DRC-2014-003361 - 0901a068810a8e82

May 13,2014
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 1st Quarter of 2014
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 1st Quarter of 2014, as required under Parts
I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at [phone] or
Mr. David Turk at [phone].
Yours very truly
'f~Ji;~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
Harold R. Roberts
David E. Turk
JoAnn Tischler
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
1st Quarter
January through March
2014
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
May 13,2014
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................................... 1
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 ................................................................................................. 4
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ........................................... .4
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 ................................................................ S
8.0 DECONTAMINATION PADS .................................................................................................................... 6
8.1 SUMMARY OF WEEKLY INSPECTIONS ........................................................................................................... 6
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ....................................................................... 7
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD .............................................................................. 7
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT ......................................... 7
9.1 LDS MONITORING ........................................................................................................................................ 7
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ........................................................... 7
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary FML ................................... 8
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS ................................................................. 8
9.2 MEASUREMENTOFWEEKLYWASTEWATER FLUIDS IN CELLS 4AAND4B ................................................... 9
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING ............................................................................................. 9
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING ................................................................................... 9
10.1 OPERATIONAL STATUS OF LDS PUMPING AND MONITORING EQUIPMENT ................................................. 1 0
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ...................................... , ................ 10
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1, 2, AND 3 ................................ , ................ 10
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... 10
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2014 .. 10
12.0 QUARTERLY PRECIPITATION DATA ................................................................................................ ll
13.0 SIGNATURE AND CERTIFICATION .................................................................................................... 12
LIST OF TABLES
Table 1-Summary of Waste Water Pool Elevations (In the Text)
Table 2-New Decontamination Pad Inspection Portal Level (In the Text)
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 Cell 4A and Cell 4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables lA and lB, Cell4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.l2)
H Weekly Feedstock Inspection Form-Feedstock Maps
I Quarterly Precipitation Data
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 1st QUARTER OF 2014
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the first quarter of 2014 (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.ll 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.ll);
• 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(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.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 Cell4B (Part I.E.12 (a)).
Attachments E and G have been left blank because there were no liner repair reports or annual
decontamination pad inspections this quarter.
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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 Cell 4A were eliminated. 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 Cell 4A LDS and are collected for this purpose. 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.
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 (fms1) the GWDP (fmsl)
Cel11 5613.24 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 5592.65 -freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Q1 2011.
Cell4B 5586.15 5594.60 5597.40
* The Dtrector approved the removal of the Cell 3 freeboard hmtt and authonzed 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 Cell4A 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 Cell4B that will accommodate
the freeboard requirements of Cells 1, 4A, and 4B.
2
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 I.D.13(c) of the GWDP provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4B, the Permittee will provide: 1)
continuous declining fluid heads in the slimes drain layer in a manner equivalent to the
requirements found in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as
measured from the lowest point of the upper FML) in 5.5 years or less.
The GWDP, dated July 14, 2011, Part I.D.3 (b)(2) states "effective July 11, 2011, the Permittee
shall conduct a quarterly slimes drain recovery test. .. ". Monthly testing was conducted through
the second quarter of 2011. The frequency change dictated by the GWDP was implemented in
the third quarter 2011. The test ensures that each tailings cell meets the following minimum
requirements: 1) includes a duration of at least 90-hours, as measured from the time that
pumping ceases, and 2) achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements with no change in water level, as measured
to the nearest 0.01 foot.
At this time, dewatering operations have not commenced in Cell 3, Cell 4A, or Cell 4B. As a
result, the requirements in Part I.E.7(b) to monitor and record monthly the depth to wastewater in
the slimes drain access pipes as described in Part I.D.3 of the GWDP apply only to Cell 2 at this
time. Accordingly, this Report is limited to slimes drain recovery head information relating to
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 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 ofPart I.F.ll of the GWDP and Section 8.2 of the DMT
Plan, was submitted with the fourth quarter 2013 report.
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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.
As noted in the 4th Quarter 2013 DMT Report, in November 2013, the Cell 2 slimes drain
pumping equipment was replaced as part of routine maintenance. No significant equipment
issues were noted prior to the replacement and no data losses were recorded, however, the
equipment is replaced to prevent future problems from occurring due to the corrosive nature of
the slimes.
