DRC-2019-002684 - 0901a068809f0e9c

State of Utah
GARY R. HERBERT
Governor
Spencer J. Cox
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
W-C-z0/ 9 -692_604-
MEMORANDUM
TO: File C-2016-94
THROUGH: Phil Goble, Section Manager pe
FROM: Russell J. Topham, P.E.
DATE: March 18, 2019
SUBJECT: Inspection of Primary Radon Barrier on Tailings Disposal Cell 2. Radioactive Materials
License UT1900479 (License) - Energy Fuels Resources (USA) Inc. (EFR) White Mesa
Mill, Blanding, Utah.
On March 14, 2019, I traveled to the White Mesa Mill to perform two inspections, including an inspection
of maintenance of the primary Radon barrier on Tailings Disposal Cell 2 detailed herein, on behalf of the
Utah Division of Waste Management and Radiation Control (DWMRC). The construction reflects the as-
yet unapproved requirements of Reclamation Plan 5.1. The additional inspection was the annual Dam
Safety Inspection which the Division does on odd-numbered years and the State Engineer's Office does on
even-numbered years. That inspection is detailed in a separate report.
Phil Goble and I checked in at the White Mesa Mill at 7:15 AM on March 14, 2019, and asked to see Terry
Slade, Site Radiation Safety Officer. Mr. Slade assigned Mr. Tanner Holliday (Environmental Lead) to
accompany us on this inspection.
When we arrived at Cell 2, Mr. Holliday indicated that he had several examples of erosion to share with us
due to a wet late winter and early spring. See Photos 3 through 8 in the attached Photo Log for examples
of the condition of the south slope of the cover. Wet conditions had hindered efforts to repair the cover.
Driving on the cover would have rutted the cover deeply except during periods when the cover was frozen,
under which conditions material compaction could not have been performed satisfactorily. From this
explanation, and the wet conditions prevailing at the time of the inspection, it is clear that EFR is aware of
the need to repair the erosion rills, and has reason to delay performing the work. The top of the cover is
unaffected by the weather and the erosion on the south slope. No photos were taken to document the
condition of the cover surface.
We visited both the primary and secondary test sections for the evapotranspirative cover system
demonstration pr9ject. See Photos 1 and 2 in the attached Photo Log. Both show emerging vegetation
with the wet winter, but it is early yet to determine whether the emerging plants represent target species or
annual weeds.
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.cleq.utah.gov
Printed on 100% recycled paper
C-2015-54
Memorandum: Inspection of March 14, 2019
Page 2
Finding: EFR appears to have followed reasonable and prudent decision making with respect to
maintaining the south slope of the Cell 2 cover system. Maintenance work is required once such can be
done without damaging the cover.
Finding: Wet conditions have encouraged growth of vegetation on the two cover test sections. It is too
early to discern whether the emerging vegetation is planted species or weeds. It is also too early to
determine i f the vegetation growth will be lasting, especially during dry periods.
Recommendation: I recommend closing out the inspection of March 14, 2019. Follow-up inspection can
be accomplished during later visits to the site to evaluate repair of erosion rills observed during this
inspection.
I discussed this inspection with Logan Shumway, the Mill Manager, Teny Slate, Steve Snyder and Tanner
Holliday prior to departing.
Attachments: Photo Log
Photo 1: Looking northwest across the evapotranspirative cover primary test
section. Photo taken March 14, 2019.
Photo 2: Looking southward across the evapotranspirative cover secondary
test section. Photo taken March 14, 2019.
Photo 3: Looking northward at south edge of Impoundment 2 cover. Note the
weather-related erosion. Photo taken March 14, 2019.
Photo 42: Looking northward at south edge of Impoundment 2 cover. Note the
weather-related erosion Photo taken March 14, 2019.
Photo 7: Looking northward at south edge of Impoundment 2 cover. Note the
weather-related erosion Photo taken March 14, 2019.
Photo 8: Looking northward at south edge of Impoundment 2 cover. Typical of
most of the south slope, this shows no erosion. Photo taken March 14, 2019.
Photo 5: Looking northward at south edge of Impoundment 2 cover. Note the
weather-related erosion and the ponding above the rills Photo taken March 14,
2019.
Photo 6: Looking northward at south edge of Impoundment 2 cover. Note the
weather-related erosion Photo taken March 14, 2019.