DRC-2015-004186 - 0901a0688054e75b

State of Utah
GARY R HERBERT
Governor
SPENCERJ COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
File C-2015-59
Phil Goble, Section Manager
Russell J. Topham, P.E.
April 20. 2015
Engineering Module 75E, DMT/BAT Field Inspection; Radioactive Materials License
Number UT 1900479 (RML) and Ground Water Discharge Permit UG370004 (GWDP).
Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
On April 16, 2015, in the company of Phil Goble of the Utah Division of Radiation Control (DRC), Garrin
Palmer and Tanner Holliday of Energy Fuels Resources (EFR); I conducted an inspection of the tailings
management facilities pertaining to the operation and maintenance of discharge minimization technology
and approved implementation of best available technologies for EFR's White Mesa uranium mill. The
following details my activities, observations and findings.
We arrived at the mill at 7:45 a.m. April 16, 2015 and checked in, asking for Mr. David Turk. Mr. Turk
was unavailable, so we were assigned to the company of Mr. Garrin Palmer and Mr. Tanner Holliday. We
talked briefly, outlining what we planned 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. I was provided Revision
12.2 of the forms. The DRC approved Revision 12.3 on April 7, 2015, which removed Roberts Pond from
the inspection regimen.
Finding: The forms provided were out of date, however, the newly approved revision of the inspection
forms only differed from the version provided by the elimination of Roberts Pond from the inspection
regimen Because the new revision was approved only 9 days prior to the inspection, the new forms had
not yet been forwarded to the mill.
Recommendation: EFRI staff should use the most current forms. The DRC should remind EFRI of this
requirement Because of the recency of approval of the new forms, and the lack of negative outcome
potential, no violation should be pursued.
We prosecuted the inspection by actually performing the daily, weekly, monthly and quarterly inspections
routinely done at the mill. The data gathered during the inspection agreed with data from previous
inspections. During the inspection, Mr. Palmer and Mr. Holliday demonstrated an understanding of the
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purposes and principles behind the data collection. No loss of attention to detail was noted since the
previous performance of this inspection module conducted on April 17, 2014.
Finding Field personnel appear to understand the significance of the data and take care to provide
accurate, comprehensive records.
While collecting data, we followed through on a pump failure associated with the leak detection system
evacuation pump for Cell 4B. To correct the issue, EFR installed a new pump in the leak detection system
pipe. The pump was apparently set at an elevation lower than the pump it replaced. The DRC should
expect to see a different fluid depth relative to the pump in the quarterly DMT report; however, the
operative datum to which fluid levels are compared remains at the flexible membrane liner beneath the leak
detection system.
Arriving at the Cell 3 leak detection system panel, we observed that the panel had no power. Therefore, no
reading was possible. Mr. Palmer called in a trouble ticket and was later informed that the panel was
powered down to allow crews to move a sprinkler system for Cell 4A on the same circuit, and would be
powered up shortly. We returned to the panel once power was restored and took the required reading. The
power was off for less than an hour, resulting in no violation condition.
We recommended exercising manual pump switches at least monthly during inspections to check
operability of equipment and to provide early discovery of failure in the pumping systems.
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. No fugitive dust was observed.
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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. 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.
Recommendation: Exercise pump switches monthly during the DMT inspection. Note that the pump and
associated electronics operate as expected.