During the routine maintenance/replacement of the Cell 2 slimes drain equipment in November
2013, piping modifications to the Cell 2 slimes drain were also completed. Verbal notification
was provided to DRC in November 2013 while the modifications were in progress. DRC
requested a written update of the modifications. Neither the verbal nor written notification, were
required by the Tailings Management System program applicable to Cell 2, or by the RML or
GWDP. The verbal notification in November 2013 and the written notification submitted to
DRC on February 18, 2014, are provided for information purposes only. The February 18, 2014
notification is included in Attachment B of this report. The modification is described in detail in
the notification letter included in Attachment B.
4.3 Quality Assurance Evaluation and Data Validation
EFRI management has evaluated all slimes drain data collected, data collection methods, and all
related calculations required by the GWDP, and have verified the accuracy and reliability of both
the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, EFRI has concluded
that the 2009, and 2010 monthly slimes drain tailings fluid elevation measurements, the 2011
monthly (through June) and quarterly (July forward), and the quarterly 2012, 2013, and 2014
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 the current 2014
period 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
4
OWDP. Part I.D.3(e) of the OWDP 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 5,619.23
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 OWDP 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
OWDP. 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 (in feet) and depth
(in inches) of any standing water noted during the weekly inspections.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, 3, 4A, and 4B were inspected on a daily basis. The results of
those inspections are recorded on the Mill's Daily Inspection Data sheets, which are available at
the Mill for review. A visual inspection of Roberts Pond was performed on a weekly basis. The
results of those inspections are recorded on the Weekly Mill Inspection forms, which are
available at the Mill for review.
Mill operations notified the EFRI Quality Assurance Manager on Thursday, March 13, 2014, of
a tear in the FML of Roberts Pond. The damage in the FML of Roberts Pond was identified,
during routine operations, apart from routine inspections. EFRI provided initial notification to
the DRC by telephone at approximately 2:45pm on Thursday, March 13, 2014, as contemplated
by Parts I.E.7 f) and 1.0.3 of the Permit. Additionally, EFRI provided 5-day written notification
to DRC contemplated by Parts I.E.7 f) and 1.0.3 of the Permit on March 18, 2014. The written
notification is included in Attachment B.
Mill staffing was increased by 12 for manual removal of the sediments in Roberts Pond to allow
for a thorough inspection of the liner in Roberts Pond. Initially, sediment removal was
completed using only hand equipment to prevent further liner damage in anticipation of repairing
5
the liner currently in place. EFRI Management subsequently determined that the liner currently
in place is not salvageable and mechanical sediment removal using a long-arm bucket excavator
was employed. Additional liner system damage discovered during the sediment removal has
been documented. Existing damage caused by the 2012 clean out activities was documented.
New damage resulting from the use of a long-arm bucket excavator in 2014 was also
documented. Newly caused damage was not included when estimating the seepage volume. The
seepage volume estimates are included in the Roberts Pond Action Plan submitted to DRC on
May 12, 2014.
The Action Plan describes the proposed procedures for remediation of any impacted soils
resulting from the liner damage. The Action Plan was submitted to DRC on May 12, 2014.
EFRI will implement the Action Plan after approval by DRC. In summary, the Roberts Pond
Liner System will be removed. The soils underneath the liner will be visually inspected for
staining or other indications that they were impacted by the solutions. Visually stained soils will
be removed. Following the removal of the stained soils, cleanup procedures using gamma
measurements and uranium analyses will be completed to the levels specified in the Action Plan.
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. Table 2 below indicates the water level measurements in each portal measured during
the quarter.
Table 2-New Decontamination Pad Inspection Portal Level for the Quarter
Portal1 Portal2 Portal 3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
1/3114 0.00 0.00 0.00
1110/14 0.00 0.00 0.00
1117/14 0.00 0.00 0.00
1/24114 0.00 0.00 0.00
1/31114 0.00 0.00 0.00
217114 0.00 0.00 0.00
2/14114 0.00 0.00 0.00
2/21114 0.00 0.00 0.00
2/28114 0.00 0.00 0.00
317/14 0.00 0.00 0.00
3/14/14 0.00 0.00 0.00
6
3/21114 0.00 0.00 0.00
3/28/14 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.
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.
7
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.12(a)(l) of the GWDP.
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
[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 13.4 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 Cell 4B LDS sump did not exceed 2.22 inches above the LDS
transducer.
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, 13,508 gallons of fluid were pumped from the
Cell 4A LDS for the quarter. Accordingly, the average daily LDS flow volume in Cell 4A 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, 2011letter, 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, in accordance with
8
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 37.10 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 Cell4A did not exceed
the calculated flow volume of 24,160 gallons/day. As mentioned above, a total of 13,508 gallons
of fluid were pumped from the Cell 4A LDS during the quarter and did not exceed the calculated
maximum allowable daily 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.
