DRC-2014-001262 - 0901a068803f9cb4

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State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2014-001262
MEMORANDUM
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TO: File C-2013-67
THROUGH: Phil Goble, Section Manager
FROM: Russell J. Topham, P.E.
DATE: January 21, 2014
SUBJECT: Compliance: 2013 Engineering Module 76, Annual Technical Evaluation Report;
Radioactive Materials License UT1900479 (RML): Findings and Closeout
On November 15,2013, the Utah Division of Radiation Control (DRC) received the 2013 Annual
Technical Evaluation Report (ATER) dated November 14, 2013 and covering the November 1, 2012 to
October 31, 2013 monitoring period. DRC received the Report in both hard copy and soft copy CD
formats.
Summary
After review of the ATER, DRC staff findings and recommendations are as follows:
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1. In the review of the ATER for 2012, the DRC noted that movement monitors were located in the J
middle of the roadway at the top of the Cell 4A containment dike. The licensee had the movement
monitors moved to the interior shoulder of the dike, along the fence, during the annual survey.
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2. The DRC should monitor performance of the tailings management system closely as Cell 4A fills,
and Energy Fuels Resources (EFR) closes Cell 3 and begins depositing tailings in Cell 4B,
looking for recurrence of historic problems maintaining freeboard. This comment repeats a
notation in the 2012 ATER review.
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General Requirements
3. Condition 12.3 of the RML requires preparation of the ATER, specifies the content, and fixes the
date by which the DRC must receive the ATER. The Tailings Management System (TMS)
document guides much of the work reviewed and reported in the ATER. EFR used TMS revision
2.1, dated July, 2012 (the most recent revision) in the preparation of the 2013 ATER. The report
as prepared and submitted meets the requirements for content and timeliness.
168 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
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Maintaining Freeboard
4. The 2011 ATER contained detail of instances where EFR failed to maintain appropriate freeboard
in the various cells involved in the TMS. The 2012 and 2013 ATERs contains data showing that
EFR successfully maintained fluid levels without exceeding freeboard during the 2012 and 2013
monitoring periods. Thus, EFR appears to have resolved the problems that historically caused the
fluid level to exceed established limits. As processing of ore and alternate feeds continues, the
tailings beach in Cell 4A expands. Given the problems maintaining freeboard during the 2011
monitoring period, the DRC should monitor freeboard performance closely as Cell 4A fills, and
as EFR retires Cell 3 from actively receiving tailings in favor of Cell 4B.
Monitoring of Lateral Displacement
5. The annual movement monitor survey for Cell 4A reports no disturbed movement monitors,
versus 8 of 28 disturbed monitors reported in 2012. Review of the movement monitor survey for
Cell 4A reveals no disturbed monitor points. The movement monitors were relocated during the
2013 annual survey. The relocation of the monitors occurred after half of the reporting year had
elapsed; thus, the movement of the monitors cannot be the sole cause of the improved
performance. During the DMT inspection conducted November 22, 2013, field crews mentioned
being particularly conscious of the monitors when driving on or grooming the surface of the dike.
Regardless ofthe cause, the monitors were not disturbed during 2013.
Movement monitors for Cell 4B showed no evidence of disturbance. ,