DRC-2013-003605 - 0901a068803e0021

ENERGYFUELS
DRC-2013-003605
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
November 25, 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
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 3rd 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 3rd 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].
W 2 '013
9/
Yours ver
•4 ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
Jo Ann Tischler
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
3rd Quarter
July through September
2013
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
November 25,2013
TABLE OF CONTENTS
I. 0 INTRODUCTION 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED 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 4
4.3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION 4
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 5
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS 6
8.0 DECONTAMINATION PADS 7
8.1 SUMMARY OF WEEKLY INSPECTIONS 7
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD 8
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD 8
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT 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 Pumped from the LDS 10
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4B 11
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING 11
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING 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
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING 12
II. 0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2013.. 12
12.0 SIGNATURE AND CERTIFICATION 13
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 LG.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 Cell 4A and Cell 4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables 1A and IB, Cell 4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part LF. 12)
H Weekly Feedstock Inspection Form - Feedstock Maps
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 3rd QUARTER OF 2013
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the third 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, the following DMT monitoring was performed or addressed, as required
under Part LD.3, I.E.7, and LF. 11 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)(l) and (2));
• Annual Slimes Drain Compliance (Part LD.3 (b) and I.F. 11);
• Weekly wastewater level measurements in Roberts Pond (Part LD.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 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.(8)(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 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 I.E.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.8 (a))
and Cell 4B (Part I.E.12 (a)).
1
3.0 WEEKLY 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 LE. 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 Cell 4A were eliminated as documented on March 14 and 15, 2011 respectively. The
freeboard limits established by the GWDP and the Mill's State of Utah Radioactive Materials
License No. UT 1900479 (the "License") are slightly different; accordingly, the stricter of the
two limits represents the regulatory standard for each cell. As indicated in Table 1, the applicable
freeboard limits were not exceeded during the Quarter for any cell.
All cells met the maximum wastewater criteria of 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.
A letter from the Director dated January 27, 2011 which approved the use of Cell 4B and a
subsequent letter dated March 15, 2011, which 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. Those limits were replaced by a freeboard limit for Cell 4B that will accommodate the
2
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
Cell
Maximum
Wastewater Elevation
Measured During the
Quarter (fmsl)
Maximum
Wastewater Elevation
Permitted Under
License Condition
10.3 (fmsl)
Maximum
Wastewater
Elevation Permitted
Under Part I.D.2 of
the GWDP (fmsl)
Cell 1 5613.40 5,615.40 5,615.50
Cell 3 Not Measured -
freeboard limit was
removed in Ql 2011
No Limit
(5,602.50*)
No Limit
(5,605.50*)
Cell 4A 5592.05 - freeboard
limit was removed in
Ql 2011.
No Limit
(5,593.74**)
No Limit
(5,595.50**)
Cell 4B 5587.33 5594.60 5597.40
* The Director approved the removal of the Cell 3 freeboard limit 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 Cell 4A to be replaced by a freeboard limit for Cell 4B 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
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 LD. 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
3
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 quarterly
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.l 1 of the GWDP and Section 8.2 of the DMT
Plan, will be included in the 4th quarter 2013 DMT Report.
4.2 Results for the Quarter
In accordance with the requirements described above, 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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage which was resolved within 24 hours with no loss of environmental monitoring
data.
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.
\
4
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 and 2013
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 LD.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 2009 through third quarter
2012, for which validated data is available (see Section 4.3 above), is included as Attachment D.
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 LD.3(e) of the
GWDP. Part LD.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 5,619.02
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The monitoring
results 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.
In the closeout letter for the first quarter 2013 DMT Report, dated July 23, 2013, DRC wrote
"EFRI noted standing water in one of the feedstock storage areas. Language in the report referred
to the standing water as a "small amount." The DRC requests that in future quarterly reports,
EFRI be more complete in quantifying and describing the location of standing water discovered
in feedstock storage areas." To comply with this request, EFRI has attached the Feedstock
Storage Area Maps ("Feedstock Maps") completed during the weekly Feedstock Storage Area
inspections as Attachment H. The Feedstock Maps include the areal extent of any standing water
noted during the weekly inspections. Depths were not specifically recorded on the forms, but
were reported by the inspector to be a maximum depth of 3 inches with most significantly less
than 3 inches. Future weekly inspections will record the maximum depth of any standing water
noted. It is important to note that during the month of September, several heavy rainstorms were
noted and that the monthly rainfall total exceeded 2.57 inches. This rainfall is greater than
5
average and contributed to the higher than normal amount of standing water noted on the
attached maps.
As mentioned above, the Mill experienced several storm events during September 2013, which
culminated in the September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013
of a temporary power outage which was resolved within 24 hours with no loss of environmental
monitoring data.
Following the September 18 storm, the Mill identified that the high volume and velocity of ore
pad runoff ruptured the earthen berms on the south end of the ore pad, carried ore pad soils
beneath the fence, and deposited soils and silt into and along the trench containing the storm
water pipe at the south end of the parking lot. The Mill cleaned up the discharged soils
originating from the ore pad using practices consistent with those used for cleaning up spilled
ores. The earthen berms were noted as being under repair by Mill Environmental Personnel on
the Weekly Ore Storage Pad Inspection form, during the September 20, 2013 inspection.
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.