Celi4B
As can be seen from a review of Attachment F, no fluids were pumped from the Cell 4B LDS for
the quarter and the flowrate is therefore below the 26,145 gallons/day limit, as stipulated by Part
I.E.12(a)(3) of the GWDP.
Based on the wastewater pool elevation surveys conducted during the quarter, the maximum
head recorded on the FML during the quarter was 28.65 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 lB 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 the 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 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.l(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. However, 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. The Cells 1, 2, and 3 LDS monitoring data are included
in Attachment F.
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10.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell 1, Cell 2, and Cell 3, including,
but not limited to, the submersible pump, pump controller, head monitoring, and flow meter
equipment, operated continuously during the quarter except as noted below.
For Cell 1, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 2, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24 hours of discovery.
For Cell 3, during the quarter, there were no failures of any pumping or monitoring equipment
not repaired and made fully operational within 24-hours of discovery.
10.2 Measurement of the Volume of Fluids Pumped from the LDS
No fluids were pumped from the Cells 1, 2 or 3 LDSs during the quarter because no fluids were
detected in the Cells 1, 2 or Cell 3 LDSs.
10.3 Measurement of Weekly Wastewater Fluids in Cells 1, 2, and 3
A summary of the fluid elevations for the Cells 1, 2 and 3 LDSs for the quarter are provided in
Attachment F. The LDS for Cells 1, 2, and 3 were dry during the quarter.
10.4 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping 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 2014
The annual slimes drain recovery head report for Cell 2 for calendar year 2014 (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 2014 DMT report which will be submitted on or before March 1,
2015.
10
12.0 Quarterly Precipitation Data
Pursuant to a verbal request from DRC personnel, EFRI is providing the quarterly precipitation
data in the quarterly DMT reports. The data are collected at the Mill, by the EFRI Field Staff,
using an on-site rain gauge. The data are included as Attachment I to this report.
11
13.0 SIGNATURE AND CERTIFICATION
This document was prepared by Energy Fuels Resources (USA) Inc. on May 13,2014.
Energy Fuels Resources (USA) Inc.
By:
Frank Filas, P.E
Vice President, Permitting and Environmental Affairs
12
CERTlFICATION:
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 possibility off and imprisonment for knowing violations.
j
Frank Filas, P,E
Vice President, Permitting and Environmental Affairs
Energy Fuels Resources (USA) Inc.
13
Attachment A
Date Celll Cell3 1 Ce114A 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
113/2014 5613.22 No Longer Required 5592.27 5586.11 5619.23
1/10/2014 5613.23 No Longer Required 5592.41 5586.04 5617.11
1/17/2014 5613.22 No Longer Required 5592.49 5586.04 5617.18
1/24/2014 5613.14 No Longer Required 5592.49 5586.01 5617.16
113112014 5613.20 No Longer Required 5592.65 5585.99 5617.14
2/7/2014 5613.21 No Longer Required 5592.55 5586.05 5617.56
2/14/2014 5613.06 No Longer Required 5592.52 5586.12 5617.50
2/2112014 5613.21 No Longer Required 5592.36 5586.10 5617.49
2/28/2014 5613.13 No Longer Required 5592.33 5586.14 5617.72
317/2014 5613.24 No Longer Required 5592.34 5586.15 5617.19
3/14/2014 5613.07 No Longer Required 5592.31 5586.00 DRY
3/21/2014 5613.01 No Longer Required 5592.31 5585.97 DRY
3/28/2014 5612.89 No Longer Required 5592.33 5585.91 DRY
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 ofthe Cell4A limit and the use of Cell4B on January 27, 2011. The weekly measurements are no longer required for
compliance with freeboard limts, but are required for the calculation of the daily allowable volume of fluids pumped from the 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 Cell4B at this time.
Attachment B
February 21, 2014
VIA EMAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Director
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Re: Modifications to Cell2 Slimes Drain Piping, White Mesa Mill
Dear Mr. Lundberg:
This letter provides Energy Fuels Resources (USA) Inc.'s ("EFRI's") follow-up to our discussion
with Mr. Phil Goble of the Utah Division of Radiation Control's ("DRC"') during a meeting on
November 12, 2013, regarding piping modifications to the Cell 2 slimes drain system at White
Mesa Mill (the Mill"). The modifications were in progress at the time of the November 2013
meeting and were completed on December 19, 2013. Neither the verbal update on November 12,
2013 nor this letter, were required by the Tailings Management System program applicable to Cell
2, or by the Mill's Radioactive Materials License or Groundwater Discharge Permit. This letter is
being provided to DRC for information purposes only.
