DRC-2014-001186 - 0901a068803f7fab

Department of
Environmental Quality
Amanda Smith
Executive Director
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
SPENCER J COX
Lieutenant Governor DRC-2014-001186
MEMORANDUM
THROUGH
TO:
Phil Goble, Section Manager
File C-2013-66
FROM: Russell J. Topham, P.E.
DATE: January 15, 2014
SUBJECT: Engineering Module 75E, DMT/BAT Field Inspection; Radioactive Materials License
Number UT1900479 (RML) and Ground water Discharge Permit UG3 70004 (GWDP).
Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
On November 22, 2013,1 conducted an inspection of the tailings management facilities and office records
pertaining to the operation and maintenance of discharge minimization technology and approved
implementation of best available technologies for the White Mesa uranium mill, Energy Fuels Resources
(USA) Inc. (EFR). The following details my activities, observations and findings.
I arrived at the mill at 7:00 a.m. November 22, 2013 and checked in with David Turk. I was assigned
Garrin Palmer as escort for the inspection. We talked briefly, outlining what I hoped to accomplish. Mr.
Palmer provided me copies of the field report forms used to perform the daily, weekly, monthly and
quarterly monitoring activities associated with the tailings management system. We prosecuted the
inspection by actually performing the daily, monthly and quarterly inspections routinely done at the mill.
During the inspection we accumulated data on the forms. Returning to the office, we performed
calculations and comparisons to detect trends and uncover anomalies or violations. During both the field
inspection and the data analysis, I queried Mr. Palmer about what he was looking for and why. He seemed
to know what the various data bits represented and the significance of the variances we looked for during
the analysis. When additional personnel were required for portions of the data collection, I queried those
individuals as well, with similar results.
Finding: All forms specified in the Discharge Minimization Technology Plan, revision 12.1, dated June
2012 were provided. The provided forms also match those provided as attachments to the quarterly DMT
reports.
Finding: Field personnel appear to understand the significance of the data and to take care to provide
accurate, comprehensive records.
Items evaluated include:
1. Tailings slurry transport system (pertains to Cells 1, 2,3,4A, 4B)
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 • T D D [phone]
www deq utah gov
Printed on 100% recycled paper
Page 2
a. Slurry pipeline - leaks, damage, blockage, sharp mends
b. Pipeline joints - leaks, loose
c. Pipeline supports - damage, loss of support
d. Valves - leaks, blocked, closed
e. Points of discharge - location and orientation
2. Operational systems and interior of cells (pertains to Cells 1, 2, 3,4A, 4B)
a. Interior cell walls: liner - visible damage
b. Fluid level
i. Elevation ~ exceeding design/approved operating level, calculate head over FML
ii. Significant change
iii. Highest beach elevation (Cell 4B had no beach visible during inspection)
c. Tailings beach - cracks, severe erosion, subsidence (Cells 3, 4A), estimates of beach and
pool areas
d. Cover - erosion, exposure of liner (Cells 1, 2, 3)
3. Dikes and embankments (pertains to Cells 4A, 4B)
a. Slopes - soughs, sliding, cracks, bulging, subsidence, severe erosion, moist areas, areas of
seepage outbreak
b. Crest - subsidence, severe erosion
4. Flow rates - slurry lines (entire length, discharge point), pond return, solution extraction tailings,
spray system
5. Dust control (Cells 2, 3, 4A, 4B) - dusting, wind movement of tailings, inches of precipitation,
meteorological conditions (The inspection occurred in the rain, so no fugitive dust was
identifiable.)
6. Leak detection system (Cells 1, 2, 3,4A, 4B) - wet/dry, initial/final level, gallons pumped
7. Slimes drain (Cell 2)
a. Pump function
b. Post- and pre-pump fluid levels
c. Volume pumped
8. New Decontamination Pad (3 portals)
a. Portal wet/dry; if wet, record fluid level. (Dry at time of inspection)
9. Diversion ditches and berms (3 ditches, 1 berm)
a. Ditches - sloughing, erosion, undesirable vegetation (obstruction), other obstruction of
flow
b. Berm - stability, signs of distress
10. Settlement monitors - signs of disturbance, read elevations, analyze for excessive settlement
11. Lateral movement monitors - signs of disturbance
12. In addition to the above, all of which were checked during the inspection, the forms ask about any
construction activities that took place, anything unusual observed, or any other concerns, as well as
notes of items that need attention.
Page 3
Finding: During inspection we detected no items requiring attention.
In a follow-up inspection to the 2012 BAT inspection, I identified a pair of issues to check during the 2013
inspection. Those are discussed below.
Minor rill erosion on exterior dikes of Cells 4A and 4B
The following is quoted from the March 30, 2013 Memorandum detailing follow-through to the
September, 2012 BAT inspection:
Finding: Minor rill erosion was noted on the embankments forming the containment dikes along
the south side of Cells 4A and 4B [during the September 12,2012 inspection]. I was informed that
the bulldozer used for grooming these side slopes was down for repair, and mill personnel claimed
the Mill had no funds to complete the repair [at the time of the inspection].
Recommendation: Groom the exterior side slopes of the Cells 4A and 4B containment dikes to
eliminate rill erosion before it progresses to a point that it endangers the stability of the dikes.
EFR has obtained a new bulldozer. During my March 7, 2013 site visit, I noted that the exterior
side slopes of Cells 4A and 4B had been groomed, eliminating all signs of erosion.
During 2013, the plant experienced several heavy rain events that impacted the exterior dikes, as reported
by plant personnel. During my November, 22, 2013 inspection, I noted that these issues of rill erosion had
been addressed. EFR had groomed slopes on the exterior of Cells 4A and 4B, as well as all other areas
where rill erosion could impact the facility. It appears that plant personnel had been transparent about the
problem of not having the right equipment to groom the slopes, since the grooming has taken place as
needed since acquisition of the new piece of equipment.
Placement of movement monitors on south side of Cell 4A
The following is quoted from the March 30, 2013 Memorandum detailing follow-through to the
September, 2012 BAT inspection:
Finding: Several movement monitors in the roadway at the top of the Cell 4A containment dike
may have been disturbed during grading activities. The placement of these monitors in the center
of the roadway makes them vulnerable to such disturbance.
Recommendation: Set movement monuments on the outer shoulder of the cell, as was done for
Cell 4B.
David Turk indicated to me that he now had funding to relocate the movement monitors. EFR will
include movement of the monitor points to the inside shoulder of the dike, inside the fence, during
the annual movement monitor survey in May.
During the routine annual survey of the movement monitors, the monitors in question were moved to the
| interior edge of the containment dike, against the fence. Operators report that maintenance is much eaqsier
without having to dodge the movement monitors.