In accordance with Part I.E.7(f) of the GWDP, in the event that any liner defect or damage is
identified during a liner system inspection, the Mill shall immediately implement the currently
approved Liner Maintenance Provisions. Further, Part I.F.2 of the GWDP provides that when a
liner repair is performed at any tailings cell or at Roberts Pond, a Repair Report shall be prepared
and included with the next quarterly DMT report.
During Mill personnel inspection of the Cell 1 liner system during the afternoon of September
20, 2013, it was observed that two erosion channels, one on the east dike and one on the central
area of the north dike, were present in the protective soil cover due to heavy rainfall received
during that week. Sufficient soil cover was removed 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 flexible membrane liner ("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. Specific details regarding the timeline of events
surrounding the Cell 1 liner inspections and discovery of damage are included in the 5-day
Notice to DRC included as Attachment B to this report.
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. EFRI provided the Utah Division of Radiation Control a 5-day
6
notification letter dated September 24, 2013. The September 24, 2013 letter 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 1 Liner System on September 20, 2013, and repairs were completed by
September 24, 2013.
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.
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 following submittal of
revisions to the DMT Plan and DRC observation of hydrostatic testing of the in-ground water
holding tanks. 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 in each portal measured during the
quarter.
7
Table 2 - New Decontamination Pad Inspection Portal Level for the Quarter
Date
Portal 1
Liquid Level
(in Feet)
Portal 2
Liquid Level
(in Feet)
Portal 3
Liquid Level
(in Feet)
7/5/2013
7/12/2013
7/19/2013
7/26/2013
8/2/2013
8/9/2013
8/16/2013
8/23/2013
8/30/2013
9/6/2013
9/13/2013
9/20/2013
9/27/2013
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
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
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 2013
annual inspections was reported in the Second Quarter DMT report submitted August 20, 2013.
The 2014 annual inspection will be conducted during the second quarter of 2014.
8.3 Annual Inspection of New Decontamination Pad
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 20, 2013. The 2014 annual inspection will be conducted during
the second quarter of 2014.
8
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report 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 both 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.
Cell 4A
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.8(a)(l)oftheGWDP.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage which was resolved within 24 hours with no loss of environmental monitoring
data.
Cell 4B
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.12(a)(l)oftheGWDP.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage which was resolved within 24 hours with no loss of environmental monitoring
data.
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 measurements of 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 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
9
[27.36 inches] above the LDS system transducer), as stipulated by Part LE.8(a)(2) of the GWDP.
During the quarter, the fluid head in the Cell 4A LDS sump did not exceed 13.5 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 LE. 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 Cell 4B sump did not record a positive value which equates to no
fluid in the LDS.
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS
The measurements of the volume of fluids pumped are provided in Attachment F.
Cell 4A
As can be seen from a review of Attachment F, 12,320 gallons of fluid were pumped from the
Cell 4A LDS for the third quarter of 2013. Accordingly, the average daily LDS flow volume in
Cell 4A did not exceed 24,160 gallons/day, as stipulated by Part LE.8(a)(3) of the GWDP.
The 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 that
approved the use of Cell 4B, and a subsequent letter dated March 15, 2011, stated approval of the
DMT and Cell 4A O&M Plans, which 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 are
documented 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 36.5 feet, the allowable flow rate would be approximately 604.0
gallons/acre/day (24,160 gallons/day for the cell), as determined by Table IA of the Mill's Cell
4A and 4B BAT Operations and Maintenance Plan, 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, a total of
12,320 gallons of fluid were pumped from the Cell 4A LDS during the quarter and did not
exceed the calculated flow volume. The allowable flow rate calculation for the quarter for Cell
4A along with Table 1A is included in Attachment F of this report.
Cell 4B
As can be seen from a review of Attachment F, no fluids were pumped from the Cell 4B LDS for
the first quarter of 2013 and the flowrate is therefore below the 26,145 gallons/day limit, as
stipulated by Part LE. 12(a)(3) of the GWDP.
10
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 by Table IB of the Mill's Cell 4A and 4B BAT Operations and Maintenance Plan,
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 quarter, no fluids were pumped from the Cell 4B LDS. The allowable flow
rate calculation for the quarter for Cell 4B is included along with Table IB 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 at this time pursuant
to Part I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING
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, and not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP. Hence it 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.
Celll
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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
11
power outage, which was resolved within 24 hours with no loss of environmental monitoring
data.
Cell 2
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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage, which was resolved within 24 hours with no loss of environmental monitoring
data.
Cell 3
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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage, which was resolved within 24 hours with no loss of environmental monitoring
data.
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 in the Cell 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 LF.l 1 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 document was prepared by Energy Fuels Resources (USA) Inc. on November 25, 2013.
Energy Fuels Resources (USA) Inc.
By:
Frank Filas, P.E
Vice President, Permitting and Environmental Affairs
13
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 complete. I am aware that there are significant penalties for submitting false information,
including theppssibiljXv of fine and imprisonment for knowing violations.
Frank Filas, P.E
Vice President, Permitting and Environmental Affairs
Energy Fuels Resources (USA) Inc.
14
November 25, 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
303 974 2140
www .energyfuels.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 3rd 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 3rd 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].
~::;;~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
J o Ann Tischler
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
3rd Quarter
July through September
2013
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
November 25, 2013
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... l
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED ....................................................... !