Background
As discussed in EFRI's letter of January 28, 2013, which addressed effects of the abnormally extended
low temperatures of December 2012 and January 2013, the Mill identified that the Cell 2 slimes drain
transfer line underwent recurrent freezing. The transfer line "freezing" appears to be due to a
combination of low temperatures, and deposition of precipitates ("scaling") which resulted from the
supersaturated condition of the slimes drain solution, as discussed below.
The Cell 2 slimes drain solutions are transferred via a pump from the Cell 2 slimes drain sump
which discharges through a 4-inch high density polyethylene ("HDPE") pipeline to the northern
edge of Cell 4A. The pipeline extends more than 300 feet with very little grade. Specifically, the
line drops 10 inches in elevation over the dike from Cell 2 to Cell 3, and has no change in elevation
for the remainder of its length. Prior to December 19, 2012, the slimes drain pipeline was above
ground atop the dikes and/or sands of Cell 2 and Cell 3, discharging into Cell 4A near the dike of
Cell4A.
N:\WMM\Cell 2\Cell2 Slimes Drain\2 21 14 Ltr toR Lundberg Cell 2 Slimes Drain Upgrade.doc
Letter to R. Lundberg
February 21, 2014
Page 2 of3
As discussed in the January 28, 2013 letter, during the initial December 2012 period of cold weather,
the Cell slimes drain transfer line to Cell4A became frozen on December 17,2012. Mill personnel
thawed the line with heating torches and returned it to service during December 18 and 19, 2012.
On December 19, 2012, Mill personnel buried the horizontal sections of pipe in 12 inches of borrow
soil atop Cell 3 to insulate the line against potential future freezing weather.
The Mill experienced another extended period of abnormally cold weather beginning on December
19, 2012. During the evening of December 19, 2012, the Cell 2 slimes drain transfer pipeline froze a
second time, even though it had been buried in 12 inches of soil. It remained frozen through January
3, 2013 despite additional efforts to thaw the line with heating torches during that period. EFRI
successfully thawed the discharge pipeline and returned the slimes drain pumping system to service
on January 7, 2013.
Mill personnel advised EFRI management that because the slimes drain line had frozen while it was
buried under a 12 inch insulating layer of cover soil, temperature was not the only factor
contributing to the line plugging problem. EFRI has concluded that scaling due to the super-
saturation (high dissolved and/or suspended solids concentration) of the slimes drain solution also
contributed to plugging of the line.
Cause of Line Plugging
The Cell 2 slimes drain transfer pump operates on a float system which turns the transfer pump on
when sufficient fluid has accumulated in the slimes drain collection area in the cell. As a result, the
pump and transfer line experience intermittent, not constant, flow. The pump operates at 20 gallons
per minute for the few hours per month it needs to pump the accumulated slimes. During most of
the year, and during typical winters, the intermittent flow is sufficient to prevent freezing of the 4-
inch transfer line. However, during the multiple cycles when the pump is off and the discharge line
is full but not flowing, the shallow overall grade prevents residual fluids from draining completely.
During these conditions, fluids remaining in the line have the opportunity to precipitate excess
solutes and/or suspended material, and produce scaling along the length of the pipeline.
Alternatives Evaluated
EFRI has evaluated two additional measures, in addition to the 12-inch soil cover insulation
discussed above, to prevent future freezing or plugging of the slimes drain discharge line.
1. A backup transfer procedure involving pumping the Cell 2 slimes drain fluids a shorter
distance to exposed tailings sands areas in Cell 3, could be used during severely cold weather
conditions. The shorter length of transfer line may permit easier thawing and maintenance of
slimes drain fluid flow. This option was identified in EFRI's letter of January 28, 2013.
2
Letter to R. Lundberg
February 21, 2014
Page 3 of 3
2. An additional volume of makeup water could be supplied to the slimes drain line to dissolve
the salts, minerals, or other solids that have contributed to scaling and plugging of the slimes
drain during periods of low or no flow.
