DRC-2016-010317 - 0901a0688066f4ca

State of Utah
GARY R HERBERT
Governor
SPENCER.I COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T Anderson
Director Df\C- 2C1G - 010317
MEMORANDUM
TO: Project File C-2016-39
THROUGH: Phil Goble, Section Manager
FROM: Russell J. Topham, PE
DATE: September 26, 2016
SUBJECT: Engineering Module 75C, Review of the 2nd Quarter 2016 (April-June, 2016) DMT
Performance Standards Monitoring Report and Cell 4A and Cell 4B BAT Performance
Standards Monitoring Report (Report). Groundwater Discharge Permit (GWDP)
UGW370004 - Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
This is a summary of Utah Division of Waste Management and Radiation Control (DWMRC) staff
review of the EFR DMT Performance Monitoring Report and Cell 4A and Cell 4B BA T Performance
Standards Monitoring Report dated August 16, 2016, and covering the 2nd Quarter 2016 (April-June,
2016) monitoring period (Report). DWMRC received the Report on August 19, 2016 in both hard copy
and CD formats. Discussions in this document reference the White Mesa Mill Discharge Minimization
Technology (DMT) Monitoring Plan, Revision 12.3 (DMT Plan), dated April, 2015.
After review of this report, DRC staff findings and recommendations are as follows:
Findings
1. Weekly monitoring of Cell 1 solution pool elevations occurred as required, and the solution
pool elevation remained below the specified limit.
2. Weekly monitoring of Cell 4A solution pool elevations occurred as required to calculate
acceptable leakage rates, and the leakage rate thus determined remained below the specified
limit
3. Weekly monitoring of Cell 4B solution pool elevations occurred as required, and the solution
pool elevation remained below the specified limit.
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address- P O Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D D [phone]
www.ficq.iitnli.gov
Printed on 100% recycled paper
Review Memorandum, Project C-2016-39
September 26, 2016
Page 2
4. Data provided in Attachment C to the Report supports a conclusion that EFR has generally met
the requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
However, the data also supports a hypothesis that the effectiveness of the current practice may
be at an end without making changes in the cover system.
5. Monitoring of the feedstock storage area occurred as required. The data support a conclusion
that no feedstock existed outside the designated feedstock storage areas.
6. EFR met the requirements for inspection of the liner systems. No damage was detected, and no
repairs were undertaken.
7. EFR has met the requirements for inspecting the New Decontamination Pad, finding no
indication of leakage from secondary containment or other indicators of substandard
performance.
8. EFR has met the requirements for inspecting the Old Decontamination Pad, finding no
indications of substandard conditions.
9. EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and corrected
all mechanical failures the same day as detected.
10. The leak detection systems in Cells 1, 2, and 3 appear to have operated properly, and no fluids
were detected therein during the 2nd Quarter 2016.
11. EFR has met the requirements for inspection and crack/joint repair of the Ammonium Sulfate
Pad.
Recommendations
1. The DRC should issue a closeout letter for the review of this report.
2. The DWMRC and EFR should continue jointly to pursue expedited revision, approval and
implementation of Reclamation Plan Revision 5.1 to provide a means of excluding as much
precipitation as possible from contributing to recharge of the slimes.
1.0 Tailings Wastewater Pool Elevation Monitoring
Part I.E.7(a) of the GWDP requires EFR to monitor and record weekly the elevation of the wastewater
pool in Tailings Cells 1 and 3 to ensure compliance with Condition 10.3 of the License. Part I.D.3(e) of
the GWDP requires EFR to operate Roberts Pond to provide a minimum two feet of freeboard at all
times. Part 3.1(d) of the DMT/BAT Plan requires EFR to measure the solution pool elevation in Cells
4A and 4B weekly, and the tailings beach maximum elevation and area within Cells 4A and 4B
monthly. The reference to Roberts Pond will be removed at the next revision to the GWDP inasmuch as
the DWMRC has approved plans to fill Roberts Pond and regrade the area, and the licensee has
completed the work, eliminating the impoundment entirely.
Cell 1
*
Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with the
prescribed freeboard requirements.
Cell 3
Tailings have nearly completely filled Cell 3. Recognizing this, letters from the Director dated January
27, 2011 and March 14, 2011 formally eliminated the need for solution pool elevation measurement in
Cell 3. The previously cited January 27, 2011 letter and another letter from the Director dated March 15,
2011 concluded a process ending the need for freeboard-related solution pool elevation monitoring in
Cell 3. However, Part 3.1(a) of the DMT/BAT Plan requires monitoring solution pool elevations in Cells
4A and 4B to facilitate determination of compliance with FML leakage rate limitations.
As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed
during the monitoring period. Attachment A to the report reflects no measurements for the reported
quarter.
Cell 4A
Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of
calculating acceptable leak rates for the liner system
Cell 4B
Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance
with the prescribed freeboard requirements.
Roberts Pond
Roberts Pond has been taken out of service following discovery of tears in the pond liner on March 13,
2014. EFRI has redirected all fluid flows previously destined for Roberts Pond to Cell 1. EFRI has
completed cleanup of contaminants released from the pond as a result of the breached liner. The pond
has been completely backfilled, with all storm water collected on the new surface directed to Cell 1.
