DRC-2012-002333 - 0901a06880322ffb

Cf
DRC-2012-002333
energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600
Lakewood, CO, US, 80228
ENERGYFUELS 303 974 2140
/ www energyfuels com
November 15, 2012
SENT VIA PDF AND OVERNIGHT DELIVERY
Mr Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O Box 144850
Salt Lake City, UT 84114-4820
Re. State of Utah Radioactive Materials License No. UTl 900479,
Annual Technical Evaluation, White Mesa Mill Tailings Management System
Dear Mr. Lundberg.
Enclosed please find one (1) copy of the Annual Technical Evaluation of the White Mesa Mill
Tailings Management System, as required by License Condition 12.3. Per the August 24, 2012
Radioactive Material License UTl900479 Amendment #05, License Condition 12 3, the Annual
Technical Evaluation report is to be submitted no later than November 15 of each year Hence,
this evaluation is for the period of November 2011 through October 2012 A CD containing
electronic files of this report, m word searchable pdf format, is also enclosed.
If you should have any questions regarding this report please contact me
Yours very truly.
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Director, Compliance
cc David C Frydenlund
Dan HI listen
Harold R Roberts ^
Steve Snyder
David E Turk
Katherine A Weinel
David A Marble, Assistant State Engineer
Evaluation Summary and Recommendations
Annual Technical Evaluation
of the
White Mesa Uranium Mill Tailings Management System
For the Period of November 2011 through October 2012
prepared by
ENERGY FUELS RESOURCES (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
in compliance with
Utah Department of Environmental Quality
Radioactive Materials License # UT1900479 Amendment #05
by
Steve R. Snyder, PE
November 15, 2012
Contents
1.0 EVALUATION PROCEDURE ................................................................................................ 3
2.0 OPERATIONS .......................................................................................................................... 5
3.0 SITE MANAGEMENT ............................................................................................................ 5
4.0 RECORDS ................................................................................................................................ 6
5.0 DIVERSION CHANNELS ....................................................................................................... 6
6.0 TAILINGS DISPOSAL CELLS ............................................................................................... 7
6.1 CellI-I ................................................................................................................................... 7
6.2 Cell 2 ...................................................................................................................................... 7
6.3 Cell 3 ...................................................................................................................................... 8
6.4 Cel14A ................................................................................................................................... 9
6.5 Cel14B ................................................................................................................................. 10
6.6 Movement Monuments ........................................................................................................ 11
7.0 SETTLEMENT MONITORS ................................................................................................. 11
8.0 11e.(2) WASTE DISPOSAL .................................................................................................. 12
9.0 TAILINGS TRANSPORT SYSTEM ..................................................................................... 12
10.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................... 13
11.0 REFERENCES ..................................................................................................................... 14
12.0 CERTIFICATION: ............................................................................................................... 17
Annual Technical Evaluation
of the
White Mesa Uranium Mill Tailings Management System
For the Period of November 2011 through October 2012
1.0 EVALUATION PROCEDURE
Energy Fuels Resources (USA) Inc. ("EFRI") currently operates the White Mesa Uranium Mill (The
"Mill") under the Utah Department of Environmental Quality Radioactive Materials License
("RML") Number UT1900479 Amendment #05. The White Mesa Mill Tailings Management
System, Revision 2.1, dated July 20 12, (which is section 3.1 of the Mill's Environmental Protection
Manual) provides the methodologies for monitoring and evaluating the Tailings Management
System. Reference documents are listed in the Reference section at the end of this summary. This
Annual Technical Evaluation Report ("ATER") satisfies the requirements in RML Condition 12.3
for preparation of an A TER.
This Annual Technical Evaluation was performed on November 9th through the 12th, 2012, in
accordance with the White Mesa Mill Environmental Protection Manual and consisted of the
following elements:
• Review of the Tailings Management System operation and maintenance procedures
and interviews with current site personnel and management to ensure there is an
adequate understanding of the requirements.
• Review of randomly selected daily, weekly, monthly, and quarterly inspection reports
to ensure established procedures are followed and that there are no irregularities that
have not been properly documented.
• Interview responsible personnel to verify that updated training has been given.
• Discuss with inspection personnel, as necessary, any non-routine or abnormal
occurrences noted during the review of the inspection reports.
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15,2012
• Inspection of the tailings embankments and appurtenances for signs of distress or
concern that could potentially affect the structural integrity of the Cell dikes and
containment.
• Inspection of the area surrounding the tailings facility to determine condition of
diversion ditches. Review of additional peripheral items, such as prairie dog activity,
which could affect the system.