Because Cell 3 is undergoing pre-closure steps and the Mill is actively reducing the remaining
liquid pool areas, EFRI has not chosen to transfer additional fluids from the Cell 2 slimes drain to
Cell 3 at this time. EFRI selected option 2, installation of a system to add makeup water to the
slimes drain line to dissolve the excess solids and keep the line flushed.
Modifications Installed
The Mill has installed a 2-inch water makeup line from groundwater chloroform pumping well
TW4-24, located at the southeast corner of Cell 1 which ties in to the Cell 2 slimes drain system.
The TW4-24 well pump operates on a delay device which turns the pump on once every two hours
for a period of twenty minutes. The TW4-24 2-inch HDPE PVC discharge line has been tied into
the Cell 2 slimes drain discharge line approximately 10 feet south of the slimes drain sump, near
the southern dike of Cell 2, and provides 18.1 gallons per minute of flow during the period that the
pump is on. This flow is frequent enough and of sufficient rate to flush and clear the slimes drain
line of scale-forming salts or solids. A check valve installed in the 2-inch makeup water line is
designed to prevent any potential backflow of fluids from the slimes drain line to the groundwater
pump discharge line. A plan view drawing of the TW4-24 transfer line and slimes drain transfer
line, and a labeled photograph showing pipeline connection details, are provided in the attachments
to this letter.
As mentioned earlier, the information above is not required by the Mill's Tailings Management
System program, but is being provided for information purposes. Please contact me if you have any
questions.
Yours very truly,
7(~/h~
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Philip Goble, Utah DRC
Dan Hillsten
Harold R. Roberts
Russ Topham, Utah DRC
David E. Turk
Attachments
3
ATIACHMENT 1
Cell 2 Piping Revisions
Legend + T\1\14-24 (Chloroform Pumping Well) + Cell 2 Slimes Drain
---~-----Water Supply Line from T\N4-24
---Cell 2 Slimes Drain Discharge Line
Notes:
·1. The Water Supply Line from TV\11!-24 is a 2-inch
HOPE pipe and is buried approximately 2 feet
below grade within the tailings cover. The Cell 2
Slimes Drain Discharge Line is 4-inch HOPE Pipe.
2. IW4-24 is programmed to pump for twenty minutes
every tvvo hours. The flow rate while pumping is
approximately ·1s gallons per minute.
3. The water from TW4-24 is used to reduce the
dissolved solids concentration in the Cell 2 Slimes
Drain Discharge to Cell 4A This will help to prevent
scaling within the pipeline and lead to better flow
characteristics and reliability.
Yl IJ;
5 300 150 0 300 600
SCi\LE IN FEET
W Energy Puels F~esources (USA) Inc.
REVISIO~IS Pro]ccl-White Mesa Mill
State: Utoh
Cell 2 Slimes Drain Discharge
I Installation of TW4-24 Dilution Pipeline
w: \uso\utah\mill\mopping\cell 2 slimes drain.dwg letter! rellls
Resources (USA) fnc.
White Mesa Mill
County: Son Juan late; Utah
l.OCaUOil: C,;ll 2
Cell 2 Slimes Drain
Pipeline Connection Detail
1\tJJh.r RE all!: 1/27/14
March 18, 2014
VIA PDF AND EXPRESS DELIVERY
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Deprutment of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Deru· Mr. Lundberg:
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Re: Utah Ground Water Discharge Permit No. UGW3700004
White Mesa Uranium Mill-Notice Pursuant to Parts I.E.7 0 and I.G.3 of the
Permit
Please take notice pursuant to Parts I.E.7 f) and I.G.3 of the White Mesa Mill's (the "Mill's")
State of Utah Groundwater Discharge Permit No. UGW370004 (the "Permit"), that Energy Fuels
Resources (USA) Inc. ("EFRI"), as operator of the Mill and holder of the Permit, identified and
will repair damage to the Roberts Pond Liner System as described in more detail below.
Mill operations notified the EFRI Quality Assurance Manager on Thursday, March 13, 2014 at
12:30 pm, of liner damage to Roberts Pond that was noted, during routine operations, apart from
routine inspections. Photographs are included as Attachment 1 to this letter. EFRI provided
initial verbal notification to the Division of Radiation Control ("DRC") of the liner damage by
telephone at approximately 2:45pm on Thursday March 13, 2014, as contemplated by Parts I.E.7
f) and I.G.3 of the Permit.
