DRC-2015-002484 - 0901a0688052e3ca

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
May 11, 2015
VIA OVERNIGHT DELIVERY DRC-2015-002484
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
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 1st Quarter of 2015
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 2015, 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,
Harold R. Roberts
David E. Turk
Dan Hillsten
Logan Shumway
Scott Bakken
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc David C. Frydenlund
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
2015
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO. 80228
May 11,2015
TABLE OF CONTENTS
1.0 INTRODUCTION .......................•..........................................................................................................•...... 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED ........................•.............................. I
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 ................................................................ 5
8.0 DECONTAMINATION PADS ..........................................•.•....•..........•....................................................... 6
8.1 SUMMARYOFWEEKLYINSPECTIONS ....... ._ ............ ._ .... ._ .... ._ ......................................................................... 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 ................................................................. 9
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 4A AND 4B ................................................. I 0
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .......................................................................................... I 0
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING ......................................................................... 10
10.1 OPERATIONAL STATUS OF LDS PUMPING AND MONITORING EQUIPMENT , ................................................ 10
10.2 MEASUREMENT OF THE VOLUME OF FLUIDS PUMPED FROM THE LDS ................................... , ................... 11
10.3 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELLS 1, 2, AND 3 .. , ................ , ............................. }1
10.4 SLIMES DRAIN RECOVERY HEAD MONITORING ............................... , .. , ........ , ................ , .. , ...... , ................... 11
11.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE CALENDAR YEAR 2015 .. 11
12.0 QUARTERLY PRECIPITATION DATA ................................................................................................ ll
13.0 SIGNATURE AND CERTIFICATION .................................................................................................... 12
1
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)
Table 3-SDRE Data to be Used for Certain Years (Attachment C)
Table 4-SDRE Data Values to be Used for 2014 (Attachment C)
Table 5-Cell2 Slimes Drain Recovery Head and SDRE Values for 2014 (Attachment C)
Table 6-Cell 2 Slimes Drain Recovery Head and SDRE Values for 2013 (Attachment C)
Table 7-Cell2 Slimes Drain Recovery Head and SDRE Values for 2012 (Attachment C)
Table 8-Cell2 Slimes Drain Recovery Head and SDRE Values for 2011 (Attachment C)
Table 9-Equation 1 Values (Attachment C)
Table 10-SDRE Compliance Calculations (Attachment C)
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 Cell4A and Cell4B Leak Detection System Data for the Quarter and BAT O&M Plan
Tables 1A and lB, Cell4A and 4B Calculations
G Annual Inspection Forms for Existing and New Decontamination Pads (Part I.F.12)
H Weekly Feedstock Inspection Form-Feedstock Maps
I Quarterly Precipitation Data
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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 2015
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the first quarter of 2015 (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.11 );
• 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.?( 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)).
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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 5,615.50, and 5597.40 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 (frnsl) License Condition Under Part I.D.2 of
10.3 (fms1) the GWDP (fmsl)
Ce111 5613.39 5,615.40 5,615.50
Ce113 Not Measured-No Limit No Limit
freeboard limit was (5,602.50*) (5,605.50*)
removed in Q 1 2011
Cell4A 5590.17 -freeboard No Limit No Limit
limit was removed in (5,593.74**) (5,595.50**)
Q1 2011.
Cell4B ' 5582.87 5594.60 5597.40
* The Drrector approved the removal of the Cell 3 freeboard hmrt and authonzed the use of Cell 4 B on January 27,
2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
**The Director granted a variance from the Cell4A 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 Cel14A 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 Cell 4A to be replaced by a freeboard limit for Cell 4B 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 )(1) 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 Peiformance Standards Monitoring Report
and Cell 4A and Cell 4B BAT Peiformance 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
2014, which addresses the requirements of Part I.F.11 of the GWDP and Section 8.2 of the DMT
Plan, was submitted with the fourth quarter 2014 report.
3
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.
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, 2014, and
2015 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 2015
period is included as Attachment D.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
The GWDP requires that when fluid is present, Mill personnel are required to monitor and record
weekly the wastewater levels at Roberts Pond to determine compliance with the DMT operations
standards in Part I.D.3(e) of the GWDP. Part I.D.3(e) of the GWDP provides that the water level
in Roberts Pond shall not exceed an elevation of 5,624 fmsl.
