DRC-2013-002933 - 0901a068803afd20

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www energyfuels com
August 20, 2013
VIA OVERNIGHT DELIVERY
"DRC-2013-002933"
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: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 2nd 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 2nd 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
August 20, 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 2nd 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 2nd Quarter of 2013, as required under Parts
1.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,
~~I.~
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Kathy Weinel
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
2nd Quarter
April through June
2013
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
August 20, 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
4.4 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 DECONTAMINATION PADS .................................................................................................................... 6
8.1 SUMMARY OF WEEKLY INSPECTIONS ........................................................................................................... 6
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ....................................................................... 7
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................................................. 7
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR THE QUARTER. 8
9.1 LDS MONITORING ........................................................................................................................................ 8
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ........................................................... 8
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 Pumped from the LDS ................................................................. 9
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4 B ............... " ................................ 10
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... 10
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING FOR THE QUARTER ......................................... 10
10.1 OPERATIONAL STATUS OFLDS PUMPING AND MONITORING EQUIPMENT ................................................. Il
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ....................................................... I I
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1, 2, AND 3 ................................................. I I
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... I I
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2012 .. 11
12.0 SIGNA TURE AND CERTIFICATION .................................................................................................... 12
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 Part I.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 Cell4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables lA and lB, Cell 4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.12)
11
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 2nd QUARTER OF 2013
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the second 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 LD.3, I.E.7, and I.F.II of the GWDP:
• Weekly tailings wastewater pool elevations for tailings Cells I and 3 (Part
LE.7(a));
• Quarterly slimes drain water levels in Cell 2 (Part LD.3(b)(1) and (2));
• Annual Slimes Drain Compliance (Part LD.3 (b) and IF. I I );
• Weekly wastewater level measurements in Roberts Pond (Part ID.3(e) and Part
LE.7(c));
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part LD.3(f) and Parts LE.7(d); and
(e));
• Any tailings cell and pond liner system repairs (Part LE.7 (f) and Part LE.(8)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g)) and
• Annual Decontamination Pad Concrete Inspection (Part IF.ll) (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 Parts I.E.8 and I.E.12 of the
GWDP:
• Leak detection system ("LDS") monitoring for Cell 4A (Part LE.8.(a)), and Cell
4B (Part LE.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part LE.8 (a))
and Cell 4B (Part I.E.12 (a)).
I
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 fmsl.
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 fmsl, 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 Ce1l4A were eliminated as documented on March 14 and 15, 2011 respectively. As
indicated in Table 1, the applicable freeboard limits were not exceeded during the Quarter for
any cell. As reported in the 1st quarter report, the freeboard limit for Cell 1 was exceeded during
the first quarter. The required notifications were submitted to the Division of Radiation Control
("DRC") on May 14, 2013. Because this notice was submitted during this reporting period, the
notification is included in this report for completeness purposes only. All investigations and
analyses regarding the freeboard exceedance in Cell 1 are included in the DMT report for the 1 st
quarter 2013. During the second quarter the applicable freeboard limits were not exceeded for
any cell.
All cells 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 Cell 1 at a liquid maximum elevation of 5,615.4 fmsl.
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 (fms1) the GWDP (fmsl)
Cell 1 5614.80 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 Q1 2011
Cell4A 5593.21 -freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Q12011.
Cell4B 5587.51 5594.60 5597.40
* The DIrector approved the removal of the Cell 3 freeboard hmlt and authOrIzed the use of Cell 4B 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 Cell 4B that will accommodate
the freeboard requirements of Cells 1, 4A, and 4B.
4.0 QUARTERL Y 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, Pcut 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 quarterly 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 qucuterly
monitoring in the quarterly White Mesa Mill DMT Performance Standards Monitoring Report
and Cell 4A 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
2013, which addresses the requirements of Part I.F.ll of the GWDP and Section 8.2 of the DMT
Plan, will be included in the 4th quarter 2013 DMT 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.
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 2009,2010,2011,2012 and 2013.
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.
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5,617.63
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The results of such
monitoring are included in Attachment A.
5
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.ll of the
GWDP. The results of these inspections are recorded on the Weekly Mill Inspection forms,
which are available at the Mill for inspection. No items of note were recorded during the third
quarter inspections.
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.
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
Decontamination Pad resumed in February 2011 and the weekly inspections were resumed as
required.
Table 2 below indicates the water level measurements III each portal measured during the
quarter.
