DRC-2013-002355 - 0901a068803867d1

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.com
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
May 29, 2013
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 1st Quarter of 2013
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell 4A
BAT Performance Standards Monitoring Report for the 1st Quarter of 2013, as required under Parts
I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Kathy Weinel
May 29,2013
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 1st Quarter of 2013
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell 4A
BAT Performance Standards Monitoring Report for the 1st Quarter of 2013, as required under Parts
I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
Yours very truly,
{lcL-y~~ !if
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Kathy Weinel
WIllTE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
1st Quarter
January through March
2013
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
May 29,2013
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE QUARTER ........ 1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING .................................. 2
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING ...................................................... 3
4.1 GENERAL ..................................... "' .. ~ ............................................................................................................. 3
4.2 RESULTS FOR THE QUARTER ..................................................................................................... _ .................. 5
4.3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION ..................................................................... 5
404 GRAPHIC COMPARISON TO PREVIOUS YEAR ................................................................................................. 5
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ............................................ 5
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS OF
FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE AREA ................. 6
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ................................................................ 6
8.0 DECONTAMINA TION PADS .................................................................................................................... 7
8.1 SUMMARY OF WEEKLY INSPECTIONS ........................................................................................................... 7
8.2 ANNUAL INSPECTION OF EXISTING DECONT AMINA TION PAD ....................................................................... 8
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................................................. 8
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR THE QUARTER. 9
9.1 LDS MONITORING ........................................................................................................................................ 9
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ........................................................... 9
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML ................................... 9
9.1.3 Measurement of the Volume of Fluids Pumpedfrom the LDS ............................................................... l0
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4 B ................................................. 11
9.3 SLIMES DRAIN RECOVERY HEAD MONlTORING .......................................................................................... 11
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING FOR THE QUARTER .......................... : .............. 11
10.1 OPERATIONAL STATUS OF LDS PUMPING AND MONITORING EQUIPMENT ................................................. 11
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ....................................................... 12
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1,2, AND 3 .......... _ ...................................... 12
lOA SLIMES DRAIN RECOVERY HEAD MONITORING ...................................................... _ .................................. 1~
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2012 .. 12
12.0 SIGNA TURE AND CERTIFICA TION .................................................................................................... 13
1
LIST OF TABLES
Table 1 -Summary of Waste Water Pool Elevations
Table 2 --' New Decontamination Pad Inspection Portal Level
ATTACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to PartI.G.3 of the GWDP
C Quarterly Cell 2 Slimes Drain Monitoring Data
D Graph of Cell 2 Slimes Drain Water Levels Over Time
E Cell Liner Repair Reports and Notices
F Cell4A and Cell 4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables lA and lB, Ce1l4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (part I.F.12)
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 1st QUARTER OF 2013
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the first quarter of 2013 (the "quarter") prepared by Energy Fuels
Resources (USA) Inc. ("EFRI"), as required under Part I.F.2 of the White Mesa Mill's (the
"Mill's") State of Utah Groundwater Discharge Permit No. UGW370004 (the "GWDP"), and the
Routine Cell 4A and Cell 4B Best Available Technology ("BAT") Performance Standards
Monitoring Reports for the quarter, as required under Part I.F.3 of the GWDP.
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER
During the quarter, the following DMT monitoring was performed or addressed, as required
under Part I.D.3, I.E.7, and I.F.ll of the GWDP:
• Weekly tailings wastewater pool elevations for tailings Cells 1 and 3 (Part
I.E.7(a));
• Quarterly slimes drain water levels in Cell 2 (Part I.D.3(b)(1) and (2));
• Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.ll);
• Weekly wastewater level measurements in Roberts Pond (Part I.D.3(e) and Part
I.E.7(c));
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part I.D.3(f) and Parts I.E.7(d); and
(e));
• Any tailings cell and pond liner system repairs (Part I.E.7 (f) and Part I.E.(S)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g)) and
• Annual Decontamination Pad Concrete Inspection (Part I.F.11) (not required this
reporting period)
Also during the quarter, the following Cell 4A and 4B BAT performance standards monitoring
was performed, or addressed, as applicable and as required by PaIts I.E.S and I.E.12 of the
GWDP:
• Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.S.(a)), and Cell
4B (Part I.E. 12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.S (a))
and Ce1l4B (Part I.E.12 (a)).
1
3.0 WEEKL Y TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in the Mill's tailings
cells during this quarter, to ensure compliance with the maximum wastewater elevation criteria
mandated by Parts I.E.7(a), I.E.8(a) and I.E.12(a) of the GWDP. The results of such
monitoring, reported as feet above mean sea level ("fmsl"), are included in Attachment A. Part
I.D.2 of the GWDP provides that under no circumstances shall the freeboard of any tailings cell
be less than three feet, as measured from the top of the flexible membrane liner ("FML"). The
top of the FML in ·Cell 1 is at 5,618.5 fmsl, and the top of the FML in Cell 4B is 5600.4 fms!'
This means that the maximum wastewater pool elevations in Cells 1 and 4B permitted under Part
I.D.2 of the GWDP are 5,615.5, and 5597.4 fms!, respectively.
The maximum wastewater pool elevations in Cells 1 and 4B, as measured during the quarter, are
summarized in the following Table 1. The requirements to meet freeboard elevation limits in
Cell 3 and Cell 4A were eliminated as documented on March 14 and 15, 2011 respectively. As
indicated in Table 1, the applicable freeboard limits were exceeded for Cell 1 during the first
quarter. The details and investigation regarding the Cell 1 freeboard exceedance are included in
the May 14, 2013 Division of Radiation Control ("DRC") Notice included in Attachment B. As
noted in the Notice in Attachment B, the wastewater pool elevations were brought back into
compliance between March 15 and March 22, 2013 and have remained below the freeboard limit
since that time. The applicable freeboard limits were not exceeded for any other Cell during the
quarter.
All cells, except Cell 1 as noted above, met the maximum wastewater criteria of the Mill's State
of Utah Radioactive Materials License No. UT 1900479 (the "License") throughout the period.
The requirements to maintain a minimum freeboard in Cell 3 and Cell 4A were removed by the
Director of the Utah Division of Radiation Control (the "Director") during the first quarter of
2011 as detailed below.
Condition 10.3 of the License provides that the freeboard limit for Cell 1 shall be set in
accordance with procedures that have been approved by the U.S. Nuclear Regulatory
Commission ("NRC"). Under those procedures the freeboard limit for Cell 1 is set as per the
January 10, 1990 Drainage Report for CellI at a liquid maximum elevation of 5,615.4 fms!'
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 Director dated January 27, 2011, which approved the use of Cell 4B, and a subsequent
letter dated March 14, 2011, stated that authorization of the use of Cell 4B and approval of the
DMT and Cell 4A Operations and Maintenance ("O&M") Plans effectively eliminated the
former freeboard elevation requirements for tailings Cell 3. The approvals of the DMT and Cell
4A O&M Plans also resolved previous freeboard exceedance issues and further stated that
former issues regarding the freeboard exceedances for Cell 3 are closed out. Pursuant to the
receipt of the March 14, 2011 letter, freeboard elevation survey measurements in Cell 3 were no
longer required or conducted.
2
A letter from the Director dated January 27, 2011 which approved the use of Cell 4B and a
subsequent letter dated March 15, 2011, stated approval of the DMT and Cell 4A and Cell 4B
O&M Plans effectively eliminated the former freeboard elevation requirements for tailings Cell
4A, which was replaced by a freeboard limit for Cell 4B that will accommodate the freeboard
requirements of Cells 1, 4A, and 4B. The approvals of the DMT and Cell 4A and 4B O&M
Plans also resolved previous freeboard exceedance issues and further stated that former issues
regarding the freeboard exceedances for Cell 4A are closed out. Pursuant to the receipt of the
March 15, 2011 letter, freeboard limits in Cell 4A were no longer required. The solution
elevation measurements in Cell 4A are not required for compliance with freeboard limits but are
required for the calculation of the daily allowable volume of fluids pumped from the Cell 4A
LDS and are collected for this purpose.
Table 1 -Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measured During the Permitted Under Elevation Permitted
Quarter (fmsl) License Condition Under Part LD.2 of
10.3 (fmsl) the GWDP (fmsl)
CellI 5616.26 5,615.40 5,615.50
Cell 3 Not Measured -No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in 012011
Ce1l4A 5593.49 -freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
01 2011.
Ce1l4B 5578.82 5594.60 5597.40
* The Director approved the removal of the Cell 3 freeboard lmllt and authonzed the use ofCe1l4B on January 27,
2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
** The Director granted a variance from the Cell 4A freeboard limit on January 13, 2011, and approved the removal
of the Cell 4A limit and authorized the use of Cell 4B on January 27, 2011. The previous freeboard limit noted
above for Cell 4A was not set out in the License. The freeboard limit of 5,593.74 for Cell 4A was set out in a letter
from the Director dated November 20, 2008. The approved DMT Plan, Revision 11.1 dated January 2011, included
the removal of the freeboard limit for Ce1l4A to be replaced by a freeboard limit for Cell4B that will accommodate
the freeboard requirements of Cells 1, 4A, and 4B.
4.0 QUARTERLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b)(l) of the GWDP provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the DMT Plan. Part I.D.3(b )(3) of the GWDP
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Part I.D.6(c) of the GWDP provides that, after the Permittee initiates pumping conditions in the
slimes drain layer in Cell 4A, the Permittee will provide: 1) continuous declining fluid heads in
the slimes drain layer, in a manner equivalent to the requirements found in Part I.D.3(b), and 2) a
3
maximum head of 1.0 feet in the tailings (as measured from the lowest point of the upper FML)
in 6.4 years or less. Similarly, Part I.D.13( c) of the GWDP provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4B, the Permittee will provide: 1)
continuous declining fluid heads in the slimes drain layer in a manner equivalent to the
requirements found in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as
measured from the lowest point of the upper FML) in 5.5 years or less.
The GWDP, dated July 14,2011, Part I.D.3 (b)(2) states "effective July 11,2011, the Permittee
shall conduct a qualterly slimes drain recovery test ... ". Monthly testing was conducted through
the second quarter of 2011. The frequency change dictated by the GWDP was implemented in
the third quarter 2011. The test ensures that each tailings cell meets the following minimum
requirements: 1) includes a duration of at least 90-hours, as measured from the time that
pumping ceases, and 2) achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements with no change in water level, as measured
to the nearest 0.01 foot.
At this time, dewatering operations have not commenced in Cell 3, Cell 4A, or Cell 4B. As a
result, the requirements in Part I.E.7(b) to monitor and record monthly the depth to wastewater in
the slimes drain access pipes as described in Part I.D.3 of the GWDP apply only to Cell 2 at this
time. Accordingly, this Report is limited to slimes drain recovery head information relating to
Cell 2 only.
Pursuant to Parts I.E.7(b) and I.F.2 of the GWDP, Section 8.2 of the DMT Plan and
correspondence from DRC, dated February 7, 2008, the results of quarterly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Performance Standards Monitoring Report
and Cell4A and Cell 4B BAT Performance Standards Monitoring Reports (the "DMT Reports").
Further, beginning in 2008, quarterly DMT Reports must include both the current year values
and a graphic comparison to the previous year. The annual slimes drain recovery head report for
2012, which addresses the requirements of Part I.F.11 of the GWDP and Section 8.2 of the DMT
Plan, are included in Section 11 of this report.
