DRC-2021-007046 - 0901a06880e96003

State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Douglas J. Hansen
Director
MEMORANDUM
DRC-2,021-007o4
TO: Project File C-2021-39
THROUGH: Phil Goble, Uranium Mill Section Manager Thi7‘,?6thie
FROM: Heather Mickelson, PE, PG 7//eatio.A. 7/1./..41.414.6w, 05/19/2021
DATE: May 19, 2021
05/19/2021
SUBJECT: 2021 BAT/DMT Field Inspection; Radioactive Materials License Number UT1900479,
Amendment # 9 and Ground Water Discharge Permit UG37004, dated January 19, 2018;
Energy Fuels Resources White Mesa Mill, Blanding, Utah
Authority
UAC R317-6-4 Issuance of a Discharge Permit
"A. The Director may issue a ground water discharge permit for a new facility if the Director
determines, after reviewing the information provided under R317-6-6.3, that:...3. the applicant is using
best available technology to minimize the discharge of any pollutant; ..."
UAC R313-15-406(2) Minimization of Contamination
"Licensees shall, to the extent practical, conduct operations to minimize the introduction of residual
radioactivity into the site, including the subsurface, in accordance with the existing radiation protection
requirements in Section R313-15-101 and radiological criteria for license termination in Sections R313-
15-1401 through R313-15-1406."
Permit and License Conditions
The data collected during the BAT/DMT inspections is used to generate reports for the quarterly DMT
Performance Standards Monitoring Report and Cell 4A BAT Performance Standards Monitoring Report
and Annual Technical Evaluation Report of the White Mesa Tailings Management System. These
reports are used to show compliance with the following conditions in the Radioactive Materials License
and the Ground Water Discharge Permit.
DRC-2021-39 195 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 (801) 5364284
www.deq.utah.gov
Printed on 100% recycled paper
2021 BAT/DMT Field Inspection
May 19, 2021
Page 2
Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.3
"The licensee shall implement a monitoring program of the leak detection systems for disposal Cells 4A
and 4B in accordance with requirements of the Permit. The licensee shall implement an operation,
maintenance, and monitoring program of the leak detection systems for disposal Cells 1, 2, and 3..."
Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.7
"Settlement Monitoring Standard Operating Procedure - the licensee shall perform settlement monitoring for
vertical settlement in the tailings management cell area in accordance with the currently Director approved
Settlement Monitoring Standard Operating Procedure (SOP) The Licensee shall document settlement
monitoring data and compare such data to previous data to track potential settlement. All data collected by
the Licensee for these purposes shall be included in an annual report to be submitted to the Director, pursuant
to License Condition 12.2. ..."
Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.8
"Movement (Displacement) Monitoring Standard Operating Procedure - the Licensee shall perform
monitoring for potential vertical and horizontal movements in the constructed dike portions of the tailings
management cells in accordance with the currently Director approved Movement Monitoring Standard
Operating Procedure (SOP). The Licensee shall document displacement monitoring data and compare such
data to previous data to track potential movement (displacement). ..."
Ground Water Discharge Permit #UGW370004, Part I.E. 7
"DMT Performance Standards Monitoring - the Permittee shall perform technology performance
monitoring in accordance with the currently approved DMT Monitoring Plan to determine if DMT is
effective in minimizing and controlling the release of Contaminants..."
Ground Water Discharge Permit #UGW370004, Part I.E.8
"Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the currently
approved Ce114A, BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall immediately
implement all monitoring and recordkeeping requirements therein..."
Ground Water Discharge Permit #UGW370004, Part I.E.12
"Cell 4B BAT Performance Standards Monitoring and Maintenance — immediately following Director
approval of the Cell 4B BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall
immediately implement all monitoring and recordkeeping requirements therein..."
Observations
Heather Mickelson, PE, PG, of the Utah Division of Waste Management and Radiation Control (the
Division), inspected the White Mesa Uranium Mill during data collection activities on May 13, 2021.
The mill is owned and operated by Energy Fuels Resources (the Licensee).
