DRC-2020-016835 - 0901a06880d4bec6

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State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
L. Scott Baird
Interim Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
ORC-202o -0(6635
MEMORANDUM
Project File C-2020-46
fig 6
Heather Mickelson, PE, PG t44,141-4--(-1/461-1 4liSot.t.J c11-2,07AD .
May 19, 2020
2020 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
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
Authority
Phil Goble, Uranium Mill Section Manager
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-20 195 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. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
May 19, 2020
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), with Phil Goble, Uranium Mill Section Manager, inspected the White Mesa Uranium Mill
during data collection activities on May 7, 2020. 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 Russ Topham on April 24, 2019. 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.
Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
May 19, 2020
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 and
4A are shown in Photos 1 and 2.
• Repair of the ramp in Cell 4B was occurring during the inspection (Photo 3). Therefore, a water
level measurement was not taken.
• 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 July
2019, September 2019, December 2020, and February 2020. The records showed similar
conditions for the previous months.
• In addition to appropriate data collection techniques and site evaluation, a records review
demonstrated ongoing maintenance to protect human health and the environment. For example,
Division Staff observed that staff routinely monitored systems for inconsistencies and made
repairs, as necessary. For instance, the crew noted on July 24, 2020 that a flow meter readout
was increasing however there was no fluid exiting the pipe of the leak detection system. They
determined that the flow meter needed repair and it was repaired on July 25, 2019. In another
example, a fire-retardant spill on the decontamination pad in September was immediately
cleaned. 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; Phil
Goble; Logan Shumway (Plant Manager), 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, updated in 2017, are being used to record the data.
No new recommendations were identified during this inspection.
Attachments: 2020 Annual BAT/DMT Inspection Photolog
Photo 1. Water level measurements of Cell 4A. Photo taken on May 7, 2020 and is
looking Northeast.
Photo 3. Repair of the ramp in Cell 4B. Photo taken on October 2, 2017 and is
looking Northwest.
Photo 2. Water level measurement in Cell 1. Photo taken on May 7, 2020 and is
looking West.