DRC-2012-002054 - 0901a06880314227

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
DRC-2012-002054
Department of
Environmental Quality
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 25, 2012
SUBJECT Cell 1 Liner Repairs Radioactive Matenals License UTl 900479 (RML) and Groundwater
Discharge Permit (GWDP) UG370004, Energy Fuels Resources, Lie (EFR) White Mesa
Mill, Blanding, Utah
EFR has completed repairs to the Cell 1 Imer system As required, EFR provided a detailed report of the
repair activity in its 2"^* Quarter DMT Performance Standards Momtonng Report EFR included a root
cause analysis with the repair report The repair effort appears to have addressed the findings of the root
cause analysis The report appears comprehensive and pertment Repair activities appear appropriate, and
field vacuum testmg appears to support a conclusion of successful repair installation
On September 20, 2012,1 reviewed field conditions, records and photos of the repair at the mill offices I
also interviewed David Turk and Gamn Palmer about the effort Following the repair, crews placed one
foot of soil over the liner matenal, thus, I took no photos dunng the inspection ^
Fluid levels in the cell have not returned to an elevation above the repau", and likely will not reach a
suitable elevation to test the repair for several weeks Thus, we must rely on the vacuum testing narrative in
the report for now
I recommend holding this project open until fluid levels approach design maximums in the cell Soon
thereafter, readings in the leak detection system can provide positive verification of the efficacy of the
repairs One month fi-om the time solution levels reach the design maximum elevation should prove
adequate
I recommend approving the repair report as sufficient to meet the requirements as presented m Revision I
of the Liner Maintenance Provisions, dated October 18, 2009, and with Part IF 2 of the RML
History
On June 2, 2010, EFR detected fluid in the Cell 1 leak detection system EFR notified the DRC verbally on
June 3, 2010 by telephone and m writing on June 7, 2010 by letter, fulfilling the notification requirements
of Part IG 3 of the GWDP The volume of fluid detected constituted a violation of Condition 11 3 of the
195 North 1950 West • Salt Uke City, UT
Mailing Address P O Box 144850 • Salt Lalce City, UT 84114-4850
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Page 2
RML, tnggenng the requirement to notify the DRC, to identify the cause of the violation, and to implement
remedial action
EFR lowered the solution level in Cell 1 to facilitate inspection and of the flexible membrane liner (FML)
Dunng June and July, 2010, EFR completed repairs of defects it identified in the FML Believing the repair
to have succeeded, EFR raised the solution level in the cell, only to detect fluid in the LDS again on
August 7, 2010 Dunng a conference call on August 12, 2010, EFR and the DRC agreed that the repair
effort had not identified and corrected all defects in the FML, necessitating further corrective action
EFR assembled a repair plan which it submitted to the DRC on August 18, 2010 DRC review and
subsequent negotiation led to EFR submitting a revised repair plan on August 30,2010 The DRC
approved the plan, with modifications, through a Confirmatory Action Letter on September 22,2010 (the
CAL)
EFR lowered the solution level to elevation 5613 feet above mean sea level (AMSL), and completed
repairs in stages dunng the summer months of 2011 and 2012
Findings and Recommendations
The Mill's Liner Mamtenance Provisions, Revision 1, dated October 18, 2009 (LMP), contain a number of
requirements for liner repair, including
1 EFR must submit a repair report The CAL required EFR to include this report with the 2"^*
Quarter, 2012 DMT Performance Standards Momtonng Report The DRC received the DMT
Report, including the repau" report, on August 27,2012 This action both fulfills the requirement to
report and the deadline by which to report repair activities to the DRC
2 The LMP requu-es a repau* report to bear the seal and signature of a professional engineer
registered in the State of Utah Harold Roberts signed and sealed the report
3 The LMP requires the report to include a descnption of the damage discovered and the work
completed to repair that damage The report attempts to fulfill this requirement Because the imtial,
limited repair effort proved ineffective, the repair plan evolved to replacement of damaged sections
of liner above elevation 5613 AMSL Thus, the descnption of specific damage and local repairs
pertained only to the imtial, failed attempt The liner failure appeared to result from wear and tear
imposed by foot traffic (sampling, momtonng, etc ), movement of discharge hoses and solution
transfer over the 30-year life of the liner The nanative and attached documentation highlights
typical damage encountered, and includes photographs of typical examples, rather than
documentmg in the report all defects identified Documentation of all defects exists at the mill's
offices I am satisfied with the narrative, given the extent of the repair effort
4 The report must include specifications for matenals employed in the repair The onginal FML
consisted of 30 mil PVC roll stock EFR chose a 320 mil PVC roll stock from Colorado Lming,
Inc for the replacement matenal Following removal of damaged sections of liner and preparation
of subgrade to receive the Imer, the repair crew cleaned the existing matenal at the site of the seam
with methyl ethyl ketone Crews then cut a patch from the roll stock and cemented it to the existing
liner matenal using an adhesive supplied with the roll stock The matenals appear appropnate for
the repair effort
"\
5 Repau- patch seams must perform satisfactonly under the vacuum test method ASTM D5641 The
report includes a tabular presentation of all seam tests, and a narrative interpretation of the results
Page 3
All seams received testing, with test sites overlapping so as to eliminate the possibility of omitting
any seam length from evaluation No vacuum leaks appear in the test logs
6 Daily reports of repair work must appear m the repair report Appendix 4 to the repair report
includes typewntten transcnptions of the daily reports
7 Quality assurance/quality control assessments must receive treatment in the report narrative As I
understand the terms, quality assurance refers to methods employed in the work to assure
production of a result meeting specified standards of quality Quality control mvolves
observational methods, inspection and testing among them, to detect deviation from quality
expectations and offer opportumty for corrective action Quality assurance should be ongoing,
while quality control can be episodic
Dunng a field mspection on September 20, 2012,1 quened David Turk and Gamn Palmer about
the repair effort Both, mdependently, cited the challenges of traming crews to perform the work
correctly, and the need for continuous rather than episodic inspection in this case For example, all
lengths of all repau* seams received vacuum box testing per ASTM D5641 as soon as the adhesive
had set, and any defects received immediate attention, the entire patch was removed and replaced
upon discovery of a leak, no matter how small, rather than nsk further failure of the seam
I am satisfied with the quality assurance and quality control activities EFR employed
8 The repair report must appear in the quarterly DMT Performance Standards Momtonng Report for
the quarter following that in which the repairs conclude Repairs concluded on June 4, 2012, the
last month of the 2"'* Quarter In the CAL, the DRC required completion of repairs on or before
July 31, 2012 The repairs concluded eight weeks ahead of deadline, and the repair report appears
one quarter ahead of deadlme
In addition to the above requirements, the CAL stipulated inclusion of a root cause analysis m the liner
repair report A root cause analysis appears as Part 3 to the report, identifying defects and damage The root
cause analysis further clanfies the damage as the likely result of foot traffic fi-om sampling, momtonng and
other such activities, effects of discharge hoses and solution transfers, and exposure to weathenng
conditions not expenenced below the operating fluid level of the cell The explanations presented seem
reasonable
Finding Given the above analysis, I find both the report and the repair effort it chronicles to meet
expectations, as nearly as can be ascertained at this date Only actual testing under field conditions will
ultimately prove the effectiveness of the repau* effort
Recommendation I recommend approval of the repau* report, and the underlying repairs I recommend
retaimng the file open until the solution level in Cell 1 reaches maximum design working elevation and
results of routine momtonng of the leak detection system support a conclusion that the repairs have
succeeded Thirty days from the date the fluid level reaches design maximum elevation should suffice