Findings: The data presented in the report demonstrate EFR compliance with the solution pool
operational requirements of the DMT/BAT plan in force during the quarter.
2.0 Slimes Drain Water Level Monitoring
Part I.F.2 of the GWDP requires EFR to include in the Report, all DMT performance standards
monitoring detailed in Parts I.D.3 and I.E.7 of the GWDP. Part I.D.3(b)(l) of the GWDP requires EFR
to maintain the fluid level in the slimes drain of Cells 2 and 3 as low as reasonably achievable at all
times, and to demonstrate that performance through adherence to the current DMT Monitoring Plan. Part
I.E.7(b) of the GWDP requires monthly monitoring and recording of the depth to wastewater in the
slimes drain access pipe as described in Part 1.D.3 of the GWDP and the current DMT Monitoring Plan.
Part 3.1(b)(v) of the DMT Monitoring Plan requires EFR to monitor and record weekly the depth to
wastewater in the Cell 2 slimes drain access pipe to determine maximum and minimum head before and
after a pumping cycle, respectively.
Review Memorandum, Project C-2016-39
September 26, 2016
Page 3
Section 4.1 of the Report asserts that the above discussed monitoring requirements only pertain to Cell 2
for the reporting period, as dewatering operations have not commenced in Cell 3. I concur with this
assessment.
Weekly water level monitoring of the Cell 2 slimes drain is not required as part of the DMT plan, but is
required under Part l.D.3(b)(1) of the GWDP. EFR retains records of Cell 2 slimes drain monitoring at
the mill.
Attachment C to the Report contains data from the quarterly recovery head measurements (discussed in
the next paragraph). The recovery head monitoring data provides indirect evidence that EFR has
maintained the fluid level in the Cell 2 slimes drain as low as reasonably achievable, as required in
GWDP, Part LD.3(b)(1). From the graph of slimes drain recovery head data in Attachment D, it is
apparent that the downward trend that has occurred since May of 2011 has not continued apace. All
measurements since the 2nd Quarter of 2014 are above the level observed during the 2nd Quarter of 2014.
It appears that the readings beginning with the 2nd Quarter of 2014 are roughly equivalent to each other,
only varying by “noise,” or imperfection, in the measurement technique.
More information is required to understand whether equilibrium has been reached with approximately
7.5 feet of hydraulic head (approximately 22.5 feet from the surface of the temporary cover on the cell)
at the pumping point (Report, Appendix D). Table 2-1 on p. 7 of the Tailings Data Analysis Report
(TDAR, April, 2015) presents a water table at a depth of between 0.2 feet and 12.3 feet of the surface of
the temporary cover. Fikewise, Table 4-1 indicates the depth to top of saturated tailings varying from
3.92 feet to 11.58 feet below the temporary cover surface, with the greater depths occurring closer to the
slimes drain alignment (TDAR, p. 17). This indicates a substantial volume of fluid yet to be removed
from the cell.
The TDAR postulates the presence of gypsum in the interstices within the tailings mass (p. 11). This
condition would reduce hydraulic conductivity within the tailings. The temporary cover is composed of
random fill, which on visual inspection appears to be a sandy gravel or gravelly sand with cobbles and
boulders. Sieve analysis reveals a fines fraction (material finer than the #200 sieve) of between 10% and
30%, with Atterberg Fimits testing suggesting the presence of clay in the fines. However, the temporary
cover was placed without densification, which would offset the ability of any clay present to resist
percolation of water. The porosity of this cover would allow surface water to penetrate into the tailings
below. While the region in which the mill is sited has experienced drought conditions, significant storms
have occurred. Those may have recharged the cell, offsetting the withdrawal through the slimes drain.
2015 saw wet conditions through the spring and early summer with normal-to-wet conditions prevailing
through the end of the year. Likewise, 2016 saw spring and summer storms.
Given the above hypotheses and the data presented in Attachment D to the report, I question whether the
current practice of withdrawing slimes will prove effective in reducing the fluid level in the cell.
Installation of final cover, with a liner system and grading to shed precipitation may be required in order
to achieve the desired fluid reduction.
One drawback has been identified to placing final cover at this time. With the amount of fluid remaining
in the cell, settlement may occur as fluid is withdrawn. This could compromise a clay radon barrier. An
alternative to placing final cover might be to place a less permeable layer to shed storm water. This
could be augmented by installing piezometers in a few well-chosen locations to monitor phreatic head in
the cell, while keeping the pump in the slimes drain active, and abandoning the practice of recovery
Review Memorandum, Project C-2016-39
September 26, 2016
Page 4
head measurement in favor of monitoring the piezometers. While not presented in the Report, the
Licensee has commenced placing random fill, compacted to a density of at least 95% of ASTM D-698
(Standard Proctor) as a primary Radon barrier, and has installed piezometers adjacent to all settlement
monitors.