• Review of the survey conducted on Movement Monitors along the boundary dikes,
and comparison of the data to recent surveys.
• Review of the tailings slurry and raffinate piping systems to ensure that their
operation does not have the potential to affect the integrity of the tailings dikes or
liner system.
• Review of maintenance activities in the tailings area that have the potential to affect
the integrity of the tailings dikes or liner system.
• Photographic documentation of the condition of the Cell dikes and surrounding areas.
• Review recommendations provided in previous technical evaluation reports and
document the implementation or continued need for action.
Page 4
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15,2012
2.0 OPERATIONS
During the period covered by this evaluation, November 2011 through October 2012, the mill was in
operation processing uranium/vanadium ore from the company's mines and several Alternate Feeds
including Honeywell CaF2, Cameco Regen, Cameco Calcined, and Cameco KF Materials. During
the evaluation period the mill processed 116,200 tons of conventional ore and 6,900 tons of
Alternate Feed. During Mill operations various solutions and solids were discharged to the Mill
tailings cells. The solids were discharged to Cell 3 and Cell 4A. Cell 1 and Cell 4B were
maintained as evaporation cells, and only raffinate solution from the solvent extraction circuit and
process water from operational Mill clean-up was discharged to Cell 1-1 and Ce1l4B. In efforts to
maintain freeboard limits solutions were transferred between cells.
3.0 SITE MANAGEMENT
Mr. Dan Hillsten is the current White Mesa Mill Manager. Mr. Hillsten has the overall responsibility
to ensure that the Tailings Management System is operated and maintained in accordance with State
of Utah Radioactive Material License No. UT1900479. Mr. David Turk was the Radiation Safety
Officer ("RSO") at the Mill until July 1,2012, at which time Mr. Ronnie Nieves was appointed to
this position. The RSO's responsibilities include administering the required radiation and
environmental safety programs. Mr. Turk's responsibilities in his current role as Environmental
Manager continue to include oversight of day-to-day monitoring and inspecting of the Tailings
Management System. Inspections of the Tailings Management System were performed by trained
Mill personnel. Under Mr. Turk the trained inspectors are:
• Tanner Holliday
• Garren Palmer
The inspectors are all from the Environmental and Safety Department at the White Mesa Mill. Each
inspector has documentation of recent training on the inspection procedures.
Page 5
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15,2012
4.0 RECORDS
The mill maintains daily, weekly, monthly, and quarterly inspections for the tailings area. Copies of
the daily and weekly inspection reports for the month of June 2012 are included as a part of this
evaluation. Also copies of all the monthly inspections and quarterly reports are included as part of
this evaluation. A review of these records was conducted to confirm use of the correct forms, verify
completeness, evaluate content, and to evaluate any unusual events. The record keeping is in
excellent order and is consistent with the requirements in the Environmental Protection Manual. It is
clear that the Environmental Department is maintaining an attentive watch over the tailings area.
5.0 DIVERSION CHANNELS
To the north of the Mill tailings cells there are three diversion channels which prevent runoff from
flowing into the tailings cells and Mill yard area. Channel #1 was found to be in good working
condition. The ditch has small vegetation growing in it none of which would affect its general
function. There was no other activity that would affect this channel. Channel #2 also had minor
vegetation covering it. hnpact of this vegetation is minimal and does not affect the function of
channel. The general condition was good with the exception of the Southern end where it appeared
that some equipment had been stuck and left some ruts around the channel. It is recommended that
this area be graded. Grading has been scheduled for November 2012. Channel #3 also had minor
vegetation covering it similar to Channels #1 and #2. This vegetation would not be detrimental to
the intended function. The general condition is good and there are no recommendations at this time.
The South side of the #1 Channel is a constructed berm varying in height from 0 to 4 feet. The berm
is in excellent condition with no erosion or other concerns. Locations of the diversion ditches are
shown in the Mill Site Drainage Basins drawing located in the Site Photographs section of this
document. Photos of the current status of the diversion ditches are included and can be seen as
Photos 1 through 8 in the Site Photographs section of this document.
Page 6
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
6.0 TAILINGS DISPOSAL CELLS
6.1 Cell I-I
Cell 1-1 (currently referred to as Cell 1) was the second cell placed into service after being completed
in 1981. The Cell was designed as an evaporation cell for tailings solutions only. No solids are to be
placed into CellI-I. The solution discharged to the Cell normally comes from the solvent extraction
circuit, but solution is periodically pumped back and forth between CeIl4A, CeIl4B, Cell 3, and Cell
1-I to maintain required freeboard limits in the entire system. The daily inspection reports indicated
that solution was transferred between the cells during this evaluation period.
