DRC-2013-001661 - 0901a0688035d679

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
DRC-2013.001661 File
Phil Goble, Section Manager
Russell J. Topham, P.E.
March 20, 2013
Engineering Module 75E, DMT/BAT Field Inspection - Follow up; Radioactive Materials
License Number UTl 900479 (RML) and Ground water Discharge Permit 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 pertaining to the operation and maintenance of discharge minimization technology and approved
implementation of best available technologies for the White Mesa uranium mill, Energy Fuels resources
(USA) Inc. (EFR). No items of noncompliance were fotmd.
We forwarded a closeout letter to EFR on September 28, 2012, in which we listed three findings. The
second and third of those findings included advisory comments, which I discuss below. On March 7, 2013,
while conducting an inspection of ISL burial activities, I took the opportunity to check up on these two
issues, and thought it best to document my observations in the file. I do not anticipate a need to write a
response to EFR at this time, inasmuch as I will conduct a DMT inspection later this year, and will be
evaluating these items at that time.
Minor rill erosion on exterior dikes of Cells 4A and 4B
The following is quoted from my report following the September, 2012 BAT inspection:
Finding; Minor rill 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 exterior side slopes of the Cells 4A and 4B containment dikes to
eliminate rill erosion before it progresses to a point that it endangers the stability of the dikes.
EFR has obtained a new bulldozer. During my March 7, 2013 site visit, I noted that the exterior side slopes
of Cells 4A and 4B had been groomed, eliminating all signs of erosion.
Placement of movement monitors on south side of Cell 4A
195 North 1950 West • Salt Lake City, UT
Mailmg Address P.O Box 144850 • Salt Uke City, UT 84114-4850
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The following is quoted from my report following the September, 2012 BAT inspection:
Finding: Several movement monitors in the roadway at the top of the Cell 4A containment dike
may have been disturbed during grading activities. The placement of these monitors in 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.
David Turk indicated to me that he now had frmding to relocate the movement monitors. EFR will include
movement of the monitor points to the inside shoulder of the dike, inside the fence, during the annual
movement monitor survey in May.