DRC-2014-005761 - 0901a0688049a3a2

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State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2014-005761
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
File C-2014-75
Phil Goble, Section Manager & *V**/zo/C/
Russell J. Topham, P.E.
September 25, 2014
Engineering Module 75C, Review of the 2nd Quarter, 2014 (April-June, 2014) DMT
Performance Standards Monitoring Report and Cell 4A and Cell 4B BAT Performance
Standards Monitoring Report (Report). Groundwater Discharge Permit (GWDP)
UG370004 - Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
This is a summary of Utah Division of Radiation Control (DRC) staff review of the EFR DMT
Performance Monitoring Report and Cell 4A and Cell 4B BA T Performance Standards Monitoring Report
dated July 22, 2014, and covering the 2nd Quarter, 2014 (April-June, 2014) monitoring period (Report).
DRC received the Report on July 28, 2014 in both hard copy and soft copy CD formats. Discussions in this
document reference the White Mesa Mill Discharge Minimization Technology (DMT) Monitoring Plan,
Revision 12.1 (DMT Plan), executed on July 25, 2012.
After review of this report, DRC staff findings and recommendations are as follows:
Findings
1. Weekly monitoring of Cell 1 solution pool elevations occurred as required.
2. The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the DMT/BAT plan in force during the quarter.
3. Data provided in Attachment C to the Report supports a conclusion that EFR has met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
Monitoring results indicate that the feedstock storage areas were dry at the time of weekly
inspections.
4. EFR met the requirements for inspection of the liner systems and appropriately repaired all
detected damage, except for the ongoing work at Roberts Pond. In the case of Roberts Pond, the
repair effort is ongoing, and involves radiological surveys and cleanup of radiological and
chemical releases prior to placing new liner or backfilling the excavation and abandoning the
pond.
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. ulah.gov
Printed on 100% recycled paper
Page 2
5. EFR has met the requirements for inspecting the New Decontamination Pad, finding no indication
of leakage from secondary containment or other indicators of substandard performance.
6. EFR has met the requirements for inspecting the Old Decontamination Pad, finding no indications
of substandard conditions.
7. EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and detected no
failures to meet those standards for the quarter.
8. The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during the 2nd quarter of 2014.
Recommendations
The DRC should issue a closeout letter for the review of this report. The only open issue is Roberts
Pond, which the DRC has been tracking as an independent project.
1.0 Tailings Wastewater Pool Elevation Monitoring and Roberts Pond Solution Level Monitoring
Part I.E.7(a) of the GWDP requires EFR to monitor and record weekly the elevation of the wastewater pool
in Tailings Cells 1 and 3 to ensure compliance with Condition 10.3 of the License. Part I.D.3(e) requires
EFR to operate Roberts Pond to provide a minimum two feet of freeboard at all times. Part 3.1(d) of the
DMT/BAT Plan requires EFR to measure the solution pool elevation in Cells 4A and 4B weekly, and the
tailings beach maximum elevation and area within Cells 4A and 4B monthly.
Tailings have nearly completely filled Cell 3. Recognizing this, letters from the Executive Secretary dated
January 27, 2011 and March 14, 2011 formally eliminated the need for solution pool elevation
measurement in Cell 3. The previously cited January 27, 2011 letter and another letter from the Executive
Secretary dated March 15, 2011 concluded a process ending the need for freeboard-related solution pool
elevation monitoring in Cell 4A. However, Part 3.1(a) of the DMT/BAT Plan requires monitoring solution
pool elevations in Cells 4A and 4B to facilitate determination of compliance with FML leakage rate
limitations.
Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with the
prescribed freeboard requirements.
As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed during
the monitoring period. Attachment A to the report reflects no measurements for the reported quarter.
Attachment A to the Report contains weekly pool elevations for Roberts Pond indicating compliance with
the prescribed freeboard requirements. Note that operators at the mill discovered damage to the Roberts
Pond liner on March 13, 2014, and withdrew all water from the pond at that time to facilitate investigation
and repair. The pond remains empty of fluids at the time of this writing. Crews have removed visual signs
of contamination from the soils beneath the pond. Crews employed gamma measurements as well to
identify hot spots for additional attention. EFR employed a consultant to collect samples at randomly
selected locations. Those samples were split, with one portion going to an independent laboratory and the
other going the EFR's laboratory for analysis. Results of this sampling effort will provide an indication of
the degree of success of the remedial actions taken.
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Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of calculating
acceptable leak rates for the liner system
Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance
with the prescribed freeboard requirements.
Findings: The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the DMT/BA T plan in force during the quarter.