1. Facts and Background Information
a) Part I.E.7 f) of the Permit requires that the licensee conduct daily inspections for each
of the tailings cells and weekly inspections of Roberts Pond. According to Part I.E.7
f):
"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."
b) Although Part l.G.3 of the Permit is stated to apply to circumstances where the
Permittee fails to maintain Discharge Minimization Technology ("DMT") or Best
Letter to Rusty Lundberg
March 18, 2014
Page 2
Available Technology ("BAT") standards, Part I.E. 7 f) requires that the notification
provisions of Part I.G.3 also apply to liner defects or damage, regardless of whether or
not the liner defect or damage constitutes a failure of DMT or BAT. Under Part I.G.3,
the Permittee is required to submit to the Director a notification and description of the
defect or damage orally within 24-hours of the Permittee's discovery, followed by
written notification within five calendar days.
c) The liner damage was identified, at 12:30 pm during routine operations, on March 13,
2014, apart from a liner maintenance inspection. The damage incident occurred as a
result of maintenance activities, when Roberts Pond was in empty condition during the
planned maintenance outage in July 2012.
d) Roberts Pond was empty and out of service in June 2012 for routine maintenance and
preparation for Mill startup. Roberts Pond underwent cleanout of accumulated
sediment during the month of July 2012. The long-arm bucket excavator used for
solids removal created a tear in the flexible membrane liner ("FML") of Roberts Pond
at approximately 1:30pm on July 5, 2012. Reference is made to the EFRI letter dated
August 6, 2012. Roberts Pond was empty at the time of the July 2012 incident, and
remained empty, due to the maintenance outage until August 2012.
e) Repairs to the liner were performed and completed during the weeks of July 5 and July
12, 2012, in accordance with the Mill's Liner Maintenance Provisions. The Mill
returned Roberts Pond to service during the week of August 6, 2012, and it received
process fluids, as necessary, thereafter.
f) EFRI estimates that the liner damage in March 2014 most likely was caused by heavy
equipment contact with the liner itself during the July 2012 maintenance outage or was
a result of stresses to the liner caused by the maintenance activities in July 2012. The
July 2012 maintenance activities are believed to be the source of the liner damage
because no other maintenance activities, involving the use of heavy equipment, have
been performed in the interim.
g) The liner damage or liner stress was not noted at the time of the July 2012 maintenance
outage because residual sediments, several inches thick, were left in place by the heavy
equipment used during the July 2012 maintenance activities.
h) The weekly liner inspections and freeboard measurements specified by the GWDP were
conducted as required. The weekly inspections did not note the liner damage due lo
the residual sediments left after the 2012 maintenance activities and because additional
sediments have accumulated during use.
Letter to Rusty Lundberg
March 18, 2014
Page 3
i) As contemplated by Parts I.E.7 f) and I.G.3 of the Permit, EFRI provided notification to
Mr. Thomas Rushing of DRC at 2:45 pm and again to Mr. Russ Topham at 3:35 pm on
March 13, 2014, within 24 hours of the Quality Assurance Manager receiving
information from Mill personnel regarding the incident.
j) This Notice constitutes the 5-day written notice contemplated by Parts I.E.7 f) and I.G.3
of the Permit.
2. Actions Taken
Upon receipt of the initial identification, the Mill's Environmental Coordinator notified the Mill
Manager immediately. The following plan of action was immediately put into place:
a) Pumping of residual fluids in Roberts Pond was immediately implemented.
b) Mill staffing was increased by 12 for manual removal (by means of hand shovels) of
the sediments in Roberts Pond to complete a thorough inspection of the liner in Roberts
Pond.
c) EFRI will develop an Action Plan to address any impacted soils that may be present
beneath the liner. The Action Plan will be submitted to DRC on or before April 8,
2014 after the sediments have been removed and a complete and thorough inspection
of the liner has been completed.
3. Actions That Will be Taken to Prevent a Reoccurrence of this Incident
Actions to prevent recurrence of this incident were delineated in the EFRI letter dated August 6,
2012 relating to the July 2012 tear. The actions specified in the August 6, 2012letter are still in
effect and have not changed since the time of issuance of the August 6, 2012 letter. The
maintenance activities that resulted in the action have not been repeated since 2012 and as such
the actions to prevent recurrence are still valid. The actions taken to prevent recurrence are
reiterated below.