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 .... .' ................................................................................ .-.................................. ,4
4.3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION ................................. : .................................. ,4
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 ................. 5
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ................................................................ 6
8.0 DECONTAMINATIONPADS .................................................................................................................... 7
8.1 SUMMARY OF WEEKLY INSPECTIONS ........................................................................................................... 7
8.2 ANNUAL INSPECTION OF EXISTING DECO NT AM INA TION PAD ....................................................................... 8
8.3 ANNUAL INSPECTION OF NEW DECO NT AM INA TION PAD ........................................... ., ................................. 8
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT ......................................... 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 Pumped from the LDS.~ ............................................ ,,_ .............. 10
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4B ................................................. 11
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING ........................................................................................... 11
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING ................................................................................. ll
10.1 OPERATIONAL STATUS OFLDS 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
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... l2
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2013 .. 12
12.0 SIGNATURE AND CERTIFICATION .................................................................................................... 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 Part I.G.3 of the GWDP
C Quarterly Cell2 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.l2)
H Weekly Feedstock Inspection Form-Feedstock Maps
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 3rd QUARTER OF 2013
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the third 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, the following DMT monitoring was performed or addressed, as required
under Part I.D.3, I.E.7, and I.F.11 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 Cell2 (Part I.D.3(b)(l) and (2));
• Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.11);
• 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(t) and Parts I.E.?( d); and
(e));
• Any tailings cell and pond liner system repairs (Part I.E.7 (t) and Part I.E.(8)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g)) and
• Annual Decontamination Pad Concrete Inspection (Part I.F.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 I.E.8.(a)), and Cell
4B (Part I.E.12 (a)); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.8 (a))
and Cell 4B (Part I.E.12 (a)).
1
3.0 WEEKLY 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 Cell4A were eliminated as documented on March 14 and 15, 2011 respectively. The
freeboard limits established by the GWDP and the Mill's State of Utah Radioactive Materials
License No. UT 1900479 (the "License") are slightly different; accordingly, the stricter of the
two limits represents the regulatory standard for each cell. As indicated in Table 1, the applicable
freeboard limits were not exceeded during the Quarter for any cell.
All cells met the maximum wastewater criteria of 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.
A letter from the Director dated January 27, 2011 which approved the use of Cell 4B and a
subsequent letter dated March 15, 2011, which 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. Those limits were replaced by a freeboard limit for Cell 4B that will accommodate the
2
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 I.D.2 of
10.3 (fmsl) the GWDP (fmsl)
Celli 5613.40 5,615.40 5,615.50
Cell3 Not Measured-No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in Q 1 2011
Ce114A 5592.05 -freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Ql 2011.
Cell4B 5587.33 5594.60 5597.40
* The Director approved the removal of the Cell 3 freeboard hmit and authonzed the use of Cell 4 B on January 27,
2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
**The Director granted a variance from the Cell4A 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 Cell4A to be replaced by a freeboard limit for Cell 4B 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 )(1) 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
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
3
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
Cell2 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 Cell 4A and Cell 4B BAT Peiformance 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.
4.2 Results for the Quarter
In accordance with the requirements described above, 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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage which was resolved within 24 hours with no loss of environmental monitoring
data.
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.
4
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 and 2013
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 2009 through third quarter
2012, for which validated data is available (see Section 4.3 above), is included as Attachment D.
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 5,619.02
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The monitoring
results 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.
In the closeout letter for the first quarter 2013 DMT Report, dated July 23, 2013, DRC wrote
"EFRI noted standing water in one of the feedstock storage areas. Language in the report referred
to the standing water as a "small amount." The DRC requests that in future quarterly reports,
EFRI be more complete in quantifying and describing the location of standing water discovered
in feedstock storage areas." To comply with this request, EFRI has attached the Feedstock
Storage Area Maps ("Feedstock Maps") completed during the weekly Feedstock Storage Area
inspections as Attachment H. The Feedstock Maps include the areal extent of any standing water
noted during the weekly inspections. Depths were not specifically recorded on the forms, but
were reported by the inspector to be a maximum depth of 3 inches with most significantly less
than 3 inches. Future weekly inspections will record the maximum depth of any standing water
noted. It is important to note that during the month of September, several heavy rainstorms were
noted and that the monthly rainfall total exceeded 2.57 inches. This rainfall is greater than
5
average and contributed to the higher than normal amount of standing water noted on the
attached maps.
As mentioned above, the Mill experienced several storm events during September 2013, which
culminated in the September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013
of a temporary power outage which was resolved within 24 hours with no loss of environmental
monitoring data.
Following the September 18 storm, the Mill identified that the high volume and velocity of ore
pad runoff ruptured the earthen berms on the south end of the ore pad, carried ore pad soils
beneath the fence, and deposited soils and silt into and along the trench containing the storm
water pipe at the south end of the parking lot. The Mill cleaned up the discharged soils
originating from the ore pad using practices consistent with those used for cleaning up spilled
ores. The earthen berms were noted as being under repair by Mill Environmental Personnel on
the Weekly Ore Storage Pad Inspection form, during the September 20, 2013 inspection.
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.
In accordance with Part I.E.7(f) of the GWDP, in the event that any liner defect or damage is
identified during a liner system inspection, the Mill shall immediately implement the currently
approved Liner Maintenance Provisions. Further, Part I.F.2 of the GWDP provides that when a
liner repair is performed at any tailings cell or at Roberts Pond, a Repair Report shall be prepared
and included with the next quarterly DMT report.
During Mill personnel inspection of the Cell 1 liner system during the afternoon of September
20, 2013, it was observed that two erosion channels, one on the east dike and one on the central
area of the north dike, were present in the protective soil cover due to heavy rainfall received
during that week. Sufficient soil cover was removed 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 flexible membrane liner ("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. Specific details regarding the timeline of events
surrounding the Cell 1 liner inspections and discovery of damage are included in the 5-day
Notice to DRC included as Attachment B to this report.