During the quarter, Robert's Pond was dry. As noted in the first quarter 2014 DMT report,
submitted on May 13, 2014, damage in the FML of Roberts Pond was identified during routine
operations, apart from routine inspections. As a result of the FML damage, no fluids have been
added to Roberts Pond since the first quarter of 2014.
As a result of the FML damage noted during the first quarter of 2014, Roberts Pond has been
permanently removed from service. Excavation activities are complete and pursuant to DRC
correspondence dated March 5, 2015, routine monitoring is no longer necessary. Roberts Pond
freeboard measurements and the associated discussion in this quarterly DMT Report will be
deleted beginning with the Q2 2015 report.
4
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 GWDP 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
GWDP. 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. During the quarter,
standing water was noted during the weekly inspections of January 16, January 22, January 30,
February 5, February 13, February 19, March 5, March 13, and March 19. Standing water noted
was the result of precipitation received during the reporting period.
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. 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 I.G.3 of the Permit. Additionally, EFRI provided 5-day written notification
to DRC contemplated by Parts I.E.7 f) and I.G.3 of the Permit on March 18, 2014.
An Action Plan was submitted to DRC on May 12, 2014 and DRC approval was received by
letter dated June 16, 2014. EFRI started implementing the Action Plan on July 14, 2014. In
summary, the Roberts Pond Liner System was removed. The soils underneath the liner were
visually inspected for staining or other indications that they were impacted by the solutions.
Visually stained soils were removed. Following the removal of the stained soils, cleanup
procedures were completed to the levels specified in the Action Plan. A final report delineating
the excavation activities and verification data was submitted to DRC on April 6, 2015. Because
5
Roberts Pond has been removed from service, and the liner will not be repaired, a liner repair
report is not necessary and will not be completed.
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 Portal3
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
12/3112014 0.00 0.00 0.00
118/2015 0.00 0.00 0.00
1115/2015 0.00 0.00 0.00
1/22/2015 0.00 0.00 0.00
1129/2015 0.00 0.00 0.00
2/5/2015 0.00 0.00 0.00
2112/2015 0.00 0.00 0.00
2/19/2015 0.00 0.00 0.00
2/25/2015 0.00 0.00 0.00
3/5/2015 0.00 0.00 0.00
3/12/2015 0.00 0.00 0.00
3/19/2015 0.00 0.00 0.00
3/26/2015 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.
6
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 2015
annual inspections will be reported in the Second Quarter DMT report submitted on or before
September 1, 20 15.
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 2015 annual inspections will be reported in the Second
Quarter DMT report submitted on or before September 1, 2015.
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.
During the quarter there was one failure of the Cell 4A monitoring equipment which were made
operational within 24-hours of discovery, as required by Part I.E.8(a)(l) for Cell4A.
On February 19, 2015 Mill Personnel noted that the Cell 4A LDS had pumped, but the flow
meter was malfunctioning and did not record the volume of fluid pumped from the LDS. The
flow meter was reset immediately upon noticing the malfunction. Full function was restored,
however, the volume of fluid pumped was not recovered. The LDS system was correctly
reporting and recording the LDS fluid head in the sump and no loss of fluid head data resulted
from the flow meter malfunction. The flow meter malfunction was likely caused by corrosive
nature of the tailings fluids. Upon review of the fluid head data, EFRI noted that the pumping
was completed when the fluid levels in the LDS reached the trigger level and there was no
exceedance of the fluid head criteria noted below. The malfunction only resulted in the loss of
gallons pumped. EFRI estimated the fluid volume pumped based on the average number of
gallons pumped during the quarter and added the estimated volume to the quarterly total. The
estimated gallons pumped are shown in Attachment F. No official notifications to DRC were
7
required as the issue was rectified within 24-hours of discovery as required by Part I.E.8(a)(l)
for Cell4A.
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.
During the quarter there were two failures of the Cell 4B monitoring equipment which were
made operational within 24-hours of discovery, as required by Part I.E.12(a)(l) for Cell4B. One
of the equipment failures reported below resulted in a notification to DRC for exceedance of the
27 inch maximum LDS limit noted in Section I.E.l2.a.2 of the GWDP. The notice is included in
Attachment B.
