2 and 3 as low as reasonably achievable at all times, and to demonstrate that performance through adherence to the cunent DMT Monitonng Plan Part IE 7(b) of the GWDP requires monthly momtonng and recording of the depth to wastewater in the slimes drain access pipe as descnbed in Part ID 3 ofthe GWDP and the cunent DMT Momtonng Plan Part 3 l(b)(v) ofthe DMT Momtonng Plan requires EFR to momtor and record weekly the depth to wastewater m the Cell 2 slimes drain access pipe to determine maximum and minimum head before and after a pumping cycle, respectively 1 Section 4 1 of the Report asserts that the above discussed momtonng requirements only pertain to Cell 2 for the reportmg penod, as dewatenng operations have not commenced in Cell 3 2 Weekly water level monitonng of the Cell 2 slimes drain is not required as part of the DMT plan, but is required under Part ID 3(b)(1) of the GWDP Inasmuch as this data is not cunently being reported elsewhere, EFR agreed in a conference call on October 26, 2011 to provide the data as part ofthe quarterly DMT Report until a more appropnate reportmg mechanism is instituted EFR has mcluded this data in Attachment C to the Report 3 Attachment C to the Report contains data from the monthly/quarterly recovery head measurements (discussed in the next paragraph) 4 The recovery head momtonng data provides indirect evidence that EFR has maintained the fluid level m the Cell 2 slimes drain as low as reasonably achievable, as required in GWDP, Part ID 3(b)(1) Finding Data provided in Attachment C to the Report supports a conclusion that EFR has met the requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable Page 3 Part ID 3(b)(2) of the revision of the GWDP in force dunng the fourth quarter of 2012 required EFR to perform a quarterly slimes drain head recovery test at each tailings cell slimes drain Specifications for the head recovery test appear m Parts ID 3(b)(2)(i) and (ii) ofthe GWDP Part ID 8 2(e) of the GWDP requires each quarterly report to contain the cunent year monthly fluid level values and a graphical companson with previous years for the Cell 2 slimes drain Part ID 3(b)(3) ofthe GWDP includes an analytical test to determine annual slimes drain compliance The analytical procedure provides a means of demonstrating the success of dewatenng operations in the tailings cell The average annual fluid level m the slimes drain must fall each year for the slimes drain to remain in compliance The latest revision of the GWDP changes the recovery test frequency firom monthly to quarterly 5 Attachment C to the Report contains the required head recovery test data 6 Attachment D to the Report contains the required graphical companson The regression senes included on the chart shows graphical evidence of general compliance with the requirement to reduce fluid head in the slimes drain Findings EFR has provided the data required in Part ID 3(b)(2) of the GWDP The data demonstrate compliance with the requirements of the GWDP for slimes drain head recovery testing The Cell 2 slimes drain fluid level appeared to continue its declining trend, as required, and in contrast to the increased elevation noted dunng the fourth quarter of 2010 2.0 Tailings Wastewater Pool Elevation Monitoring and Roberts Pond Solution Level Monitoring Part IE 7(a) of the GWDP requires EFR to momtor and record weekly the elevation ofthe wastewater pool in Tailings Cells 1 and 3 to ensure compliance with Condition 10 3 of the License Part ID 3(e) requires EFR to operate Roberts Pond so as to provide a nummimi two feet of freeboard at all times Part 3 1(d) of the DMT/BAT Plan requires EFR to measure the solution pool elevation in Cells 4A and 4B weekly, and the tailings beach maximum elevation and area within Cells 4A and 4B monthly Tailings have nearly completely filled Cell 3 Recognizing this, letters from the Executive Secretary dated January 27, 2011 and March 14, 2011 formally eliminated the need for solution pool elevation measurement m Cell 3 The previously cited January 27, 2011 letter and another letter from the Executive Secretary dated March 15, 2011 concluded a process obviating the need for freeboard-related solution pool elevation momtonng m Cell 4A However, Part 3 1(a) of the DMT/BAT Plan requires monitonng solution pool elevations m Cells 4A and 4B to facilitate determinanon of compliance with FML leakage rate limitations 1 Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with the prescnbed freeboard requirements 2 As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed dunng the second