6
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)
4/5/2013 0.00 0.00 0.00
4112/2013 0.00 0.00 0.00
4119/2013 0.00 0.00 0.00
4/26/2013 0.00 0.00 0.00
5/3/2013 0.00 0.00 0.00
5/10/2013 0.00 0.00 0.00
5117/2013 0.00 0.00 0.00
5/24/2013 0.00 0.00 0.00
5/31/2013 0.00 0.00 0.00
6/7/2013 0.00 0.00 0.00
6114/2013 0.00 0.00 0.00
6/2112013 0.00 0.00 0.00
6/28/2013 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 I.D.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
The Existing Decontamination Pad was taken out of service and inspected during the second
quarter on April 8, 2013, to ensure the integrity of the steel tank, as required by Part I.H.5(c) of
the Permit and Section 6.5 of the DMT Plan. No significant cracks (greater than 1/8 inch),
deterioration or damage were identified. A few minor cracks (less than 1/8 inch) were observed.
Repairs and maintenance, including caulking and sealing of cracks, were completed on April 9,
2013 to prevent additional deterioration. The decontamination pad was returned to service after
the completion of the repair and maintenance activities.
The inspection report and photos taken during the inspection are provided in Attachment G.
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
7
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 lO-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.
The New Decontamination Pad was taken out of service and inspected on April 10, 2013 to
ensure integrity of the wash pad's exposed concrete surface, as required by Part LF.12 of the
GWDP and Section 6.5 of the DMT Plan. No abnormalities were identified. No significant
cracks (greater than 1/8 inch), deterioration or damage were identified. A few minor cracks (less
than 1/8 inch) and small areas of surface abrasions were observed. These minor cracks and the
surface abrasions were repaired on April 10, 2013 to prevent additional deterioration, even
though the repairs are not required by the GWDP.
The inspection report and photos taken during the inspection are provided in Attachment G.
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 Report for the quarter, as required under Part LF.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.
Cell4A
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
LE.8(a)(1) for Ce1l4A.
Cell4B
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
LE.12(a)(1) 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.
8
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.
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 I-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring this I-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 Cell4A 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 I-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 I-foot distance equates to 2.25 feet (27 inches) above the LDS system. During
the quarter the fluid head in the Cell4B 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.
Ce1l4A
As can be seen from a review of Attachment F, 9,420 gallons of fluid were pumped from the Cell
4A LDS for the second quarter of 2013. Based on this, the average daily LDS flow volume in
Cell4A did not exceed 24,160 gallons/day, as stipulated by Part 1.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 Cell 4B, 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 38 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 Cell4A did not exceed the calculated
flow volume of 24,160 gallons/day. As mentioned above, during first quarter of 2013, a total of
9,420 gallons of fluid were pumped from the Ce114A LDS during the period and did not exceed
9
the calculated flow volume. The allowable flow rate calculation for the quarter for Cell 4A is
included in Attachment F of this report.
Ce1l4B
As can be seen from a review of Attachment F, no fluids were pumped from the Cell4B LDS for
the first quarter of 2013 and the flow rate 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 30 feet. The allowable flow
rate would therefore be approximately 528.4 gallons/acre/day (19,958 gallons/day for the cell),
as determined under the Mill's Cell 4A 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 37.77 acres of liquid area. The average daily flow volume in Cell 4B did not
exceed the calculated flow volume of 19,958 gallons/day. During second quarter 2013, no fluids
were pumped from Cell 4B LDS and therefore did not exceed the calculated flow volume. The
allowable flow rate calculation for the quarter 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 Cell4A or Cell4B 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
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.
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 2013
The annual slimes drain recovery head report for Cell 2 for calendar year 2013 (the "Period"), as
required under Parts I.D.3 (b) and I.F.ll 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.
11
12.0 SIGNATURE AND CERTIFICATION
This document was prepared by Energy Fuels Resources (USA) Inc. on August 20,2013.
llr es (USA) Inc.
By:
Davi . Fryclenl und
Senior Vice President, General Counsel and Corporate Secretary
12
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and compl teo T am aware that there are significant penalties for submitting false information,
in hiding e p ssibility of fine and imprisonment for knowing violations.
David . ry nlund
Senior Vice President General Counsel and Corporate Secretary
Energy Fuels Resources (USA) Inc.