On February 25, 2015 Mill Personnel noted that the Cell4B LDS pump was operating. The Cell
4B LDS pump is designed to operate when the fluid head in the LDS reaches the trigger level.
The trigger level, as measured and recorded by the transducer, had not been reached when the
pump turned on. Mill Personnel noted that the flow meter recorded a large volume of fluid had
been pumped during this time. Based on the fluid levels it appeared that the flow meter was
erroneously recording fluids pumped based on incorrect data from the main control unit. Mill
Personnel replaced the main control unit. Full functionality of the Cell4B monitoring equipment
was restored within 24-hours of discovery. No official notifications to DRC required by Part
I.E.12(a)(l) were completed because the issue was rectified within 24-hours.
On March 30, 2015, Mill Personnel noted that the Cell 4B pump was alarming noting that the
fluid level trigger limit had been reached. The pump was not operating and the fluid level
recorded by the transducer was at 18-inches above the lowest point in the lower FML on the Cell
floor. The pump was manually turned on, but failed to operate. Mill Personnel replaced the
pump within 4 hours of noting the failure. After the pump was replaced, the fluid level recorded
by the transducer read 38-inches above the lowest point in the lower FML on the Cell floor.
Official notification to DRC was required for the exceedance of the 27 inch maximum LDS limit
noted in Section I.E.12.a.2 of the GWDP. The notice is included in Attachment B.
It is important to note that these periodic malfunctions of the equipment are due to the super-
saturated nature of the fluids in the LDS system, which crystallize on the electronic components
and cause the components to malfunction and/or fail prematurely. EFRI inspects the equipment
daily to preclude data loss and maintains spare parts to replace the components on an as needed
basis. In addition, EFRI has researched and purchased a new flow metering system from a
different manufacturer. The flow metering system was installed in Cell 4B LDS on a trial basis
to determine if the new flow metering system provides more accurate and reliable data and
service. As of the writing of this report, the new system appears to provide more reliable service.
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.
8
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 14.0 inches above the
LDS transducer.
As reported above, the fluid head in the Cell 4B LDS sump did exceed the 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, and immediately after the pump replacement, the
fluid head in the Cell 4B LDS sump measured approximately 38 inches above the LDS
transducer. Telephone notification was provided to DRC on March 30, 2015 and written notice
was provided as a follow up on April 3, 2015. The April 3, 2015 notice is included in
Attachment B.
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, 10,766 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, 2011 letter, 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
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 34.62 feet, the allowable flow rate would be approximately 587.5 gallons/acre/day
(23,099 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 39.32 acres of liquid area. The average daily flow volume in Cell 4A did not
exceed the calculated flow volume of 23,099 gallons/day. As mentioned above, a total of 10,766
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 lA is included in Attachment F of this report.
9
Ceii4B
As can be seen from a review of Attachment F, 111,908 gallons of fluid were pumped from the
Cell4B LDS for the quarter. The average daily LDS flow volume in Cell4B did not exceed 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 25.37 feet. The allowable flow rate would
therefore be approximately 475.6 gallons/acre/day (17,202 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 35.91 acres of liquid area. The
average daily flow volume in Cell 4B did not exceed the calculated flow volume of 17,202
gallons/day based on the calculations (i.e. weekly gallons pumped divided by 7 days) in the
approved DMT Plan Section 3.1a). The allowable flow rate and average daily flow rate
calculations for the quarter for Cell 4B are 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.
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 Prut I.E.8(b) of the GWDP.
10.0 CELL 1, CELL 2, AND CELL 3 LDS MONITORING
The requirement in Section 3.1(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 quruterly DMT reports. The Cells 1, 2, and 3 LDS monitoring data are included
in Attachment F.
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.
10
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 2015
The annual slimes drain recovery head report for Cell 2 for calendar year 2015 (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 fourth quarter 2015 DMT report which will be submitted on or before March 1,
2016.
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 11, 2015.
Energy Fuels Resources (USA) Inc.
By:
~~t----
Scott A. Bakken
Director, Permitting and Environmental Affairs
12
CERTIFICATION:
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 of fine and imprisonment for knowing violations.
-Scott A. Bakken
Director, Permitting and Environmental Affairs
Energy Fuels Resources (USA) Inc.
