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HomeMy WebLinkAboutDRC-2018-011999 - 0901a0688093261aY FUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com November 14, 2018 Sent VIA OVERNIGHT DELIVERY Mr. Scott Anderson Division of Waste Management and Radiation Control Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4820 Div of 'AfaF,te Management and Radiation Control NOV 1 6 2018 i) RC- Zoi6-0H99, Re: Response to Utah Division of Waste Management and Radiation Control ("DWMRC") September 25, 2018, Groundwater Module 65, Storm Water Inspection at the White Mesa Mill, Request for Information ("RFI"), Groundwater Discharge Permit UGW370004 Dear Mr. Anderson: This letter responds to DWMRC's above-named letter dated October 5, 2018 which Energy Fuels Resources (USA) Inc. ("EFRI") received on October 15, 2018, regarding the DWMRC storm water inspection conducted at the White Mesa Mill (the "Mill") on September 25, 2018. For ease of review, this letter provides each of DWMRC's comments, in italics, below, followed by EFRI' s response. Request for Information DRC Comment 1. Berms on the north and east margins of the ore storage pad need to be repaired and reconstructed in some areas. The ore storage pad on the east side of the fuel island (between the fuel island and the perimeter fence) needs to be re-graded to avoid ponding/pooling in that area. Please provide confirmation of repair of these berms. EFRI Response: The berms on the north and east of the ore storage pad ("OSP") have been repaired. Photographic documentation of the repairs is included in Attachment A. The OSP east of the fuel island (between the fuel island and the perimeter fence has been regraded. Photographic documentation of the regrading is included in Attachment B. Letter to Scott Anderson November 14, 2018 Page 2 of 5 DRC Comment 2. The storm water detention tank at the south side of the ore storage pad needs to be cleaned out. It was noted that the detention tank was being used for operational purposes other than storm water management and that water and sediment were being pumped to the tank. In cases where storm water management controls are being used for purposes other than storm water management, the control should be maintained and returned for storm water management as soon as possible. Please provide confirmation that the detention tank has been cleaned out. EFRI Response: The storm water detention tank at the south side of the OSP has been cleaned out. Photographic documentation is included as Attachment C. The Quality Assurance Manager ("QAM") conducted refresher training via e-mail with personnel who routinely conduct the weekly OSP inspections. The retraining focused on having inspection personnel complete work orders or send e-mails to the maintenance department when the storm water detention tank needs attention. The training also noted that during subsequent inspections a follow up to verify issues have been addressed should be completed. If issues have not been addressed the inspector should follow up with appropriate personnel. A copy of the e-mail documenting training is included in Attachment D. The Mill Manager has addressed the use of the storm water detention tank for uses other than storm water management. Other alternatives will be used and the storm water detention tank will not be used for non-storm water management except in extreme circumstances. EFRI is proposing to address the design issues with the storm water detention tank that lead to sediment in the bottom of the tank. Currently, the tank' s concrete pipe outlet is several inches above the concrete floor of the tank. This design allows for sediment to "fall out" of the storm water that enters the tank. The sediment does not affect the tank performance, but builds up and results in the tank needing frequent cleanout. To address this issue EFRI is planning on putting a layer of concrete in the floor of the tank to build up the floor so that it is at the same level as the bottom of the outlet pipe. The concrete will be sloped towards the outlet pipe to increase flow of the tank contents into the outlet pipe. Due to weather and temperatures, EFRI expects this modification will be complete by the end of April 2019 when conditions are more suitable for concrete curing. 3. It was noted that the pumps at both decontamination pads were leaking (photos 13 and 32). During the close-out inspection, it was reported that the pumps could not be repaired to prevent the leakage, although it is unclear why this would be the case. The eastern new decontamination pad pump was leaking into a concrete sump and accumulated water was then pumped back to the water storage boxes. In the case of the older existing decontamination pad, the pump was leaking onto the nitrate corrective action pad concrete cover and was left to evaporate. Leaks from these pumps need to be repaired to minimize leakage or the pumps need to be replaced to manage potential discharges to storm water. 