DRC-2018-003247 - 0901a068807e2cc0

Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T Anderson
Director DRC-Zo - 3032A-1 GARY R HERBERT
Governor
SPENCER J COX
Lieutenant Governor
MEMORANDUM
TO: File C-2018-37
THROUGH Phil Goble, Section Manager PIC
FROM: Russell J. Topham, P.E.
DATE: March 28, 2018
SUBJECT: Engineering Module 75E, DMT/BAT Field Inspection; Radioactive Materials License Number
UT1900479 (RML) and Ground Water Discharge Permit UG370004 (GWDP). Energy Fuels
Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
On March 26, 2018, in the company of, 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.
I arrived at the mill at 7:00 a.m. March 26, 2018 with Phil Goble of the DWMRC and checked in, asking for Mr.
David Turk. After briefing Mr. Turk on our intended onsite activity for the day, we commenced inspection of
receipt and handling of the initial Sequoiah Fuels alternate feed loads. We continued in that activity until crews
broke for lunch. Following lunch we commenced the BAT/DMT field inspection with Mr. Garrin Palmer and Mr.
Tanner Holliday.
Mr. Palmer provided me copies of the current revision of the field report forms used to perform the daily, and
weekly monitoring activities associated with the tailings management system, Revision 12.4. A copy of the field
notes accumulated by Mr. Palmer and Mr. Holliday are attached to this report.
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, as
described below. During the inspection, Mr. Palmer and Mr. Holliday demonstrated an understanding of the
purposes and principles behind the data collection. During this inspection I focused on the leak detection
technology installed in the tailings and fluid management impoundments. Both crew members demonstrated a
good knowledge of the construction and operation of the system as well as procedures to take when the inspection
reveals data deviating from the norm.
Items evaluated during the inspection include:
1. Tailings slurry transport system (pertains to Cells 1, 2, 3, 4A, 4B, Spot checked only inasmuch as no
fluids were being pumped.)
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address P.0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Review Memorandum, Project C-2018-37
March 28, 2018
Page 2
a. Slurry pipeline — leaks, damage, blockage, sharp bends
b. Pipeline joints — leaks, loose
c. Pipeline supports — damage, loss of support
d. Valves — leaks, blocked, closed
e. Points of discharge — location and orientation (no flow in piping during inspection, so no relevant
observation to make)

2. Operational systems and interior of impoundments (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 (cursory visual inspection only)
Cover — erosion, exposure of liner (Cells 1, 2, 3 — noted one place needing repair on south side of
Cell 2 radon barrier)
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 (no flow during inspection, so nothing to observe)

5. Dust control (Cells 2, 3, 4A, 4B) — dusting, wind movement of tailings, inches of precipitation,
meteorological conditions. (No fugitive dust was observed.)
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 (Cell 2 was undergoing fluid head recovery testing at the time of
the inspection.)
c. Volume pumped (Cell 2 was undergoing fluid head recovery testing at the time of the inspection.)
8. New Decontamination Pad (3 portals)
a. Portal wet/dry; if wet, record fluid level. (Dry at time of inspection)
b. Condition of pad surface (Noted 2 areas of crack sealing material that had come out of the cracks
and required replacement; noted damage to pad surface done by sheeps-foot roller during
decontamination last fall)

9. In addition to the above, all of which were checked during the inspection except as noted, 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. (The only construction relevant to this inspection was
construction of Cell 2 radon barrier which was treated in construction inspection reports last fall.)
Finding: During inspection we detected no items requiring immediate attention. One emerging erosion rill was
observed on the south side of the Cell 2 radon barrier. Field personnel appear to understand the significance of
the data and take care to provide accurate, comprehensive records. Report forms are the correct revision
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 18 of 25
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date: 312.611g Inspectors: &o.rri.... Po. ( To..t.Ae_r i-611;dAy
1. Pond and Beach
elevations (msl, ft)
Cell 1: (a) Pond Solution Elevation .5414.96
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b)) 17.96
Cell 4A: (a)Pond Solution Elevation SseS_ 56
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b)) Õ. 4-12.
Cell 4B: (a)Pond Solution Elevation 55-77 4-15
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b)) 1
(d)Elevation of Beach Area with Highest Elevation
(monthly)
2. Leak Detection Systems
Observation:
New Decon Pad, Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
wet ,---dry wet ,...-dry wet .....-tlry
If wet, Record liquid
level:
— Ft to Liquid — Ft to Liquid — Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? 6/no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete): be.co.... po,ek is ;i. Soo e.0A. Ouer-,k1t.
tvitt c. o0.4.? t..fÀ Acori.A.L. a.e.c.ock keit.
White Mesa Mill — Discharge Minimization Technology Monitonng Plan 12/16 Revision: EFRI 12.4
Page 17 of 25
ATTACHMENT A-1
DAILY INSPECTION DATA
Inspector: 6.-cr...... f'...1.4.4-r- Date: 1126/11
Accompanied by:
Time: .34044rt I t-13.0
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak ....-- Checked ,---- Checked ......--- Checked ,.----- Checked .......--- Checked
Detection
System Wet ..---- Dry Wet .......--"Dry Wet _....-- Dry ,..7--Wet Dry .....--- Wet Dry
Checked
Initial level Initial level Initial level — Initial level ci. 7 Initial level 9. 7 .Sr-
Final Final Final Final Final — —_ level level level level 33744" g level 6q iisg
— Gal. pumped Gal. pumped Gal. pumped — Gal. pumped 0 Gal. pumped 0
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-1)
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