2.0 Slimes Drain Water Level Monitoring
Part 1.F.2 of the GWDP requires EFR to include in the Report, all DMT performance standards monitoring
detailed in Parts I.D.3 and I.E.7 of the GWDP. Part I.D.3(b)(l) of the GWDP requires EFR to maintain the
fluid level in the slimes drain of Cells 2 and 3 as low as reasonably achievable at all times, and to
demonstrate that performance through adherence to the current DMT Monitoring Plan. Part I.E.7(b) of the
GWDP requires monthly monitoring and recording of the depth to wastewater in the slimes drain access
pipe as described in Part I.D.3 of the GWDP and the current DMT Monitoring Plan. Part 3.1(b)(v) of the
DMT Monitoring Plan requires EFR to monitor and record weekly the depth to wastewater in the Cell 2
slimes drain access pipe to determine maximum and minimum head before and after a pumping cycle,
respectively.
Section 4.1 of the Report asserts that the above discussed monitoring requirements only pertain to Cell 2
for the reporting period, as dewatering operations have not commenced in Cell 3. I concur with this
assessment.
Weekly water level monitoring of the Cell 2 slimes drain is not required as part of the DMT plan, but is
required under Part I.D.3(b)( 1) of the GWDP. EFR retains records of Cell 2 slimes drain monitoring at the
mill.
Attachment C to the Report contains data from the quarterly recovery head measurements (discussed in the
next paragraph). The recovery head monitoring data provides indirect evidence that EFR has maintained
the fluid level in the Cell 2 slimes drain as low as reasonably achievable, as required in GWDP, Part
I.D.3(b)(l).
Finding: Data provided in Attachment C to the Report supports a conclusion that EFR has met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
3.0 Feedstock Storage Monitoring
This section addresses both bulk conventional feedstock (ore) and alternate feed stored onsite. Ore is stored
on the ore pad. Part 1 .D. 11 of the GWDP anticipates and governs storage of alternate feed outside the
confines of the ore pad.
Weekly inspection revealed no evidence of ore beyond the boundaries of the ore pad. Storage practices for
alternate feeds appeared compliant with GWDP requirements. No standing water was noted in feedstock
storage areas during the quarter.
Finding. Monitoring of the feedstock storage area occurred as required. The data support a conclusion
that no feedstock existed outside the designated feedstock storage areas.
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4.0 Tailings Cells and Pond Liner System Repairs
Weekly inspection of all cells and of Roberts Pond occurred weekly during the period covered in the
report. The report indicated no case of liner damage in the tailings cells discovered or repaired during the
quarter. However, the 1st Quarter report indicated that crews detected liner damage in Roberts Pond on
March 13, 2014. EFR notified the DRC verbally on March 13, 2014 of the damage, and followed that
notice with a letter on March 18, 2014. The DRC has tracked the remediation associated with that liner
damage as a separate project.
Finding: EFR met the requirements for inspection of the liner.
5.0 Decontamination Pads
Weekly inspection of the New Decontamination Pad occurred as required under Part I.F.I2 of the GWDP.
The monitoring portals were dry during all inspections, indicating no leakage from primary containment.
Annual inspections for both decontamination pads occurred during the second quarter of 2014, resulting in
no requirements for remedial action. EFR performed preventive crack sealing even though no cracks
exceeded the 1/8-inch limit.
Finding- EFR has met the routine and annual requirements for inspecting both the Old and New
Decontamination Pads, finding no indication of leakage from secondary containment.
6.0 Cells 4A and 4B BAT Performance Standards Monitoring
Requirements for measuring BAT performance for Cells 4A and 4B include verifying that leak detection
system equipment operates appropriately, verifying that fluid head in the leak detection system sumps does
not exceed 1 foot above the lowest point in the secondary (lower) flexible membrane liner, and recording
the volume of fluid pumped from the leak detection systems for the two cells. EFR must also record the
fluid head in Cell 4B for compliance purposes, and in Cell 4A for computation of acceptable leakage rate
in Cell 4A. The data provided in the report and its attachments provide evidence of compliance with the
Cells 4A and 4B BAT performance monitoring standards in place during the monitoring period.
Finding: EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and detected no
failures to meet those standards for the quarter.
7.0 Cells 1,2 and 3 Leak Detection System Monitoring
Leak detection system monitoring requirements for Cells 1, 2 and 3 appear in the Radioactive Materials
License rather than the GWDP. For consistency, the DRC requested that this monitoring be included as
part of the quarterly report and EFR has consented to do so.
The report and its attachments contain weekly monitoring data for the operational status of the leak
detection system equipment, fluid levels detected in the leak detection systems, and volumes of fluid
pumped. From the data, EFR represents that no failures of the monitoring equipment occurred that were
not corrected within 24 hours. Leak detection systems for the three cells measured dry; therefore, no fluids
were pumped therefrom.
Finding' The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during the 2ml quarter of 2014.