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. EFRI provided the Utah Division of Radiation Control a 5-day
6
notification letter dated September 24, 2013. The September 24, 2013 letter 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 1 Liner System on September 20, 2013, and repairs were completed by
September 24,2013.
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.
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 following submittal of
revisions to the DMT Plan and DRC observation of hydrostatic testing of the in-ground water
holding tanks. 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 m each portal measured during the
quarter.
7
Table 2-New Decontamination Pad Inspection Portal Level for the Quarter
Portal I Portal2 Portal3
Liquid Level Liquid Level Liquid Level
Date (in_ Feet) (in Feet) (in Feet)
7/5/2013 0.00 0.00 0.00
7112/2013 0.00 0.00 0.00
7119/2013 0.00 0.00 0.00
7/26/2013 0.00 0.00 0.00
8/2/2013 0.00 0.00 0.00
8/9/2013 0.00 0.00 0.00
8116/2013 0.00 0.00 0.00
8/23/2013 0.00 0.00 0.00
8/30/2013 0.00 0.00 0.00
9/6/2013 0.00 0.00 0.00
9113/2013 0.00 0.00 0.00
9/20/2013 0.00 0.00 0.00
9/27/2013 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
As required by Part I.F .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 2013
annual inspections was reported in the Second Quarter DMT report submitted August 20, 2013.
The 2014 annual inspection will be conducted during the second quarter of 2014.
8.3 Annual Inspection of New Decontamination Pad
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 20, 2013. The 2014 annual inspection will be conducted during
the second quarter of 2014.
8
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report 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 both 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 that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.8(a)(l) of the GWDP.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage which was resolved within 24 hours with no loss of environmental monitoring
data.
Cell4B
During the quarter, there were no failures of any pumping or monitoring equipment that were not
repaired and made fully operational within 24-hours of discovery, as contemplated by Part
I.E.l2(a)(l) of the GWDP.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage which was resolved within 24 hours with no loss of environmental monitoring
data.
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 measurements of 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 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
9
[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 13.5 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 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 Pumped from the LDS
The measurements of the volume of fluids pumped are provided in Attachment F.
Cell4A
As can be seen from a review of Attachment F, 12,320 gallons of fluid were pumped from the
Cell 4A LDS for the third quarter of 2013. Accordingly, the average daily LDS flow volume in
Cell4A did not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the GWDP.
The 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 that
approved the use of Cell4B, and a subsequent letter dated March 15, 2011, stated approval of the
DMT and Cell 4A O&M Plans, which effectively eliminated the former freeboard elevation
requirements for tailings Cell4A. Pursuant to the receipt of the March 15, 2011 letter, freeboard
limits in Cell 4A were no longer required. However, the weekly wastewater elevations are
documented 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 36.5 feet, the allowable flow rate would be approximately 604.0
gallons/acre/day (24,160 gallons/day for the cell), as determined by Table 1A of the Mill's Cell
4A and 4B BAT Operations and Maintenance Plan, 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, a total of
12,320 gallons of fluid were pumped from the Cell 4A LDS during the quarter and did not
exceed the calculated flow volume. The allowable flow rate calculation for the quarter for Cell
4A along with Table 1A is included in Attachment F of this report.
Cell4B
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 flowrate is therefore below the 26,145 gallons/day limit, as
stipulated by Part I.E.12(a)(3) of the GWDP.
10
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 by Table 1B of the Mill's Cell4A and 4B BAT Operations and Maintenance Plan,
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 quarter, no fluids were pumped from the Cell4B LDS. The allowable flow
rate calculation for the quarter for Cell 4B is included along with Table 1B 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 at this time pursuant
to Part I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING
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, and not a DMT performance monitoring standard required by Parts
I.D.3 or I.E.7 of the GWDP. Hence it 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.
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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
11
power outage, which was resolved within 24 hours with no loss of environmental monitoring
data.
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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage, which was resolved within 24 hours with no loss of environmental monitoring
data.
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.
The Mill experienced several storm events during September 2013, which culminated in the
September 18 rain and hailstorm. EFRI alerted DRC on September 19, 2013 of a temporary
power outage, which was resolved within 24 hours with no loss of environmental monitoring
data.
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 in the Cell 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.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 document was prepared by Energy Fuels Resources (USA) Inc. on November 25,2013.
Frank Filas, P.E
Vice President, Permitting and Environmental Affairs
13
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 complete. I am aware that there are significant penalties for submitting false information,
including the . ibili of fi ne and imprisonment for knowing violations.
Frank Filas, P.E
Vice President, Permitting and Environmental Affairs
Energy Fuels Resources (USA) Inc.
14
Attachment A
Date Celll Cell3 1 Cell4A 2 Cell4B 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
7/5/2013 5613.40 No Longer Required 5591.56 5587.33 DRY
7/12/2013 5613.33 No Longer Required 5591.33 5587.26 DRY
7/19/2013 5613.23 No Longer Required 5591.30 5587.10 DRY
7/26/2013 5613.24 No Longer Required 5591.16 5587.08 DRY
8/2/2013 5613.24 No Longer Required 5591.13 5586.88 DRY
8/9/2013 5613.18 No Longer Required 5591.14 5586.86 5616.79
8/16/2013 5612.97 No Longer Required 5591.12 5586.55 5617.05
8/23/2013 5612.92 No Longer Required 5591.18 5586.57 5617.72
8/30/2013 5612.94 No Longer Required 5591.46 5586.61 5617.99
9/6/2013 5612.80 No Longer Required 5591.57 5586.48 5618.05
9113/2013 5612.82 No Longer Required 5591.79 5586.47 5618.35
9/20/2013 5612.96 No Longer Required 5592.02 5586.49 5619.02
9/27/2013 5612.95 No Longer Required 5592.05 5586.42 5617.67
1Cell 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, 2011letters 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 Cell 4A 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 Ce114B at this time.