Recent activity on amendment of Reclamation Plan Revision 5.1 appears focused, in part, on resolving
the questions presented above. Placement of the primary Radon barrier provides an opportunity to
evaluate the effect of surcharge to accelerate fluid withdrawal capability. The new fill, if properly
contoured at the surface, may also shunt storm water aside, preventing much of the recharge that may
occur in the slimes due to percolation. The design slope is generally 0.5%, which will be difficult
enough to construct that imperfections in the construction and consolidation due to surcharging will
likely result in ponding of water on the surface of the cell. While this is not ideal, it is an improvement
over the condition at the commencement of the report period.
Finding: Data provided in Attachment C to the Report supports a conclusion that EFR has generally
met the requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
However, the data also supports a hypothesis that the effectiveness of the current practice may be at an
end without making changes in the cover system.
Recommendation: The DWMRC and EFR should continue jointly to pursue expedited revision, approval
and implementation of Reclamation Plan Revision 5 to provide a means of excluding as much
precipitation as possible from contributing to recharge of the slimes.
3.0 Feedstock Storage Monitoring
This section addresses both bulk conventional feedstock (ore) and alternate feed stored onsite. Ore is
stored on the ore pad. Part I.D. 11 of the GWDP anticipates and governs storage of alternate feed outside
the confines of the ore pad.
Weekly inspection revealed no evidence of ore beyond the boundaries of the ore pad. Storage practices
for alternate feeds appeared compliant with GWDP requirements.
The current report highlighted no example of significant amounts of standing water persisting on the ore
pad after storms.
Finding: Monitoring of the feedstock storage area occurred as required. The data support a conclusion
that no feedstock existed outside the designated feedstock storage areas. Standing water problems were
addressed during the quarter.
Recommendation: Efforts to address the storm water issue should be monitored over several inspections
and report review cycles to see that changes made by the licensee are effective and lasting. Inasmuch as
this is not a failure in monitoring, but in operations, this follow through activity should not prevent
closing out the review of the Report.
4.0 Tailings Cells and Pond Liner System Repairs
Inspection of all cells occurred weekly during the period covered in the report. The report indicated no
case of liner damage in the tailings cells discovered or repaired during the quarter.
Review Memorandum, Project C-2016-39
September 26, 2016
Page 5
Review Memorandum, Project C-2016-39
September 26, 2016
Page 6
Finding: EFR met the requirements for inspection of the liner.
5.0 Decontamination Pads
Weekly inspection of the New Decontamination Pad occurred as required under Part I.F.12 of the
GWDP. The monitoring portals were dry during all inspections, indicating no leakage from primary
containment. Cracks were repaired during the Report period.
Finding: EFR has met the routine and annual requirements for inspecting both the Old and New
Decontamination Pads, finding no indication of leakage from secondary containment.
6.0 Ammonium Sulfate Pad
Phase I of the Nitrate Corrective Action Plan required installation of a concrete pad to prevent water
penetrating to nitrate-containing soils in the area of the ammonium sulfate crystal tank. This pad was
installed and inspected by DWMRC during the Report quarter. The DWMRC approved the construction
by letter on June 26, 2015, near the end of the Report period. Plant personnel inspected the pad and
applied sealant to joints and cracks as required. Inspections are required quarterly for eight consecutive
quarters, and annually thereafter thereafter.
Finding: EFR has met the routine requirements for inspecting the Ammonium Sulfate Pad, and has
sealed joints and cracks therein.
7.0 Cells 4A and 4B BAT Performance Standards Monitoring
Requirements for measuring BAT performance for Cells 4A and 4B include verifying that leak detection
system equipment operates appropriately, verifying that fluid head in the leak detection system sumps
does not exceed 1 foot above the lowest point in the secondary (lower) flexible membrane liner, and
recording the volume of fluid pumped from the leak detection systems for the two cells. EFR must also
record the fluid head in Cell 4B for compliance purposes, and in Cell 4A for computation of acceptable
leakage rate in Cell 4A. The data provided in the report and its attachments provide evidence of
compliance with the Cells 4A and 4B BAT performance monitoring standards in place during the
monitoring period.
Cell 4A
No failures were noted in the Cell 4A leak detection system during the Report period.
Cell 4B
No failures were noted in the Cell 4B leak detection system during the Report period.
Finding: EFR has met the monitoring requirements for Cell 4 A and 4B BAT performance. No
mechanical failures were noted during the quarter.
8.0 Cells 1, 2 and 3 Leak Detection System Monitoring
Leak detection system monitoring requirements for Cells 1,2 and 3 appear in the Radioactive Materials
License rather than the GWDP. For consistency, the DRC requested that this monitoring be included as
part of the quarterly report and EFR has consented to do so.
The report and its attachments contain weekly monitoring data for the operational status of the leak
detection system equipment, fluid levels detected in the leak detection systems, and volumes of fluid
pumped. From the data, EFR represents that no failures of the monitoring equipment occurred that were
not corrected within 24 hours. Leak detection systems for the three cells measured dry; therefore, no
fluids were pumped therefrom.
Finding: The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during reporting period.
Review Memorandum, Project C-2016-39
September 26, 2016
Page 7