The requirement in Section 3.1(b)(v) of the DMT Plan to monitor the depth to wastewater in the
Cell 2 slimes drain access pipe weekly to determine maximum and minimum fluid head is a
requirement of the License, is not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP, and hence is not required to be included in the routine DMT
Performance Standards Monitoring Report under Part I.F.2 of the GWDP. EFRI included the
depth to wastewater in the Cell 2 slimes drain access pipe in previous DMT reports. The
information was included based on a request from DRC for completeness. EFRI revised the
DMT Plan by preparing two separate plans for the GWDP and the License requirements and
submitted the revised plans on July 25, 2012. EFR received DRC approval of the plans on
August 6, 2012. Since the approval of the revised DMT plan was received mid-third quarter, the
Cell 2 slimes drain data are included in the third quarter report. As noted in the third quarter
DMT report, EFRI provided quarterly DMT reports addressing only the GWDP DMT
requirements beginning with the fourth quarter 2012 report. The data for the weekly depth to
wastewater measurements in the Cell 2 slimes drain are no longer included in this report. The
4
weekly depth to wastewater measurements for the Cell 2 slimes drain are available at the Mill for
inspection.
Attachment B includes a Notice regarding missed weekly depth to wastewater measurements in
the Cell 2 slimes drain. The measurements were missed as a result of weather related
complications due to prolonged freezing temperatures during the first week of the first quarter
2013. As noted above, this notice and the reporting of the missed measurements are not required
to be included in this DMT report. The Notice is included for information purposes only.
4.2 Results for the Quarter
In accordance with these requirements, the quarterly slimes drain recovery head monitoring data
for the quarter, which includes the date and time for the start and end of the recovery test, the
initial water level, and the final depth to stable water level for the quarter, are included as
Attachment C to this Report.
4.3 Quality Assurance Evaluation and Data Validation
EFRI management has evaluated all slimes drain data collected, data collection methods, and all
related calculations required by the GWDP, and have verified the accuracy and reliability of both
the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, EFRI has concluded
that all of the 2009, and 2010 monthly slimes drain tailings fluid elevation measurements, the
2011 monthly (through June) and quarterly (July forward), and the quarterly 2012 slimes drain
tailings fluid elevation measurements to date meet the test performance standards found in Part
I.D.3(b)(2) of the GWDP and can be used for purposes of determining compliance with the
requirements of Part I.D.3(b)(2) of the GWDP.
4.4 Graphic Comparison to Previous Year
A graph showing the final depth to stable water level readings for each month in 2009 through
third quarter 2012 (quarterly beginning in July 2011), for which validated data is available (see
Section 4.3 above), is included as Attachment D, which shows a graphic comparison of this
quarter's data to data for 2009, 2010, 2011 and 2012. Stable water levels have decreased by one
foot in 2012 and four feet since 2009.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
During the quarter, Mill personnel monitored and recorded weekly the wastewater levels at
Roberts Pond to determine compliance with the DMT operations standards in Part I.D.3(e) of the
GWDP. Part I.D.3(e) of the GWDP provides that the water level in Roberts Pond shall not
exceed an elevation of 5,624 fmsl.
5
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5,621.73
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The results of such
monitoring are included in Attachment A.
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the GWDP and that all alternate feedstock located outside the defined
feedstock area is maintained in compliance with the requirements of Part I.D.11 of the
GWDP. The results of these inspections are recorded on the Weekly Mill Inspection forms,
which are available at the Mill for inspection. One item was noted during the third quarter
inspections. During the weekly inspections conducted on January 25, February 1, February 8,
February 15, February 22, February 28, and March 8, 2013 standing water was noted in the one
of the feedstock storage areas. The water was the result of precipitation. No corrective actions
were necessary as the areas where water was noted are sloped towards a drainage sump that
allows the water to drain to Cell 1. The remaining water noted during the weekly inspections
listed above, was a small amount which remained after the majority of the rain water had
drained.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, 3, 4A, and 4B were inspected on a daily basis. The results of
those inspections are recorded on the Mill's Daily Inspection Data sheets, which are available at
the Mill for review. A visual inspection of Roberts Pond was performed on a weekly basis. The
results of those inspections are recorded on the Weekly Mill Inspection forms, which are
available at the Mill for review.
The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached only single digit highs on December 19, 2012. On December 19, 2012 a
transformer supplying power to the Cell 1 area failed. The Mill managed this power interruption
by temporary installation of two portable generators on December 20, 2012. This incident was
described in EFRI's telephone notification to DRC on December 19,2012, and in written notices
of January 8, January 12, and January 17, 2013 which are included in Attachment B. On the
afternoon of January 11, 2013 as part of the repairs and corrective actions resulting from the
power loss, Mill maintenance personnel were using a backhoe to prepare a trench for replacing a
failed power line. The maintenance plan was for the trench to be excavated with one section in a
north-south direction in the area east of Cell 2, and a second section in an east-west direction
along the dike between Cell 2 and Cell 3. During the repairs the backhoe snagged and tore a
portion of the Cell 2 liner where it rises over the dike and enters the anchor trench south of Cell
2. The tear was above and outside the cell and outside the area containing any tailings material
or cover material. Cell 2 is in interim closure status and is not in service. EFRI notified the Utah
6
Division of Radiation Control via an email dated January 12, 2013. The January 12,2013 e-mail
is included in Attachment B.
In accordance with Part I.E.7(f) and I.G.3 of the GWDP, EFRI identified, and initiated repairs to
damage to the Cell 2 Liner System. Repairs to the liner were completed on January 17, 2013, in
accordance with the Mill's Liner Maintenance Provisions. A copy of the January 17, 2013
notification is included in Attachment B of this DMT report.
Repairs were performed by qualified liner repair personnel. Pursuant to Part I.F.2 a Liner Repair
Report is included with this DMT Report as Attachment E.
The second quarter 2012 DMT report included the Cell 1 FML repair activities report as required
by the September 22, 2010 Confirmatory Action Letter. DRC approved the EFRI Cell 1 FML
repair report by letter dated September 25,2012. The September 25, 2012 DRC letter also noted
"The DRC will maintain an open file for the Cell 1 liner repair until the design maximum
operating fluid level is held for 30 days and monitoring of the leak detection system yields
results supporting a finding of successful repair. Routine leak detection system monitoring, as
presented in the quarterly DMT report will suffice as a reporting tool, along with noting the date
the fluid level reached design maximum." As noted in the September 22, 2010 Confirmatory
Action Letter, the fluid level design was lowered to 5613.1 fmsl to facilitate liner repair. The
design maximum operating fluid level is therefore above that level. Mill personnel monitored
and recorded weekly the elevation of wastewater in Cell 1 during the first quarter 2013. The
weekly measurements are included in Attachment A. As noted in Attachment A, the fluid level
in Cell 1 was greater than 5613.1 fmsl all of the first quarter 2013. The DRC requirements for
closure of the Cell 1 liner repair is that a fluid level above 5613.1 be held for 30 days and the
leak detection system yield results supporting a finding of successful repair. The leak detection
system for Cell 1 did not report any fluid levels during the reporting period and the level above
5613.1 was held. These items will not continue to be monitored and reported in future DMT
reports since the DRC conditions for closure of the Cell 1 FML repair report are met.
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Inspections
Part I.F.7 (g) of the GWDP and Section 3.1 of the DMT Plan require that a weekly inspection of
the New Decontamination Pad be performed, and that the vertical inspection portals on the New
Decontamination Pad which are located between the primary and secondary containments be
visually observed on a weekly basis as a means of detecting any leakage from the primary
containment into the void between the primary and secondary containments. The BAT
performance standards for the New Decontamination Pad are set out in Part I.D.14 of the
GWDP. The New Decontamination Pad was placed into service on March 22,2010. Use of the
New Decontamination Pad was temporarily suspended during the second quarter 2010 as a result
of a cease and desist order from DRC dated May 18, 2010. Because the New Decontamination
Pad was not in use after the second quarter 2010, the weekly inspections of the containments
were stopped for the remainder of 2010. The Executive Secretary provided authorization for use
of the New Decontamination Pad in a letter dated February 1, 2011. Use of the New
7
Decontamination Pad resumed in February 2011 and the weekly inspections were resumed as
required.
Table 2 below indicates the water level measurements in each portal measured during the
quarter.
Table 2 -New Decontamination Pad Inspection Portal Level for the Fourth Quarter 2012
Portal 1 Portal 2 Portal 3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
114/2013 0.00 0.00 0.00
1/14/2013 I 0.00 0.00 0.00
1/18/2013 0.00 0.00 0.00
112512013 0.00 0.00 0.00
2/1/2013 0.00 0.00 0.00
2/8/2013 0.00 0.00 0.00
2/15/2013 0.00 0.00 0.00
2/22/2013 0.00 0.00 0.00
3/1/2013 0.00 0.00 0.00
3/8/2013 0.00 0.00 0.00
3/15/2013 0.00 0.00 0.00
3/22/2013 0.00 0.00 0.00
3/2912013 0.00 0.00 0.00
As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the quarter.
Any soil and debris identified during the weekly inspections was removed from the wash pad of
the New Decontamination Pad, in accordance with part LD.14 (a) of the GWDP and Section 3.1
(e)(i)(F) of the DMT Plan. No cracks greater than 1/8" were observed during any weekly
inspections.
8.2 Annual Inspection of Existing Decontamination Pad
As required by Part LF.12 of the Permit, annual inspections of the existing decontamination pad
must be conducted during the second quarter of each year. The documentation for the 2012
annual inspections was reported in the Second Quarter DMT report submitted August 23, 2012.
The 2013 annual inspection will be conducted during the second quarter of 2013.
8.3 Annual Inspection of New Decontamination Pad
As previously stated, the New Decontamination Pad was placed into service on March 22, 2010.
Use of the New Decontamination Pad was temporarily suspended as a result of a cease and desist
order from DRC dated May 18,2010. DRC's approval for use of the New Decontamination Pad
8
was granted on February 1, 2011, following submittal of revisions to the DMT Plan and DRC
observation of hydrostatic testing of the in-ground water holding tanks. Revisions to the DMT
Plan were submitted by Denison on November 12, 2010 and reviewed by DRC. Hydrostatic
testing was re-performed from November 24 to 26, 2010 following a 10-day advanced notice to
DRC on November 12, 2010. The Executive Secretary provided an authorization for use of the
New Decontamination Pad in a letter dated February 1, 2011. Use of the New Decontamination
Pad resumed in February 2011.
Annual inspections of the new decontamination pad are conducted during the second quarter of
each year. The documentation for the annual inspections was reported in the Second Quarter
DMT report submitted August 23, 2012. The 2013 annual inspection will be conducted during
the second quarter of 2013.
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR
THE QUARTER
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring RepOlt for the quarter, as required under Part I.F.3 of the GWDP.
9.1 LDS Monitoring
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 4A and Cell 4B, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment,
operated continuously during the quarter except as noted below.
Ce1l4A
During the quarter, there were no failures of any pumping or monitoring equipment which were
not repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.8(a)(l) for Ce1l4A.
Ce1l4B
During the quarter, there were no failures of any pumping or monitoring equipment which were
not repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E. 12(a)(l) for CeIl4B.
It is important to note that the Cell 4B LDs records negative fluid levels. The negative values are
due to the LDS having no fluid which the transducer "reads" as a negative value because of
barometric pressure differences.
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML
The readings pertaining to the fluid head above the lowest point in the secondary FML for Cells
4A and 4B are provided in Attachment F.
