DRC-2012-002070 - 0901a0688031511a

State of Utah
GARY R HERBERT
Govemor
GREG BELL
Lieutenant Govemor
DRC-2012-002070
Department of
Environmental Quahty
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO File
THROUGH Phil Goble, Section Manager
FROM Russell J Topham, P E
DATE September 27,2012
SUBJECT Engineenng Module 75E, DMT/BAT Field Inspection, Radioactive Matenals License
Number UTI900479 (RML) and Ground water Discharge Pennit UG370004 (GWDP)
Energy Fuels Resources, Inc (EFR) White Mesa Mill, Blanding, Utah
On September 20 and 21, 2012,1 conducted an inspection of the tailings management facilities and office
records pertaimng to the operation and maintenance of discharge mininuzation technology and approved
implementation of best available technologies for the White Mesa uranium mill, Energy Fuels resources
(USA) Inc (EFR) The following details my activities, observations and findmgs
I amved at the mill at 7 45 a m September 20, 2012 and checked in with David Turk I was assigned
Gamn Palmer as escort for the inspection We talked bnefly, outlining what I hoped to accomplish Mr
Palmer provided me copies of the field report forms utilized to perform the daily, weekly, monthly and
quarterly monitonng activities associated with the tailings management system We prosecuted the
inspection by actually performing the daily, monthly and quarterly inspections routinely done at the mill
Dunng the inspection we accumulated data on the forms Retuming to the office, we performed
calculations and compansons to detect trends and uncover anomalies or violations During both the field
inspection and the data analysis, I queried Mr Palmer about what he was looking for and why He seemed
to know what the vanous data bits represented and the significance of the vanances we looked for dunng
the analysis When additional personnel were required for portions of the data collection, I quened those
individuals as well, with similar results
Finding All forms specified in the Discharge Mimmization Technology Plan, revision 115, dated
February 2012 were provided A newer revision, Revision 12 1, dated June, 2012 received DRC approval
July 25, 2012 The provided forms also match those provided as attachments to the quarterly DMT reports
The onginal intent was to implement the new forms at the beginning of the next reporting cycle, October 1,
2012, which should be satisfactory m this instance
Recommendation Begin using the latest forms The use of the older forms did not lead to a loss of data or
an omission in this inspection, inasmuch as the revisions to the forms were minor, however, had a major
revision taken place, a cntical element could have been overlooked Inasmuch as EFR intends to transition
to the new forms October 1, no formal recommendation will be forwarded
195 North 1950 West • Salt Lake City. UT
Mailing Address P O Box 144850 • Sah Lake City, UT 84114-4850
Telephone [phone] "Fax [phone] -TDD (801) 536^14
www deq Utah gov
Pnnted on 100% recycled paper
Page 2
Finding Field personnel appear to understand the sigmficance of the data and to take care to provide
accurate, comprehensive records
Items evaluated include
1 Tailings slurry transport system (pertains to Cells 1, 2, 3,4A, 4B)
a Slurry pipeline - leaks, damage, blockage, sharp mends
b Pipeline joints - leaks, loose connections (Dunng this phase we detected leaking flange
joints (2) on a solution decant return line from Cell 4A Those leaks were repaired pnor to
noon on September 20)
c Pipeline supports - damage, loss of support
d Valves - leaks, blocked, closed
e Points of discharge - location and orientation
2 Operational systems and intenor of cells (pertains to Cells 1, 2, 3, 4A, 4B)
a Intenor cell walls liner - visible damage
b Fluid level
I Elevation ~ exceeding design/approved operating level, calculate head over FML
II Significant change
m Highest beach elevation (Cell 4B only - no beach visible dunng inspection)
c Tailings beach - cracks, severe erosion, subsidence (Cells 3, 4A), estimates of beach and
pool areas ^
d Cover - erosion, exposure of liner (Cells 1, 2, 3)
3 Dikes and embankments (pertains to Cells 4A, 4B)
a Slopes - soughs, sliding, cracks, bulging, subsidence, severe erosion, moist areas, areas of
seepage outbreak (Dunng the inspection, areas of minor nil erosion were noted)
b Crest - subsidence, severe erosion
4 Flow rates - slurry lines (entire length, discharge point), pond return, solution extraction tailings,
spray system
5 Dust control (Cells 2, 3, 4A, 4B) - dusting, wind movement of tailings, inches of precipitation,
meteorological conditions
6 Leak detecUon system (Cells 1, 2, 3, 4A, 4B) - wet/dry, imtial/final level, gallons pumped
7 Slimes drain (Cell 2)
a Pump fijnction
b Post- and pre-pump fluid levels
c Volume pumped
8 New Decontamination Pad (3 portals)
a Portal wet/dry, if wet, record fluid level (Dry at time of inspection)
9 Diversion ditches and berms (3 ditches, 1 berm)
a Ditches - sloughing, erosion, undesirable vegetation (obstmction), other obstruction of
flow
b Berm - stability, signs of distress
Page 3
10 Settlement monitors - signs of disturbance, read elevations, analyze for excessive settlement
11 Lateral movement monitors - signs of disturbance (Dunng the inspection, several movement
monitors along the south side of Cell 4A were observed that may have been disturbed dunng
grading operations to groom the road along the top of the dike)
12 In addition to the above, all of which were checked dunng the inspection, the forms ask about any
construction activities that took place, anything unusual observed, or any other concems, as well as
notes of Items that need attention
Finding We detected two leaking flange joints on the solution decant retum line from Cell 4A The leaks
appeared to be recent The leak was located over Tailings Cell 2 Mr Palmer immediately summoned
repair crews who replaced and/or tightened flange bolts to stop the leaks, and removed and replaced
contaminated soil Any soil removed was disposed in Cell 3 Inspection and repair procediu-es appear to
work in these types of cases
Finding Minor nil erosion was noted on the embankments forming the containment dikes along the south
side of Cells 4A and 4B I was informed that the bulldozer used for grooming these side slopes was down
for repair, and mill personnel claimed the Mill had no funds to complete the repair
Recommendation Groom the extenor side slopes of the Cells 4A and 4B containment dikes to eliminate
nil erosion before it progresses to a point that it endangers the stability of the dikes
Finding Several movement monitors in the roadway at the top of the Cell 4A containment dike may have
been disturbed dunng grading activities The placement of these monitors ii) the center of the roadway
makes them vulnerable to such disturbance
Recommendation Set movement monuments on the outer shoulder of the cell, as was done for Cell 4B
Finding The above findings represent all exceptions noted dunng the inspection The only additional
information to note was incomplete grooming of the cover soil over the newly-repaired lmer in Cell 1 This
condition does not constitute a defipiency, and Mr Palmer indicated it would be addressed as soon as the
dozer is released from the repair shop
Photo 1. Typical rill erosion encountered on exterior of Cell 4 A and cell 4B dikes.
Photo 3. Leaking flange joint on solution retum line. This leak was located over Tailings
Cell 2, which is clay lined.
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-Z- \ Photo 2. One of several movement monitors on the Cell 4A dike that looks like it may have
been disturbed during grooming of the road surface.
Photo 4. Measuring solution level in Roberts Pond. The same technique was used for Cells 4A
and4B.
Photo 5. Reading levels on settlement monitors. Tanner Holliday operated the level instrument. Photo 6. Reading levels on settlement monitors, Garrin Palmer operated the rod.