DRC-2014-004679 - 0901a06880477fff

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director DRC-2014-004679
SPENCER J. COX
Lieutenant Governor
MEMORANDUM
TO: File C-2014-77
THROUGH Phil Goble, Section Manager
FROM: Russell J. Topham, P.E. / f
DATE: July 11,2014
SUBJECT: Engineering Module 75E, DMT/BAT Field Inspection; Radioactive Materials License
Number UT1900479 (RML) and Ground water Discharge Permit UG370004 (GWDP).
Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
On April 17, 2014,1 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 8:00 a.m. April 17, 2014 and checked in with David Turk. My primary purpose for
visiting the site involved on-site discussions and data gathering with regard to the design of pavement to
cap the area affected by the apparent release of ammonium sulfate (the Nitrate CAP issue) from the
ammonium sulfate crystal tank. The inspection activities described below followed completion of the
Nitrate CAP field assignment.
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. No loss of attention to detail was noted since the previous performance of this
inspection module conducted on November 22, 2013. When additional personnel were required for
portions of the data collection, 1 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 matched those provided as attachments to the quarterly DMT
reports.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Page 2
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)
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
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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.
Finding: During inspection we detected no items requiring attention.