quarter Attachment A to the report reflects no measurements for the reported quarter 3 Attachment A to the Report contains weekly pool elevations for Roberts Pond indicating compliance with the prescnbed freeboard requirements 4 Attachment A to the Report contains weekly solution pool elevations for Cell 4A m support of calculating acceptable leak rates for the lmer system EFR failed to take the required solution pool measurements in Cell 4A dunng the first and second quarters, and part of the third quarter of 2011 Page 4 However, EFR has retumed to compliance, having taken and reported the required elevation readings for the latter portion of the third quarter the entire fourth quarter of 2011, and the first and second quarters of 2012 5 Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance with the prescnbed freeboard requirements Findings The data presented in the report demonstrate EFR compliance with the solution pool operational requirements of the License and the DMT/BAT plan in force dunng the quarter 3.0 Leak Detection System Monitoring Part 3 1(a) ofthe DMT/BAT Plan requires EFR to monitor the leak detection system (LDS) for Cell 1 and Cell 3 weekly EFR would either report the LDS as dry or report the fluid level in the LDS monitor pipe Presence of fluid m the LDS tnggers a requirement to extract the fluid, measure the extracted volume, and compute a leakage rate for the cell 1 Attachment C to the Report contains data showing the Cell 1 and Cell 3 LDS dry dunng the first quarter of 2012 Findings Cell 1 and Cell 3 seem to have had no detectable leakage during the first quarter of 2012 Part ID 6(a) of the GWDP requires EFR to operate Cell 4A in a manner to maintam fluid head in the LDS not more than 1-foot above the lowest point on the lower FML on the cell floor Part ID 6(b) requires that the leak rate through the Cell 4A FML not exceed 24,160 gallons per day Part 3 1(a) ofthe DMT/BAT Plan reiterates the GWDP requirements just discussed Table 1A in Appendix E to the DMT/BAT Plan relates solution pool head above the liner system to maximum allowable FML leak rate 2 Calculation of solution pool head requires measunng the solution pool elevation Attachment A to the Report presents the required solution pool elevation readings for Cell 4A 3 Attachment F to the Report presents LDS fluid level monitonng data and number of gallons pumped from the LDS 4 QuantiUes of fluid pumped from the Cell 4A LDS support a finding of compliance with the operational requuements ofthe GWDP and DMT/BAT Plan Findings EFR is compliant with the FML leakage rate provisions of the DMT/BAT Plan with respect to cell 4A This includes solution pool elevation monitonng, extracting fluid when it exists in the LDS, and maintaining FML leakage rate below the prescnbed limits Part ID 13(a) of the GWDP requires EFR to operate Cell 4B in a manner to maintain fluid head in the LDS not more than 1-foot above the lowest point on the lower FML on the cell floor Part ID 13(b) requires that the leak rate through the Cell 4B FML not exceed 26,145 gallons per day Part 3 1(a) of the DMT/BAT Plan reiterates the GWDP requirements just discussed Table IB m Appendix E to the DMT/BAT Plan relates solution pool head above the liner system to maximum allowable FML leak rate 5 Calculation of solution pool head requires measunng the solution pool elevation Attachment A to the Report presents the required solution pool elevation readings for Cell 4B 6 Attachment F to the report presents LDS fluid level momtonng data and number of gallons pumped from the LDS Page 5 7 QuantiUes of fluid pumped from the Cell 4A LDS support a finding of compliance with the operational requu-ements ofthe GWDP and DMT/BAT Plan Findings EFR is compliant with the FML leakage rate provisions of the DMT/BAT Plan with respect to cell 4B This includes solution pool elevation monitonng, extracting fluid when it exists in the LDS, and maintaining FML leakage rate below the prescnbed limits Part IE 8(a)(1) of the GWDP requires EFR to provide continuous operation of the Cell 4A LDS pumping and momtonng equipment, and to make such equipment operational within 24 hours of discovery of a failure of such equipment Part ID 12(a)(1) of the GWDP requires EFR to provide continuous operation of the Cell 4B LDS pumping and momtonng equipment, and to make such equipment operational within 24 hours of discovery of a failure of such equipment 8 On March 14,2012, while performing the daily inspection regimen, EFR plant personnel discovered that the flow rate reporting circuit for the LDS pumping