Attachment B
-e
VIA EMAIL AND OVERNIGHT DELIVERY
September 24, 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
303 974 2140
www.energyfuels.com
Re: State of Utah Ground Water Discharge Permit ("GWDP") 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 1liner 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 1.G.3 of the Mill's GWDP requires that:
•J
"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\Cell1 5 day notice hail damage 09.18.13\Cell1 hail damage notice 09.24.13.doc
Letter to Rusty Lundberg
September 24, 2013
Page 2 of 4
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 1 '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
expo'sed 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 3:00PM 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,
2013.
If you have any questions, please contact me at [phone].
Yours very truly,
(_
\ /) / //. I
)tf._f..::.[v 1.c ~~~4---r__./(CCt , __
I
ENERGY FUELS RESOURCES (USA) INC.
J o 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
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Dates: 9/17/13-9/23/13
Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
9/17/13 9/18/13 9/19/13 9/20/13 9/21/13 9/22/13 9/23/13
700 34.45 27.30 25.10 24.21 23.40 22.60
800 33.50 27.20 25.07 24.16 22.25
900 32.94 27.10 25.03 24.12 22.25
1000 32.48 26.99 24.99 24.08 22.25
1100 31.94 26.84 24.95 24.05
1200 31.50 26.69 24.90 24.01
1300 31.20 26.54 24.85 23.97
1400 30.82 26.41 24.81 23.95
1500 30.42 26.29 24.75 23.93
Comments: Final reading for the quarter is 22.25
Attachment D
n tl) --N
(/') --· 3
tl)
(/)
c ..,
OJ -· ::::s
I
N
0
0 \D ...
N
0 .....
0 ...
N 0 ..... ..... ...
N
0 .....
N ...
20
N
0 ..... w
+ Vl ro :::::!. ro Vl N
c
:::l ro Q) ....
Ul ro :::::! • ro Vl ~
N ""' 0 0
Feet Below Top of Standpipe
N N 1-' 1-' 1-'
N 0 00 en ""' 0 0 0 0 0 0 0 0 0 0
1/30/2009
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
7/31/2013
Attachment E
WHITE MESA MILL
REPAIR REPORT
CELL 1
November 2013
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill - Repair Report, Cell 1
WHITE MESA MILL
REPAIR REPORT
CELLl
TABLE OF CONTENTS
Page 2 of 12
1. INTRODUCTION .................................................................................................................. 3
2. INCIDENT HISTORY AND CHRONOLOGY ..................................................................... 4
3. REP AIR NARRATIVE ......................................................................................................... 5
4. REP AIR MATERIAL TYPE AND DESCRIPTION ............................................................. 5
5. POST-REPAIR TEST SPECIFICATIONS AND TEST METHODS ................................... 6
6. DAILY REPORTS DURING THE REPAIR WORK ........................................................... 6
7. REPAIR TEST RESULTS/QUALITY ASSURANCE/QUALITY CONTROL. .................. 6
8. CONCLUSIONS .................................................................................................................... 7
9. CERTIFICATION .................................................................................................................. 8
Appendix 1
Appendix 2
Appendix 3
Appendix 4
APPENDICES
DRC and EFRI Letters and Correspondence
Liner Repair Daily Reports
Liner Maintenance Provisions
Photographs
White Mesa Mill -Repair Report, Cell 1 Page 3 of 12
1. INTRODUCTION
Energy Fuels Resources (USA) Inc. ("EFRI"), operates the White Mesa Mill (the "Mill") Tailings
Cell 1 as the Mill's primary liquid evaporation basin. Performance standards, monitoring and
maintenance requirements for Tailings Cell 1 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, ifEFRI 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 (Appendix 3), 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 1 Flexible Membrane Liner ("FML") on September 201h through
September 261h, 2013, as discussed below. As a result of those repairs, this Cell 1 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 I.F.2 ofthe 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 I.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 third quarter of 2013. This Repair
Report has been included with the third quarter 2013 DMT Report, being submitted on or before Dec
1, 2013.
Due to Senate Bill21 of the 2012 Utah Legislative Session, references to the Executive Secretary of
White Mesa Mill -Repair Report, Cell 1 Page 4 of 12
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 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 1 '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 rainstonnfhailstorms 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. Photographs of the damage can be seen in
Appendix 4.
White Mesa Mill -Repair Report, Cell 1 Page 5 of12
• All damage identified on the Cell 1liner occurred above the Cell 1 solution level of 5615.40
feet.
EFRI provided written notice on September 24th, 2013 (provided in Appendix 1). Repair of the
damaged liner occurred on September 20th through September 26th' 2013 with testing occurring on
September 23rd and 26th.
