DRC-2013-003208 - 0901a068803c2cc7

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVER
September 24, 2013 £s<^,,DRC-2013-003208 II
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
Re: State of Utah Ground Water Discharge Permit ("GWDF') No. UGW370004
White Mesa Uranium Mill
Notice Pursuant to Parts I.E.7.f) and I.G.3 of the GWDP
Dear Mr. Lundberg:
Please take notice pursuant to part I.E.7.f) and I.G.3 of the White Mesa Mill's (the "Mill's")
GWDP No. UGW370004 that Energy Fuels Resources (USA) Inc. ("EFRI") identified and
repaired damage to the tailings Cell 1 liner system, as described in more detail below.
1. Facts and Background Information
1.1 Regulatory Background
Part I.E.7.f) of the Mill's GWDP requires for tailings cells 1, 2, 3, and Robert Pond that:
"In the event that 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."
Part I.G.3 of the Mill's GWDP requires that:
"Notification shall be given orally within 24 hours. . ." and shall be followed up
by written notification ". .. within 5 calendar days".
Part I.F.2 and the Mill's Liner Maintenance Provisions require that a:
"Repair Report shall be included with the next quarterly DMT Report."
N:\WMM\Notices\Cell 1 5 day notice hail damage 09.18.13\Cell 1 hail damage notice 09.24.13.doc
Letter to Rusty Lundberg
September 24, 2013
Page 2 of4
1.2 Sequence of Events
The sequence of events associated with the liner damage at Cell 1 is as follows:
• The Mill site is graded and sloped to drain on-site precipitation to the Mill's tailings
system. Precipitation on the northern section of the Mill drains to Cell 1 over its northern
dike.
• Cell l's liner system consists of a 30 mil PVC flexible membrane liner ("FML") with a
protective soil cover of 18 inches on the interior side slopes.
• The Mill experienced combined rainstorm/hailstorms on September 17 and 18, 2013.
During the September 18, 2013 storm, the Mill received nearly the highest daily
precipitation in its history, specifically 0.76 inches of rainfall and hail within 10 minutes,
as measured by the Mill's on-site meteorological station. The September 17 and 18, 2013
rainfall was accompanied by hail ranging up to 4 centimeters in diameter.
• During September 18 and 19, 2013, rainwater from the storm event pooled to create a
number of temporary "lakes" north of Cell 1. The pooled rainwater drained into the
tailings cell area over the northern dike of Cell 1 throughout the two storms and
continuing through September 19, 2013.
• Mill environmental personnel performed daily liner inspections during the mornings of
September 18 and September 19, and during the afternoon of September 20, 2013.
During the mornings of September 18 and 19, 2013 the lower access road at Cell 1 was
inundated and inaccessible due to the volume of water draining to the tailings cell.
Drive-through inspections were conducted, to the extent practicable, from the upper
access road.
• The lower access road became accessible on September 20, 2013. During Mill personnel
inspection of the cell liner system during the afternoon of September 20, 2013, it was
observed that two channels, one on the east dike and one on the central area of the north
dike, had been eroded in the protective soil cover, which removed sufficient soil cover to
expose the FML. Neither of the channels were visible during the September 18 and 19,
2013 inspections. The exposed area on the east dike exhibited no liner damage. The
exposed area on the north dike exhibited a number of pinholes and star-shaped punctures
in the FML, apparently from hail impacting the exposed FML.
• All damage identified on the Cell 1 liner occurred above the Cell 1 solution level of
5615.40 feet.
It should be noted that the provisions of UCA 19-5-107 have not been violated as a result of the
liner damage. 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
Letter to Rusty Lundberg
September 24, 2013
Page 3 of 4
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.
It should also be noted that there was no discharge of solutions from the Mill's tailings
impoundments at any time during the storm event, and no exceedance of the Mill's Groundwater
Discharge Permit or Radioactive Materials License freeboard requirements for any cell in the
Mill's tailings system as a result of the storm event.
2. Action Taken
The Mill took the following actions:
• Corporate Environmental Management was notified of the liner damage at
approximately 3:00 PM on September 20, 2013.
• EFRI provided oral notification to Mr. Kevin Carney of DRC by telephone at
approximately 3:45 PM on September 20, 2013, within one hour of receiving
notification of the Mill's findings.
• Repairs to the liner were initiated on September 20, 2013, and were completed by
September 24, 2013. The repairs included replacement of a section of the liner on the
north dike as described in Section 4, below, and replacement of the soil cover on the
exposed areas of the north and east dikes.
3. Root Cause
The damage to the Cell 1 liner was not the result of any action or inaction by Mill personnel. The
root cause was the combination of:
1. The excessive rainfall in storm events on September 17 and 18, 2013 which contributed to
erosion and sloughing of the protective soil cover on the Cell 1 dikes, and
2. The two successive hailstorms which impacted one exposed area of the Cell 1 FML
sometime during September 18 or 19, 2013.
4. Actions That Will be Taken to Prevent a Recurrence of This Incident
As discussed above, the damage to the Cell 1 liner was not the result of any action or inaction by
Mill personnel, and resulted from a natural event , the successive rainstorms/hailstorms on
September 17 and 18, 2013.
Mill maintenance personnel have taken the following steps to confirm that all damage to the
FML has been identified and repaired.
Letter to Rusty Lundberg
September 24, 2013
Page 4 of 4
• At the damaged area on the north dike, the soil was removed to at least two feet around
the visible damage. The extra two-foot perimeter around the known damage was
inspected for pinholes, breaks, or other damage, and none was found.
• The entire uncovered area, including the two-foot perimeter, was replaced with a new
section of liner material.
• The exposed FML area on the north and east dikes of Cell 1 were recovered with 12
inches of soil.
• A Repair Report meeting the requirements of the Mill's Liner Maintenance Provisions
will be included with the third quarter 2013 DMT report to be submitted on December 1,
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
[phone]
[e-mail]
cc Frank Filas, EFRI
David C. Frydenlund, EFRI
Phil Goble, Utah DRC
Dan Hillsten, EFRI
N. Tanner Holliday, EFRI
Garrin Palmer, EFRI
Harold R. Roberts, EFRI
Russ Topham, Utah DRC
David E. Turk, EFRI
Kathy Weinel, EFRI
2013.