DRC-2012-002965 - 0901a06880367123

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
DRC-2012-00205A
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
File
Phil Goble, Section Manager
Russell J. Topham, P.E.
September 25,2012 D R C " 2 0 1 £ - Q 0 2 9 6 g
Cell 1 Liner Repairs. Radioactive Materials License UTl900479 (RML) and Groundwater
Discharge Permit (GWDP) UG370004; Energy Fuels Resources, Inc. (EFR) White Mesa
Mill, Blanding, Utah
EFR has completed repairs to the Cell 1 liner system. As required, EFR provided a detailed report of the
repair activity in its 2"^ Quarter DMT Performance Standards Monitoring 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 pertinent. Repair activities appear appropriate, and
field vacuum testing 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 Garrin Palmer about the effort. Following the repair, crews placed one
foot of soil over the liner material; thus, I took no photos during the inspection.
Fluid levels in the cell have not retumed to an elevation above the repair, 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 in Revision 1
of the Liner Maintenance Provisions, dated October 18, 2009, and with Part LF.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 in writing on June 7,2010 by letter, fiilfilling the notification requirements
of Part LG.3 of the GWDP. The volume of fluid detected constituted a violation of Condition 11.3 of the
195 North 1950 West • Sah Lake City, UT
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Page 2
RML, triggering 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 ofthe flexible membrane liner (FML).
During 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. During a conference call on August 12, 2010, EFR and the DRC agreed that the repau-
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 during the summer months of 2011 and 2012.
Findings and Recommendations
The Mill's Liner Maintenance 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 Monitoring Report. The DRC receiyed the DMT
Report, including the repair report, on August 27,2012. This action both fulfills
report and the deadlme by which to report repair activities to the DRC.
the requirement to
The LMP requires a repair report to bear the seal and signature of a professional
registered in the State of Utah. Harold Roberts signed and sealed the report.
engmeer
3. The LMP requires the report to include a description of the damage discovered aid the work
completed to repair that damage. The report attempts to fulfill this requirement. Because the initial,
limited repair effort proved ineffective, the repair plan evolved to replacement oi'damaged sections
of liner above elevation 5613 AMSL. Thus, the description of specific damage and local repairs
pertained only to the initial, failed attempt. The liner failure appeared to result from wear and tear
imposed by foot traffic (sampling, monitoring, etc.), movement of discharge hoses and solution
transfer over the 30-year life of the liner. The narrative and attached documentation highlights
typical damage encountered, and includes photographs of typical examples, rather than
docimienting 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 ofthe repair effort.
4. The report must include specifications for materials employed in the repair. The original FML
consisted of 30 mil PVC roll stock. EFR chose a 320 mil PVC roll stock from Colorado Lining,
Inc. for the replacement material. Following removal of damaged sections of liner and preparation
of subgrade to receive the liner, the repair crew cleaned the existing material at the site ofthe seam
with methyl ethyl ketone. Crews then cut a patch from the roll stock and cemented it to the existing
liner material using an adhesive supplied with the roll stock. The materials appear appropriate for
the repair effort.
5. Repair patch seams must perform satisfactorily 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 in the repair report. Appendix 4 to the repair report
includes typewritten transcriptions 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 involves
observational methods, inspection and testing among them, to detect deviation from quality
expectations and offer opportunity for corrective action. Quality assurance should be ongoing,
while quality control can be episodic.
During a field inspection on September 20, 2012,1 queried David Turk and Garrin Palmer about
the repair effort. Both, independently, cited the challenges of training crews to perform the work
correctly, and the need for continuous rather than episodic inspection in this case. For example, all
lengths of all repair 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 risk further failure ofthe seam.
I am satisfied with the quality assurance and quality control activities EFR employed.
8. The repair report must appear in the quarterly DMT Perfomiance Standards Monitoring 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 deadline. \
In addition to the above requirements, the CAL stipulated inclusion of a root cause analysis in the liner
repair report. A root cause analysis appears as Part 3 to the report, identifying defects and damage. The root
cause analysis further clarifies the damage as the likely result of foot traffic fi-om sampling, monitoring and
other such activities, effects of discharge hoses and solution transfers, and exposure to weathering
conditions not experienced below the operating fluid level ofthe 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 imder field conditions will
ultimately prove the effectiveness of the repair effort.
Recommendation: I recommend approval of the repair report, and the underlying repairs. I recommend
retaining the file open imtil the solution level in Cell 1 reaches maximum design working elevation and
results of routine monitoring ofthe 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.