This inspection was specific to the Licensee's Standard Operating Procedures, Discharge Minimization
Plan (DMP), dated December 2016, and Tailings Management System (TMS), dated March 2017, for
the time period since the previous inspection last performed by Heather Mickelson on May 19, 2020.
The Licensee provided copies of the current revision of the field report forms used to perform the daily,
weekly, and annual inspections for the DMP and the daily, weekly, monthly, and quarterly inspections
for the TMS.
2021 BAT/DMT Field Inspection
May 19, 2021
Page 3
Mr. Garrin Palmer, Mr. Tanner Holiday, and Mr. Deen Lyman conducted the daily and weekly
inspections of the DMP and the TMS. The monthly inspection for the TMS was also executed. As the
quarterly inspection for the TMS is a summary of the quarter's activities and overall status of the tailings
cells, this inspection was not performed during this visit. The annual inspection for the decontamination
pad and the ammonium sulfate cover area for the DMP is pending for the 2nd Quarter of 2020.
All individual inspections components of the inspection are not reviewed in this narrative. During the
collection of the data, I agreed with the data collected and the staff's evaluation of the status of the
Mill's components. The Licensee's staff demonstrated an appropriate understanding the data collected
and its further use. Specific components of the onsite inspection are discussed further.
• Pictures showing the methods used by Mill staff to measure the liquid elevation in Cells 1, 4A,
AB are shown in Photos 1- 3.
• The leak detection system for the Decon Pad was checked for leaks (Photo 4.)
• The fuel tank and pump area was in good condition with no obvious signs of leakage and cracks
on the concrete were filled (Photos 5 and 6).
• Diversion ditches were free of debris to allow for water movement away from the site during a
significant storm event.
• A records review of the data collected since the last inspection was performed following the site
inspection. I specifically reviewed the daily, weekly, monthly, and quarterly reports for
November 2020, December 2020, February 2021, March 2021, and April 2021. The records
show similar conditions for the previous months.
• In addition to appropriate data collection techniques and site evaluation, the records review
demonstrated ongoing maintenance to protect human health and the environment. For instance,
the crew noted in December 2020, a 5 gal of calcine was spilled and was cleaned immediately.
They also are aware of conditions that might degrade the site. In February 2021, they noted
muddy conditions and recommended that activities on the roads and tails were limited until they
dried out. They are also proactively maintaining the facility by clearing of ditches of vegetation
and weed clearing throughout the mill site.
A close out meeting to discuss observations from the inspection included with Heather Mickelson, Terry
Slade (Radiation Safety Officer), Garrin Palmer and Tanner Holiday.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements with respect to
DMT/BAT data collection and evaluation. The Licensee's personnel appear to understand the
significance of the data being collected and provide accurate and comprehensive records. In addition,
the correct forms are being used to record the data.
No new recommendations were identified during this inspection.
Attachments: 2021 Annual BAT/DMT Inspection Photolog
Photo 1. Liquid level measurement in Cell 1. Photo was taken on May 13, 2021 and
is looking west.
Photo 2. Liquid level measurement in Cell 4A. Photo was taken on May 13, 2021 and
is looking east.
Photo 3. Liquid level measurement n Cell 4B. Photo was taken on May 13, 2021 and Photo 4. Checking for leaks in the leak detection system on the Decon Pad. Photo
is looking west. was taken on May 13, 2021.
Photo 5. Diesel and gasoline tanks. Tanks appear to be in good condition and cracks
under them have been filled. Photo was taken on May 13, 2021.
Photo 6. Diesel and gasoline tanks and pumps. Both appcar in good condition. Photo
was taken on May 13, 2021.
Photo 7. Diversion ditch I looking south toward the mill. Water flows north from the
middle of the picture to the right lower corner of the photo. Photo was taken on May
13. 2021.
Photo 8. Diversion Ditch 1 water moves down from the left lower corner to the center
of the photo. Photo was taken on May 13, 2021 and looks north.