DRC-2016-009989 - 0901a068806687f7

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvruels.com
September 6, 2016
Sent VIA OVERNIGHT DELIVERY
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Div of Waste Management
and Radiation Control
SEP - 7 2016
DftC-2014-
Re: State of Utah Ground Water Discharge Permit (“GWDP”) No. UGW370004
White Mesa Uranium Mill
Notice Pursuant to Parts I.E.T.f) and I.G.3 of the GWDP
Dear Mr. Anderson:
Please take notice pursuant to part I.E.V.f) and I.G.3 of the White Mesa Mill’s (the “Mill’s”) GWDP No.
UGW370004 that Energy Fuels Resources (USA) Inc. (“EFRI”) identified and repaired damage to the tailings
Cell 2 liner system, as described in more detail below. Please note that repairs to the liner were completed on
August 31, 2016, in accordance with the Mill’s Liner Maintenance Provisions. Cell 2 Phase 1 cover placement
commenced in April 2016 and Cell 2 is not in service.
1. Facts and Background Information
1.1 Regulatory Background
Part I.E.7.f) of the Mill’s GWDP requires for tailings cells 1, 2, 3, and Robert Pond that:
“In the event that any liner defect or damage is identified during a liner system inspection, the
Permittee shall: 1) report and repair said defect or damage pursuant to Part I.G.3 by
implementation of the currently approved Liner Maintenance Provisions, and 2) report all repairs
made pursuant to Part I.F.2.”
Part 1 .G.3 of the Mill’s GWDP requires that:
“Notification shall be given orally within 24 hours. . .” and shall be followed up by written
notification “. . . within 5 calendar days”.
Part I.F.2 and the Mill’s Liner Maintenance Provisions require that a:
“Repair Report shall be included with the next quarterly DMT Report.”
Letter to Scott Anderson
September 6, 2016
Page 2 of 3
1.2 Sequence of Events
The sequence of events associated with the liner damage at Cell 2 is as follows:
• Cell 2 ceased receiving tailings in 1995 and lle.(2) byproduct materials in 2000 and is no longer in
operation. EFRI placed interim fill in stages on Cell 2 from 1991 through 2008. Additional minor
volumes of interim fill (less than 1 foot in thickness) were placed on Cell 2 in select areas after 2008.
• The edges of Cell 2 on the south have been blended into the dike of Cell 3 during previous interim fill
activities.
• Cell 2 is full of solids and there is no liquid pool present.
• Cell 2 Phase 1 cover placement commenced in April 2016.
• Cell 2’s liner system consists of a 30 mil PVC flexible membrane liner (“FML”) constructed of solvent
welded seams, overlain by a soil cover layer of 12-inches on the cell floor and 18-inches on the interior
side slope.
• As part of the Phase 1 cover placement, EFRI will construct a performance monitoring test section within
the Cell 2 cover (the “Test Section”). The Test Section will be constructed as a design-build project in
accordance with Section L.4 of Appendix L and the Installation Instructions set out in Attachment L.2 of
Appendix L of Reclamation Plan Revision 5.1. The Test Section is located in the southeast comer of Cell
2. Electronic components and monitoring equipment are located in a vault south of the Test Section on
the dike between Cells 2 and 3.
• During August 29, and 30, 2016, Mill cover construction personnel were using a backhoe to prepare a
trench to route the power lines and electronic components associated with the Test Section to the vault
located on the dike south of Cell 2. The trench was dug south of the Test Section. During the trenching
on August 30, 2016 the backhoe snagged and tore a portion of the Cell 2 liner on the southeast corner of
Cell 2.
• Slimes which accumulated in the trench prior to and during the repairs were immediately removed.
It should be noted that the provisions of UCA 19-5-107 have not been violated as a result of the liner damage.
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.
2. Action Taken
The Mill took the following actions:
• Corporate Environmental Management was notified of the liner damage at approximately 10:00 AM
on August 30, 2016.
• EFRI provided oral notification to Mr. Phil Goble by telephone at approximately 11:30 AM on
August 30, 2016, within one and a half hours of receiving notification of the Mill’s findings.
Letter to Scott Anderson
September 6, 2016
Page 3 of 3
• Repairs to the liner were initiated on August 31 2016, and were completed the same day. The repairs
included replacement of a section of the liner.
3. Root Cause
The damage to the Cell 2 liner was the result of the blending of the southern edge of Cell 2 with the dike of Cell
3, which made the determination of the liner location difficult.
4. Actions That Will be Taken to Prevent a Recurrence of This Incident
As discussed above, the incident occurred during the installation of the vault for the Cell 2 cover Test Section.
The Test Section and the associated monitoring equipment is a one-time activity, which will not reoccur in the
future. As such, no specific actions are necessary to prevent recurrence.
5. Required Reporting
As required by Part I.F.2 of the permit, a liner repair report will be submitted to the Director with the next
quarterly DMT Report following completion of the repairs. Repairs were completed during the third quarter of
2016. The repair report will be submitted with the third quarter 2016 DMT Report on or before December 1,
2016. The repair report will contain the following elements:
• Repair narrative describing the nature of the damage and the repair work completed to repair the damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
If you have any questions, please contact me at [phone].
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
cc Phil Goble. DWMRC
Russ Topham. DWMRC
Logan Shumway
Harold R. Robens
David E. Turk
David Frydenlund
Scott Bakken