DRC-2020-018828 - 0901a06880d8abe5

Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2020
Inspection Date: October 20, 2020

-212-C-ZOZO-010020
Module Reviewer Name:
Phil Goble, Manager
Module Prepared by/Date Prepared:
Tom Rushing, P.G./November 3, 2020

JP- 1113/e-ozo

DWMRC Staff Present: Tom Rushing (Inspector)
Phil Goble (Management Inspection Accompaniment)
Energy Fuels Resources Staff Present: Garrin Palmer
Energy Fuels Resources Staff Interviewed: Garrin Palmer
Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements
Inspected:
Part I.D.10 — Requires management of contact and non-contact storm water and control of
contaminant spills in accordance with the currently approved Storm Water Best Management
Practices Plan (SWBMPP), Spill Prevention Control and Countermeasures Plan (SPCC), and
applicable sections of the Utah Administrative Code.
Part I.D.11 — Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Area, including requirements for container integrity, storage on an engineered
impervious surface, and controls for storm water run-on and run-off.
Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm
Water Best Management Practices Plan (SWBMPP) for the White Mesa Uranium Mill:
Date: October 14, 2019 (Approved by DWMRC on December 9, 2019)
Section I — Document Review
SWBMPP (Documentation Requirements):
SWBMPP Part 4.1.4. -- Diversion ditches, drainage channels and surface water control
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.
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Findings:
The Utah Division of Waste Management and Radiation Control ("DWMRC") conducted an
inspection of upland diversion ditches 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. It was noted that the ditches had not been cleared
of vegetation, however, due to dry conditions during the year the amount of vegetation was
not significant and would not affect drainage.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DWMRC reviewed the February 28, 2020
monthly form and noted that the EFR Inspector (Deen G. Lyman) noted that the Diversion
Ditches showed no signs of sloughing, erosion, undesirable vegetation, or obstructions of
flow. Additionally the form notes that diversion berms show no stability issues or signs of
distress. The form notes that the diversion ditches "look good."
SWBMPP Appendix 1 — Spill Prevention, Control, and Countermeasures Plan (SPCC)
(Documentation Requirements):
1.6.1. — Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DWMRC August 8, 2012 Request for Information which
stated as follows: "The EFR Spill Prevention, Control, and Countermeasures Plan, Part
1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include
the inspection findings with the daily inspection form used for storm water inspection
documentation within 30 days from your receipt of this letter," EFR has removed the daily
inspection requirement on the basis that the propane is a gas at ambient conditions and would
be immediately vaporized under all foreseeable leakage conditions at the Mill. DWMRC
concurred with this action and this item is no longer inspected as part of the documentation
review or included on the site walkthrough.
1.9.1. — External Notification of "reportable quantity" spills.
Findings: No reportable quantity spills were reported by EFR during the period reviewed,
DWMRC has no additional comments.
1.9.2. Internal Notification of incidents, spills, and significant spills.
The White Mesa Mill employees are using a formatted card to report the small quantity
spills; the card is titled "Non-Reportable Reportable Spillage." The card provides the
following information: Name, Date of Discovery, Approximate Amount Spilled, Time of
Discovery, Location of Incident, Description of Material Spilled, Cleanup Activities Taken
and Signature. The reports additionally include photographs of the spill and follow up
actions in most cases.
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Small quantity spill reports were reviewed (Inspection range 3/24/2020 through 10/27/2020)
for the seven-month period prior to the inspection. A total of 13 small quantity spills and
follow up actions were reported during that time frame. Per DWMRC review it appears that
the spills are being adequately reported and follow up actions are described, and in many
cases photos of the spill and clean-up are included.
During 2020, EFR implemented the storm water training program with the annual
radiological refresher in four sessions (February 21, 2020; February 24, 2020; February 25,
2020, and February 28, 2020). A total of 61 employees were trained during 2020 as of the
date of the inspection.
DWMRC notes that the internal spill reporting processes and SWBMPP training activities
are very effective. The spill reporting provides records of identification and follow-up
procedures thereby making the chemical management at the mill transparent and supports
employee involvement in spill identification, reporting, and follow-up.