9
As can be seen from a review of Attachment F, at no point in the quarter did the fluid head in the
Cell 4A LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring this 1-foot distance equates to 2.28 feet
[27.36 inches] above the LDS system transducer), as stipulated by Part I.E.8(a)(2) of the GWDP.
During the quarter, the fluid head in the Ce1l4A LDS sump did not exceed 13.0 inches above the
LDS transducer.
As can be seen from a review of Attachment F, at no point in the quarter did the fluid head in the
Cell 4B LDS sump exceed a 1-foot level above the lowest point in the lower FML on the Cell
floor, as stipulated by Part I.E.12(a)(2) of the GWDP. For the purposes of compliance
monitoring this 1-foot distance equates to 2.25 feet (27 inches) above the LDS system. During
the quarter the fluid head in the Ce1l4B sump did not record a positive value which equates to no
fluid in the LDS.
9.1.3 Measurement of the Volume of Fluids Pumpedfrom the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment F.
Cell.4A
As can be seen from a review of Attachment F, 9,487 gallons of fluid were pumped from the Cell
4A LDS for the first quarter of 2013. Based on this, the average daily LDS flow volume in Cell
4A did not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the GWDP.
Daily allowable volume of fluids pumped from the Cell 4A LDS have also been calculated based
on weekly tailings cell fluid measurements using the calculations provided in the Cell 4A BAT
Operations and Maintenance Plan. 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 Cell 4A Operations and Maintenance ("O&M") Plans and effectively eliminated the
former freeboard elevation requirements for tailings Cell 4A. Pursuant to the receipt of the
March 15, 2011 letter, freeboard limits in Cell 4A were no longer required. However, the
weekly wastewater elevations were completed in order to calculate the maximum daily allowable
flow volume, based on in the Cell 4A BAT Operations and Maintenance Plan. Based on the
wastewater pool elevation surveys conducted during the quarter, and the maximum head
recorded on the FML during the quarter of approximately 39 feet, the allowable flow rate would
be approximately 604.0 gallons/acre/day (24,160 gallons/day for the cell), as determined under
the Mill's Cell 4A and 4B BAT Operations and Maintenance Plan, Table 1A (also included in
Attachment F of this report), and assuming a liner elevation of 5555.55 feet and approximately
40 acres of liquid area. The average daily flow volume in Cell 4A did not exceed the calculated
flow volume of 24,160 gallons/day. As mentioned above, during first quarter of 2013, a total of
9,487 gallons of fluid were pumped from the Ce1l4A LDS during the period and did not exceed
the calculated flow volume. The first quarter allowable flow rate calculation for Cell 4A is
included in Attachment F of this report.
10
Cell4B
As can be seen from a review of Attachment F, no fluids were pumped from the Ce1l4B LDS for
the first quarter of 2013 and the flowrate is therefore below the 26,145 gallons/day limit, as
stipulated by Part I.E. 12(a)(3) of the GWDP.
Based on the wastewater pool elevation surveys conducted during the quarter, the maximum
head recorded on the FML during the quarter was approximately 26 feet. The allowable flow
rate would therefore be approximately 475.6 gallons/acre/day (17,202 gallons/day for the cell),
as determined under the Mill's Cell4A and 4B BAT Operations and Maintenance Plan, Table IB
(also included in Attachment F of this report), and assuming a liner elevation of 5557.5 feet and
approximately 36.17 acres of liquid area. The average daily flow volume in Cell 4B did not
exceed the calculated flow volume of 17,202 gallons/day. During first quarter 2013, no fluids
were pumped from Cell 4B LDS and therefore did not exceed the calculated flow volume. The
first quarter allowable flow rate calculation for Cell 4B is included in Attachment F of this
report.
9.2 Measurement of Weekly Wastewater Fluids in Cells 4A and 4B
Weekly fluid elevations for Cells 4A and 4B for the quarter are provided in Attachment A along
with elevations for Cell 1 and Roberts Pond.
9.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping of the Cell 4A or Cell 4B slimes drain systems at this time,
monthly recovery head tests and fluid level measurements are not required to be made at this
time pursuant to Part I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING FOR THE QUARTER
The requirement in Section 3.1(a) of the DMT Plan to monitor the LDS for Cells 1,2, and 3 is a
requirement of the License, is not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP, and hence is not required to be included in the routine DMT
Performance Standards Monitoring Report under Part I.F.2 of the GWDP. DRC has requested
that the LDS monitoring for Cells 1, 2, and 3 be included on the DMT inspection forms and that
the results of the monitoring be reported in the quarterly DMT reports. EFRI agreed to include
the Cells 1, 2, and 3 LDS monitoring in the quarterly DMT reports. The Cells 1, 2, and 3 LDS
monitoring data are included in Attachment F.
10.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 1, Cell 2, and Cell 3, including,
but not limited to, the submersible pump, pump controller, head monitoring, and flow meter
equipment, operated continuously during the quarter except as noted below.
11
For Cell 1, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 2, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 3, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
10.2 Measurement of the Volume of Fluids Pumped from the LDS
No fluids were pumped from the Cells 1, 2 or 3 LDSs during the quarter because no fluids were
detected in the Cells 1, 2 or Cell 3 LDSs.
10.3 Measurement of Weekly Wastewater Fluids in Cells 1,2, and 3
A summary of the fluid elevations for the Cells 1, 2 and 3 LDSs for the quarter are provided in
Attachment F. The LDS for Cells 1, 2, and 3 were dry during the quarter.
10.4 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Cells 1 or Cell 3 slimes drain system at
this time, monthly recovery head tests and fluid level measurements are not required at this time.
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2012
The annual slimes drain recovery head report for Cell 2 for calendar year 2013 (the "Period"), as
required under Parts ID.3 (b) and I.F.11 of the GWDP and Section 8.2 of the DMT Plan will be
included with the 4th quarter DMT report which will be submitted on or before March 1,2014.
12
12.0 SIGNATURE AND CERTIFICATION
This documenl was prepared by Energy Fuels Resources (USA) Inc. on May 29. 20 \3.
es rces (US A) Inc.
By:
Dav id . ryd nlund
Senior Vice PrcsidcnL, General Counsel and Corporale Secretary
13
CERTIFICATION:
1 cerlify, lri1der penalty of law., ilia ilii, do Urilent and aU attachments were prepared under my
dire-etion 0r supervisi.on ill accordance with a y tern dc, igned to a 'Ufe that qualified pe · 'onnei
properly gather and evaluate the information , ubmitted. Sa 'ed on my iuguiry of the per on or
pex on' who manage the sy tern, or 'rho e per. ons directly re pon ible for gathering the
information the information ubmitted i ,to the be. t of my knowledge and belief lrue, accurate
and com ete. am aware thal lhere are ignificant penalties for 'ubmitting fa! e iIi formation ,
incladh the s ibiJity of fine and imprisonment for knowing violations.
Da .' Fry enLund.
enjor Vice Pre ident, GeQeral Coun eJ and Ol-porate Secretary
Energy Fuels Re Olll.'Ces (USA) Inc,
14
Attachment A
Date CellI Cell 3 1 Cell 4A 2 Cell 4B 3 Roberts Pond
Freeboard 5615.40 -RML 5594.6 -
Limit 5615.50 -GWDP GWDP 5624.00 -GWDP
1/4/2013 5614.00 No Longer Required 5593.37 5578.11 5618.87
1/14/2013 5614.50 No Longer Required 5593.75 5578.17 5620.49
1/18/2013 5614.63 No Longer Required 5593.79 5578.18 5621.73
1/25/2013 5614.97 No Longer Required 5594.06 5578.24 5620.80
2/1/2013 5615.44 No Longer Required 5594.45 5578.38 5621.06
2/8/2013 5615.81 No Longer Required 5594.42 5578.29 5619.91
2/15/2013 5616.04 No Longer Required 5594.37 5578.79 5618.95
2/22/2013 5616.26 No Longer Required 5594.14 5579.11 5617.44
3/1/2013 5616.22 No Longer Required 5594.03 5580.08 5617.36
3/8/2013 5615.84 No Longer Required 5593.93 5580.92 5617.48
3/15/2013 5615.47 No Longer Required 5593.79 5582.39 5616.98
3/22/2013 5615.21 No Longer Required 5593.63 5582.91 DRY
3/29/2013 5614.72 No Longer Required 5593.41 5583.94 5617.10
lCell 3 is nearly full of solids, and is undergoing pre-closure steps. The freeboard limit is no longer required and the
weekly measurements are no longer required per the January 27 and March 14, 2011 letters from DRC.
2 The previous freeboard limit of 5,593.74 for Ce1l4A is set out in a letter from the Director dated November 20,2008.
EFRl proposed in the DMT Plan revision dated November 12,2010 the removal of the freeboard limit for Ce1l4A to be
replaced by a freeboard limit for new Cell4B that will accommodate the freeboard requirements of Cells 2,3, 4A, and 4B.
The Director granted a variance from the Ce1l4A freeboard limit on January 13,2011 and approved the removal of the
Ce114A limit and the use of Cell 4B on January 27, 2011. The weekly measurements are no longer required for
compliance with freeboard limts, but are required for the calculation of the daily allowable volume of fluids pumped from
the Cell 4A LDS.
3 The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A pool surface
area of 40 acres is used because there are no beaches present in Cell 4B at this time.
Attachment B
January 8, 2013
Sent VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
Re: Status Update and Follow-up to Notification Regarding Cell 2 Slimes Drain Freeze
Dear Mr. Lundberg:
This letter is a follow-up to Energy Fuels Resources (USA) Inc. 's ("EFRI's") telephone calls to the
Utah Division of Radiation Control ("DRC") on January 3, 2013 regarding the effects of freezing
weather conditions on the Cell 2 slimes drain transfer pipeline at theWhite Mesa Mill (the "Mill").
The Mill's Tailings Management System program commits that EFRI will repair the slimes drain
pumping system within 15 days, if it is observed not to be working properly.
As discussed below, the Mill experienced an abnormally extended period of cold conditions during the
last two weeks of December and first week of January, which resulted in freeze damage to a number
of areas at the Mill, including power transformers supplying Cell 2. During the period of ongoing low
temperature, the slimes drain pump and monitoring equipment remained intact, and power was
available to the area via a portable generator. However, the transfer line to Cell 4A became frozen on
December 19, 2012, and due to the extended period of freezing weather, could not be thawed and
returned to operation until January 7,2013.
Although not required by the Tailings Management System program applicable to Cell 2, EFRI has
chosen to make the telephone notifications and this follow-up letter for information purposes, to keep
DRC apprised of the Mill's efforts to restore the transfer line to operation, and to inform DRC that the
line has been thawed and the system has been returned to service.
Letter to R. Lundberg
January 8,2013
Page 2
1. Facts and Background
a) The Mill's Tailings Management System Plan revision 2.1 states that:
"Cell 2 slimes drain pump is checked weekJy to observe that it is operating and that
the water level probe and 110at mechanism are working properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed to be not
working properly, it will be fixed or replaced within 15 days."
b) The Cell 2 slimes drain solutions are transferred through a 3-inch pipeline to Cell 4A. Prior
to December 19, 2012, the pipeline was above ground atop the dikes and/or sands of Cell 2
and Cell 3, discharging into Cell 4A near the dike of Ce1l4A.
c) Mill personnel conducted the Cell 2 slimes drain quarterly pump test, required by Pmi l.D.3
of the GWDP, from December L I to December 17, 2012. The pump and transfer line
operated properly until after the test was concluded. Following shutdown of the pump test,
the line froze during the evening of December 17, 2012.
d) Mill personnel thawed the line with heating torches and returned it to service during
December 18 and 19, 2012. On December 19, 2012, Mill personnel buried the horizontal
sections of pipe in 12 inches of borrow soil atop Cell 3 for insulation against potential future
freezing weather.
e) The Mill experienced an extended period of abnormally cold weather beginning on
December 19, 2012. During the evening of December 19, 2012, the Cell 2 slimes drain
transfer pipeline froze, even though it had been buried in 12 inches of soil. It remained frozen
through January 3, 2013 despite additional efforts to thaw the line with heating torches
during that period.