system had ceased recording or displaymg pumped flow rate shortly following the previous day's inspection Plant personnel, in conference with the system vendor, attempted repair of circuit on March 14 and 15, ultimately determimng that the PLC required replacement The new PLC amved March 16, whereupon plant personnel completed the replacement and restarted the system The repair was not completed within 24 hours of discovery of the problem, but was completed as rapidly as EFR could acquire the required parts The repair appears to have been successfiil 9 Section IE 8(a)(1) of the GWDP requires EFR to provide continuous operation of all elements of the leak detection systems for thcvanous cells Failure to repair a failed system and bnng it to fiill operation within 24 hours constitutes a violation of the GWDP and of BAT 10 EFR notified the DRC on March 14, 2012 by telephone, with wntten notice, including conective acUons taken provided in a Notice dated March 19, 2012, of the cdndition and violation Additional mformation related to the violation and conective actions taken appears in the Report 11 EFR has not expenenced a repeat failure installation of the new PLC Findings EFR expenenced failure of the Cell 4B leak detection pump rate recording module within the PLC and attempted repair in accordance with GWDP intentions The repair did not succeed, and acquisition of the replacement PLC extended well beyond the 24 hour limit, violating the GWDP Sufficient information existed in the remaining records to demonstrate compliance with GWDP provisions for LDS performance The system is now repaired and functioning properly DRC should issue a Notice of Enforcement Discretion regarding this issue Recognizing that the problem has not recurred since repair on March 15, 2012, the DRC should consider the issue closed Part IE 7(f) of the GWDP stipulates procedures to implement upon detection of any FML defect or damage On September 22,2010 DRC extended conditional approval for a liner repair plan for Cell 1 EFR committed to complete repairs under that plan by July 31, 2012 12 EFR completed no repair work on the Cell 1 liner dunng the Report penod Findings EFR completed no work on the approved Celll liner repair plan during the Report period 4.0 Decontamination Pad Inspections Page 6 Part 3 1(e)(1) ofthe DMT/BAT Plan sets forth requirements for monitonng the New Decontamination Pad Subpart (B) requires weekly measurement of fluid level m the inspection portals to detect leakage of the pnmary containment bamer Subpart (F) imposes requirements to inspect weekly the integnty ofthe concrete compnsing the New Decontamination Pad surfaces and to repair any cracks greater than 1/8 inch in width or other abnormalities in the pad surface Part 3 l(e)(ii) imposes requirements to inspect weekly the integnty of the concrete compnsing the Existing Decontamination Pad surfaces and to repair any cracks greater than 1/8 mch in width or other abnormalities in the pad surface ^ 1 The inspection portals of the New DecontaminaUon Pad contained no fluid at the weekly inspections 2 No cracking in excess of 1/8 inch or other abnormality of the surface oif the New Decontamination Pad was observed dunng the Report quarter 3 Although measunng less that 1/8 mch, cracks in the surface of the Existing Decontamination Pad were repaired Inspectors noted no other anomalies on the pad surface Findings Data presented in the report demonstrate EFR compliance with the decontamination pad inspection and maintenance requirements of the DMT/BAT Plan 5.0 Feedstock Storage Area Inspections Part 3 3 of the DMT/BAT Plan requires weekly confirmation that bulk feedstock storage occurs in the areas defined in the GWDP, that a four foot buffer exist between feedstock stockpiles and the storage area boundary, and that altemate feedstock stored outside the defined feedstock storage area is maintamed in water tight containers or are placed on a hardened surface 1 Location of stockpiles within the bulk storage area appeared properly placed 2 Standing water from rain events was noted in the feedstock storage area This water was directed to the sump, and ultimately to Cell 1 for disposal Findings EFR has met the provisions of the DMT/BAT Plan with regard to feed matenal stockpiles 6.0 Recommendations 1 The DRC should issue a Notice of Enforcement Discretion and Closeout to document the violation of the GWDP with respect to the failure and attempted repair ofthe Cell 4B LDS PLC and EFR's retum to compliance 2 The DRC should issue a closeout letter with respect to the Report