2 Letter to Scott Anderson November 14, 2018 Page 3 of 5 EFRI Response: EFRI notes that the pump leakage is minimal and cannot have an overall impact on storm water management because the pumps are located within concrete sumps. As noted during the close-out the pumps are not reparable for a long-term solution. The lack of a fresh water source at the decontamination pad requires "packing" seals to be used which leak instead of mechanical seals which leak very little. In light of this, EFRI will redesign the system at the new decontamination pad and move the pump above the tank so that any leaked water goes directly back into the tank rather than the concrete sump. EFRI will remove the existing frame mounted pump that sits within the concrete sump. The tank discharge flange will be blind flanged and the pump will be installed above the clean section of the tank to feed the wash system. The drainage lines will be capped off. EFRI expects to complete these modifications by the end of December 2018 weather permitting. At the old decontamination pad, a weekly program of inspecting, tightening and greasing the packing will be initiated which will significantly reduce the amount of water that drips off of the pump packing. This weekly inspection and maintenance will be recorded by the mill maintenance department. It is important to note that when this pump packing leaks, it is completely contained on a concrete pad which is graded to flow to a sump/drain system, but efforts will be made to minimize or eliminate the leakage. 4. During the inspection, solid powder material was noticed on the pavement around the soda ash tanks and ammonium sulfate tanks. Please provide confirmation that these areas are swept and will be routinely swept and kept clean. In accordance with the Storm Water Best Management Practices Plan Part 4.1.3, areas should be swept regularly to prevent paved areas from becoming pollutant sources. EFRI Response: EFRI has completed cleanup activities around the soda ash tank and the ammonium sulfate tanks. Photographic documentation is included as Attachment E. Training of site personnel will be completed during the next regularly scheduled monthly training sessions scheduled for November 19, and 21, 2018. Recommended Action It was noted during the inspection that contractors are not required to undergo storm water management training, including spill reporting training. In some cases, contractors may be working at the site for an extended period of time and may be unsupervised by Mill personnel (e.g. well drilling). In these cases, it would be appropriate to provide training/briefing to the individuals to notify them of the spill reporting procedures implemented at the Mill and of the importance of maintaining the integrity of storm water control measures installed and implemented at the Mill. 3 Letter to Scott Anderson November 14, 2018 Page 4 of 5 EFRI Response: The EFRI training manual has been revised to provide storm water management training to long term contactors. The training manual changes are included as Attachment F. Groundwater Module 65, DWMRC Annual Storm Water Inspection Note: Only the Sections of the Inspection Report which require an EFRI response are reproduced here. If a noted item in the inspection report is included in the RFI (numbers 1-4), it is not repeated here. Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the White Mesa Uranium Mill: Date: December 2016 Section I - Document Review SWBMPP (Documentation Requirements): Part 4.1.4. -- Diversion ditches, drainage channels and surface water confrol structures in and around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair, such as excessive vegetative growth channel erosion or pooling of surface water runoff, will be reported to appropriate departments and all follow up actions are to be documented. Findings: The Utah Division of Waste Management and Radiation Control ("DWMRC") conducted an inspection of upland Diversion Ditch 1, 2 and 3 and associated diversion berms. Per the inspection, the ditches and berms appeared to be well maintained. No excessive debris or erosion was noted in the ditches. An accumulation of tumbleweeds was noted in Ditch 2, however it did not appear that the utility of the ditch would be affected. EFR reported that the tumble weeds would be cleared. EFRI Response: As noted, the utility of the ditches was not affected, but the tumble weeds were removed. Photographic documentation is included as Attachment G. Section II — Site Walk-through Inspection Findings: Ammonium Sulfate Crystal Tanks - Powder was noted around the tank storage. The powder need[s] to be cleaned up per good housekeeping requirements. 