2. Action Taken
a) EFRI contacted Mr. Phil Goble of DRC on January 3, 2013 to advise DRC that due to the
persistence of the abnormally cold weather and the Mill's inability to thaw the Cell 2 slimes
drain pipe, EFRI was unable to perform the Cell 2 slimes drain pump check tests, required by
the Tailings Management System program applicable to Cell 2, during the weeks of
December 21 and 28,2012 and January 4,2013.
b) EFRI committed to advise DRC as soon as weather conditions supported thawing of the
discharge pipeline.
c) EFRI committed to resume the weekly testing as soon as the pipeline was thawed.
Letter to R. Lundberg
January 8,2013
Page 3
d) Mr. Goble instructed EFRI to document the efforts to date, and to advise DRC when a more
definitive date for returning the system to service was known.
e) EFRI successfully thawed the discharge pipeline and returned the slimes drain pumping
system to service on January 7, 2013.
f) EFRI has determined that for future potential freeze situations, a backup transfer procedure
involving pumping the Cell 2 sJimes drain fluids a shorter distance to exposed tailings sands
areas in Cell 3, could be used if weather conditions may prevent performance of the weekly
slimes drain pump check. The shorter length of transfer line may permit easier thawing and
maintenance of slimes drain f1uid flow.
3. Root Cause
The slimes drain transfer pump operates on a float system which turns the transfer pump on when
sufficient fluid has accumulated in the slimes drain system. As a result, the pump, and transfer line,
experience intermittent, not constant, flow. During most of the year, and during typical winters, the
intermittent f10w is sufficient to prevent freezing of the 3-inch transfer line. During the prolonged
cold period in which the ambient temperature remained below frcezing during the day and as low as
single digits during some nights, the intermittent flow was not sufficient to keep the line from
freezing, even below the 12 inches of insulating soil.
4. Actions Taken to Maintain Compliance
EFRI has taken the following steps to return the Cell 2 slimes drain transfer system to compliance in
as short a time as possible.
a) Notification
By virtue of the initial oral notification given to DRC at on Thursday, January 3, 2013, and this
written status letter, EFRI has made good faith efforts to keep DRC apprised of the situation
resulting in loss of three rounds of pump checks, as well as effmis to restore the system to operation.
b) Failure was not ll1tentional or Caused by EFRI's Negligence
The failure to conduct the three missed weekly slimes drain pump checks was not due to EFRI's
negligence, either in action or in failure to act. The prolonged cold did not afford any opportunity to
get the slimes drain dischmge line thawed and keep it thawed long enough to put the pump system
back in service.
c) EFRI Has Taken Adequate Measures to Meet Requirements of the Tailings Management
System Program
Letter to R. Lundberg
January8,20 13
Page 4
EFRJ immediale'ly lhawed and returned the slimes drain transFer line t() service when it first .froze
During December 18, and 19,2012. When it became evident that it would not be possible to
maintain the system in a thawed and operati ve condition, EFRI advised ORC and sought DRC's
input on what DRC wou ld req uire. EPRt complied with ORe's requirements as enumerated in
Section 2, above.
If you :;hould have any questions Tcgarding this status report plca<;e contact me.
Yoms very tru ly.
ENEKGY 'tm . RESOtlRCES (USA) INC.
Dc' . -ryden lund
Senior Vice Pres iden t, General Counsel and Corporate Secretary
cc: Scot Christianson
Jo Ann Tischler
Dan Hill sten
N. Tanner Holliday
Garfin Palmer
Harold R. Roberts
David E. Turk
Kathy Weinel
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Jo Ann Tischler [[e-mail]]
Saturday, January 12, 2013 4:41 PM
[e-mail]
[e-mail]; Harold Roberts; David Turk; David Frydenlund; Dan Hillsten; Kathy
Weinel; [e-mail]
Notification regarding Cell 2 liner
Energy Fuels Resources (USA) Inc, ("EFRI") is providing this email to the Utah Division of Radiation Control
("DRC") to notify DRC that in the late afternoon on Friday, January 11,2013, maintenance personnel at the
White Mesa Mill (the "Mill") identified a tear in the liner of tailings Cell 2. Mr. Ryan Johnson of advised EFRI
that these type of notification could be made by email if the notice needed to be submitted during non-business
hours.
Mill Environmental Management became aware of the damage to the liner after 5"00 PM on Friday, January 11,
2013. This notification is being submitted within 24 hours of Corporate Environmental Management being
made aware of the incident, as required by the Mill Groundwater Discharge Permit.
During the late afternoon if January 11,2012, Mill maintenance personnel were using a backhoe to dig a trench
along the edge of Cell 2 to place a new power cable. Cell 2 is a closed tailings cell with an interim cover.
EFRI has provided previous notifications to DRC on December 19, and 21, 2012 regarding the loss of power to
multiple areas of the tailings system due to failure of an aging transformer during the prolonged December 2012
freeze. As part of the repairs and corrective actions, the Mill was preparing a trench to be used in replacing a
power line associated with the failed transformer. The backhoe snagged a portion of the Cell 2 liner above the
level of of the tailings and cover material. Construction of the trench was halted until the liner can be repaired.
Liner repairs cannot be performed during the current extremely low temperatures, due to a combination of
factors including the inability to successfully seal the liner and test the repairs in freezing conditions. EFRI
anticipates completing the liner repairs during the week of January 14,2013.
A liner repair report will be included in the DMT report for the first quarter of 2013.
Please contact me if you have any questions on this notification.
JoAnn Tischler
Manager, Compliance and Licensing
Energy Fuels Resources (USA) Inc.
1
VIA EMAIL AND OVERNIGHT DELIVERY
Janaury 17, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranitun Mill
Utah Ground Water Discharge Permit No. UGW3700004
Energv FUels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
White Mesa Uranium Mill-Notice Pursuant to Parts LE.7.f) and I.GJ of the Permit
Dear Mr. Lundberg:
Please take notice pursuant to Parts I.E.7.f) and I.G.3 of the White Mesa MilPs (the "Mill's") State of
Utah Groundwater Discharge Permit No. UGW370004 (the "Permit"), that Energy Fuels Resources
(USA) Inc. ("EFRI"), as operator of the Mill and holder of the Permit, identified, and initiated repairs to,
damage to the Cell 2 Liner System as described in more detail below.
Repairs to the liner were completed on January 17, 2013, in accordance with' the Mill's Liner
Maintenance Provisions. Cell 2 is in interim closure status and is not in service.
1. Facts and Background Information
a) Part I.E.7.f) of the Permit requires that the licensee conduct daily inspections for each of the
tailings cells and weekly inspections of Roberts Pond. According to Part I.E.7.f):
"In the event any liner defect or damage is identified during a liner system inspection,
the Permittee shall: 1) report and repair said defect Or damage pursuant to Part I.G.3
by implementation of the currently approved Liner Maintenance Provisions, and 2)
report all repairs made pursuant to Part I.F.2."
b) Although Part 1.G.3 of the Permit is stated to apply to circumstances where the Permittee
fails to maintain Discharge Minimization Technology ("DMT") or Best Available
Technology ("BAT") standards, Part I.E.7.f) requires that the notification provisions of
Part I.G.3 also apply to liner defects or damage, regardless of whether or not the liner
defect or damage constitutes a failure ofDMT or BAT. Under Part I.G.3, the Permittee is
required to submit to the Director a notification and description of the defect or damage
Letter to Rusty Lundberg
January 17,2013
Page 2 of 4
orally within 24-hours of the Permittee's discovery, followed by written notification within
five calendar days."
c) The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached single digits on December 19,2012. EFRI has provided notifications to
DRC on December 19, and 21, 2012 regarding the loss of power to multiple ar~as of the
tailings system due to failure of an aging transfonner during the prolonged December 2012
freeze.
d) In the afternoon of January 11, 2013 as part of the repairs and corrective actions resulting from
the power loss, Mill maintenance personnel were using a backhoe to prepare a trench for
replacing a failed power line. The maintenance plan was for the trench to be excavated with
one section in a north-south direction in the area east of Cell 2, and a second section in an east-
west direction along the dike between Cell 2 and Cell 3. The east-west portion was to begin at
the southeast comer of Cell 2 and the northeast comer of Cell 3 and be cut straight along the
dike between the cells.
e) The backhoe operator was instructed that the excavation was not to divert from Jhe assigned
path, and that if any obstructions prevented the excavation from following the designated path,
the backhoe operator was to contact Mill management to have the obstructions removed.
f) The backhoe operator followed the designated path until reaching an area near temporarily
stored drums in the north portion of Cell 3. The operator did not contact Mill management to
have the obstruction removed, and chose to divert from the excavation plan by curving the
backhoe path northward away from the drums.
g) In trenching outside the planned area, the backhoe snagged and tore a portion of the Cell 2
liner where it rises over the dike and enters the anchor trench south of Cell 2. The tear was
above and outside the cell and outside the area containing any tailings material or cover
material.
2. Actions taken
The following actions were taken following identification of the liner tear.
a) ·Mill Maintenance informed Mill Management of the liner tear in the early evening of Friday
January 11, 2013. Mill environmental management notified EFRI Corporate Environmental
Management during the evening/night of January 11,2013.
b) EFRI notified the Utah Division of Radiation Control via an email dated January 12,2013.
c) In response to a request by the Director of DRC, EFRI provided photographs of the liner
damage to DRC on January 14,2013.
Letter to Rusty Lundberg
January 17,2013
Page 3 of4
d) Mill maintenance personnel initiated repairs to the liner during the week of January 14,2013.
Repairs and testing of the liner were completed on January 17,2013. Since:
(i) the cell was in interim closure and not in service, and
(ii) the liner damage was outside of the cell and its tailings and cover material (it was in the
anchor trench),
there was no effect on the cell's contents or cover.
3. Actions Taken to Prevent a Recurrence of This Incident
The following actions will be taken to prevent a reoccurrence of this incident:
a) As discussed above, the liner tear occurred during trenching and replacement of a power line
associated with response to freeze-related failures of older power equipment. The older power
transformers and buried power lines have been replaced with new, upgraded equipment.
Affected older power line installations have been upgraded by replacement with jacketed lines
and/or conduit for additional protection from traffic and weather. It is anticipated that these
upgrades and replacements will prevent further power supply failures in future cold weather,
and prevent the need for further repair-related trenching.
b) The obstructions were moved further south within the Cell 3 area to ensure the trench
excavation could be completed in the proper location, and liner repair activity could proceed
with ample working space.
c) The maintenance backhoe operator has been retrained and his instruction has emphasized that
the direction of excavation or intrusion work, especially in the tailings area, cannot be
arbitrarily changed without contacting Mill management prior to varying from the work plan.
