The URL can be used to link to this page

Home My WebLink AboutDRC-2016-010004 - 0901a06880668c8dENERGYFUELS Div of Waste Management and Radiation Control Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Uakewood, CO, US, 80228 303 974 2140 www.energvfuels.com September 13, 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 DRC-£.0(6-oiOOo4- 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.7.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.T.f) of the Mill’s GWDP requires for tailings cells 1, 2, 3, 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 I.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 13, 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 1 le.(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 corner 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. • On September 8, 2016, Mill cover construction personnel were using a backhoe to prepare a trench south of Cell 2 to route the power lines from the transformer to the vault located on the dike south of Cell 2. The trench was dug on the south side of Cell 2. During the trenching, the backhoe snagged and tore a portion of the Cell 2 liner where it rises over the dike and enters the anchor trench of Cell 2. The tear was above and outside the cell and outside the area containing any tailings material or cover material. 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 10:44 AM on September 8, 2016. • EFRI provided oral notification to Mr. Russ Topham by telephone at approximately 2:30 PM on September 8, 2016. Letter to Scott Anderson 'September 13, 2016 Page 3 of 3 • Repairs to the liner were initiated on September 9, 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 a power line necessary for the installation of the Cell 2 cover Test Section. The utility line placement for the Test Section and the associated 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 (303) 389-4134. Yours very truly, Energy Fuels Resources (USA) Inc. Kathy Weinel Quality Assurance Manager cc Phil Goble, DWMRC Russ Topham. DWMRC Logan Shumway Harold R. Roberts David E. Turk David Frydenlund Scott Bakken