13
Attachment A
Date Celli Cell 3 1 Ce1l4A 2 Ce1l4B 3 Roberts Pond
Freeboard 5615.40 -RML 5593.74 -RML 5594.60 -RML
Limit 5615.50 -GWDP 5595.50 -GWDP 5597.40 -GWDP 5624.00 -GWDP
4/5/2013 5614.80 No Longer Required 5593.21 5584.95 5617.63
4112/2013 5614.39 No Longer Required 5593.01 5585.40 5616.54
4119/2013 5614.34 No Longer Required 5592.91 5585.93 5617.18
4/26/2013 5614.40 No Longer Required 5592.60 5586.34 5617.20
5/3/2013 5614.50 No Longer Required 5592.60 5586.60 5616.46
5110/2013 5614.46 No Longer Required 5592.89 5586.91 5616.56
5117/2013 5614.40 No Longer Required 5592.64 5587.09 5616.83
5/24/2013 5613.39 No Longer Required 5592.16 5587.34 5617.10
5/3112013 5614.22 No Longer Required 5591.75 5587.47 5617.30
6/7/2013 5614.07 No Longer Required 5592.18 5587.51 5616.62
6114/2013 5613.88 No Longer Required 5592.56 5587.18 5616.76
6/2112013 5613.71 No Longer Required 5592.27 5587.30 DRY
6/28/2013 5613.58 No Longer Required 5591.94 5587.31 DRY
I Cell 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 Cell4A is set out in a letter from the Director dated November 20,2008. EFRI proposed in the DMT
Plan revision dated November 12,2010 the removal of the freeboard limit for Cell4A 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 Cell4A freeboard limit on January 13,
2011 and approved the removal of the Cell4A limit and the use of Cell4B 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 Cell4A 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 Cell4B at this time.
Attachment B
I~~~~ t(.;i]_/r;~ERGYFUELS
VIA EMAIL AND OVERNIGHT DELIVERY
May 14,2013
Mr. Rusty Lundberg, Director
Utah Division of Radiation Control
State of Utah Department of Enviromnental 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 1.G.3 ofthe Permit and UAC R317-6-6.16 (C)
Dear Mr. Lundberg:
Please take notice pursuant to part 1.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 I.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 of EFRI' 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 I.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 of the Mill's Radioactive Materials License (the "License") states that:
N:\WMM\Notices\Celll 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 I.D.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 I.D.2 of the
GWDP therefore requires satisfaction of the 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 CellI, 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,
CellI 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 CellI 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 Cell 1 to Cell
4B.
• Mill Maintenance personnel installed a transfer pump on the pump barge and initiated transfer of
solutions from CellI to Ce1l4B 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 Ce1l4B.
• The transfer pump on the Cell 1 pump barge (transferring solutions to Cell 48) 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 CellI 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 CellI to Ce1l4B began on February 8, 2013.
• Pumping of solution from Cell 1 to Ce114B was increased to 700 gpm on February 21, 2013.
• Pumping ofSX raffinate solution to CellI ceased on February 21, 2013.
• Cell 1 solution elevation returned to compliance with the Part I.D.2 limits 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, and/or 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 I 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 of the 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 and/or emergencies, and
• provide dual coverage and responsibility for environmental compliance, emergency response,
and notification to Corporate Management and appropriate regulatory authorities.
3. EFRI 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. EFRI is re-evaluating the primary documents which require internal or external notification
under specific conditions or situations. Specifically, EFRI 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
Page60f6
carried into the Tailings Management System document applicable to Cells 1 and 3 when it was
drafted.
EFRI plans to modify these and/or the procedures and plans derived from these documents to ensure that
the requirements for notification are spelled out clearly. As apPr<lpriate, EFRI will provide draft
revisions of these documents to DRe for review and approval.
If you have any questions, please contact me at (303) 3894132.
Yours very truly.
CfL~
!,NERGY Ii UELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Complianc.e and Licensing
cc David C. Frydenlurtd
Phil Goble, Utah DRC
Dan Hillsten
N. Tanner Holliday
Garnn Palmer
Harold R. Roberts
Russ Toph~ Utah DRe
David E. Turk
Kathy Weinel
Table 1
Cell 1 Solution Level Data for Ql 2013
Remaining
Remail11rig 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 (lriches) (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 ofthis Notice.
Attachment c
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 6/17/13 -6/24/13 -Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
6/17/13 6/18/13 6/19/13 6/20/13 6/21/13 6/22/13 6/23/13 6/24/13
700 27.97 25.54 24.46 23.7 22.16
800 27.80 25.46 24.43 23.69 22.16
900 34.40 27.64 25.39 24.39 23.67 22.16
1000 33.70 27.48 25.32 24.35 23.65
1100 32.96 27.40 25.26 24.30 23.61
1200 32.69 27.29 25.19 24.26 23.57
1300 32.24 27.17 25.13 24.22 23.54
1400 31.70 27.05 25.06 24.19 23.51
1500 31.46 26.92 24.97 24.15 23.47
2000 22.80 22.26
Comments: Final reading for the quarter is 22.16.