4. Required Reporting
As required by Part I.F.2 of the permit, a liner repair report will be submitted to the Director with the
next quarterly DMT Report following completion of the repairs. Repairs were completed during the
first quarter of2013. The repair report will be submitted with the first quarter 2Q13 DMT Report on or
before June 1, 2013. The repair report will contain, in addition to a root cause analysis, the following
elements:
• Repair narrative describing the nature of the damage and the repair work completed to repair the
damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other)
• Daily reports during the repair work
• Repair test results
Letter to Rusty Lundberg
January 17,2013
Page 4 of4
• Quality Assurance/Quality Control Infonnation
5. Affrrmative Defense
EFR does not believe that identification of a defect or damage to the Cell 2 liner caused by maintenance
activities and repair of such defect or damage in accordance with the Mill's Liner Maintenance
Provisions constitutes a failure of BAT under the Permit. Further, the damage to the Cell 2 liner was
above the level and outside the perimeter of any tailings or cover material contained in the cell. As a
result, EFR is not making a claim for an affinnative defense under Part I.G.3 of the Pennit.
If you have any questions, please contact me at [phone].
Yours very truly,
~~
ENERGY FuELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phillip Goble, DRC
Russ Topham, DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Katherine A. Weinel
"'B~ ~' ,; r , (' .
v ~ "
I r V ENERG Y FUELS
VIA EMAIL AND OVERNIGHT DELIVERY
May 14, 2013
Mr. Rusty Lundberg, Director
Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill
Notice Pursuant to Part l.G.3 of the Permit and UAC R317-6-6.16 (C)
Dear Mr. Lundberg:
Please take notice pursuant to part l.G.3 of the White Mesa Mill's (the "Mill's") State of Utah
Groundwater Discharge Permit No. UGW370004 (the "GWDP") and Utah Administrative Code
("UAC") R313-6-6.16 (C) that Energy Fuels Resources (USA) Inc. ("EFRI") as operator of the Mill and
holder of the GWDP, failed to meet discharge minimization technology ("DMT') standards by allowing
the wastewater elevation in the Mill's tailings Cell 1 to exceed the freeboard limits set out in Part l.D.2
of the GWDP, as described in more detail below.
This exceedance was discovered by Mill personnel on February 1, 2013 and continued until
approximately March 22,2013. It was first brought to the attention ofEFRI's Corporate Environmental
Management at 4:00 pm on Wednesday, May 8, 2013. Initial notice of this freeboard exceedance was
given to Mr. Russ Topham of the Utah Department of Radiation Control ("DRC") at 1 :40 pm on
Thursday, May 9, 2013.
1. Facts and Background Information
1.1 Regulatory Background
Part l.D.2 of the Mill's GWDP requires that:
"Authorized operation and maximum disposal capacity in each of the existing tailings
cells shall not exceed the levels authorized by the License. Under no circumstances shall
the freeboard be less than three feet, as measured from the top of the FML."
Condition 10.3 ofthe Mill's Radioactive Materials License (the "License") states that:
N:\WMM\Notices\Cell 1 Freeboard Notice 05.14.13\Celll Freeboard Notice 5-14 13 revision 4.doc
Letter to Rusty Lundberg
May 14,2013
Page 2 of6
"The Freeboard limit for Cell 1 shall be set annually in accordance with the procedures
set out in Section 3.0 to Appendix E of the previously approved NRC license application,
including the January 10, 1990 Drainage Report."
As a result of the calculations set out in the above-described documents, the Mill's Tailings
Management Plan states that the resulting freeboard limit for Cell 1 under the License is 5,615.40
FMSL.
Part LD.2 of the GWDP also sets a freeboard limit of not less than three feet from the top of the flexible
membrane liner (FML). For Cell 1, this limit is 5,615.50 FMSL. Compliance with Part LD.2 of the
GWDP therefore requires satisfaction ofthe stricter of these two freeboard limits.
1.2 Sequence of Events
The sequence of events associated with the operation of Cell 1 before and since the freeboard
exceedance is as follows:
• During the period from June 2010 to June 4, 2012, the Mill performed repairs to the Cell 1
flexible membrane liner ("FML") based on commitments in letters dated August 30, 2010 and
September 30, 2010.
• During October 2012, the Mill commenced raising the level of solutions in Cell 1, to achieve the
elevation of 5613.1 FMSL to confirm the integrity of the repairs to the FML; that is, to monitor
whether any solutions appeared in the leak detection system.
• During the period preceding and during the solution level exceedance of the freeboard limits,
Cell 1 was receiving solutions from:
o Solvent extraction ("SX") raffinate discharge
o Alternate feed circuit solution discharge
o Groundwater from the chloroform and nitrate pumping wells
o Minor volumes from laboratory sinks and drains
o Minor and sporadic volumes from pumping of pooled rainwater
• During the process of repairing the FML, the Mill removed the raft (also referred to as the dock
or barge), which held the transfer pump used to transfer solutions from Cell 1 to other cells.
• Mill environmental personnel performed tailings inspection and solution level monitoring
consistently during the entire quarter, as indicated in the daily and weekly tailings inspection
reports which are retained at the Mill.
• Mill environmental personnel notified EFRI's Manager, Environmental, Health and Safety (the
"Environmental Manager") and the Mill Manager on February 1,2013 that the solution elevation
level of 5615.44 FMSL exceeded the freeboard limit set out in the License and referenced in Part
LD.2 of the GWDP.
Letter to Rusty Lundberg
May 14,2013
Page 3 of6
• Mill environmental personnel apprised the Environmental Manager and the Mill Manager each
week that the Cell 1 solution elevation exceeded the freeboard limits set out in the License and as
referenced in Part I.D.2 of the GWDP (February 8, February 15, February 22, March 3, March 8,
and March 15,2013), until the week in which the weekly solution level measurement was again
within the freeboard limits (March 22, 2013). The attached Table 1 provides the solution
elevation data relative to applicable freeboard limits for each week during the first quarter of
2013.
• Mill Maintenance personnel constructed repairs/replacement of the raftlbarge during the period
from January 30 to February 3, 2013. The raft was in place prior to the daily tailings inspection
on February 6, 2013.
• Mill Maintenance personnel constructed repairs/replacement of the Drisco transfer line during
the period from February 4 to February 8,2013, to allow transfer of solutions from CellI to Cell
4B.
• Mill Maintenance personnel installed a transfer pump on the pump barge and initiated transfer of
solutions from Cell I to Cell 4B on February 8, 2013.
• On February 21, 2013, SX raffinate solution discharge into Cell 1 ceased and the raffinate
solution was transferred to discharge into Ce114B.
• The transfer pump on the Cell 1 pump barge (transferring solutions to Cell 4B) was replaced
with a larger transfer pump (125 hp1700 gpm) on February 21, 2013, and the larger pump was
immediately put into service.
• The coupler on the Cell 1 transfer pump failed during the night of February 15 to 16,2013. The
coupler was replaced and the pump returned to service on February 16, 2013. The temporary
interruption of transfer flow was minimal.
• Cell 1 returned to compliance between the weekly solution elevation measurements on March
15, 2013 (of 5615.47 FMSL) and March 22, 2013 (of 5615.21 FMSL). The solution elevation
measurements on Cell 1 elevation have remained in compliance continually since the March 22,
2013 measurement.
• Corporate, Environmental Management was not notified of the exceedance at any time during the
period when the solution elevations were in excess of the freeboard limits.
It should be noted that the provisions of UCA 19-5-107 have not been violated. There has been no
discharge of a pollutant into waters of the state. EFRI has not caused pollution which constitutes a
menace to public health and welfare, or is harmful to wildlife, fish, or aquatic life, or impairs domestic,
agricultural, industrial, recreational, or other beneficial uses of water, nor has EFRI placed or caused to
be placed any waste in a location where there is probable cause to believe it will cause pollution.
Letter to Rusty Lundberg
May 14,2013
Page 4 of6
There was no discharge of solutions from the Mill's tailings impoundments at any time during the period
when the solution elevation exceeded the freeboard.
2. Action Taken
As discussed above, the Mill took the following action to return the Cell 1 solution levels to
compliance with Part I.D.2 of the GWDP:
• Pumping of solution from Cell 1 to Cell4B began on February 8,2013.
• Pumping of solution from Cell 1 to Cell 4B was increased to 700 gpm on February 21, 2013.
• Pumping of SX raffmate solution to CellI ceased on February 21,2013.
• CellI solution elevation returned to compliance with the Part I.D.2limits between March 15
and March 22, 2013.
• EFRI Corporate Environmental Management identified that Cell I solution elevation had
exceeded the Part I.D.2 limits during the quarter while reviewing solution elevation data for
preparation of the quarterly DMT report for the first quarter of2013, on May 8, 2013.
• EFRI Corporate Environmental Management notified DRC on May 9, 2013.
3. Root Cause
Three root causes resulted in the non-compliance condition described above.
First, the Mill Manager was not sufficiently familiar with the applicable requirements in the GWDP,
License and Contingency Plan that restrict solutions level in the tailing cells, andlor require notifications
and actions when the solution elevation standard is exceeded. As a result, the Mill Manager did not
respond to the initial notification from tailings inspection personnel that solution elevation in Cell 1 was
approaching, and later exceeded, the freeboard limits set out in Part I.D.2 of the GWDP, which includes
the limits in Condition 10.3 ofthe License.
Second, the Mill plans and procedures governing response, actions and notifications for exceedances of
limits and failures of compliance did not adequately address internal and external (to DRC) notifications
or provide cross references to plans, procedures and permits that do clearly require notifications. During
the period of freeboard exceedance, Mill personnel referred to the Freeboard Sections and Tailings
Emergencies sections of the Tailings Management System document applicable to Cell 1. The Tailings
Management System document did not provide a requirement to make internal notifications to
Corporate Environmental Management or external notifications to DRC for exceedances of freeboard
limits. Further, that document did not refer to the requirements of the Contingency Plan or Part I.G.3 of
the GWDP, which were overlooked by Mill management.
Third, there was a breakdown in communications between the Environmental Manager and the Mill
Manager. The Mill has undergone a recent reorganization in which the former RSO has assumed
responsibilities as the Environmental Manager, which include responsibilities at EFRI's mines as well as
at the Mill. At the same time a new RSO was appointed at the Mill. The Environmental Manager
appeared to have misunderstood the level of his responsibilities in reporting information to, and advising
Letter to Rusty Lundberg
May 14,2013
Page 5 of6
what actions are required by, the Mill Manager under abnormal circumstances and non-compliant
situations, in light of these organizational changes.
As a result of these root causes,
• The Mill Manager did not understand that the freeboard exceedance situation required certain
immediate actions to bring the cell solution level into compliance as quickly as possible,
• The Mill manager did not understand the requirement to ensure that a timely notification be
provided to DRC either by contacting DRC directly or by ensuring that Corporate Environmental
Management had the information to make the notification, and
• The Environmental Manager did not advise the Mill Manager to perform the required
management and notification steps.
4. Actions That Will be Taken to Prevent a Recurrence of This Incident
The following corrective actions have been initiated.
1. As discussed under Root Cause, above, the Mill Manager was not sufficiently familiar with the
applicable requirements in the plans and procedures that govern control of tailings solution levels
and require internal and external (to DRC) notifications when certain conditions are not met.
The Mill Manager is undergoing re-training in the requirements of the License, the GWDP, the
Contingency Plan and the other plans derived from the requirements of these documents.