1.10 Records and Reports.
Period of Records Examined During Inspection:
Begin/Ending: 2/1/2020 through 2/28/2020
No. of On-site Records Required: Daily, Weekly, and Monthly Forms
No. of On-site Records Found: All Stormwater Related Records/Reports Onsite
No of Records Examined: February 2020 (29 days)
How Selected: DWMRC Inspected a random month of daily, weekly, and monthly
forms completed since the last annual DWMRC Storm Water Inspection.
Daily Tailings Inspection Data:
Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-1 of the
Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport
system (Slurry pipeline, pipeline joints and supports, valves and point of discharge); 2.
Operational systems (interior cell walls, water level, beach, liner and cover); 3. Dikes and
embankments (slopes and crest) to check for erosion and seepage; 4. Physical inspection of
the slurry lines, and; 5. Dust control and leak detection, are conducted daily and documented
on a daily inspection form. The forms additionally include fields for observations of
potential concerns and action required. Spills and clean up actions are noted in the text boxes
for these fields. Additionally, EFR inspects tank integrity daily (including fuel tanks) and
reports comments (e.g. odors or leaks) on the "Operating Foreman's Daily Inspection" log.
DWMRC randomly selected and reviewed the Appendix A- 1 daily forms and foreman's log
for the month of February 2020 (daily forms) and 2/1/2020 (foreman's log). The forms and
log appeared to be appropriate and inspections were conducted on all days. There are no
additional comments regarding the forms or log.
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection
Manual Section 3.1.). The forms include sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, 4B and
Roberts Pond, as well as slimes drain liquid levels in Cell 2, Existing Decontamination Pad
and general tailing area. The form also includes information regarding the leak detection
systems for Cells 1, 2, 3, 4A and 4B as well as the potential blowing of tailings, and
condition of concrete at the decontamination pad.
DWMRC inspected the February 2020 weekly forms. All forms were filled out and
identified the individuals completing the inspections. Per the 2020 DWMRC storm water
inspection, the inspection forms reviewed appeared to be completed appropriately. There are
no additional comments regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness:
Findings: Monthly inspection data is documented on Appendix A-3 of the Environmental
Protection Manual, Section 3. DWMRC reviewed the EFR monthly inspection report dated
February 28, 2020. Note that the monthly inspection reports include comments related to the
slurry pipelines that "pipeline looks good, no leaks." There are no additional comments
regarding the forms.
Quarterly Tailings Inspection, Embankments:
Findings: Quarterly inspection data is documented on Appendix A-4 of the Environmental
Protection Manual, Section 3. DWMRC reviewed the EFR quarterly inspection report dated
March 31, 2020. Regarding the embankment inspection it was noted "all embankments are
in good condition." There are no additional comments regarding the forms.
Tank to soil potential measurements:
Findings: This item was included as part of a September 1, 2011 DWMRC Request for
Information ("RFI"), RFI # 2. DWMRC had concerns regarding on-grade tanks (tanks where
the bottom is in contact with soil). Per DWMRC communication with EFR it was clarified
that tanks which sit on the ground must have cathodic protection or sit on a concrete
foundation.
Per DWMRC inspection of the tank foundations during the 2020 inspection, no issues
regarding the concrete foundations were noted.
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Tank and pipeline thickness tests:
Findings: During the inspection period, as noted on the EFR monthly inspection form, the
slurry pipelines were noted to be in good condition by EFR.
Spill Incident Reports:
Findings: This item is discussed above in the section related to reportable and small quantity
spills. DWMRC notes that an effective spill reporting and tracking system has been
implemented at the Mill.
1.11 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files):
Personnel training for spill prevention are discussed in the internal notification of spills
section of this module above. Per DWMRC findings the personnel training has been
implemented and appears to be effective. Mill staff attends annual training regarding the
small quantity internal spill notification process.
Section II -- Site Walk-through Inspection
Areas and Observations:
Ore Storage:
Berms and storm water detention tank (kiva) was well maintained. Pad appeared to be
graded, but no precipitation at the time of the inspection so potential ponding on the pad was
not inspected. No additional comments regarding the ore storage pad.
Reagent Yard:
Per DWMRC observations no issues were noted regarding reagent storage.
Shop/Vehicle Maintenance Area:
DWMRC notes that areas inside of the vehicle maintenance shop and surrounding area drain
through the pipeline to Cell 1. DWMRC noted that hydraulic fluid and oil drums were stored
on pallets with secondary containment. The secondary containments looked dry and the
pallets appeared to be in good condition.