Solution freeboard limits for all of the tailings cells are established in Section 3.0 to Appendix D of
the approved license application and confirmed as License Condition 10.3 of the current license. The
established maximum freeboard limit for Cell I-lis 5615.4 feet MSL. A review of the records found
that there were no instances of the solution level in Cell 1-I exceeding the freeboard limit during the
evaluation period.
The south side of Cell 1-1 originally shared a dike with Cell 2. Cell 2 has since been filled and
covered with the initial layer of engineered fill. The cover around the interior perimeter of the
tailings cell has been disturbed as a result of maintenance that has been accomplished Qn the Cell 1
liner. The soil serves to cover and protect the liner from UV coming from direct sunlight. During
the evaluation period the soil was re-dressed. Photos 9 through 12 show views around the perimeter
of Cell 1-1. The roadways around the cell are well maintained.
6.2 Cell 2
Cell 2 was the initial tailings cell constructed and was placed into service when the Mill first began
processing ore in 1980. It is no longer receiving any discharge from the mill and has been deemed
full. The first stage of reclamation has been completed by covering the cell with approximately four
Page 7
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15,2012
feet of random fill (platform fill) which prevents the migration of windblown tailings. In July of
2011 the surface of the cell was covered with additional fill and re-graded to prevent the collection of
surface water. The disturbed surface has grass planted which is in its initial stages of growth. The
eastern end of the cell was left undisturbed and had established vegetation. Photos 13 and 14 show
the cell surface.
In order to monitor the consolidation of the tailings sands contained within Cell 2 elevation readings
on settlement monitors are taken monthly. The trending of these readings will be used to determine
when acceptable consolidation of the tailings sands has occurred. A summary of the settlement
monitor elevations is included with this report along with graphs of the settlement data.
The south dike of Cell 2 is the north dike of Cell 3. As a part of the work on the Cell 2 surface the
spillway between Cell 2 and Cell 3 was covered as it no longer serves the intended purpose. The
roadways around the cell are well maintained.
6.3 Cell 3
Cell 3 was constructed and placed into service in 1983. It is currently an active cell for disposal of
tailings sand as well as 11(e).2 waste materials from in-situ uranium producers. During the
evaluation period, slurry tailings from conventional ore processing was being discharged to the Cell
in several locations. Photos 19 and 20 show areas of deposited tailings solids. Cell 3 is in its final
stages of being filled with tailings. Soil fill is brought in to cover tailings sands and also to tighten
the boundaries of the tailings deposit area on a semi-continual basis. This will help in controlling the
solution level in the cell. Photos 15 and 16 show the current status of the interim cover on the east
and west ends of the cell. There is minor vegetation growing thereon. Photo 21 shows the Cell 3
Spillway which is in excellent condition.
Condition 10.3 of the License also provides that the freeboard limit for Cells 3, 4A and 4B shall be
recalculated annually in accordance with the procedures approved by the Director. A letter from the
Page 8
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
Director dated January 27, 2011 which approved the use of CeIl4B, and a subsequent letter dated
March 14, 2011, stated that authorization of the use of Cell 4B and approval of the Discharge
Minimization Technology ("DMT") Plan and Cell4A Operations and Maintenance ("O&M") Plans
effectively eliminated the former freeboard elevation requirements for tailings Cell 3. Pursuant to
the receipt of the March 14, 2011 letter, freeboard elevation survey measurements in Cell 3 were no
longer required or conducted.
The south dike of Cell 3 is shared with Cell4A and CeIl4B. Photos 18 and 22 show the top surface
of the dike between Cell 3 and Cells 4Aand 4B. The dike crest and all roadways around the cell are
well maintained.
Approximately 70% of Cell 3 has been covered with random fill. In order to monitor the
consolidation of the tailings sands contained within Cell 3 elevation readings on settlement monitors
are taken monthly. The trending of these readings will be used to determine when acceptable
consolidation of the tailings sands has occurred. A summary of the settlement monitor elevations is
included with this report along with graphs of the settlement data.
6.4 Ce1l4A
Cell4A was originally constructed in 1989 and placed into service in 1990. Cell4A was never used
for disposal of tailings material other than process solutions during the first years of its operation.
Cell 4A fell into disrepair and was removed from service in the early 1990' s after a brief period of
use. The original40-mil high-density polyethylene (HDPE) liner was removed from the Cell as well
as all contaminated materials and soil. The Cell was relined with a new HDPE lining system
beginning in the fall of 2007 and finishing in the summer of 2008. The Cell was placed into service
in October of 2008.