2. The Environmental Manager will be retrained in his responsibilities to:
• advise the Mill Manager in all environmental, safety and radiation protection compliance
issues andlor emergencies, and
• provide dual coverage and responsibility for environmental compliance, emergency response,
and notification to Corporate Management and appropriate regulatory authorities.
3. EFRl is e-evaluating its corporate and Mill environmental management functions and
organizational structures to identify any further changes that will minimize the chance of re-
occurrence of such misunderstandings of responsibilities and resulting miscommunications.
4. EFRl is re-evaluating the primary documents which require internal or external notification
under specific conditions or situations. Specifically, EFRl will incorporate cross references to
the Contingency Plan and the notification requirements of Part I.G.3 of the GWDP into the
sections of the Tailings Management System document applicable to Cell 1 that deal with
freeboard exceedances. This should minimize the chance of the required actions being
overlooked in the future. It should be noted that references to the notification requirements of
Part I.G.3 of the GWDP had previously been added to the sections of the DMT Monitoring Plan
that deal with freeboard exceedances for Cells 4A and 4B. However, those references were not
Letter to Rusty Lundberg
May 14, 2013
Page 6 of6
carried into the Tailings Management System document applicable to Cells 1 and 3 when it was
drafted.
EFRI plans to modify these and/Qr the procedures and plans derived from these documents to ensure that
the requirements for notification are spelled out clearly. As appropriate, EFRI will provide draft
revisions of these documents to DRC for review and approval.
If you have any questions, please contact me at [phone].
Yours very truly,
.~ J . /J if
\
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
GC David C. Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
N. Tanner Holliday
Garrin Palmer
Harold R. Roberts
Russ Topham, Utah DRC
David E. Turk
Kathy Weinel
Table 1
Cell 1 Solution Level Data for Q1 2013
Remaining
Remaining Remaining GWDP Remaining freeboard
Solution License freeboard Freeboard freeboard freeboard Capacity per
Elevation freeboard Capacity per Capacity per Limit Capacity per GWDP
Date level (FMSl) Limit (FMSl) RMl(feet) RMl (inches) (FMSl) GWDP (feet) (inches)
1/4/2013 5614.00 5615.40 1.40 16.80 5615.50 1.50 18.00
1/14/2013 5614.50 5615.40 0.90 10.80 5615.50 1.00 12.00
1/18/2013 5614.63 5615.40 0.77 9.24 5615.50 0.87 10.44
1/25/2013 5614.97 5615.40 0.43 5.16 5615.50 0.53 6.36
2/1/2013 5615.44 5615.40 -0.04 -0.48 5615.50 0.06 0.72
2/8/2013 5615.81 5615.40 -0.41 -4.92 5615.50 -0.31 -3.72
2/15/2013 5616.04 5615.40 -0.64 -7.68 5615.50 -0.54 -6.48
2/22/2013 5616.26 5615.40 -0.86 -10.32 5615.50 -0.76 -9.12
3/1/2013 5616.22 5615.40 -0.82 -9.84 5615.50 -0.72 -8.64
3/8/2013 5615.84 5615.40 -0.44 -5.28 5615.50 -0.34 -4.08
3/15/2013 5615.47 5615.40 -0.07 -0.84 5615.50 0.03 0.36
3/22/2013 5615.21 5615.40 0.19 2.28 5615.50 0.29 3.48
3/29/2013 5614.72 5615.40 0.68 8.16 5615.50 0.78 9.36
Cell 1 Solution Elevation has remained below the License-based (strictier) freeboard limit of 5615.4 FMSL
through the date of this Notice.
Attachment C
QUARTERLY HEAD M EASU REM ENT TEST
Location: Date: 3/25/2013
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
3/18/13 3/19/13 3/20/13 3/21/13 3/22/13 3/23/13 3/24/13 3/25/13
700 27.45 25.3 23.87 22.96 21.86
800 34.97 27.39 25.22 23.84 22.93 21.85
900 34.08 27.34 25.14 23.79 22.89 21.85
1000 33.27 27.19 25.06 23.75 22.87
1100 32.52 27.05 25.01 23.71 22.84
1200 32.10 26.94 24.97 23.68 22.82 22.54 21.98
1300 31.71 26.85 24.89 23.63 22.80
1400 31.33 26.74 24.79 23.59 22.78
1500 30.95 26.68' 24.70 23.55 22.77
Comments:
Final reading for 1st quarter 2013 is 21.85.
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Attachment E
WHITE MESA MILL
REPAIR REPORT
TAILINGS CELL 2
May 2013
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill-Repair Report, Tailings Cell 2
WHITE MESA MILL
REPAIR REPORT
TAILINGS CELL 2
TABLE OF CONTENTS
Page 2 of 10
1. INTRODUCTION .................................................................................................................. 3
2. INCIDENT HISTORY AND CHRONOLOGY .................................................................... 4
3. REPAIR NARRATIVE ......................................................................................................... 4
4. REPAIR MATERIAL TYPE AND DESCRIPTION ............................................................ 5
5. POST-REPAIR TEST SPECIFICATIONS AND TEST METHODS ................................... 5
6. DAILY REPORTS DURING THE REP AIR WORK ........................................................... 6
7 . REPAIR TEST RESULTS/ QUALITY ASSURANCE/QUALITY CONTROL. ................. 6
8. CONCLUSIONS .................................................................................................................... 6
9. CERTIFICATION .................................................................................................................. 7
Appendix 1
Appendix 2
Appendix 3
APPENDICES
DRC and Denison Letters and Correspondence
Liner Repair Daily Reports
Liner Maintenance Provisions
White Mesa Mill -Repair Report, Tailings Cell 2 Page 3 of 10
1. INTRODUCTION
Energy Fuels Resources (USA) Inc. ("EFRI"), , operates White Mesa Uranium Mill (the "Mill").
Tailings Cell 2 is the first cell constructed for the disposal of solid tailings from the Mill processes.
Cell 2 is in interim closure status and is not in service. Performance standards, monitoring and
maintenance requirements for Tailings Cell 2 are specified in the Discharge Minimization
Technology requirements in the Mill's Groundwater Discharge Permit (the "Permit").
Per Part I.F.2 of the Mill's Permit, if EFRI identifies any damage to the liners of any tailings cell or
Roberts Pond, EFRI is required to repair the damage in accordance with the Mill's Liner
Maintenance Provisions, and provide a liner Repair Report to the Director of the Division of
Radiation Control. This Repair Report shall be included with the next quarterly DMT.
EFR performed repairs to the Cell 2 Flexible Membrane Liner ("FML") on January 15th and 16th,
2013, as discussed below. As a result ofthose repairs, this Tailings Cell 2 Liner Repair Report (the
"Report") is being submitted to comply with the Mill's Liner Maintenance Provisions, Revision 1,
dated October 18,2009 and with Part 1.F.2 of the Mill's Permit. The Liner Maintenance Provisions
require that the Repair Report be signed by a Utah licensed professional engineer and contain the
following information:
• Repair narrative describing the nature of the damage and the repair work completed to repair
the damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM D5641)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
Accordingly, the sections of this Repair Report, below, are organized consistent with the items
above.
Part 1.F.2 of the RML requires that following the repairs, the
"Repair Report shall be included with the next quarterly DMT Report".
Repairs resulting from the event above were completed during the first quarter of 20 13. This Repair
Report has been included with the first quarter 2013 DMT Report, being submitted on June 1,2013.
Due to Senate Bill 21 of the 2012 Utah Legislative Session, references to the Executive Secretary of
White Mesa Mill -Repair Report, Tailings Cell 2 Page 4 of 10
the Utah Radiation Control Board in the Utah Radiation Control Act have been modified to refer to
the Director of Radiation Control. This Report and the correspondence in its appendices utilize both
titles interchangeably.
2. INCIDENT HISTORY AND CHRONOLOGY
The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached single digits on December 19, 2012. EFRI has provided notifications to DRC
on December 19, and 21, 2012 regarding the loss of power to multiple areas of the tailings system
due to failure of an aging transformer during the prolonged December 2012 freeze.
In the afternoon of January 11, 2013 as part of the repairs and corrective actions resulting from the
power loss, Mill maintenance personnel were using a backhoe to prepare a trench for replacing a
failed power line. The maintenance plan was for the trench to be excavated with one section in a
north-south direction in the area east of Cell 2, and a second section in an east-west direction along
the dike between Cell 2 and Cell 3. The east-west portion was to begin at the southeast corner of
Cell 2 and the northeast corner of Cell 3 and be cut straight along the dike between the cells.
The backhoe operator followed the designated path until reaching an area near temporarily stored
drums in the north portion of Cell 3, at which point the trench was diverted from the excavation plan
by curving the backhoe path northward away from the drums.
In trenching outside the planned area, the backhoe snagged and tore a portion of the Cell 2
liner where it rises over the dike and enters the anchor trench south of Cell 2. The tear was above
and outside the cell and outside the area containing any tailings material.
EFRI provided notice of the torn liner via email to the Director on January 12t\ 2013 and written
notice on January 17th, 2013 (provided in Appendix 1). Repair of the torn liner occurred on January
15th and 16th, with testing occurring on January 16th.
3. REPAIR NARRATIVE
Cell 2 contains a single 30 mil PVC FML constructed of solvent welded seams, overlain by a
protective soil cover layer of 12-inches on the cell floor and 18-inches on the interior side slope.
Repairs to the Cell 2 FML occurred on January 15th and 16th indicated on the liner repair report in
Appendix 2. The liner repair was performed in the following steps:
• Removal of the soil around the discovered damage,
• Visual inspection of the FML,
• Cleaning and preparing the liner for patch adhesion,
• Installation of repair patches over the damaged location,
White Mesa Mill -Repair Report, Tailings Cell 2 Page 5 of 10
• Vacuum testing of each installed repair patch, and
• Replacement and/or regluing and retesting of repaired areas if necessary.
The liner was patched with sections cut from 30 mil PVC roll stock supplied by Colorado Lining,
Inc. Prior to placement of the new lining material repair patch, the soil surface was swept clean of
any protruding rocks that might damage the lining material. Prior to seaming, the lining material was
cleaned with methyl ethyl ketone (MEK). The liner was then seamed using an adhesive supplied by
Colorado Lining, Inc. The repaired seams were then 100% vacuum box tested according to the
procedures in the attached report. Testing results are included in the attached liner repair report. The
final repair activities involved the replacement of the soil cover in order to protect the lining material
from exposure to UV degradation.
4. REPAIR MATERIAL TYPE AND DESCRIPTION
Vacuum testing used the following equipment:
• soapy water solution
• vacuum check sheets
• vacuum testing equipment (vacuum box) consistent with ASTM Standard D5461.
Liner repairs used the following equipment:
• Personnel protective equipment appropriate for protection from cell solutions and safety
along banked sidewalls of the cell
• Various sized sections of 30 mil black PVC liner material
• PVC to PVC adhesive glue
• methyl ethyl ketone (,2-butanone" or "MEK") as a surface and glue cleaner
• sandbags
• wire brushes
• paint brushes and paint rollers to apply PVC glue
• TSP/Manu-Tech Service Projects vacuum testing device (referred to as the "vacuum box")
• Liner Daily Repair Forms
5. POST-REPAIR TEST SPECIFICATIONS AND TEST METHODS
As mentioned above, each repaired location was tested using a "vacuum box" and soapy water to
identify any remaining leaks by observation of air bubbles through the repair seam.