3. REPAIR NARRATIVE
Cell 1 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 1 FML occurred on September 20th through September 26th as described in the
daily liner repairs 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,
• Vacuum testing of each installed repair patch, and
• Replacement and/or regluing and retesting of repaired areas where 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 acetone. 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 Appendix 2 of this 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 and materials:
• soapy water solution
• vacuum check sheets
• vacuum testing equipment (vacuum box) consistent with ASTM Standard D5461.
White Mesa Mill -Repair Report, Cell I Page 6 of 12
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 polyvinyl chloride ("PVC") liner material
• PVC to PVC adhesive glue
• acetone 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
was greater, until the entire seam was tested. Per D5461, 4 to 8 pounds per square inch ("psi")
vacuum was applied to each seam and checked 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 tests were repeated.
Specifically, the regulated pressure to the vacuum box was maintained at 15 pounds per square inch
guage ("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.
White Mesa Mill -Repair Report, Cell 1 Page 7 of 12
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 1 liner repair activities were observed by Utah Registered Professional Engineer Steve
Snyder.
EFRI believes that the Cell 1 liner repairs have been performed consistent with the required Liner
Maintenance Provisions.
White Mesa Mill-Repair Report, Cell l Page 8 of12
9. CERTIFICATION
I, Steve Snyder, a Utah Registered Professional Engineer, inspected the repair site on Cell 1 and
personally discussed the repairs with maintenance personnel. I discussed foundation preparation
activities, liner patch placement, cleaning and seaming of the liner, and vacuum box testing ofthe
repaired seams.
I also reviewed the daily records and documentation of the work conducted. Based upon the daily
records and documentation, all of the work was performed in good workman like manner, and the
repairs were completed in accordance with industry standard practices. The vacuum box testing was
being conducted in accordance with the manufacturer's recommendations and in general agreement
wi . I certify that the work was conducted in accordance with the White Mesa Mill's
· ~ 'liit~h~ · visions Revision 1, dated October 18, 2009. o«..···· ···.~~ ~~/ .... ~
i No. 5049193·2202~ ~~-. -~STEVE R. SNYDER;
\ Steve-~ tyder, Utah Registered Professional Engineer No. 5049193-2202 . . . . . . . .· ·.. .. ~'"-<~rtof=· \}~"'-<-
White Mesa Mill -Repair Report, Cell I
APPENDIX 1
LETTERS AND CORRESPONDENCE
REGARDING
CELL 1 LINER REPAIRS
Page 9 of 12
VIA EMAIL AND OVERNIGHT DELIVERY
September 24, 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
303 974 2140
www.energyfuels.com
Re: State of Utah Ground Water Discharge Permit ("GWDP") 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.t) and 1.0.3 of the White Mesa Mill's (the "Mill's")
OWDP No. UOW370004 that Energy Fuels Resources (USA) Inc. ("EFRI") identified and
repaired damage to the tailings Cell !liner system, as described in more detail below.
1. Facts and Background Information
1.1 Regulatory Background
Part I.E.7.t) of the Mill's OWDP 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 1.0.3 by implementation of the currently approved Liner
Maintenance Provisions, and 2) report all repairs made pursuant to Part I.F.2."
Part 1.0.3 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 of 4
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 1 '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 of4
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 ofthe storm event.
2. Action Taken
The Mill took the following actions:
• Corporate Environmental Management was notified of the liner damage at
approximately 3:00PM 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-sl0ughing of the proteetive soil cove-r 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 of4
• 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,
2013.
If you have any questions, please contact me at [phone].
Yours very truly,
9u2L< t_/ &'-
ENERGY FUELS REsOURCES (USA) INC.
J o 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
White Mesa Mill -Repair Report, Cell 1 Page 10 of 12
APPENDIX2
LINER REPAIR DAILY REPORTS
Cell# Cell #1
Date: _September 20th -26th . 2013
Start Time: 7:00am
End Time: 5:30pm
Liner Repair Report
Linear feet exposed for inspection: Minimum of 12"x 12" to Max of 75"x75"
Description of damage or clear of any defects:
Slope on North side 5 areas where repair was needed!
Description of the repair work utilized to repair the damage:
Middle portion of liner.
Material used to complete the repairs:
Acetone (cleaner)
Wire Brush
Paint Brushes
Repair Material-(describe in detail):
PVC Liner, Acetone and Glue.
Weather Conditions:
*54 Degrees in the Morning.
*67 Degrees midafternoon.
Personnel performing the repair work:
*PVC Liner Repair Crew-Noah and Truit.
*Vacuum Testers-Noah and Truit.
Vacuum Checks if conducted: Conducted Vacuum Checks. See Below.
Notes: Reached the proper cure times and all vacuum tests passed!
9 Vacuum Tests-23rd 2013. 75"x58",
1) 40 hg.
2) 40 hg.
3) 40 hg.
4) 40 hg.
5) 40 hg.
6) 40 hg.
7) 40 hg.
8) 40 hg.
9) 40 hg.
4 Vacuum Tests-23rd 2013. 15"x16"
1) 40 hg.
2) 40 hg.
3) 40 hg.
4) 40 hg.
4 Vacuum Tests-23rd 2013. 9.5"x9.5"
1) 40 hg.
2) 40 hg.
3) 40 hg.
4) 40 hg.
6 Vacuum Tests-23nt 2013. 3l"x13"
1) 40 hg.
2) 40 hg.
3) 40 hg.
4) 40 hg.
5) 40 hg.
6) 40 hg.
4 Vacuum Tests-26th 2013. 13.5"x15"
1) 40 hg.
2) 40 hg.
3) 40 hg.
4) 40 hg.
