DRC-2012-002071 - 0901a06880315167

State of Utah
GARY R HERBERT
Govemor
GREG BELL
Lieutenant Govemor \_
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
LHlf -2012-002071
MEMORANDUM
TO
THROUGH
FROM
DATE
SUBJECT
File
Phil Goble, Section Manager
Russell J Topham, P E
September 28, 2012
Inspection of Disposal of Bulk Byproduct Matenal September 20, 2012 Radioactive
Matenals License UTI900479 (License) - Energy Fuels Resources (USA) Inc (EFR)
White Mesa Mill, Blanding, Utah
On September 20 and 21, 2012,1 conducted an inspecfion at the EFR White Mesa mill on behalf of the
DRC One of my purposes was to observe placement and bunal of bulk byproduct matenal generated at m-
situ leach facilities pursuant to an 1 le (2) Byproduct Receipt Notification from EFR, dated September 10,
2012 EFR is allowed to dispose this byproduct material in Tailings Cell 3 only, which is allowed by
License Condition 10 5 of the EFR Radioactive Matenals License
On September 10, 2012 DRC received nofice that EFR would receive eight loads of 1 le (2) byproduct
matenal, and intended to dispose of that waste in Cell 3 on September 20, 2012 Seven loads were
ulfimately received I checked in at the White Mesa mill at 7 45 a m on September 20, 2012 to conduct
this and several other inspections Soon thereafter I met with Mr Gamn Palmer, who accompanied me
through all inspections this day The 11 e (2) waste disposal operation commenced about 2 00 p m in three
excavations Excavations extended into the first 12 inches of tailings sand, and exposed solution at
approximately the elevation of the top of the tailings deposit
Mr Palmer and Mr Tanner Holliday surveyed the level at the bottom of the excavations pnor to placement
ofthe bulk waste therein Using a front-end loader and small backhoe-loader unit, crews placed the waste
in the excavations and tamped it down to approximately one foot below the top of the excavation Mr
Palmer and Mr Holliday then surveyed the elevation of the top of the waste, and the crew filled the
excavation to the top with soil Using the front-end loader, the fill soil was wheel-walked until the surface
ceased visibly yielding to the pressure of the wheels Then the crew groomed the surface to match the
surrounding grade
Dunng document review following the field observation, I paid particular attention to documents detailing
honzontal and vertical location of the waste, both for this and for a number of previous bunal events EFR
documents honzontal location of all bunals in an AutoCAD file and on a paper plat map, with all waste
168 North 1950 West • Sak Lake City, UT
Mailing Address P O Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] .TDD [phone]
www deq Utah gov
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from a given source receivmg interment in a location reserved for that generator Vertical location includes
an elevation measurement taken immediately prior to placement to establish the bottom of the trench, and
another measurement on the top of the waste load after placement m the trench but pnor to placement of
cappmg fill I reviewed at random approximately 30 records of vertical placement elevation data, mcluding
the June 8, 2012 instance, and found no case of the top of waste any higher than 1 6 feet below the plane or
grade ofthe top (at the cell penmeter) of the uppermost flexible membrane liner in the cell Thus, DUS A
appears compliant with Part 10 5 E (2) of the RML with respect to the elevation of bunal It appeared that
all provisions ofthe approved disposal SOP were followed dunng placement and bunal of the bulk waste
I have attached a photo log documenting parts of the biuial operation
Photo 1. Surveying the elevation of the bottom of one of the excavations for ISL disposal. Photo 2. Placement of waste in one of three excavations.
Photo 3. Surveying the elevation of the top of the waste prior to placing cover fill. Photo 4. Placing cover fill over the waste.