Tests were conducted in accordance with ASTM Standard D5461 utilizing the Manu-tech Service
Projects vacuum box referred to above. Per this standard, tests were conducted such that test areas
overlapped by at least 10% of the minimum vacuum chamber length or at least 2 inches, whichever
is greater, until the entire seam was tested. Per D5461, 4 to 8 psi vacuum was applied and the seam
White Mesa Mill -Repair Report, Tailings Cell 2 Page 6 of 10
was observed for air bubbles. If any air bubbles were observed during vacuum testing of the seam,
the test was considered to indicate a seam failure, and the repair and vacuum test repeated.
Specifically, the regulated pressure to the vacuum box was maintained at 15 psig during the test
process and vacuum pressure within the box was recorded in inches of mercury. Test results are
provided with the Liner Repair Daily Reports in Appendix 2.
6. DAILY REPORTS DURING THE REPAIR WORK
Liner Repair Daily Reports have been provided in Appendix 2.
7. REPAIR TEST RESULTS/QUALITY ASSURANCE/QUALITY CONTROL
Results from vacuum testing of patch seams was recorded on the Liner repair Daily Reports.
As discussed above, the quality control standard applied to testing assumed that any single
appearance of a bubble in any part of a tested patch would be considered to be a failure of the patch,
requiring replacement and reattachment of the entire patch.
Following the testing, the test results were listed by number on the Liner Repair Daily Report.
Vacuum tests results are provided in Appendix 2.
8. CONCLUSIONS
The Cell 2 liner repair activities were observed by Utah Registered Professional Engineer Steve
Snyder.
EFR believes that the Cell 2 liner repairs have been performed consistent with the required Liner
Maintenance Provisions.
White Me!ia MiIl -Repair Reporr, Tailings Cell 2 Page 7 of 10
'9. CERTIFICATION
I, Steve Snyder, a Utah Registered Professional Engineer visited U1e repair site on CeU 2 and
personally aisous ed the repairs with maintenance per onne!. 1 discussed foundation preparation
activities, liner patch placement cleaning and seaming of the liner, and vacuum box testing of the
repaired seams.
I also l'eviewed the daily records<U1d documentation of the worle conducted. Based upon the daily
records and documentation al1 of the work was performed in good workman Like manner and the
repairs were completed in accordance withindustFy standard practices. The-vacuum box testing wa
being conducted in accordance with the manufacturer's recomm,endatiolls and in general agreement
w. ith ASTM D 5641 . I certify that the work was conducted in aocordance with the White Mesa Min; s
LinerMainten~llce Provisions, Revision 1 dated October 18 2009.
Steve R Snyder, Utah rNo.5049193-2202
Page ~ of 10
APPENDIX!
Kathy Weinel
From: Kathy Weinel
Sent:
To:
Wednesday, May 15, 2013 2:28 PM
Steve Snyder
Subject: FW: Notification regarding Cell 2 liner
From: Jo Ann Tischler [mailto:[e-mail]]
Sent: Saturday, January 12, 2013 4:41 PM
To: [e-mail]
Cc: [e-mail]; Harold Roberts; David Turk; David Frydenlund; Dan Hillsten; Kathy Weinel; [e-mail]
Subject: Notification regarding Cell 2 liner
Energy Fuels Resources (USA) Inc, ("EFRI") is providing this email to the Utah Division of Radiation Control
("DRC") to notify DRC that in the late afternoon on Friday, January 11,2013, maintenance personnel at the
White Mesa Mill (the "Mill") identified a tear in the liner of tailings Cell 2. Mr. Ryan Johnson of advised EFRI
that these type of notification could be made by email if the notice needed to be submitted during non-business
hours.
Mill Environmental Management became aware of the damage to the liner after 5"00 PM on Friday, January 11,
2013. This notification is being submitted within 24 hours of Corporate Environmental Management being
made aware of the incident, as required by the Mill Groundwater Discharge Permit.
During the late afternoon if January 11, 2012, Mill maintenance personnel were using a backhoe to dig a trench
along the edge of Cell 2 to place a new power cable. Cell 2 is a closed tailings cell with an interim cover.
EFRI has provided previous notifications to DRC on December 19, and 21,2012 regarding the loss of power to
multiple areas of the tailings system due to failure of an aging transformer during the prolonged December 2012
freeze. As part of the repairs and corrective actions, the Mill was preparing a trench to be used in replacing a
power line associated with the failed transformer. The backhoe snagged a portion of the Cell 2 liner above the
level of of the tailings and cover material. Construction of the trench was halted until the liner can be repaired.
Liner repairs cannot be performed during the current extremely low temperatures, due to a combination of
factors including the inability to successfully seal the liner and test the repairs in freezing conditions. EFRI
anticipates completing the liner repairs during the week of January 14, 2013.
A liner repair report will be included in the DMT report for the first quarter of 2013.
Please contact me if you have any questions on this notification.
JoAnn Tischler
Manager, Compliance and Licensing
Energy Fuels Resources (USA) Inc.
1
VIA EMAIL AND OVERNIGHT DELIVERY
Janaury 17,2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill
Utah Ground Water Discharge Permit No. UGW3700004
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
3039742140
www.energyfuels.com
White Mesa Uranium Mill-Notice Pursuant to Parts I.E.7.:£) and I.G.3 ofthe Permit
Dear Mr. Lundberg:
Please take notice pursuant to Parts LE.7.:£) and I.G.3 of the White Mesa Mill's (the "Mill's") State of
Utah Groundwater Discharge Permit No. UGW370004 (the "Permit"), that Energy Fuels Resources
(USA) Inc. ("EFRI"), as operator of the Mill and holder of the Permit, identified, and initiated repairs to,
damage to the Cell 2 Liner System as described in more detail below.
Repairs to the liner were completed on January 17, 2013, in accordance with ' the Mill's Liner
Maintenance Provisions. Cell 2 is in interim closure status and is not in service.
1. Facts and Background Information
a) Part 1.E.7.:£) of the Permit requires that the licensee conduct daily inspections for each of the
tailings cells and weekly inspections of Roberts Pond. According to Part I.E.7.:£):
"In the event any liner defect or damage is identified during a liner system inspection,
the Permittee shall: 1) report and repair said defect or damage pursuant to Part I.G.3
by implementation of the currently approved Liner Maintenance Provisions, and 2)
report all repairs made pursuant to Part I.F.2."
b) Although Part 1.G.3 of the Permit is stated to apply to circumstances where the Permittee
fails to maintain Discharge Minimization Technology ("DMT") or Best Available
Technology ("BAT") standards, Part I.E.7.:£) requires that the notification provisions of
Part I.G.3 also apply to liner defects or damage, regardless of whether or not the liner
defect or damage constitutes a failure ofDMT or BAT. Under Part I.G.3, the Permittee is
required to submit to the Director a notification and description of the defect or damage
Letter to Rusty Lundberg
January 17,2013
Page 2 of4
orally within 24-hours of the Permittee's discovery, followed by written notification within
five calendar days."
c) The Mill experienced freezing temperatures for most of the week of December 17, 2012.
Temperatures reached single digits on December 19,2012. EFRI has provided notifications to
DRC On December 19, and 21, 2012 regarding the loss of power to multiple areas of the
tailings system due to failure of an aging transformer during the prolonged December 2012
freeze.
d) In the afternoon of January 11,2013 as part of the repairs and corrective actions resulting from
the power loss, Mill maintenance personnel were using a backhoe to prepare a trench for
replacing a failed power line. The maintenance plan was for the trench to be excavated with
one section in a north-south direction in the area east of Cell 2, and a second section in an east-
west direction along the dike between Ce112 and Cell 3. The east-west portion was to begin at
the southeast comer of Cell 2 and the northeast comer of Cell 3 and be cut straight along the
dike between the cells.
e) The backhoe operator was instructed that the excavation was not to divert from the assigned
path, and that if any obstructions prevented the excavation from following the designated path,
the backhoe operator was to contact Mill management to have the obstructions removed.
f) The backhoe operator followed the designated path until reaching an area near temporarily
stored drums in the north portion of Cell 3. The operator did not contact Mill management to
have the obstruction removed, and chose to divert from the excavation plan by curving the
backhoe path northward away from the drums.
g) In trenching outside the planned area, the backhoe snagged and tore a portion of the Cell 2
liner where it rises over the dike and enters the anchor trench south of Cell 2. The tear was
above and outside the cell and outside the area containing any tailings material or cover
material.
2. Actions taken
The following actions were taken following identification of the liner tear.
a) ·Mill Maintenance informed Mill Management of the liner tear in the early evening of Friday
January 11, 2013. Mill environmental management notified EFRI Corporate Environmental
Management during the evening/night of January 11,2013.
b) EFRI notified the Utah Division of Radiation Control via an email dated January 12, 2013.
c) In response to a request by the Director of DRC, EFRI provided photographs of the liner
damage to DRC on January 14,2013.
Letter to Rusty Lundberg
January 17,2013
Page 3 of4
d) Mill maintenance personnel initiated repairs to the liner during the week of January 14, 2013.
Repairs and testing of the liner were completed on January 17,2013. Since:
(i) the cell was in interim closure and not in service, and
(ii) the liner damage was outside of the cell and its tailings and cover material (it was in the
anchor trench),
there was no effect on the cell's contents or cover.
3. Actions Taken to Prevent a Recurrence of This Incident
The following actions will be taken to prevent a reoccurrence of this incident:
a) As discussed above, the liner tear occurred during trenching and replacement of a power line
associated with response to freeze-related failures of older power equipment. The older power
transformers and buried power lines have been replaced with new, upgraded equipment.
Affected older power line installations have been upgraded by replacement with jacketed lines
and/or conduit for additional protection from traffic and weather. It is anticipated that these
upgrades and replacements will prevent further power supply failures in future cold weather,
and prevent the need for further repair-related trenching.
b) The obstructions were moved further south within the Cell 3 area to ensure the trench
excavation could be completed in the proper location, and liner repair activity could proceed
with ample working space.
c) The maintenance backhoe operator has been retrained and his instruction has emphasized that
the direction of excavation or intrusion work, especially in the tailings area, cannot be
arbitrarily changed without contacting Mill management prior to varying from the work plan.
4. Required Reporting
As required by Part LF.2 of the permit, a liner repair report will be submitted to the Director with the
next quarterly DMT Report following completion of the repairs. Repairs were completed during the
first quarter of 2013. The repair report will be submitted with the first quarter 2013 DMT Report on or
before June 1; 2013. The repair report will contain, in addition to a root cause analysis, the following
elements:
• Repair narrative describing the nature of the damage and the repair work completed to repair the
damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other)
• Daily reports during the repair work
• Repair test results
Letter to Rusty Lundberg
January 17,2013
Page 40f4
• Quality Assurance/Quality Control Information
5. Affirmative Defense
EFR does not believe that identification of a defect or damage to the Cell 2 liner caused by maintenance
activities and repair of such defect or damage in accordance with the Mill's Liner Maintenance
Provisions constitutes a failure of BAT under the Pennit. Further, the damage to the Cell 2 liner was
above the level and outside the perimeter of any tailings or cover material contained in the celL As a
result, EFR is not making a claim for an affIrmative defense under Part 1.0.3 ofthe Permit.
Jfyou have any questions, please contact me at (303) 389~4132.
Yours very truly,
9fJ-~
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Phillip Goble, DRC
Russ Topham, DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Katherine A. Weinel
White Mesa Mill -Repair Report, Tailings Cell 2 Page 9 oflO
APPENDIX 2
LINER REPAIR DAILY REPORTS
Cell # Cell #2
Date: 15-16 Jan. 2013
Start Time: 7:00am
End Time: 5:30pm
Liner Repair Report
Linear feet exposed for inspection: __ -=10..::5:..... ___ _
Description of damage or clear of any defects:
Slope on South side two areas where repair was needed!