Mill Processing Areas:
SX Building Roof Drainage:
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
It was noted that the area around the SX building had been stabilized with rock riprap and
that the drainage channel had been improved. No comments during the 2020 inspection.
Alternate Feed Circuit South of the SX Building:
Observations: Concrete staging pads need to be inspected and repaired. DWMRC noted
several large cracks/seams which were open and had not been repaired. DWMRC also noted
that the curbing was cracked to ground level in several locations.
Old Decontamination Pad:
Observations: No observations noted during the 2020 inspection. The old decontamination
pad was not being used (was offline) at the time of the inspection.
New Decontamination Pad:
Observations: Pump had been moved to the top of the decontamination pad. Any leaks from
the pump will re-enter the water circuit. This was in response to comments documented
during the 2018 inspection. Per DWMRC inspection findings no evidence of a discharge
outside of the restricted area was noted and no additional comments were noted during the
2020 inspection.
Reagent Tanks:
Sodium Chloride Tanks — Per past agreements between DWMRC and EFR (Agreements
made in 2005) the secondary containment for these tanks is earthen. Per the agreement, all
reagent tanks that pre-existed the Ground Water Permit (3/05) would be acceptable as is —
and that as upgrades or replacements were installed, EFR would work to meet BAT
requirements. More detail regarding this agreement is in the December 2004 Statement of
Basis for the site Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit.
No issues were noted during the 2020 inspection.
Kerosene Tanks (West of Shop) — The kerosene tanks and concrete platforms appeared in
good condition.
Ammonia Tanks — Secondary containment is earthen per the same agreement as the sodium
chloride tanks. Per observations no comments were noted.
Ammonium Sulfate Crystal Tanks — The Mill fire suppression water line had burst, and a
portion of the nitrate CAP concrete pad had been removed in the area of the ammonium
sulfate crystal tanks to inspect and repair the water line. It was discussed during the
inspection and inspection close out that the pad areas need to be repaired as soon as possible
to maintain the integrity of the pad as a nitrate corrective action. No additional comments
specific to the crystal tanks was noted.
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Kerosene Tank (shop) — The shop kerosene tank sits in the same secondary containment as
the used oil tank. DWMRC did not note any problems regarding taps and valves on the tank.
No additional comments.
Fuel Tanks — Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks — No comments were noted.
Vanadium Pregnant Liquor (VPL) Tanks — No comments were noted.
Clean Water Tank — No standing water was noted around the tank. The tank appeared in
good condition. No comments were noted.
Sulfuric Acid Tank — The tank, concrete platform appeared in adequate condition. The
berm around the tank was in good condition. No comments noted.
Caustic Soda Tank — Cracks and spalling was noted in the secondary containment for the
tank. The concrete needs to be inspected and repaired.
Soda Ash Tanks — No comments regarding the soda ash tanks was noted.
Tailings Cells Areas (Note that upland drainage was included in comments above) —
DWMRC toured the tailings cell areas (Cells 4A and 4B) and observed the condition of the
outer toe areas of the dikes to ensure that excessive erosion or damage (e.g. burrowing
animal intrusion or rooting damage) was not present. No areas of excess erosion were noted
during the 2020 inspection.
Summary of Onsite Closeout Meeting:
Date/Time: October 20, 2020/11:00 A.M.
EFR Representatives Present — Garrin Palmer
Logan Shumway (Plant Manager)
DWMRC Representatives Present — Tom Rushing
Phil Goble
An onsite close-out meeting took place to discuss findings of the storm water. Specifically,
the following issues were discussed by DWMRC:
Documentation: DWMRC discussed that the documentation review appeared to be fully
filled out and to address the requirements of the permit. No specific issues were identified.
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Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Site Walkthrough: DWMRC discussed that during the site walkthrough no specific
violations were noted but that areas were noted which required inspection and repair.
Specifically, that maintenance/repair of concrete at the caustic soda tank, nitrate concrete cap
and alternate feed staging areas is needed
Conclusions
A close-out will be sent to EFR regarding the 2020 storm water inspection at the White Mesa
Uranium Mill which will include an advisory concerning maintenance/repair of concrete at
the caustic soda tank, nitrate concrete cap and alternate feed staging areas.
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