DRC-2014-006785 - 0901a068804bb23e

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DRC-2014-006785 www.energyfuels.com
November 14, 2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") September 23, 2014 Storm
Water Inspection at the White Mesa Mill, Division of Radiation Control ("DRC")
Request for Information ("RFI"), Groundwater Discharge Permit UGW370004
Dear Mr. Lundberg:
This letter responds to DRC's above-named letter dated October 20, 2014, which Energy Fuels
Resources (USA) Inc. ("EFRI") received on October 24, 2014, regarding the DRC storm water
inspection conducted at the White Mesa Mill (the "Mill") on September 23, 2014.
For ease of review, this letter provides each of DRC's comments, in italics, below, followed by
EFRI's response.
Request for Information
DRC Comment
1. DRC noted that large erosion rills were present on the east side of the fueling island (north of
the new decontamination pad) where it was apparent that storm water had flowed east from of
the pad area. The erosion was observed continuing into the vegetated areas beyond the chain-
link fence which delineates the ore pad. This has been an ongoing area of concern per previous
DRC inspections. DRC notes that there is no berm along the margins of the ore storage pad in
this area and the pad is graded to discharge water in a south easterly direction along the eastern
pad margin. Additionally, since there is an existing berm on areas north of the area of concern, a
significant amount of storm water runoff is channeled along the berm (southward) towards the
non bermed area and there is potential for considerable run off out of the fenced area at that
spot. Based on the observed erosion rills, it appears that this was the case previous to the
inspection.
Letter to Rusty Lundberg
November 14, 2014
Page 2 of 7
Per DRC Staff discussion with onsite EFR representatives, it was noted that the area needs
additional erosion and/or sediment controls to ensure that contaminated soil from the ore pad
does not wash out of the restricted area (The restricted area was reported by EFR
Representatives to be bounded by a wire fence about 100 feet east of the chain-link fence). Per
discussion during the inspection close-out meeting it was discussed that DRC would likely issue
a request for information regarding this issue and that EFR would need to provide a proposal
for sediment and/or erosion controls at this ore pad location.
Please provide a response to DRC within 30 calendar days of your receipt of this letter with
proposed sediment and/or erosion controls to be installed at this area of the ore pad (e.g.
continuation of the perimeter berm). Also, please provide a proposed timeline for installation of
the controls.
EFRI Response:
The perimeter berm was extended on the east side of the fueling island and north of the new
decontamination pad on October 3, 2014. Since the berm work has been completed no further
schedule for completion is necessary. Pictures of the completed berm work are included as
Attachment A to this letter.
DRC Comment
2. DRC noted during the inspection that the Roberts Pond Liner had been removed and that
contaminated soils had been removed in anticipation of re-grading the area. The Roberts Pond
excavation (pit) was observed during the inspection. DRC notes that storm water drainage (and
other drainage) from areas of the Mill are directed to discharge where Roberts Pond was in use.
Within 30 days of your receipt of this letter, please provide information regarding how these
discharges will be directed and discharged in the future.
EFRI Response:
The discharges and other drainages that were previously directed to Roberts Pond will be re-
routed to Cell 1. The drainage plans and designs will be finalized during the Roberts Pond
closure activities.
Groundwater Module 65, DRC Annual Storm Water Inspection
Note: Only the Sections of the Inspection Report which require an EFRI response are reproduced
here.
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the
White Mesa Uranium Mill:
Date: September, 2012
Revision No. 1.5
2
Letter to Rusty Lundberg
November 14, 2014
Page 3 of 7
Section I - Document Review
SWBMPP (Documentation Requirements):
Part 4.1.4. — Diversion ditches, drainage channels and surface water control structures in and
around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair,
such as excessive vegetative growth channel erosion or pooling of surface water runoff, will be
reported to appropriate departments and all follow up actions are to be documented.
Findings:
The Utah Division of Radiation Control ("DRC") conducted an inspection of upland Diversion
Ditches 1 and 2; and Diversion Berms 1 and 2 as shown on the Energy Fuels inspected the
outfall locations for Diversion Ditch 1 and 2 to verify the directions of upland drainage (ensure
that drainage is directed to areas distant from the Mill Facility).
DRC found Ditch 1 and berms to be adequately maintained, it was noted that in some areas
there was standing water present, indicating that the ditch was not correctly graded. Photos of
Ditch 1 and the outfall location, taken during the day of the inspection are included the Memo
Appendix 1. DRC notes that storm water entering Ditch 1 is draining toward the west, fans out
onto areas of Dakota/Burro Canyon Fm. Outcrop, and ultimately into the Westwater Creek
Drainage.
DRC found Ditch 2 and berms to be well maintained (Photos included in Appendix 1). Drainage
is towards the north and drained water is diverted to a vegetated area. It was noted that the Mill
property berms are at a higher elevation than the Ditch 2 outfall and water is not expected to run
onto the Mill confines.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DRC reviewed the March 31, 2014 monthly form
and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion Ditches J, 2 and 3
showed no sloughing, erosion, undesirable vegetation or obstructions of flow with the exception
of erosion at Diversion Ditch I. The form notes that "diversion ditches are still in good working
condition. Waiting for plan from Ryan Ellis to make repairs on erosion cfiannels." Per
discussion with David Turk it was noted that an engineering plan was created by Ryan Ellis to
improve drainage from Diversion Ditch 1 due to EFR observations that the ditch was retaining
water in some spots. It was noted that the ditch had been re-graded per the engineering plan but
was still detaining water at some spots. EFR reported that more work would be done to the ditch
to eliminate standing water.
