DRC-2013-001788 - 0901a0688035f9d0

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DFVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
Phil Goble, Section Manager ^ ^/^ ^/^g>i 3,
DRC-2013-001788
Russell J. Topham, P.E
March 19, 2013
Engineering Module 75A, Project C-2013-62: Review of the 4* Quarter, 2012 (October-
December, 2012) DMT Performance Standards Monitoring Report and Cell 4A and Cell
4B BAT Performance Standards Monitoring Report (Report). Groundwater Discharge
Permit (GWDP) UG370004 - Energy Fuels Resources, hic. (EFR) White Mesa Mill,
Blanding, Utah
This is a summary of Utah Division of Radiation Control (DRC) staff review of the EFR DMT
Performance Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards Monitoring Report
dated Febmary 28, 2013, and covering the 4* Quarter, 2012 (October-December, 2012) monitoring period
(Report). DRC received the Report on March 1, 2013 in both hard copy and soft copy CD formats.
Discussions in this document reference the White Mesa Mill Discharge Minimization Technology (DMT)
Monitoring Plan, Revision 12.1 (DMT Plan). The DMT Plan in force during the Period in question was
executed on July 25, 2012.
After review of this report, DRC staff findings and recommendations are as follows:
1. EFR has provided the weekly slimes drain maximum/minimum fluid level monitoring data in
support of compliance with Part I.F.2 of the GWDP and Part 3.1(b)(v) of the DMT Monitoring
Plan.
2. EFR has provided the data required in Part I.D.3(b)(2) of the GWDP. The data demonstrate
compliance with the requirements of the GWDP for slimes drain head recovery testing.
3. The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the License and the DMT/BAT plan in force during the quarter.
4. EFR monitored the Cell 4B solution pool elevation as required to demonstrate compliance with
the freeboard requirement.
5. EFR included in the Report data from tailings beach elevation and area surveys.
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 'TDD (801) 536^414
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Printed on 100% recycled paper
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6. EFR included in the Report leak detection system monitoring data and leakage rate calculations
for Cell 1 and Cell 3.
7. EFR performed solution pool elevation monitoring in Cell 4A to facilitate determination of
allowable FML leak rate. Cell 4A solution pool monitoring data and the numerical determination
of compliance with FML leak rate standards for Cell 4A and Cell 4B appear in the Report
Attachments.
8. EFR maintenance crews, while working on pipe drops associated with the tailings transfer piping,
tore the pond liner in three locations very close to one another near the top of Cell 4A. These tears
occurred above the tailings beach on the north bank of the cell^ well above the solution fluid level.
The liner tear occurred on December 20, 2012, with repair completed the same day. In summary,
the repairs appear successful. Vacuum testing indicates that repair crews achieved a competent
bond between the liner fabric and the repair patch. Should down-gradient ground water
monitoring reveal adverse changes in water quality, the repair should receive scmtiny to ascertain
whether a failure of this patch, or some other undetected damage to the liner might be the source
of the contamination.
9. Data presented in the report demonstrate EFR compliance with the decontamination pad
inspection and maintenance requirements of the DMT/BAT Plan.
10. EFR has met the provisions of the DMT Plan with regard to feed material stockpiles.
The DRC should issue a closeout letter for the review of this report.
1.0 Slimes Drain Water Level Monitoring
>
Part I.F.2 of the GWDP requires EFR to include in the Report, all DMT performance standards monitoring
detailed in Parts I.D.3 and I.E.7 of the GWDP. Part I.D.3(b)(l) of the GWDP requires EFR to maintain the
fluid level in the slimes drain of Cells 2 and 3 as low as reasonably achievable at all times, and to
demonstrate that performance through adherence to the current DMT Monitoring Plan. Part I.E.7(b) of the
GWDP requires monthly monitoring and recording of the depth to wastewater in the slimes drain access
pipe as described in Part I.D.3 of the GWDP and the current DMT Monitoring Plan. Part 3.1(b)(v) of the
DMT Monitoring Plan requires EFR to monitor and record weekly the depth to wastewater in the Cell 2
slimes drain access pipe to determine maximum and minimum head before and after a pumping cycle,
respectively.
1. Section 4.1 of the Report asserts that the above discussed monitoring requirements only pertain to
Cell 2 for the reporting period, as dewatering operations have not commenced in Cell 3.
2. Weekly water level monitoring of the Cell 2 slimes drain is not required as part of the DMT plan,
but is required under Part I.D.3(b)(l) of the GWDP, Inasmuch as this data was not being reported
elsewhere, EFR agreed in a conference call on October 26, 2011 to provide the data as part of the
quarterly DMT Report until a more appropriate reporting mechanism was instituted. EFR included
results of Cell 2 slimes drain level monitoring in the quarterly DMT reports from that time forward
until, and including, the report for the 3"* Quarter of 2012.On July 25, 2012, the DRC approved a
new EFR Tailings Management System document. Revision 2.1. This document now captures the
Cell 2 slimes drain monitoring requirement. Thus, with this report, EFR has discontinued including
this data in the quarterly DMT reports.