Attachment D
n to
N
(I)
T --. VI 3 Cll ::1. Cll to II> U) IV
C ..,
QJ -. ::::s
N 0
0 c: U) ::J Cll ... ell -. N VI 0 Cll ::1 . ..... Cll II> 0 ~ ...
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0 ..... ..... ...
N
0 .....
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20
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IV .j:> o o
Feet Below Top of Standpipe
IV IV o o
IV o o o
I-' 00 o o
I-' en o o
I-' .j:> o o -rr--I 1 1/30/2009 -wJ
3/30/2009
5/30/2009
··7/30/2009
·9/30/2009
11/30/2009
1/31/2010
3/31/2010
5/31/2010
7/31/2010
9/30/2010
11/30/2010
1/31/2011
-3/31/2011
5/31/2011
7/31/2011
9/30/2011
• 11/30/2011
-1/31/2012
3/31/2012
5/31/2012
7/31/2012
9/30/2012
11/30/2012
1/31/2013
·3/31/2013
5/31/2013
Attachment E
This attachment has been deliberately left blank.
Attachment F
April 2013
Date
4/5/2013
4/12/2013
4/19/2013
4/26/2013
Cell 4A LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
11.6
8.0
9.1
9.8
Flow Meter in Gallons
290421
293388
293388
293388
Highest level for the month based on the daily data was 13.0 inches and the lowest level for the month
was 6.3 inches. Total number of gallons pumped was 2967.
May 2013
Date
5/3/2013
5/10/2013
5/17/2013
5/24/2013
5/31/2013
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
11.8
7.8
9.7
10.7
11.0
Flow Meter in Gallons
293388
296404
296404
296404
296404
Highest level for the month based on the daily data was 12.8 inches and the lowest level for the month
was 6.2 inches. Total number of gallons pumped was 3016.
June 2013
Date
6/7/2013
6/14/2013
6/21/2013
6/28/2013
Weekly measurements in
inches from transducer at
the bottom of the LOS
sump.
5.5
9.5
10.0
11.8
Flow Meter in Gallons
299841
299841
299841
299841
Highest level for the month based on the daily data was 13.0 inches and the lowest level for the month
was 5.5 inches. Total number of gallons pumped was 3437.
For the2nd Quarter 2013, the highest level was 13.0 inches and the lowest level was 5.5 inches and
9420 gallons were pumped.
April 2013
Date
4/5/2013
4/12/2013
4/19/2013
4/26/2013
Cell 48 LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
-1.12
-0.29
-0.29
-0.29
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.
May 2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
Date sump. Flow Meter in Gallons
5/3/2013 -0.29 118
5/10/2013 -0.29 118
5/17/2013 -0.29 118
5/24/2013 -0.29 118
5/31/2013 -0.29 118
Highest level for the month based on the daily data was -0.29 inches and the lowest level for the
month was -0.29 inches. No gallons were pumped.
June 2013
Date
6/7/2013
6/14/2013
6/21/2013
6/28/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
-0.29
-1.12
-0.29
-0.29
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.
For the 1 st Quarter 2013, the highest level was -0.29 inches and the lowest level was -1.12 inches
and no gallons were pumped.
Max head on Cell4A FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1A (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4A -Q2 2013
5593.21
5555.55
37.66
604.0
40
24160
Max head on Cell4B FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table lB (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B -022013
5587.51
5557.50
30.01
528.4
37.77
19958
Calculation of Maximum Daily Allowable LDS Flow Volume for Varying Head Conditions in
Cells 4A and 4B
The equation for the calculation of maximum daily allowable flow volume in Cells 4A and 4B is
as follows:
Step 1)
Where:
Step 2)
Step 3)
Step 4)
Elevation I-Elevation 2 = Head (ft.)
Elevation 1 is the maximum elevation in feet measured during the reporting
period.
Elevation 2 is the FML elevation in feet.
Determine Calculated Action Leakage Rate from Table lA (for CeIl4A) or Table
IB (for Cell 4B) using the head calculated in Step 1 above. If the head calculated
in step 1 above falls between two values in the Head Above Liner System (feet)
column, then the closer of these two values will be used to determine the
Calculated Action Leakage Rate.