13
Attachment A
Date Celll Cell3 1 Ceii4A 2 Ceii4B 3 Roberts Pond4
Freeboard 5615.40-RML 5593.74-RML 5594.60 -RML
Limit 5615.50-GWDP 5595.50-GWDP 5597.40 -GWDP 5624.00 -GWDP
12/3112014 5612.17 No Longer Required 5589.80 5582.63 DRY
118/2015 5612.18 No Longer Required 5589.88 5582.70 DRY
1115/2015 5612.26 No Longer Required 5589.97 5582.73 DRY
1122/2015 5612.29 No Longer Required 5590.02 5582.68 DRY
1129/2015 5612.25 No Longer Required 5590.17 5582.73 DRY
2/5/2015 5612.42 No Longer Required 5590.11 5582.77 DRY
2/12/2015 5612.64 No Longer Required 5589.64 5582.70 DRY
2/19/2015 5612.77 No Longer Required 5589.44 5582.71 DRY
2/25/2015 5612.90 No Longer Required 5589.59 5582.81 DRY
3/5/2015 5612.99 No Longer Required 5589.69 5582.86 DRY
3112/2015 5613.28 No Longer Required 5589.19 5582.87 DRY
3/19/2015 5613.39 No Longer Required 5588.75 5582.68 DRY
3/26/2015 5613.31 No Longer Required 5588.75 5582.73 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, 2011 letters 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 Ce114A freeboard limit on January 13,
2011 and approved the removal of the 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 Cell 4B at this time.
4 Pursuant to a letter from DRC dated March 5, 2015, Roberts Pond has been permanently removed from service. Excavation activites
are complete and routine monitoring is no longer necessary. Roberts Pond freeboard measurements will be deleted from this report
beginning with the Q2 2015 report.
Attachment B
VIA EMAIL AND OVERNIGHT DELIVERY
April3, 2015
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: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill
-Notice Pursuant to Part I.G.3 of the Permit and UAC R317-6-6.16(C)
Dear Mr. Lundberg:
Please take notice pursuant to Part I.G.3 of the White Mesa Mill's (the "Mill's") State of Utah
Groundwater Discharge Permit No. UGW370004 (the "Permit") and Utah Administrative Code
("UAC") R313-6-6.16(C) that Energy Fuels Resources (USA) Inc. ("EFRI"), as operator of the Mill
and holder of the Permit, failed to meet the Best Available Technology ("BAT") standards in Part
I.E.12.a.2 of the Permit, by not maintaining the fluid head in the Cell 4B leak detection system
("LDS") below the required limit as described in more detail below.
Section I.E.12.a.2 of the Permit states that "Under no circumstances shall [the] fluid head in the leak
detection system (LDS) sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner on the cell floor." For the purposes of compliance monitoring, this 1-foot distance
equates to 2.25 feet (27 inches) above the LDS system. On Monday March 30, 2015, Field Personnel
noted that the pump in the Cell4B LDS was not working. The pump was replaced immediately. After
the pump replacement, it was noted that the fluid level in the LDS had exceeded the 27 inch maximum
noted in the Permit. Immediately after the pump replacement, pumping of the 4B LDS system was
started. Initial notice was given by telephone to Mr. Phil Goble of DRC at approximately 3:00pm on
Monday March 30, 2015 (within 24 hours of the discovery).
1. Facts and Background Information
a) Section I.E.12.a.2 of the Permit states that "Under no circumstances shall [the] fluid head in the
leak detection system (LDS) sump exceed a 1-foot level above the lowest point in the lower
flexible membrane liner on the cell floor. Any occurrence of leak detection system fluids
above this 1-fot limit shall constitute failure of BAT, and a violation of this Permit."
b) The LDS systems in all Cells is inspected daily in accordance with the Permit and the DRC-
Letter to Rusty Lundberg
April 3, 2015
Page 2 of 4
approved Discharge Minimization Technology Monitoring Plan ("DMT Plan").
c) The LDS systems were inspected on Sunday March 29, 2015. No problems or issues were
identified with the Cell 4B LDS system during the daily inspection.
d) On March 29, 2015, Field Personnel noted that, based on fluid levels, pumping of the Cell 4B
LDS would start within 24-hours.
e) The Mill Personnel inspected the Cell4B LDS on Monday March 30, 2015. The LDS system
was alarming due to the pump failure and because the fluid level had exceeded the trigger level
of 15-inches.