The following actions taken to prevent a reoccurrence of this incident delineated in the August 6,
2012letter are:
a) The Mill will perform cleanouts of Roberts Pond on a more frequent basis, to minimize
the volume of solids accumulated, and reduce the size of equipment needed for solids
removal.
b) If heavy equipment is required for solids removal from Roberts Pond, the Mill will use
equipment smaller than the long-arm bucket excavator used in July 2012, where
possible.
Letter to Rusty Lundberg
March 18, 2014
Page4
c) A repair report and further documentation of the repairs will be submitted to the
Director with the quarterly DMT Report following the incident, as discussed in Section
4, below.
4. Required Reporting
As required by Part l.F.2 of the permit and by the Mill's Liner Maintenance Provisions, a repair
report will be submitted to the Director with the next quarterly DMT Report folJowing
completion of the repairs and implementation of the action plan. Repairs are planned to be
completed during the second quarter of 2014. The repair report will be submitted with the
second quarter 2014 DMT Report on or before September 1, 2014. The repair report will contain
the following elements:
• 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 or other)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
5. Affirmative Defense
EFRI does not believe that identification of a defect or damage to the Roberts Pond liner caused
by maintenance activities constitutes a failure of DMT under the Permit. With respect to the liner
damage, the damage was not intentional and we believe it was not negligent. Further, EFRI has
taken adequate measures, has an adequate plan and schedule for meeting GWDP requirements.
Please contact me if you have any additional questions or require any further information.
+!-~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Dan Hillsten
Harold R. Roberts
David E. Turk
Attachment 1
Roberts Pond Liner Damage Photographs
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 3/14/2014 -3/20/2014
Slimes Cell# 2
Sampler: Garrin Palmer
Tanner Holliday
3/14/14 3/15/14 3/16/14 3/17/14 3/18/14 3/19/14 3/20/14
700 35.28 24.51 23.73 23.52 23.05
800 34.01 24.45 23.72 23.51 23.00
900 33.07 24.37 23.70 23.49 23.00
1000 32.24 24.31 23.68 23.47 23.00
1100 31.73 24.24 23.67 23.47
1200 31.30 24.18 23.66 23.45
1300 30.98 27.10 25.54 24.12 23.65 23.41
1400 30.65 24.06 23.64 23.37
1500 30.32 23.97 23.62 23.34
Comment Final reading for the quarter is 23.00.
Attachment D
n It) --N
(/\ --· 3
It)
"' c
""' Ql -· ::::J
I
N 0
0
\D ...
N
0 ~ 0 ...
N
0
~
~ ...
N 0 ~ N ...
20
N 0 ~ w
Vl C1)
""' (i)"
"' N
c:
::J C1)
QJ
""' Vl C1)
""' (i)"
"' N -
N
""" 0 0
Feet Below Top of Standpipe
N N 0 0
N 0 0 0
1-' 00
0 0
1-' 0"\ 0 0
1-'
""" 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
9/30/2013
11/30/2013
1/31/2014
Attachment E
Th is attachment has been deliberately left blank.
Attachment F
Cell 4A LOS Monitoring Information
January 2014
Weekly
measurements in
inches from transducer
at the bottom of the
Date LOS sump. Flow Meter in Gallons
1/3/2014 9.2 318404
1/10/2014 11.9 318404
1/17/2014 8.6 321430
1/24/2014 5.0 323935
1/31/2014 10.1 323935
Highest level for the month based on the daily data was 12.9 inches and the lowest level
for the month was 5.0 inches. Total number of gallons pumped was 5,531.
February 2014
Date
2/7/2014
2/14/2014
2/21/2014
2/28/2014
Weekly
measurements in
inches from transducer
at the bottom of the
LOS sump.
10.9
7.0
8.3
11.9
Flow Meter in Gallons
323935
326541
326541
326541
Highest level for the month based on the daily data was 12.4 inches and the lowest level
for the month was 6.3 inches. Total number of gallons pumped was 2,606.
March 2014
Date
3/7/2014
3/14/2014
3/21/2014
3/28/2014
Weekly
measurements in
inches from transducer
at the bottom of the
LOS sump.
8.7
9.2
9.9
8.7
Flow Meter in Gallons
329243
329243
329243
331912
Highest level for the month based on the daily data was 13.4 inches and the lowest level
for the month was 5.5 inches. Total number of gallons pumped was 5,371.
For the 1st Quarter 2014, the highest level was 13.4 inches and the lowest level was 5.0
inches and 13,508 gallons were pumped.