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3. Attachment C to the Report contains data from the quarterly recovery head measurements
(discussed in the next paragraph).
)
4. The recovery head monitoring data provides indirect evidence that EFR has maintained the fluid
level in the Cell 2 slimes drain as low as reasonably achievable, as required in GWDP, Part
I.D.3(b)(l).
Finding: Data provided in Attachment C to the Report supports a conclusion that EFR has met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
Part I.p.3(b)(2) of the revision of the GWDP in force during the 4*^ quarter of 2012 required EFR to
perform a quarterly slimes drain head recovery test at each tailings cell slimes drain. Specifications for the
head recovery test appear m Parts I.D.3(b)(2)(i) and (ii) of the GWDP.
Part I.D.8.2(e) of the GWDP requires each quarterly report to contain the current year monthly fluid level
values and a graphical comparison with previous years for the Cell 2 slimes drain. Part I.D.3(b)(3) of the
GWDP includes an analytical test to determine annual slimes drain compliance. The analytical procedure
provides a means of demonstrating the success of dewatering operations in the tailings cell. The average
annual fluid level in the slimes drain must fall each year for the slimes drain to remain in compliance. The
latest revision of the GWDP changes the recovery test frequency from monthly to quarterly.
5. Attachment C to the Report contains the required head recovery test data.
6. Attachment D to the Report contains the required graphical comparison. The regression series
included on the chart shows graphical evidence of general compliance with the requirement to
reduce fluid head in the slimes drain.
Findings: EFR has provided the data required in Part I.D. 3 (b)(2) of the GWDP. The data demonstrate
compliance with the requirements of the GWDP for slimes drain head recovery testing. The Cell 2 slimes
drain fluid level appeared to continue its declining trend, as required, and in contrast to the increased
elevation noted during the fourth quarter of 2010.
2.0 Tailings Wastewater Pool Elevation Monitoring and Roberts Pond Solution Level Monitoring
Part I.E.7(a) of the GWDP requires EFR to monitor and record weekly the elevation of the wastewater pool
in Tailings Cells 1 and 3 to ensure compliance with Condition 10.3 of the License. Part I.D.3(e) requires
EFR to operate Roberts Pond so as to provide a minimum two feet of freeboard at all times. Part 3.1(d) of
the DMT/^AT Plan requires EFR to measure the solution pool elevation in Cells 4A and 4B weekly, and
the tailings beach maximum elevation and area within Cells 4A and 4B monthly.
Tailings have nearly completely filled Cell 3. Recognizing this, letters from the Executive Secretary dated
January 27, 2011 and March 14, 2011 formally eliminated the need for solution pool elevation
measurement in Cell 3. The previously cited January 27, 2011 letter and another letter from the Executive
Secretary dated March 15, 2011 concluded a process obviating the need for freeboard-related solution pool
elevation monitoring in Cell 4A. However, Part 3.1(a) of the DMT/BAT Plan requires monitoring solution
pool elevations in Cells 4A and 4B to facilitate determination of compliance with FML leakage rate
limitations.
1. Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with
the prescribed freeboard requirements.
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2. As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed
during the third quarter. Attachment A to the report reflects no measurements for the reported
quarter.
3. Attachment A to the Report contains weekly pool elevations for Roberts Pond indicating
compliance with the prescribed freeboard requirements.
4. Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of
calculating acceptable leak rates for the liner system. EFR failed to take the required solution pool
measurements in Cell 4A during the and 2"** quarters, and part of the 3"^ quarter of 2011.
However, EFR has retumed to compliance, having taken and reported the required elevation
readings for the latter portion of the 3^'^ quarter and the entire 4* quarter of 2011, and all quarters of
2012.
5. Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating
compliance with the prescribed freeboard requirements.
Findings: The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the DMT/BAT plan in force during the quarter. Repair of damage to the Cell 4A liner
appears successful.
3.0 Leak Detection System Monitoring ^
Part 3.1(a) of the DMT/BAT Plan requires EFR to monitor the leak detection system (LDS) for Cell 1 and
Cell 3 weekly. EFR would either report the LDS as dry or report the fluid level in the LDS monitor pipe.
Presence of fluid in the LDS triggers a requirement to extract the fluid, measure the extracted volume, and
compute a leakage rate for the cell.
1. Attachment C to the Report contains data showing the Cell 1 and Cell 3 LDS dry during the 4^^
quarter of 2012.
Findings: Cell 1 and Cell 3 seem to have had no detectable leakage during the 4'^ quarter of 2012.
Part I.D.6(a) of the GWDP requires EFR to operate Cell 4A in a manner to maintain fluid head in the LDS
not more than 1 foot above the lowest point on the lower FML on the cell floor. Part I.D.6(b) requires that
the leak rate through the Cell 4A FML not exceed 24,160 gallons per day. Part 3.1(a) of the DMT/BAT
Plan reiterates the GWDP requirements just discussed. Table 1A in Appendix E to the DMT/BAT Plan
relates solution pool head above the^liner system to maximum allowable FML leak rate.