4 Letter to Scott Anderson November 14, 2018 Page 5 of 5 EFRI Response: As noted in item 4 above, the cleanup was completed. Soda Ash Tanks - Powder material was noted around the soda ash tanks, outside of the secondary containment. This material needs to be swept up to prevent storm water contamination. EFRI Response: As noted in item 4 above, the cleanup was completed. Photographs Photo 11 - Sump on southeast corner of ore storage pad. Note sump is full of water and sediment and needs to be cleaned out. EFRI Response: The sump on the southeast corner of the OSP has been cleaned out. Photographic documentation is included as Attachment H. Photo 12 — Storm water diversion ditch on the southeast area of the ore storage pad. Note ditch needs to be cleaned out. EFRI Response: The storm water diversion on the southeast area of the OSP has been cleaned out. Photographic documentation is included as Attachment I. Please contact me if you have any questions or require any further information. Yours very truly, off ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc: Dave Frydenlund Terry Slade Logan Shumway Scott Bakken Paul Goranson 5 ATTACHMENT A North fence line — looking west from the east Berm north of the fuel island on the east side of the OSP — south looking north •• • Berm east of the fuel island Berm that connects to east drainage ditch - east side of the decontamination pad — looking south from the fuel island ATTACHMENT B ATTACHMENT C ATTACHMENT D Kathy Weinel From: Kathy Weinel Sent: Monday, October 29, 2018 10:13 AM To: Justin Perkins Cc: Terry Slade; N. Tanner Holliday; Garrin Palmer Subject: Training Justin, As you know we had a Storm Water inspection in September by UDEQ. UDEQ commented and requested action on the sediment in the Kiva. l believe it has been cleaned out, which answers the immediate issue. As part of our long term corrective action, l am conducting additional training with you since you do the weekly inspections. This e-mail serves as the documentation of that training. Training: Please note that after your weekly inspections, if the Kiva needs attention, please fill out a work order and give copies of the work order to Terry, Tanner, Garrin and the utility crew (Tyrone Blackhorse). On the following weekly inspection, please verify that actions were taken to address your findings. lf not please follow up. The weekly inspections are well done and well documented — we are just trying to streamline the process for continuous improvement. Terry/Garrin: - Please print this e-mail and place a copy in Justin's training file. Thanks to all for your help. Energy Fuels Resources (USA) Inc. Kathy Weinel Quality Assurance Manager t: 303.389.4134 I f: 303.389.4125 225 Union Blvd., Suite 600 Lakewood, CO 80228 http://www.energyfuels.com This e-mail is intended for the exclusive use of person(s) mentioned as the recipient(s). This message and any attached files with it are confidential and may contain privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or copy this message if you are not the intended recipient(s). 1 ATTACHMENT E r Soda ash area 11011 112DM 112:00 ATTACHMENT F 1 White Mesa Mill Date: 4311/18 Revision: EFR 3.31 Book #13 Training Manual 98 of 101 XVII. ARCHAEOLOGICAL DETERMINATION During the course of any work performed by Contractor, if any archaeological evidence is discovered, i.e., artifacts or remains, the work must cease immediately and Contractor must notify the Owner Representative immediately. XVIII. LIGHTNING If you hear thunder, lightning is close enough to strike you. Immediately stop what you are doing and seek safety in a substantial building or metal topped vehicle with the windows up. In the event that thunderstorm conditions develop, Energy Fuels Safety Department will notify all on site personnel to seek shelter. Stay in until 30 minutes after you hear the last thunder or until the Safety Department determines it is safe to resume work activities. XIX. STORM WATER AND SPILL CONTROL The White Mesa Mill is a zero-discharge facility and no water effluents leave the site. Control mechanisms for maintaining the zero-discharge status of the site include but are not limited to the earthen berms surrounding the site. Any activity conducted on site should avoid disturbing the berms if possible. This includes but is not limited to vehicular traffic, construction, drilling, grading etc. If a berm is damaged or compromised please notify a Radiation Technician or Environmental Technician immediately. Operational and management practices should be employed to minimize and prevent spills. In the event of a spill on site, EFRI has specific procedures that are followed. For the purposes of these procedures a spill is defined as any amount of solid or liquid (except water) that is on the ground. In the event of a spill, take photographs of the spill and notify a Radiation Technician or Environmental Technician immediately. The Radiation Technician or Environmental Technician will implement the Mill procedures and complete the required paperwork. ATTACHMENT G ATTACHMENT H Sump on the southeast corner of the OSP ATTACHMENT I - ' = ° < • i* 4 # , - -* . • . . 4 - • .• Drainage ditch and sump on the southeast corner of the OSP * , -4- - .. ••• ],"°° - Oahe - _A•