Calculate the acres of tailings cell fluids based on the area of the base of the cell,
the head, and the angle of the sideslopes of the cell.
Action Leakage Rate (from Table lA or IB) X Acres of Tailings Cell Fluids =
Maximum Daily Allowable Flow Volume
Nee liner sy~t~rn tr.II~J •
. 15
20
. 25
.' '1
..
Celli, Cell 2, and Cell 3 LOS Monitoring Information -Second Quarter 2013
Celli 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.
4/5/2013 Dry 4/5/2013 Dry 4/5/2013 Dry
4/12/2013 Dry 4/12/2013 Dry 4/12/2013 Dry
4/19/2013 Dry 4/19/2013 Dry 4/19/2013 Dry
4/26/2013 Dry 4/26/2013 Dry 4/26/2013 Dry
Celli 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.
5/3/2013 Dry 5/3/2013 Dry 5/3/2013 Dry
5/10/2013 Dry 5/10/2013 Dry 5/10/2013 Dry
5/17/2013 Dry 5/17/2013 Dry 5/17/2013 Dry
5/24/2013 Dry 5/24/2013 Dry 5/24/2013 Dry
5/31/2013 Dry 5/31/2013 Dry 5/31/2013 Dry
Celli 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 lDS sump. bottom of the lDS sump.
6/7/2013 Dry 6/7/2013 Dry 6/7/2013 Dry
6/14/2013 Dry 6/14/2013 Dry 6/14/2013 Dry
6/21/2013 Dry 6/21/2013 Dry 6/21/2013 Dry
6/28/2013 Dry 6/28/2013 Dry 6/28/2013 Dry
Attachment G
New Decon Pad
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A·4
7112 Revision: Denison 12,1
Page 21 of26
ANNUAL DECONTAMINATION/AMMONIUM SULFATE PAD INSPECTION
Date of Inspection: 1..1 1 1 D /13
Inspector: /0.,,.,;.... P .... l"""c-r-
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
tLYes _No
Is there any significant deterioration or damage of the pad surface? __ Yes -t.L..,.No
Findings:
-A eCce..,.) (. Ce,JK.s leU ... ,.., fOc./,ul "'" i-I,...,..c---1"a6.L..£"'-+C p~~ +-l,....(.,.t.. 6-tf.,L.Uo!. t( p4..ir-L
-1)(.(0",,-boltlj~ t,. ... ~.c a.e' j .... d e,., .. M .... .,li b'q.& (srcc fh,ot-c.c)
Repair Work Required:
G C4..( k.. S c.u.r-( CtlkA. Wl i-k .(e.d.: ..... + I S 4'-hi4-,. (k"ul pk.n+QS
Existing Decontamination Pad:.,. x:: ..... ,'P(.d ,A ... J ~ I &3 I L./ , '" /1 'J
Were there any observed problems with the steel tank? __ Yes ~No
Findings:
tl.·,btu .... jA. f+,.,(,\ + .......... k. ;c 4"&A-"-i ~ b IT! ,5-+"kl is it\-.c,ac<j.l c.oo.ci;+'c",
-SaMe--4r~ "",c.A « + .. '\c,.l «\..6.Al r C -Se ...... luA Oh 1,.t2&1.rc..+4 peJ..
-Kj v ....... is ie.,s.aa..J. 4(/<,,&..;"-~oA . Ala re..~""; J "'" uJ..,J,.
Repair Work Required:
L.,r4-(~{ r> A. La 6.4t:0<.. f>""e.l t.Jc..Cc c= (" e.G"'r pt. Sr ,r 1"> b.",·rc>,s
C;\DocufnelliS and Settillgs\gpaJmcr\Loca) Setlillgs\Temporary Illiernet FiIes\Contenl.OutJookl7HUQ34A9lDMT Plan July 2012 Rev 12 I
cJeIDl.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
Ammonium Sulfate Pad:
7/12 Revision: Denison I 2. I
Page 22 of26
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
_Yes ..,.LNo
Is there any significant deterioration or damage of the pad surface? V' Yes __ No
Findings:
Ec!:5(...$ or 4-1..., <Q!lV'".r-e..:b:... pd..9~ A.rt, w--lJ"""--!?l;~: ,1.10 l.cc ..... dW W"'I""L C(2 u AA
btl t (Lr( he $ a C= M · 4, L p(.s,.~+=:!:£<-..!.".:.!;~O~""~411oo:.:l+c..:!;~""~~!T"-' _________________ _
Repair Work Required:
~..ib."C&'r(..,.A.." .,:£ L 0 A.L.N." :hE
CL"'-c.A~ lul. ~pr +:bL 6"(",,.,4
, ......
