DRC-2017-006101 - 0901a06880740009

GARY R HERBERT
Governor
SPENCER.I COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scotl T. Anderson
Director
PRC-201T-OO6IO
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
Project File C-2017-20
Heather Mickelson, PE, Peer Reviewer \\ HY ^ ftyH'A' /
Phil Goble, Section Manager P12.& ^
Russell J. Topham, PE
August 16, 2017
SUBJECT: Engineering Module 75A, Review of the 4th Quarter 2016 (October-December, 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 4 A and Cell 4B BAT Performance
Standards Monitoring Report dated February 8, 2017, for the 4th Quarter of 2016 (October-December,
2016) monitoring period (Report). DWMRC received the Report on February 10, 2017 in both hard
copy and CD formats. Discussions in this document reference the IVhite Mesa Mill Discharge
Minimization Technology (DMT) Monitoring Plan, Revision 12.3 (DMT Plan), dated April, 2015.
After review of this report, DWMRC staff findings and recommendations are as follows:
Summary of 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
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3. Weekly monitoring of Cell 4B solution pool elevations occurred as required, and the solution
pool elevation remained below the specified limit.
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 current method of demonstrating
successful efforts to maintain fluid levels as low as possible may be inadequate to reflect the
realities encountered in the field.
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. All damage detected during the
reporting period was promptly and appropriately repaired, and no fluid releases occurred.
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.
Summary of Recommendations
1. The DWMRC 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 and revision of the slimes drain monitoring
criteria in the GWDP to assure good processes and monitoring practices are in place to maintain
optimum dewatering performance.
1.0 Tailings Wastewater Pool Elevation Monitoring
Requirements
Part l.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.
Review Memorandum, Project C-2017-20
August 16, 2017
Page 2
Part l.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.
Results
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 January 27, 2011 letter and a 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, 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 4R
Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance
with the prescribed freeboard requirements.
Roberts Pond
Roberts Pond was removed from 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.
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.
Findings: The data presented in the report demonstrate EFR compliance with the solution pool
operational requirements of the DMT/BA T plan in force during the quarter.
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August 16, 2017
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Review Memorandum, Project C-2017-20
August 16, 2017
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2.0 Slimes Drain Water Level Monitoring
Requirements
Part 1.F.2 of the GWDP requires EFR to include in the Report, all DMT performance standards
monitoring detailed in Parts I.D.3 and FE.7 of the GWDP.
Part I.D.3(b)(1) 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 I.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.
Results
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 I.D.3(b)(l) 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 I.D.3(b)(l). From the graph of slimes drain recovery head data in Attachment D, it is
apparent that the downward trend that occurred between May of 2011 and April of 2014 has not
continued. All measurements since the 2nd Quarter of 2014 are above this measurement. 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. Furthermore, the trend reversed abruptly
during the reporting quarter. The abrupt rise in the recovery head measurement is attributable to recent
cover construction activity and will be discussed toward the end of this section.
In reviews of previous Reports, I stated that 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. Likewise, 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. Recent installation of additional
cover material has surcharged the tailings, and simultaneously increased the yield from the slimes drain
as well as increasing the fluid level within the tailings mass.
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 Limits 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 additional platform fill and primary Radon barrier has resulted in buildup of excess pore
pressure in the tailings mass which, in turn, has pushed the phreatic surface upward and delivered more
fluid to the drain for removal. The withdrawal rate has increased by approximately 2,000 gallons per
month.
The licensee has placed piezometers at the settlement monitoring points and will include the fluid levels
measured in the piezometers in future quarterly reports. I have received weekly reports of fluid level
measurements in the piezometers which showed a progressive rise in the phreatic surface as crews
placed and compacted the first two layers of the final cover system, followed by a fall in the phreatic
surface. I attribute the fall in the fluid surface to dissipation of the excess pore pressure created by
surcharging of the tailings mass and accelerated withdrawals of the slimes from the drain. The phreatic
surface shows a dip along the alignment of the slimes drain. Having a network of piezometers will
prov ide a means of assessing the slimes content of the tailings mass and of estimating the length of time
that may be required to evacuate the slimes.
The placement of additional platform fill and primary Radon barrier has changed the conditions being
monitored. At a minimum, the clock needs to be restarted with respect to the requirement to maintain
the slimes drain hydraulic head three-year running average in decline. A new baseline will also be
needed following completion of construction of the primary Radon barrier. The DWMRC and the
Licensee may benefit from revising the requirement in the GWDP relative to fluid withdrawal to require
continual operation of the pump and demonstration of reducing fluid volume remaining through analysis
of the phreatic surface plots generated during successive periodic measurement cycles rather than the
current method of showing a three-year running average decline in fluid head. I have included a
suggestion to that effect in the proposed amendment to the GWDP currently going to public comment.
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 current method of demonstrating successful
Review Memorandum, Project C-2017-20
August 16, 2017
Page 5
efforts to maintain fluid levels as low as possible may be inadequate to reflect the realities encountered
in the field.
Recommendation: 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.
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.
Requirement
Part l.D.l 1 of the GWDP anticipates and governs storage of alternate feed outside the confines of the
ore pad.
Results
Weekly inspection revealed no evidence of ore beyond the boundaries of the ore pad. Storage practices
for alternate feeds appear compliant with GWDP requirements.
The current report highlighted no example of significant standing water volme 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
Requirement
Parts I.E.7(f) and 1.G.3 specifies how the licensee must address leaks discovered in the pond liner
system. Part 1.F.2 specifies reporting requirements for such liner breaches.
Results
Inspection of all cells occurred weekly during the period covered in the report. The report indicated no
cases of liner damage in the tailings cells discovered or repaired during the quarter.
Finding: EFR met the requirements for inspection and repair of the liners.
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August 16, 2017
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5.0 Decontamination Pads
Requirement
Weekly inspection of the New Decontamination Pad for leakage occurred as required under Part I.F.12
of the GWDP.
Results
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
Requirement
Phase 1 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. Inspections and filling of cracks are required quarterly for eight consecutive
quarters following approval, and annually thereafter.
Results
Plant personnel inspected the pad and applied sealant to joints and cracks as required.
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
Requirement
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.
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August 16, 2017
Page 7
Results
Cell 4A and 4B
No failures were noted in the Cell 4A 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
Requirement
Leak detection system monitoring requirements for Cells 1,2 and 3 appear in the Radioactive Materials
License rather than the GWDP. For consistency, the DWMRC requested that this monitoring be
included as part of the quarterly report and EFR has consented to do so.
Results
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 from them. .
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.
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