f) Mill Personnel attempted to turn on the Cell 4B LDS pump manually. The pump
malfunctioned and would not operate. The fluid level reading in the Cell 4B LDS was
approximately 18-inches.
g) Mill Personnel immediately began replacement of the faulty pump. The replacement pump
was installed within four hours of discovery. After replacement of the pump, the fluid level
reading in the Cell4B LDS was approximately 38-inches.
h) Mill personnel notified the EFRI Quality Assurance Manager ("QAM") of the fluid level
readings.
i) The EFRI QAM notified Mr. Phil Goble of DRC at approximately 3:00pm on Monday March
30, 2015 of the fluid level exceedance.
j) The fluid level difference is attributed to the faulty pump and the associated equipment on the
malfunctioning pump. The nature and composition of the tailings fluids causes the equipment
to malfunction prematurely.
2. Actions Taken
Upon identification of the malfunctioning pump, EFRI took the following actions:
a) Mill Personnel immediately replaced the pump, transducer and all associated equipment.
b) Mill Personnel observed the system more frequently to confirm proper operation.
3. Root Cause
The root cause analysis is as follows:
a) Issues have been identified with the current system. The issues are caused by the nature and
composition of the fluids present in the system, which fluids cause the equipment to
malfunction premature! y.
Letter to Rusty Lundberg
April 3, 2015
Page 3 of 4
4. Actions That Will be Taken to Prevent a Reoccurrence of this Incident
The following action will be taken to prevent a reoccurrence of this incident:
a) Mill Personnel have historically checked the pump quarterly by manually switching it on to
verify it is operating. Mill Personnel will increase the frequency of the operation checks to
monthly.
5. Affirmative Defense
EFRI believes that the affirmative defense in Part I.G.3.c) of the Permit should be applicable to this
incident, for the following reasons:
a) Notification
By virtue of the initial oral notification given to UDEQ at 3:00 PM on Monday March 30, 2015
(within 24 hours of the discovery) and this written notice, EFRI has submitted notification according
to UAC R317-6-6.13.
b) Failure was not Intentional or Caused by the Permittee's Negligence
The failure of the LDS equipment was not caused by EFRI's negligence, either in action or in failure
to act. As discussed above, the equipment malfunctioned due to the nature and composition of the
tailings fluids. Mill Personnel will increase the frequency of manual checks of the system to monthly.
c) The Permittee has Taken Adequate Measures to Meet Permit Conditions
Mill personnel complete daily checks of the fluid levels as required. The exceedance of the prescribed
fluid level is the result of malfunctioning equipment. EFRI has set the systems to pump the LDS well
before the limit is exceeded, however, the pumping equipment suffered a premature failure due to the
nature and composition of the tailings fluids.
d) EFRI has taken adequate measures to meet Permit conditions in a timely manner.
The provisions of the Permit were implemented immediately. DRC was notified within 24 hours of
discovery of the solution measurement information.
e) The Provisions ofUCA 19-5-107 Have Not Been Violated
The provisions of Utah Code 19-5-107 have not been violated. There has been no discharge of a
pollutant into waters of the state. EFRI has not caused pollution which constitutes a menace to public
health and welfare, or is harmful to wildlife, fish or aquatic life, or impairs domestic, agricultural,
industrial, recreational, or other beneficial uses of water, nor has EFRI placed or caused to be placed
any waste in a location where there is probable cause to believe it will cause pollution.
Letter to Rusty Lundberg
April 3, 2015
Page4 of4
There was no discharge of solutions from the Mill's tailings impoundments.
If you have any questions, please contact me at [phone].
y~~
E • RGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc Phil Goble
Dean Henderson, DRC
Dan Hillsten
Harold R. Roberts
David E. Turk
Attachment C
QUARTERLY HEAD MEASUREMENT TEST
Location: Date: 3116115 -3/23115 -Slimes Cell # 2
Sampler: Garrin Palmer
Tanner Holliday
3116115 3117115 3118115 3119115 3/20/15 3/21115 3/22/15 3/23115
600
700 34.50 27.81 25.60 24.56 24.07 23.46 23.00 22.58
800 33.88 27.69 25.55 24.53 24.05 22.58
900 33.23 27.59 25.49 24.51 24.03 22.58
1000 32.77 27.48 25.45 24.49 24.02
1100 32.21 27.37 25.40 24.47 24.01
1200 31.73 27.23 25.35 24.45 23.98
1300 1.3:5 27.09 25.31 24.43 23.97
1400 31.04 26.97 25.25 24.39 23.94
1500 30.74 26.86 25.13 24.34 23.90
1600 30.52 26.76 25.08 24.29
Comme1 Final reading was 22.58.
