DRC-2012-002681 - 0901a0688034661b

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO
THROUGH
FROM
DATE
SUBJECT
File
Phil Goble, Section Manager
Russell J Topham, P E
November 29, 2012 2012-0U268 1 Comphance 2012 Engineenng Module 76, Annual Technical Evaluation Report,
Radioactive Matenals License UTI900479 (RML) Findings and Closeout
On November 16, 2012, the DRC received the 2012 Annual Techmcal Evaluation Report (ATER) dated
November 15, 2012 and covenng the November 1, 2011 to October 31,2012 monitoring penod DRC
received the Report in both hard copy and soft co)py CD formats
Summary
After review of the ATER, DRC staff findings and recommendations are as follows
1 The movement monitors along the south side of Cell 4A are in the center of the road atop the
dike Grooming activities endanger the momtonng points DRC recommends relocating those
momtonng points to the outer shoulder of the dike, as was done for Cell 4B, to prevent disturbing
the momtors
2 The DRC should monitor performance of the tailings management system closely as Cell 4A fills,
and EFR closes Cell 3 and begins depositmg tailings in Cell 4B, looking for recurrence of histonc
problems maintaimng freeboard
General Requirements
3 Condition 12 3 of the RML requires preparation of the ATER, specifies the content, and fixes the
date by which the DRC must receive the ATER The Tailings Management System (TMS)
document guides much of the work reviewed and reported in the ATER EFR used TMS revision
2 1, dated July, 2012 in the preparation of the 2012 ATER TMS Revision 2 1 presented stncter
requirements for tailings management in one or two particulars, and received DRC approval on
July 25 2012 TMS Revision^2 1 did not take effect until the approval date, thus, relying on
Revision 2 1 in the preparation of the ATER represents a more aggressive approach to
compliance than relying on its predecessor for the penod preceding the approval date The report
as prepared and submitted meets the requirements for content and timeliness
168 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
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Page 2
Maintaining Freeboard
4 The 2011 ATER contained detail of instances where EFR failed to maintain appropriate freeboard
in the vanous cells involved in the TMS The 2012 ATER contains data showing that EFR
successfiilly maintained fluid levels without exceeding freeboard during the momtonng penod
Thus, EFR appears to have resolved the problems underlying the freeboard exceedances observed
in the past Placing Cell 4B in service appears as a cntical element in resolving the freeboard
exceedance issues previously expenenced Additionally, repainng the liner in Cell 1 and placing
It back in service certainly provides an added measure of safety The 116,200 tons of
conventional ore and 6,900 tons of altemate feed processed dunng the compliance penod
provided tailings sufficient to fill a sigmficant portion of Cell 4A Given the problems
maintaimng freeboard durmg the 2011 momtormg penod, the DRC should momtor fi-eeboard
performance carefiilly as Cell 4A fills, and as EFR retires Cell 3 from actively receiving tailmgs
in favor of Cell 4B
Monitoring of Lateral Displacement
5 The annual movement monitor survey for Cell 4A reports 8 of 28 momtor pomts as disturbed
Review of the movement momtor survey for Cell 4B reveals no disturbed momtor pomts A
cursory review of the data for Cell 4A leads to a hypothesis that not all of the momtor pomts were
disturbed dunng the momtonng penod, but that the problem has accumulated over time On
September 20 and 21, 2012, DRC staff performed a DMT/BAT field mspection as specified under
Engineermg Module 75E Dunng that mspection, staff noted placement of the Cell 4A momtor
points near the center of the roadway atop the perimeter dike, and placement of the Cell 4B
momtor points on the shoulder of the roadway In a letter dated September 28, 2012 detailing the
findings of the annual DMT/BAT field inspection, the DRC suggested moving the Cell 4A
movement momtors to the shoulder of the roadway to reduce the potential for disturbance dunng
maintenance activities The data provided in the ATER supports this recommendation The DRC
should reiterate the recommendation to move the movement momtor points for Cell 4A to the
shoulder of the dike, mirronng the location for Cell 4B momtor points