NOTE: All testing of the repaired material will be in compliance with ASTM D5641
White Mesa Mill -Repair Report, Cell 1 Page 11 of 12
APPENDIX3
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 pe1forming 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 l, 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(1) 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 Pa1t
I.G.3.(c) of the Permit).
Repair Repmt
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
White Mesa Mill -Repair Report, Cell 1
APPENDIX4
PHOTOGRAPHS
Page 12 of 12
Attachment F
July 2013
Date
7/5/2013
7/12/2013
7/19/2013
7/26/2013
Cell 4A LOS Monitoring Information
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
2.5
8.0
8.5
8.9
Flow Meter in Gallons
303540
303540
303540
303540
Highest level for the month based on the daily data was 13.5 inches and the lowest level for the month
was 2.5 inches. Total number of gallons pumped was 3699.
August 2013
Date
8/2/2013
8/9/2013
8/16/2013
8/23/2013
8/30/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
9.8
5.9
6.8
5.6
10.1
Flow Meter in Gallons
303540
307257
308650
308650
308650
Highest level for the month based on the daily data was 13.5 inches and the lowest level for the month
was 3.4 inches. Total number of gallons pumped was 5110.
September 2013
Date
9/6/2013
9/13/2013
9/20/2013
9/27/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
7.1
9.7
9.3
9.5
Flow Meter in Gallons
308650
308650
308650
312161
Highest level for the month based on the daily data was 12.5 inches and the lowest level for the month
was 3.9 inches. Total number of gallons pumped was 3511.
For the 3rd Quarter 2013, the highest level was 13.5 inches and the lowest level was 2.5 inches and
12,320 gallons were pumped.
Cell 48 LOS Monitoring Information
July 2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
Date sump. Flow Meter in Gallons
7/5/2013 -0.29 118
7/12/2013 -0.29 118
7/19/2013 -0.29 118
7/26/2013 -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.
August2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
Date sump. Flow Meter in Gallons
8/2/2013 -0.29 118
8/9/2013 -0.29 118
8/16/2013 -0.29 118
8/23/2013 -0.29 118
8/30/2013 -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.
September 2013
Date
9/6/2013
9/13/2013
9/20/2013
9/27/2013
Weekly measurements in
inches from transducer at
the bottom of the LDS
sump.
-0.29
-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 -0.29 inches. No gallons were pumped.
For the 3rd Quarter 2013, the highest level was -0.29 inches and the lowest level was -0.29 inches
and no gallons were pumped.
Max head on Ceii4A FML
Max elevation (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-Q3 2013
5592.05
5555.55
36.5
604.0
40
24160
Max head on Ceii4B 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-Q3 2013
5587.33
5557.50
29.83
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 !-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 Cell 4A) or Table
1B (for Cell4B) 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 1A or lB) X Acres of Tailings Cell Fluids=
Maximum Daily Allowable Flow Volume
&osynttc CDnsultrlnts Table 1A
C. leu fated Action Le1kqe Rita for Ylrfoul Head Conditions
Cei14A, White Mesa Mill
Blandlns, Utah
Head Above Uner CilcUllt8d Acllan I.Hir ........
System (feet) (plani/ICN/dly)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
TflblelB
calculated Action Leakase Rates for Various Head CondltTons
Ceii4B, White MeN Mill
Blandin& Utah
Held Move uner System Cllcullted Action LuJcqe Rite
(flit) (llrtons/ICfl/dayJ
5 211.4
10 317.0
15 369.9
zo 422.7
25 475.6
30 528.4
35 570.0
37 581.2
I
Cell 1, Cell 2, and Cell 3 LOS Monitoring Information -Third Quarter 2013
Cell1 Cell2 Cell3
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.
7/5/2013 Dry 7/5/2013 Dry 7/5/2013 Dry
7/12/2013 Dry 7/12/2013 Dry 7/12/2013 Dry
7/19/2013 Dry 7/19/2013 Dry 7/19/2013 Dry
7/26/2013 Dry 7/26/2013 Dry 7/26/2013 Dry I
Cell1 Cell2 Cell3
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.
8/2/2013 Dry 8/2/2013 Dry 8/2/2013 Dry
8/9/2013 Dry 8/9/2013 Dry 8/9/2013 Dry
8/16/2013 Dry 8/16/2013 Dry 8/16/2013 Dry
8/23/2013 Dry 8/23/2013 Dry 8/23/2013 Dry
8/30/2013 Dry 8/30/2013 Dry 8/30/2013 Dry
Cell1 Cell2 Cell3
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 LOS sump. bottom of the LOS sump.
9/6/2013 Dry 9/6/2013 Dry 9/6/2013 Dry
9/13/2013 Dry 9/13/2013 Dry 9/13/2013 Dry
9/20/2013 Dry 9/20/2013 Dry 9/20/2013 Dry
9/27/2013 Dry 9/27/2013 Dry 9/27/2013 Dry
-
Attachment G
This attachment has been deliberately left blank.
Attachment H
White Mesa Mill-Discharge Minimization Technology Monitoring Plan
N
t
7112 Revision: Denison 12.1
Page 24 of26
E:\Mill SOP Master Copy\Boolc ll_Environmental Procedures\07 License Renewal\DMT Plan .July 2012 Rev 12 !.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
(
N
1
\
\ I
,f"
.-·
7/1 2 Revision: Denison 12.1
Page 24 of26
' l ~ i ,
I \ I \
) I
E:\Mill SOP Master Copy\Book II_Environmental Procedures\07 License Renewai\DMT Plan July 2012 Rev 12 !.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
/ .J
(
...... _ ~
N
t
7/12 Revision: Denison 12.1
Page 24 of26
r ; (.