The Cell 4A dikes are currently the final containment of tailings at the White Mesa Mill site. The
east and south dike slopes were covered with moderate vegetative growth except where the slope had
Page 9
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
been re-dressed to remove growing erosion channels. There are currently no significant erosion
channels other than the minor rivulets that typically occur from surface water. These slopes are
shown in photos 31 and 32. The west dike is shared with Ce1l4B. The top surface and roadways on
the dikes are all well maintained.
The former freeboard limit of 5,593.74 for Ce1l4A was set out in a letter from the Director dated
November 20,2008. A letter from the Director dated January 27,2011 which approved the use of
Ce1l4B and a subsequent letter dated March 15,2011, stated approval of the DMT and Ce1l4A and
Ce1l4B O&M Plans effectively eliminated the former freeboard elevation requirements for tailings
Ce1l4A. Pursuant to the receipt of the March 15, 2011 letter, freeboard limits in Ce1l4A were no
longer required.
6.5 Cell4B
Ce1l4B was constructed in 2010 and approved for service in 2011. It is currently used only for
solution containment. The cell is lined with the same HDPE system as is installed in Ce1l4A.
This cell currently serves as the final collection point for tailings solutions.
The South dike is shown in Photos 28 through 30. There is minor vegetation covering the slope
except where it had been re-dressed to remove growing erosion channels. There are currently no
significant erosion channels other than the minor rivulets that typically occur from surface water.
The top surface and roadways on the dikes are all well maintained.
Solution freeboard limits for all of the tailings cells are established iq Section 3.0 to Appendix D
of the approved license application and confirmed as License Condition 10.3 of the current
license. The established maximum freeboard limit for Ce1l4B, as calculated consistent with
Section 6.3.5 of the current version of the Tailings management System, is 5594.6 feet above
mean seal level ("FMSL"). A review of the records found that there were no instances of the
solution level in Ce1l4B exceeding the freeboard limit during the evaluation period.
Page 10
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
6.6 Movement Monuments
The Movement Monuments are placed along the outside boundary dikes in the mill tailings area.
The intent is to survey these monuments yearly and monitor for any movement in the dike. The
current boundary consists of the South Ce1l4A dike and the South Ce1l4B dike. The current
year's survey data has been provided in a July 2012 report by Jones and Demille Engineers of
Richfield, Utah, along with the previous two years points. Generally there appears to be no
significant movement with the exception of Monitor Number 426 which dropped .24 feet in
elevation. The adjacent monitors do not follow this trend and it is suspected that this is an error
or the monitor was disturbed. It is recommended that the next survey be compared with the
previous to verify this conclusion. Also Monitor Number 507 was reset in December 2011
resulting in a raise in elevation of 1.58 inches.
7.0 SETTLEMENT MONITORS
Settlement monitors are required to be placed on covered tailings cells. Cell 2 has a series of
monitors covering the cell. Cell 3 also has monitors located where cover has been placed over filled
areas. The locations of the monitors are shown on the Settlement Monitor Points drawing. The
tracking of the changing elevations of the monitors shows the settlement or stability of the tailings
within the cell.
Elevation surveys of all settlement monitors are taken monthly. The trend of the data from these
monuments shows the settling or stability of the tailings sands. Cell 2 has continued to show a slow
settling trend on most monuments. The monuments on Cell 3 appear to be mixed, with some
showing relative stability, and others showing a settling trend. On Cell 3 there were 11 new
settlement monitors added since the last evaluation. The collected data and charts for each
settlement monitor are included with this evaluation.
Page 11
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
The requirement to place monitors over 11e.(2) disposal areas has also been added since the last
evaluation. These monitors are only required to be surveyed once per year. There has not been
enough data collected to establish any kind of trend, and therefore a chart is not provided for the
11e.(2) settlement monitors. In August of 2012 monitors M-1 and M-2 were hit twice by mobile
equipment which tipped the casings approximately 20 degrees. In both cases the monitors were
straightened and resurveyed. Both surveys were less than 0.05 feet different than the Jones and
Demille survey points which occurred in July. No further action should be necessary.
8.0 lle.(2) WASTE DISPOSAL
There were 2,683 tons of 11e.(2) waste material received and disposed of during the evaluation
period, all of which was placed in Cell 3. This evaluation included review of documentation and
procedures to confirm that each load of 11e.(2) material was placed and documented in accordance
with the Standard Operating Procedures for 11e.(2) Byproduct Disposal. The review confirmed that
only materials approved by the RSO were received and disposed, that each load has been placed,
compacted, and covered consistent with the requirements of the SOP, and that Mill personnel have
been documenting each load consistent with the requirements of the SOP.