2. Calculation of solution pool head requires measuring the solution pool elevation. Attachment A to
the Report presents the required solution pool elevation readings for Cell 4A.
3. Attachment F to the Report presents LDS fluid level monitoring data and number of gallons
pumped from the LDS.
4. Quantities of fluid pumped from the Cell 4A LDS support a finding of compliance with the
operational requirements of the GWDP and DMT/BAT Plan.
Findings: EFR has complied with the FML leakage rate provisions of the DMT/BAT Plan with respect to
cell 4A. This includes solution pool elevation monitoring, extracting fluid when it exists in the LDS, and
maintaining FML leakage rate below the prescribed limits.
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Part I.D. 13(a) of the GWDP requires EFR to operate Cell 4B in a manner to maintain fluid head in the LDS
not more than 1-foot above the lowest point on the lower FML on the cell floor. Part I.D. 13(b) requires that
the leak rate through the Cell 4B FML not exceed 26,145 gallons per day. Part 3.1(a) of the DMT/BAT
Plan reiterates the GWDP requirements just discussed. Table IB in Appendix E to the DMT/BAT Plan
relates solution pool head above the liner system to maximum allowable FML leak rate.
5. Calculation of solution pool head requires measuring the solution pool elevation. Attachment A to
the Report presents the required solution pool elevation readings for Cell 4B.
V
6. Attachment F to the report presents LDS fluid level monitoring data and number of gallons
pumped from the LDS.
7. Quantities of fluid pumped from the Cell 4A LDS support a finding of compliance with the
operational requirements of the GWDP and DMT/^AT Plan.
Findings: EFR has complied with the FML leakage rate provisions of the DMT/BAT Plan with respect to
cell 4B. This includes solution pool elevation monitoring, extracting fluid when it exists in the LDS, and
maintaining FML leakage rate below the prescribed limits.
Part I.E. 8(a)(1) of the GWDP requires EFR to provide continuous operation of the Cell 4A LDS pumping
and monitoring equipment, and to make such equipment operational within 24 hours of discovery of a
failure of such equipment. Part I.D. 12(a)(1) of the GWDP requires EFR to provide continuous operation of
the Cell 4B LDS pumping and monitoring equipment, and to make such equipment operational within 24
hours of discovery of a failure of such equipment.
8. On July 23, 2012, while performing the daily inspection regimen, EFR plant personnel discovered
that the Cell 4A LDS system displayed data, but the data logger had ceased recording. Plant
personnel recorded on the inspection forms the readings required under the DMT Plan. Plant
personnel reset the recording equipment, after which proper recording resumed. Having recorded
the required data on the inspection form, no violation of the data acquisition portions of the DMT
Plan occurred. EFR retumed the system to proper operation within 24 hours of discovery of the
malfunction, as required.
9. Section I.E.8(a)(l) of the GWDP requires EFR to provide continuous operation of all elements of
the leak detection systems for the various cells. Failure to repair a failed system and bring it to full
operation within 24 hours constitutes a violation of the GWDP and of BAT. EFR had no instances
of failures not corrected and made operational within 24 hours of discovery.
Findings: EFR has complied with the operational and, monitoring requirements pertaining to the LDS and
its attendant equipment for- the quarter.
4.0 Decontamination Pad Inspections
Part 3.1(e)(i) of the DMT/^AT Plan sets forth requirements for monitoring the New Decontamination Pad.
Subpart (B) requires weekly measurement of fluid level in the inspection portals to detect leakage of the
primary containment barrier. Subpart (F) imposes requirements to inspect weekly the integrity of the
concrete comprising the New Decontamination Pad surfaces and to repair any cracks greater than 1/8 inch
in width or other abnormalities in the pad surface. Part 3.1(e)(ii) imposes requirements to inspect weekly
the integrity of the concrete comprising the Existing Decontamination Pad surfaces and to repair any cracks
greater than 1/8 inch in width or other abnormalities in the pad surface.
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1. The inspection portals of the New Decontamination Pad contained no fluid at the weekly
inspections.
2. No cracking in excess of 1/8 inch or other abnormality of the surface of the New Decontamination
Pad was observed during the Report quarter.
Findings: Data presented in the report demonstrate EFR compliance with the decontamination pad
inspection and maintenance requirements of the DMT/BAT Plan.
5.0 Feedstock Storage Area Inspections
Part 3.3 of the DMT/BAT Plan requires weekly confirmation that bulk feedstock storage occurs in the
areas defined in the GWDP, that a four foot buffer exist between feedstock stockpiles and the storage area
boundary, and that ahemate feedstock stored outside the defined feedstock storage area is maintained in
water tight containers or are placed on a hardened surface.
1. Location of stockpiles within the bulk storage area appeared proper.
2. Standing water from rain events was noted in the feedstock storage area. This water was directed to
the sump, and ultimately to Cell 1 for disposal.
Findings: EFR has met the provisions of the DMT/BAT Plan with regard to feed material stockpiles.
6.0 Recommendations
1. The DRC should issue a closeout letter with respect to the Report.