\
(
E:\Mill SOP Master Copy\Book ll_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 l.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
N
t
-__ ..... .,... ...
7/12 Revision: Denison12. l
Page 24 of26
1 l~t/).3_
I I
1.·
E:\Mill SOP Master Copy\Book !!_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 I .doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
'· J , .
./ ,
' ( .j
·~/' --~ -,. e ... I,
...
N
t
7/12 Revision: Denisonl2.1
Page 24 of26
. 7 !.~ll/.3_ -
J I 'I I
\ J
I •. r ,•
E:\Mill SOP Master Copy\Book II_Environmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 I .uoc
i
\Vhite Mesa Mill -Discharge Minimization Technology Ivlonitoring Plan
' ' . ~...... . ~.t 'r ·~ •
-· ,.
··.
(
,.
\
l.f'x u • t \
I ' ~
o' f G '1-/0 I I
D f-l.)} I
• II \1
I • /j_l I ' I ~ r
I (
)
.....
N
'
..
7/12 Revision: Denison12.1
Page 24 of26
: : { I . . ,
; <
) .
.,
I ~z.'
'
·~ f
,·
'
'· I '
·~,~-J~:~!..J.:_~.1
i --h-..
E:\Mill SOP Mnster Copy\Bool< II_Hnvironmental Procedures\07 License Renewa!\DMT Plan July 2012 Rev 12 l.doc
\Vhite Mesa Mill -Discharge Minimization Technology Monitoring Plan
..
.I
.. •
t .... 1
··~-. J
I .. -
I ·'
N
, .
7112 Revision: Denison12.1
Page24 of26
' I
. ! . 'I
-·
E:\iV.ill SOP Master Copy\Book ll_Fnvironrnental Procedures\07 License Renewai\DMT Plan July 2012 Rev 12 !.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
\ .
-·
N
1
,.
( .
i ,. .. ' ,.
·( J ... .
! 1 ... \ l ... ~."--' .
I ' ..
7/12 Revision: Denison 12.l
Page 24 of26
l :·.
E:\Mill SOP Master Copy\Boolc ll_Envitonmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 !.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
.... -· ·--..
'-' > I
(t
,/ ,. .-.;
, . \ (
1.1 ~j_. .... \
N
t
•'
7/12 Revision: Denison12.l
Page 24 of26
·1 •
.. O,Jt 8
'1l1o 10!
.. l
)
l
E:\Mill sOl> Muster Copy\Book I URnvironmental Proceclures\07 License Renewai\DMT Plan July 2012 Rev 12 !.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan
. .,.
\ I },· \ " . . r·l(
I I j '
(l'J lb·--, .
·:·.'::J
I ' ..
. . ' t-'-1 ' . .-. )' ./ 'I . c I '·, ' i· i
~ f ::' I i
f{ II (
1\ l ~--... . ..!y j '
' _(, I . 'l
·~; .~ -j~ I I
lt.:..:J ~
r ~f : ' ~ -~~
·" ... ·-··-··'
N
7 /l2 Revision: Denison 12.1
Page 24 of26
.. ,
I ll .' I '
' I' • ~· j• ~,.
I
E:\Mill SOP !\•Jaster Copy\Book ll_F.nvironmental Procedures\07 License Renewal\DMT Plan July 2012 Rev 12 (.doc
White Mesa Mil! -Discharge Minimiz<JI.ion Technology Monitoring Plan
I I
·~--·
l ) . -. o4 ~I -'<>
< ......
N
I
X( ,· i:)
c.\ { .... '; . ; . '
)
... .
-J... .. , -
•, ....
•'
7112 Revision: Denison 12.1
Page 24 of26
~
0
·I
i
. •
E:IMHI SOP J\·la'lter Capyl.8ook l l_f.nvimnmentul Pmccdurcs\07 License Rcncwal\DMT Plan July 2012 Hcv 12 l.doc
White Mesa Mill --Discharge Minimization Technology Monitoring Plan
'
-• .. I '· .-$'v v _. •
.-f *'\.I ~
• "'~L ,,
"--""-L
'
'("" l
~r ~ " '1 ..... -
'Yt. • ~
~ ' ,, ~ ~~
l
' I
.l y • I r ,, -x
j . ' .l )
I
./.' lr;" .. I
~! <.
N
71! 2 Revision: Denison 12.1
Page 24 of26
E:\Mill SOP t'vla.~!.~l CopyYRook II_Bnviromnental Procec!ure~\07 Llcense Renewal\DMT Plan l11ly 2012 R<:Jv 12 !.doc
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 7/12 Revision: Denison12.1
Page 24 of26
I I
I
'(f .
~J
1
·. ) .. .. ,
)
j
! t:J
.
. ! ' ~ I
j f_ f { !
i ,
I
<I ( . . •
\ l
I
'
N 'YHfl!l ~~ ~ -;;:r:-:~~~~~
, l!n•A .. --
. f~rtr.;~:W Stmt(J'J /'(l.'Hlibtl
-!"( ... ~li. . i ~-~ -r-r t..
E:\Mill SOP Master Copy\Boo.lc ll_Environmental Procedures\07 License Renewal\DMT Plan .July 20'12 Rev 12 l.do<:
I
. 'I 1 I t' :. I