EFRI Response:
The area of Drainage Ditch 1, noted as having standing water during the inspection, will be
addressed through additional excavation/backfilling activities. The grade in the area of concern
3
Letter to Rusty Lundberg
November 14, 2014
Page 4 of 7
in Drainage Ditch 1 will be checked and corrected as necessary based on the results of the field
assessment.
DRC Comment
Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
EFRI Response:
No response required.
DRC Comment
1.9.1. - External Notification of "reportable quantity" spills.
EFRI Response:
No response required.
DRC Comment
1.9.2. Internal Notification of incidents, spills, and significant spills.
EFRI Response:
No response required.
DRC Comment
1.10 Records and Reports
EFRI Response:
No response required.
DRC Comment
1.11 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files)
4
Letter to Rusty Lundberg
November 14, 2014
Page 5 of 7
EFRI Response:
No response required.
DRC Comment
Section II — Site Walk through Inspection
Areas and Observations:
Ore Storage:
Observations: DRC noted that large erosion rills were present on the east side of the fueling island
(north of the new decontamination pad) where storm water had apparently flowed from the pad,
through the chain link fence, and the erosion was observed to continue into the vegetated areas. This
has been an ongoing area of concern per previous years DRC inspections. The area has been a
concern since there is no berm along the margins of the ore storage pad in this area and the pad is
graded to discharge water in a south easterly direction along most of the eastern pad margin.
Additionally, since there is an existing berm on areas north of the area of concern, a significant
amount of storm water runoff is channeled along the berm (southward) towards the non bermed area
and there is potential for considerable run off out of the fenced area at that spot. Based on the
observed erosion rills, it appears that this was the case previous to the inspection.
Per DRC Staff discussion with onsite EFR representatives, it was agreed that the area needs
additional erosion and/or sediment controls to ensure that contaminated soil from the ore pad does
not wash out of the restricted area. DRC is including a request for information for EFR plans to
reduce the potential for offsite drainage from the area of concern.
EFRI Response:
See the response to RFI finding number 1.
DRC Comment
Reagent Yard:
No comments regarding the reagent yard.
EFRI Response:
No response required.
DRC Comment
Shop/Vehicle Maintenance Area:
5
Letter to Rusty Lundberg
November 14, 2014
Page 6 of 7
DRC notes that areas inside of the vehicle maintenance shop and surrounding area were designed to
drain to Roberts Pond. Since the pond has been removed DRC will request information regarding
where these areas will drain in the future.
EFRI Response:
See the response to RFI finding number 2.
DRC Comment
Mill Processing Areas:
SX Building Roof Drainage:
As discussed above, the north end of the SX building roof is designed to drain to pre-existing Roberts
Pond. Since the pond has been removed, DRC will request information regarding the new discharge
location for the drainage.
EFRI Response:
See the response to RFI finding number 2.
DRC Comment
Note: DRC had no comments requiring an EFRI response after inspection of the following areas:
• Alternate Feed Circuit South ofSX Building
• Old Decontamination Pad
• New Decontamination Pad
• Reagent Tanks
o Sodium Chloride Tanks
o Kerosene Tanks (west of the shop)
o Ammonia Tanks
o Used Oil Tank
o Kerosene Tank (shop)
o Fuel Tanks
o Uranium Liquor Tanks
o Vanadium Pregnant Liquor Tanks
o Clean Water Tank
o Sulfuric Acid Tank
o Caustic Soda Tank
o Soda Ash Tanks
• Tailings Cells Areas
6
Letter to Rusty Lundberg
November 14, 2014
Page 7 of 7
EFRI Response:
No response required.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Harold R. Roberts
David E. Turk
Dan Hillsten
Scott Bakken
Ryan Ellis
7
ATTACHMENT A
ATTACHMENT A
4 *
•
MJB
ii>{'" ' X ^ *' '
^ ..V.5,>' if r.-.-JI'
4
•c v « •• •
v J * > • »•••.
•SH
' • •. «: *%:x' • ; *
\ ' • • *» X . X 4 »' . ' . .
V i' V .'. 4 . . '• % V -J >, * - •>
«;; -' . - • '/ vi -; 4- . - •. v;.-. -
'X * v. v ; *
v.. • t\*.«+ • i . *T ;* • '? •
$ * • ' v'C / i-. • «: \ ,• •'
^•V ' - v':. ;-
iv if, •* ^ K rJ
. - . >y ; >. M
VA.. , ,t .
X - V " A- t' «¥» * * -•
r
-:
K • . i- <». *i 1
1 • t I
"if* * * ' ;
ill
S^«v "I; ;
v ?
i
mkam kit i>
1
!)», v, J-». \- 1 *
LiffiK '-'V' >*»A I" I , ''i } ? '
mm ¥wi:.
R Pi ' W^l-Vl^ * * «; m^-fv-. Sl V!v'v < Alt'."-
.. ...
Nf
:1,
- • •
%XX^,
ft
9
r1' f «H • 31 :; -
It 1 1
HI
i UfthT 1 mh
i
v-.->-
<
ff
y
y
y
y
s
y
^y "***y ^^fc J. If."
v \ y
/
/ y / / y ^>y \ y' y y y y y / y y >y 1 < y y
/ y / y
•jr y. V / y
46 / y
x y :y. ?
/
If , H
.KIT
\ -'ft
* '1
K \
m
V1
-*5
-
ft
«<•« 3ft -4
55
V
aw p.
T\ " i a
1* 4^ m 1 . 1
4 "»•••»
•*. -Vs' .n Tk «o 'JO
k »
* * • *
Si '.-.V' • \
',•4
M. y wC. 1/ / \/' '*•-/ x
f? ,• <• -- .' / . /',
X.
•9 y
ill
6$.
JM
s'-r *
...V -HQ
m 4
--4