Attachment D
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Feet Below Top of Standpipe
N 0
0 0
1-' 00 0 0
1-' en
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
• 3/31/2014
5/31/2014
7/31/2014
• 9/30/2014
11/30/2014
1/31/2015
Attachment E
This attachment has been deliberately left blank.
Attachment F
Cell 4A LDS Monitoring Information
January 2015
Weekly measurements in inches
from transducer at the bottom of
Date the LOS sump. Flow Meter in Gallons
12/3112014 11.1 368015
1/8/2015 8.6 369652
1115/2015 6.4 372111
1122/2015 9.0 372111
1129/2015 10.8 372111
Highest level for the month based on the daily data was 12.9 inches and the lowest level for the month was
6.4 inches. Total number of gallons pumped was 4,096.
February 2015
Date
2/5/2015
2/12/2015
2/19/2015
2/25/2015
Weekly measurements in inches
from transducer at the bottom of
the LOS sump.
7.3
8.1
5.5
9.2
Flow Meter in Gallons
372111
372149
37220'0
372200
~ npt~d hl See~ion,r~.l.f •. ~m ~~ 19/1 .s~ Mill P-er (>nt\QI nat~d t;habltte· Cell 41\ I...D -vi p,!lin-plng., .litit t)lj)
flow meter was malftmcH~niryg ~nd wa. not recording,th~ v.dlum~ qf'fl!-}id' p1Jn1p~d fr~m th~ L~S. -a ed
ltpcm de -reas 'n .th LQ -ht!ad me ul·ement f.r:om I LOon 2/.l.8H5 [O 7'.6 inell · on 2.fl9/15 rt i .. apparent
ll'at theLP pum_pell ~ TQ -. t'iroa:te)h(H~~~~~m gump d rh! _ 2 g_allcm ppn1ped m~~ u~~$ m: I'OnHI) __
q~latt~r were a: emgect The :t¥einge is,j·s$9 miUon . .An adciiftional 89 gal lon manuaJ iy pumped wnich w,as
a:C;Id_ed_ o :the: aveMge of 55~ for ·an -. Liruated. tetal of a·648 pumpM during>.lhe qu-arter.
Highest level for the month based on the daily data was 12.2 inches and the lowest level for the month was
5.5 inches. Total number of gallons pumped was 3648.
March 2015
Date
3/5/2015
3112/2015
3/19/2015
3/26/2015
Weekly measurements in inches
from transducer at the bottom of
the LOS sump.
11.9
1.7
7.4
6.3
Flow Meter in Gallons
372200
375222
375222
375222
Highest level for the month based on the daily data was 13.7 inches and the lowest level for the month was-
3.2 inches. Total number of gallons pumped was 3,022.
For the 1st Quarter 2015, the highest level was 14.0 inches and the lowest level was -3.2 inches and 10,766
gallons were pumped.
The daily fluid pumped is not calculated for Cell 4A because the total pumped for the entire quarter does not
exceed the daily allowable volume and therefore the calculation is not necessary.
Cell 4B LDS Monitoring Information
January 2015
Weekly measurements in inches
from transducer at the bottom Flow Meter in Gallons Gallons
Date of the LDS sump. Gallons pumped/week Pumped/day*
12/31/2014 9.75 127105
1/8/2015 9.75 127105 0 0
1115/2015 9.57 127105 0 0
1122/2015 9.75 127108 3 0.43
1/29/2015 12.24 127165 57 8
Highest level for the month based on the daily data was 12.24 inches and the lowest level for the month was 8.90
inches and 60 gallons were pumped.
February 2015
Weekly measurements in inches
from transducer at the bottom Flow Meter in Gallons Gallons
Date of the LDS sump. Gallons pumped/week Pumped/day*
2/5/2015 13.92 127172 7 1
2/12/2015 14.75 127172 0 0
2/19/2015 7.22 134743 7571 1082
2/25/2015 7.22 184127 49384 7055
Highest level for the month based on the daily data was 15.75 inches and the lowest level for the month was -0.29
inches and 56,962 gallons were pumped.