Note: For the annual inspection of the Existing, New Decontamination Pads and the Ammonium
Sulfate Pad, the annual inspection findings, any repairs required, and repairs completed, along
with a summary of the weekly inspections of the Decontamination Pads, shall be discllssed in the
2nd Quarter report, due September 1 of each calendar year
C:\DocumenlS and Selling'\gpalrner\Local Settings\Temporary Internet Files\ContenLOutlook\7HUQ34A9\DMT Plan July 2012 Rev 12 1
~ 1 ~,... .... J .........
New Decontamination Pad -4/1012013
Concrete pad before repair (facing south)
~ .......
0 N -... 0 ....... -... -.::t
I !l)
'"d ~ !l) ro I-< 0... u
~ I=: I=: 0 0 U .-I=: -' ro .-~ ~ ·S g " ro I-< ~ U I=: 0 u !l)
Q
~ !l)
Z
New Decontamination Pad -4/10/2013
Sealed crack in concrete
New Decontamination Pad -411212013
Holding tanks and pump area
Existing Decon Pad
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
ATTACHMENT A-4
7112 Revision: Denison 12.1
Page 21 of26
ANNUAL DECONTAMINATION/AMMONIUM SULFATE PAD INSPECTION
Date ofInspection: LI t J 0 /13
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 118 inch of separation?
L Yes_No
Is there any significant deterioration or damage of the pad surface? __ Yes ~N o
Findings:
-A Fe..., (,. .. .LILJ .. Jt;.r=c £<,,,4 (2A +L...,,= , . .Dr'\'.U +e. t2aA. tk.r_~ ""=L"c.etc A r( fA-irs
-1;)(."" .... ',"old.:....".g +-...... "s: 4,.., i ... ~,.c .+ 4!o.tta,'QA (stU.. fh"hu)
Repair Work Required:
cr4.d;r , ... JO"c:. CllkA w~+k it'6l?d+' (C:d' 4o..i ....... ,1..,c:A pko+oS
Existing DecontaminationPad:/ ~",,~p£.dLA ~/~/r3 I Y /'l(13
Were there any observed problems with the steel tank? __ Yes ~N o
Findings:
-Rv~b(.y :.1\.. ,J~(L\ +-......... J,~ ic ,.r +L.lc.i--:s b Ld ,Stu." iJ jA hOoeA. (o ..... ,,:l~+iM,
Repair Work Required:
L roo.' k:. r " A L <I A.4 c:--+.L S"'A e.L w.;.,.ree= .!'<--L..-l,.A.. Sr (, p k", +cS
C\DoclImen1s and Setlingslgpalmer\Local SeltingslTemporary Intemet Files\Contenl.OutJook\7HUQ34A9\DMT Plan July 20!2 Rev 12 i
c1ean.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
Ammonium Sulfate Pad:
7112 Revision: Denison12.1
Page 22 of26
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
_Yes L No
Is there any significant deterioration or damage of the pad surface? VYes __ No
Findings:
E.cl.£)W C?~ tt...c t Q"'-krG=+ec p~ J:...rL t....r;"l.!-'-b l:~ . ..va c:.r<'-l k-s !,,)c:.cc.-CovNt
bV'~ tV"'C&,$ a£-~d 4.J-L J.,(.-+-c:.r;",...Ji~.
Repair Work Required:
/'le 91&kt ........ t.A..~ 12 f '-~ ...... t.."?-h .
Note: For the annual inspection of the Existing, New Decontamination Pads and the Ammonium
Sulfate Pad, the annual inspection findings, any repairs required, and repairs completed, along
with a summary of the weekly inspections of the Decontamination Pads, shall be discussed in the
2nd Quarter report, due September 1 of each calendar year
C:\Documents and SettingslgpaJmer\Local SettingslTemporary Internet FilesIContent.OutlookI7HUQ34A9\DMT Plan July 2012 Rev 12 1
Existing Decontamination Pad -4/8/2013
Steel Tank
, , · ~
/
\ 'I
Existing Decontamination Pad -4/9/2013
Concrete Pad After Repairs (facing east)
Existing Decontamination Pad -4/9/2013
Concrete Pad After Repairs (facing west)