Cell 48 LOS Monitoring Information
January 2014
Weekly
measurements in
inches from
transducer at the
bottom of the LOS
Date sump. Flow Meter in Gallons
1/3/2014 -0.29 118
1/10/2014 -0.29 118
1/17/2014 -0.29 118
1/24/2014 -0.29 118
1/31/2014 -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.
February 2014
Date
2/7/2014
2/14/2014
2/21/2014
2/28/2014
Weekly
measurements in
inches from
transducer at the
bottom of the LOS
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.
March 2014
Date
3/7/2014
3/14/2014
3/21/2014
3/28/2014
Weekly
measurements in
inches from
transducer at the
bottom of the LOS
sump.
-0.29
0.55
1.38
2.22
Flow Meter in Gallons
118
118
118
118
Highest level for the month based on the daily data was 2.22 inches and the lowest level
for the month was -0.29inches. No gallons were pumped.
For the 1st Quarter 2014, the highest level was 2.22 inches and the lowest level was -
0.29 inches and no gallons were pumped.
~~~~~ ~~~
C.lallated Action Le1kqe Rates for Various Head Conditions
Ceii4A, White Mesa Mill
Blandfns, Utah
Head Above Uner ~ Ad:lon Le-.kap Rate
System (feet) (pUonJ/Icte/Oy)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
Geosyntec CDnsulttlnts Table1B
Calculated Attion Leakage Rates for Various Head Conditions
Ceii4B, White MBH Mill
Blandlna, Utah
Head Move Uner System Cllcullted .Action ltllcqe Rite
(feet) (llflons/acre/day)
5 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
35 570.0
37 581.2
Max head on Ceii4A FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1A (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4A-Q12014
5592.65
5555.55
37.1
604.0
40
24160
Max head on Cell 48 FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 18 (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B-Q12014
5586.15
5557.50
28.65
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 1-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 Cell4A) or Table
1B (for Cell 4B) using the head calculated in Step 1 above. If the head calculated
in step 1 above falls between two values in the Head Above Liner System (feet)
column, then the closer of these two values will be used to determine the
Calculated Action Leakage Rate.
Calculate the acres of tailings cell fluids based on the area of the base of the cell,
the head, and the angle of the sideslopes of the cell.
Action Leakage Rate (from Table lA or lB) X Acres of Tailings Cell Fluids =
Maximum Daily Allowable Flow Volume
Celll, Cell 2, and Cell 3 LOS Monitoring Information -First Quarter 2014
Celll 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.
1/3/2014 Dry 1/3/2014 Dry 1/3/2014 Dry
1/10/2014 Dry 1/10/2014 Dry 1/10/2014 Dry
1/17/2014 Dry 1/17/2014 Dry 1/17/2014 Dry
1/24/2014 Dry 1/24/2014 Dry 1/24/2014 Dry
1/31/2014 Dry 1/31/2014 Dry 1/31/2014 Dry
Celll 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.
2/7/2014 Dry 2/7/2014 Dry 2/7/2014 Dry
2/14/2014 Dry 2/14/2014 Dry 2/14/2014 Dry
2/21/2014 Dry 2/21/2014 Dry 2/21/2014 Dry
2/28/2014 Dry 2/28/2014 Dry 2/28/2014 Dry
Celll 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.
3/7/2014 Dry 3/7/2014 Dry 3/7/2014 Dry
3/14/2014 Dry 3/14/2014 Dry 3/14/2014 Dry
3/21/2014 Dry 3/21/2014 Dry 3/21/2014 Dry
3/28/2014 Dry 3/28/2014 Dry 3/28/2014 Dry
Attachment G
This attachment has been deliberately left blank.
Attachment H
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Attachment I
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014
Rain Snow
1 1-----1-----1
2 1-----1-----1
3 41-----+----i
5 61-----+----i
7 1-----+-----i 8 1-----+----t
9
10 1-----+-----t
1-----+-----1 11 1-----+-----1 12 1-----+----t
13 1------+-----1 14 1------+-------l
15 1-----+-------l 16 L-------'-----J
Combined
Total:
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Month January
Rain Snow
,05
(
1
2
3
4
5
6
7
8
9
10
11
.12
13
14
15
16
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014
Rain Snow
tYL
~o"Z-
Combined
Total:
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Month February
Rain Snow
.,01
.oy
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2014 Month March
Rain Snow Rain Snow
.Z.L. 17
18
19
20
<II 0 (;:, 21
22
23
24
25
26
27
28
29
30
31
Combined
Total: o2.8