9.0 TAILINGS TRANSPORT SYSTEM
The tailings slurries and solutions are transported to the tailings cells via HDPE pipelines. During
mill operation these lines are inspected on a daily basis for leaks or other potential problems. The
majority of tailings produced during this period of evaluation were transported to Cell 4A. The
pipelines are run to the interior of the cell such that the discharge does not impact the dikes or cell
liner. In Ce1l4A the pipes are run down "splash pads", which are an added layer of liner on top of
the standard cell lining.
Page 12
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
10.0 CONCLUSIONS AND RECOMMENDATIONS
The White Mesa Uranium Mill Tailings Management System is functioning as designed according to
the routine inspection reports and the observations from this Annual Technical Evaluation conducted
on November 9th through 12th, 2012. The inspection records were complete and the personnel
involved were adequately trained to detect any abnormalities or signs of distress in a timely manner.
The following items should be monitored or addressed:
• The vegetative growth is moderate in all of the diversion ditches. Growth of vegetation
should continue to be monitored during routine inspections and maintenance action taken as
necessary.
• Vegetative growth along the Ce1l4A dike faces is moderate on all areas of the dikes. The
continued growth of vegetation should be monitored to ensure that it does not grow heavy or
dense such that inspection cannot be accomplished.
• Annual refreshers on the requirements and operation of the Tailings Management System had
been given to all personnel that are currently conducting the inspections. Annual refreshers
for the inspectors are recommended, particularly with the additional requirements that are
included in the Ce1l4A BAT Operations and Maintenance Plan. Trainers should ensure that
all the inspectors have read and understand the Ce1l4A BAT Operations and Maintenance
Plan. Documentation of the most recent training of inspection personnel was well organized
and available for review.
• Cell 3 is very near capacity and is basically closed to solids deposit from mill processing.
Inspection records indicate that there have been occurrences of blowing sands from Cell 3. It
is recommended that the sands be graded and kept moist to prevent blowing while the cell is
being closed and covered.
Page 13
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15,2012
• Surface water erosion on the exterior slopes of Cell4A and Cell4B should be monitored and
repaired as necessary.
• Prairie dog activity was found in the vicinity of Cell 1 and Diversion Ditch 1. The activity
was not detrimental and the Environmental Department is keeping control of the population,
however it should be continued to be monitored and controlled to prevent expansion.
11.0 REFERENCES
The following documents were used or referenced in the annual technical evaluation of the White
Mesa Uranium Mill Tailings Management System:
State of Utah Radioactive Materials License No. UT1900479 Amendment #05, dated August 24,
2012
u.S. NRC Materials License SUA-1358 with Amendment No. 13, dated February 10,2000
"Site Selection and Design Study, Tailings Retention and Mill Facilities" by Dames & Moore, May
15,1978.
"Environmental Report, White Mesa Uranium Project, San Juan County, Utah".
"Engineer's Report, Second Phase Design -Cell 3 Tailings Management System, White Mesa
Uranium Project, Blanding, Utah" by D'Appolonia Consulting Engineers, February 1982.
"Construction Report, Second Phase, Tailings Management System, White Mesa Uranium Project"
by Energy Fuels Nuclear, Inc., March 1, 1983.
"Ce1l4 Design -Tailings Management System, White Mesa Project, Blanding, Utah" by Umetco
Minerals Corporation, August, 1988.
"Design, Construction and Inspection of Embankment Retention Systems for Uranium Mills",
October, 1980, Nuclear Regulatory Commission Guide 3.11.1.
"Safety Evaluations of Existing Dams", Bureau of Reclamation.
/
Page 14
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
"White Mesa Mill-Drainage Reportfor Submittal to NRC" dated January, 1990.
"White Mesa Mill -Environmental Protection Manual, Section 3.1 entitled White Mesa Mill Tailings
Management System Revision 2.1, July 2012, Denison Mines (USA) Corp.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System" , 1996, 1997,
1998,1999,2000,2001,2002.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", June 2002
through May 2003.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", June 2003
through May 2004.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", June 2004
through July 2005.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", July 2005
through July 2006.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", July 2006
through July 2007.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", August 2007
through July 2008.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", August 2008
through July 2009.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", August 2009
through October 2010.
"Annual Technical Evaluation of the White Mesa Mill Tailings Management System", November
Page 15
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
2010 through October 2011.
Page 16
Annual Technical Evaluation
White Mesa Uranium Mill
Tailings Management System
November 15, 2012
12.0 CERTIFICATION:
This report has been prepared by a Utah Registered Professional Engineer as indicated below.
Page 17