March 2015
Weekly measurements in inches
from transducer at the bottom Flow Meter in Gallons Gallons
Date of the LDS sump. Gallons pumped/week Pumped/day*
3/5/2015 6.39 184127 0 0
3112/2015 12.24 195811 11684 1669
3/19/2015 7.22 222610 26799 3828
3/26/2015 12.24 239013 16403 2343
Highest level for the month based on the daily data was 17.47 inches and the lowest level for the month was -0.29
inches and 8,217 gallons were pumped.
For the 1st Quarter 2015, the highest level was 17.47 inches and the lowest level was -0.29 inches and 111,908
gallons were pumped.
* Pursuant to Section 3.la) of the approved DMT Plan, the total volume of all fluids pumped from the LDS on a
weekly basis shall be recovered from the data collector. The weekly fluid pumped will be used to calculate an
average pumped per day.
White Mesa Mill -Discharge Minimization Technology Monitoring Plan 4/15 Revision: EFRI 12.3
Page 23 of23
ATTACHMENT C
TABLES
Table 1A
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons I acre I day )
Table 1B
Calculated Action leakage Rates
for Various head Conditions
Cell 4 B White Mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons I acre I day )
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
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-012015
5590.17
5555.55
34.62
587.5
39.32
23,099
Max head on Ceii4B FML
Max elevation (ft.)
FML elevation (ft.)
Head (ft.)
From BAT O&M Table 1B (gallon/acre/day)
Acres of fluid based on maximum level (acres)
Max allowable flow rate (gal/day)
4B-012015
5582.87
5557.50
25.37
475.6
36.17
17,202
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 1A (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 1A or 1B) X Acres of Tailings Cell Fluids=
Maximum Daily Allowable Flow Volume
Cell 1, Cell 2, and Cell 3 LOS Monitoring Information -First Quarter 2015
Cell1 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 LDS sump. bottom of the LDS sump. bottom of the LDS sump.
12/31/2014 Dry 12/31/2014 Dry 12/31/2014 Dry
1/8/2015 Dry 1/8/2015 Dry 1/8/2015 Dry
1/15/2015 Dry 1/15/2015 Dry 1/15/2015 Dry
1/22/2015 Dry 1/22/2015 Dry 1/22/2015 Dry
1/29/2015 Dry 1/29/2015 Dry 1/29/2015 Dry
Cell1 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 LDS sump. bottom of the LDS sump. bottom of the LDS sump.
2/5/2015 Dry 2/5/2015 Dry 2/5/2015 Dry
2/12/2015 Dry 2/12/2015 Dry 2/12/2015 Dry
2/19/2015 Dry 2/19/2015 Dry 2/19/2015 Dry
2/25/2015 Dry 2/25/2015 Dry 2/25/2015 Dry
Cell1 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 LDS sump. bottom of the LDS sump. bottom of the LDS sump.
3/5/2015 Dry 3/5/2015 Dry 3/5/2015 Dry
3/12/2015 Dry 3/12/2015 Dry 3/12/2015 Dry
3/19/2015 Dry 3/19/2015 Dry 3/19/2015 Dry
3/26/2015 Dry 3/26/2015 Dry 3/26/2015 Dry
Attachment G
This attachment has been deliberately left blank.
Attachment H
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Attachment I
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Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2015 Month January
Rain Snow Rain Snow
1 17 .. zq
2 18
3 19
4 20
5 21
6 22
7 23
8 ~ '
9 25
10 26
11 27 uU7
12 28 ,..f'Z..
13 29 .58
14 30 (),35
15 31 so
16
Combined
Total: j. 8i
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Precipitation Chart
Rain or Snow Recorded in Inches of Moisture Received
YEAR 2015 Month February
Rain Snow Rain Snow
1 17
2 18
3 19
4 20
5 21
6 22 I. DO
7 23 ."10
8 24 • 1.7
9 25
10 26 .. ocr
11 27
12 28 • 24
13 29
14 30
15 31
16 .__ __ __.__ __ ____.
Combined
Total: 1..., '2
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 2015 Month March
Rain Snow Rain Snow
. 7'6 17
. 68 18
19
20
21
22
23
24
25
26
27
28
29
30
31
Combined
Total: 0.~