Description of the repair work utilized to repair the damage:
Upper portion of liner going inside of trench.
Material used to complete the repairs:
Acetone (cleaner)
Wire Brush
Paint Brushes
Repair Material -(describe in detail):
PVC Liner, Glue and used a portable heater to reach temperatures to make necessary
repairs.
Weather Conditions:
*-2 Degrees in the Morning.
*16 Degrees mid afternoon.
Personnel performing the repair work:
*PVC Liner Repair Crew-Darin, Greg and Floyd.
*Vacuum Testers-Kendall and Truit.
Vacuum Checks if conducted: Conducted Vacuum Checks. See Below
Notes: Reached and kept temperatures at 60-65 degrees while repairs and curing the
repairs on the liner.
4 Vacuum Tests-16th of Jan 2013.
1) 12hg.
2) 12 hg.
3) 12 hg.
4) 12 hg.
NOTE: All testing ofthe repaired material will be in compliance with ASTM D5641
White Mesa Mill -Repair Report, Tailings Cell 2 Page 10 of 10
APPENDIX 3
LINER MAINTENANCE PROVISIONS
Liner Maintenance Provisions-Cells 1, 2, 3 and Roberts Pond Rev. 1 (10-18-09)
Inspections
Tailings cells 1, 2, and 3 are the subject of comprehensive daily inspections which are
conducted by either the Environmental Technician or the Radiation Technician, as well
as once per shift Daily Operations Inspections which are conducted by the Mill Shift
Foreman or other trained personnel designated by the Shift Foreman. The details of these
daily inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
In each case, these inspections are recorded on inspection forms (Daily Inspection Data
Form and Operating Foreman's Daily Inspection Form, respectively). In addition, non-
recorded Daily Operations Patrols are conducted twice per shift by operations personnel.
With regard to Roberts Pond, this facility is observed on a weekly basis when the
Environmental or Radiation Technician visits the facility for the recording of water levels
at that location.
Training
All individuals performing inspections described in Sections 2.1 and 2.2 of the DMT
Monitoring Plan must have Tailings Management System Training as described in
Appendix C to the DMT Monitoring Plan (Tailings Inspection Training). As and element
of the "Operational Systems" inspection, inspectors are trained and required to observe
the conditions of the PVC liner. Because the PVC liners in Tailings Cells 1,2 and 3 are
sensitive to sunlight and can degrade as a result of prolonged exposure, inspectors are
cautioned to observe any situation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are trained to cover
small areas of exposure immediately, whereas, larger areas are reported to the radiation
Safety Officer to prompt the issuance of a work order to the Maintenance Department. In
keeping with this inspection requirement, inspectors are trained to observe any
degradation of exposed liners. Such degradation can be that caused by exposure to
sunlight, abrasion due to erosive wave action and/or any rips or tears in the liner material.
Given the fact that the liner material is provided with an earthen cover, erosive damage
and/or rips and tears are unlikely. Inspectors are trained to record all observations of
liner exposure or disrepair on the inspection report, as well as the date and nature of any
repair activity.
Roberts Pond is lined with Hi Density Polyethylene (HDPE) material which is not
sensitive to sun damage and, as such, is not covered with earthen material. In this case
the inspector observes the conditions of the liner to the extent that visual observation is
possible (i.e. above the water level and any visually observable near surface condition).
As is the case for the tailing cell inspections, the liner will be observed for any abrasion
due to erosive wave action and/or any rips or tears in the liner material.
Repairs
Repairs to PVC liners in Cells 1,2 and 3 and to the HDPE liner in Roberts Pond are made
on a case by case basis and usually involves the installation of a repair patch over the
damaged location. PVC patches require the use of glues or adhesive solvents to fuse the
patch to the repair location. HDPE repairs are accomplished by use of an extrusion
welder. Subsequent to any repair of a liner, the repair location will be tested using a
"vacuum box" and soapy water to assure that the repair is acceptable. Tests are
conducted such that test areas overlap by at least 10% of the minimum vacuum chamber
length or at least 2 inches, whichever is greater until the entire seam has been tested.
The observation of bubbles through the repair seam while vacuum (4-8 psi per ASTM
D5641) is being applied to the seam constitutes seam failure and the repair must be
redone until all seams are acceptable. In the case of Cells 1, 2, and 3, after a patch has
been applied, the repair location must be covered with earthen material, again to avoid
exposure to sunlight. Adequate supplies of PVC and HDPE liner material, repair
material and vacuum test equipment are maintained either in the Mill warehouse or the
maintenance department. The continued availability of these supplies will be verified as
an element of the Quarterly Tailings Inspection conducted by the Radiation Safety
Officer or his designee.
Any leak, hole or other damage to the liners in Cells 1, 2, 3 and the Roberts Pond will be
reported orally to the Executive Secretary within 24 hours of the discovery and in writing
within 5 days of the discovery. The oral and written notifications will include a
notification and description of the failure in accordance with Part I.G.3.(a) of the GWDP
and be in accordance with R317-6-6.16.C(l) of the regulations. In addition to the
descriptive information about the failure, a plan and schedule for the FML repair will be
included with the notification to the Executive Secretary (in accordance with Part
I.G.3.(c) of the Permit).
Repair Report
Each report will be signed by a Utah licensed professional engineer and will address the
following elements as they apply to the case-by-case repairs which are implemented:
• Repair narrative describing the nature of the damage and the repair work
completed to repair the damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM D5641)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
Attachment F
January 2013
Date
1/3/2013
1/10/2013
1/17/2013
1/24/2013
1/31/2013
Cell 4A LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
8.6
11.3
11.2
7.6
10.2
Flow Meter in Gallons
280934
280934
281650
284479
284479
Highest level for the month based on the daily data was 12.7 inches and the lowest level for the month
was 5.3 inches. Total number of gallons pumped was 3545.
February 2013
Date
2/7/2013
2/14/2013
2/21/2013
2/28/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
11.3
12.6
9.4
10.1
Flow Meter in Gallons
284479
284479
287525
287525
Highest level for the month based on the daily data was 13.0 inches and the lowest level for the month
was 7.6 inches. Total number of gallons pumped was 3046.
March 2013
Date
3/7/2013
3/14/2013
3/21/2013
3/28/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
6.7
8.2
9.3
10.6
Flow Meter in Gallons
290421
290421
290421
290421
Highest level for the month based on the daily data was 12.7 inches and the lowest level for the month
was 5.3 inches. Total number of gallons pumped was 2896.
For the 1 st Quarter 2013, the highest level was 13.0 inches and the lowest level was 5.3 inches and
9487 gallons were pumped.
January 2013
Date
1/3/2013
1/10/2013
1/17/2013
1(24/2013
1/31/2d13
Cell 48 LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
-0.10
-0.29
-0.29
-0.29
-0.10
Flow Meter in Gallons
118
118
118
118
118
Highest level for the month based on the daily data was -0.10 inches and the lowest level for the
month was -1.12 inches. No gallons were pumped.
February 2013
Date
2/7/2013
2/14/2013
2/21/2013
2/28/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
-1.12
-0.29
-1.12
-1.12
Flow Meter in Gallons
118
118
118
118
Highest level for the month based on the daily data was -0.29 inches and the lowest level for the
month was -1.12 inches. No gallons were pumped.
March 2013
Date
3/7/2013
3/14/2013
3/21/2013
3/28/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
-0.29
-0.29
-1.12
-1.12
Flow Meter in Gallons
118
118
118
118
Highest level for the month based on the daily data was -0.10 inches and the lowest level for the
month was -1.12 inches. No gallons were pumped.
For the 1 st Quarter 2013, the highest level was -0.10 inches and the lowest level was -1.24 inches
and no gallons were pumped.
Max head on Cell4A FMl
Max elevati on (ft.)
FMl elevation (ft.)
Head (ft.)
From BAT O&M Table lA (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4A -Q12013
5594.45
5555.55
38.9
604.0
40
24160
Max head on Cell4B FMl
Max elevation (ft.)
FMl elevation (ft.)
Head (ft.)
From BAT O&M Table IB (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B -01 2013
5583.94
5557.50
26.44
475.6
36.17
17202
Calculati on of Maximum Daily Allowable LOS Flow Vo lume for Varying Head Conditi ons in
Cells 4A and 4B
Thc eq uation for the calc ul ation of maximum daily all owable flow volume in Cells 4A and 4B is
as follows:
Step I)
Where:
Step 2)
Step 3)
Step 4)
Elevation I-Elevati on 2 ~ Head (II.)
Elevation I is the max imum elevation in feet measured during the reporting
period.
Elevation 2 is the FML elevation in feet.
Detemline Calculated Action Leakage Rate from Table IA (for CeIl 4A) or Table
I B (for Cell 4B) using the head calculated in Step I above. If the head calculated
in step I above falls between two values in the Head Above Liner System (feet)
co lumn. the n the closer of th ese two values will be used to determine the
Calc ulated Action Leakage Rate.
Calcul ate the acres of tail ings cell fluids based on Lbe area of the base of Lbe cell,
th e bead, and the angle of the sidcslopes of the cell.
Action Leakage Rate (from Table 1 A or IB) X Acres of Taili ng, Cell Fluids ~
Maximum Dail y Allowab le Flow Volume
. ' -..
H.etd iNsoV8 tln,r -"kl!tqI~~IIft~'" .Svd~m (Je~~) . ("lfo~l·rA(lfqa • -,Ul,M
~ .u;ct .
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20 M4JtJi
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.' .31 . Jig,to
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1'11111.1.
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!;e11Q,-Whllio M ... Mill
lII.nom;" Ulih
Cell 1, Cell 2, and Cell 3 LOS Monitoring Information· First Quarter 2013
Cell 1 Cell 2 Cell 3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the LOS sump.
1/4/2013 Dry 1/4/2013 Dry 1/4/2013 Dry
1/14/2013 Dry 1/14/2013 Dry 1/14/2013 Dry
1/18/2013 Dry 1/18/2013 Dry 1/18/2013 Dry
1/25/2013 Dry 1/25/2013 Dry 1/25/2013 Dry
Cell 1 Cell 2 Cell 3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LOS sump. bottom of the LOS sump. bottom of the LOS sump.
2/1/2013 Dry 2/1/2013 Dry 2/1/2013 Dry
2/8/2013 Dry 2/8/2013 Dry 2/8/2013 Dry
2/15/2013 Dry 2/15/2013 Dry 2/15/2013 Dry
2/22/2013 Dry 2/22/2013 Dry 2/22/2013 Dry
Cell 1 Cell 2 Cell 3
Measurement in inches Measurement in inches Measurement in inches
Date from transducer at the Date from transducer at the Date from transducer at the
bottom of the LDS sump. bottom of the LDS sump. bottom of the LDS sump.
3/1/2013 Dry 3/1/2013 Dry 3/1/2013 Dry
3/8/2013 Dry 3/8/2013 Dry 3/8/2013 Dry
3/15/2013 Dry 3/15/2013 Dry 3/15/2013 Dry
3/22/2013 Dry 3/22/2013 Dry 3/22/2013 Dry
3/29/2013 Dry 3/29/2013 Dry 3/29/2013 Dry
Attachment G
This attachment has been deliberately left blank.