DRC-2013-002791 - 0901a0688039ff0f

1
Department of
Environmental Quality
Amanda Smith
Executive Director
• I DRC-2013-002791 II
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
June 21, 2013
Jo Ann Tischler
Director Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 17th St. Suite 950
Denver, Colorado, 80265
Subject: Transmittal of Findings of the Utah Division of Radiation Control June 4,2013 Storm
Water Inspection at the WHiite Mesa Uranium Mill: DRC Close-out
Dear Ms. Tischler:
This is to transmit the findings of the Utah Division of Radiation Control (DRC) 2013 storm water
inspection which took place on June 4, 2013 at the White Mesa Uranium Mill (Mill). A copy of
the DRC modular inspection memo (DRC Groundwater Module 65) is attached for your records.
Based on the inspection findings, it appears that EFR is in compliance with Utah Ground Water
Discharge Permit, Permit No. UGW370004 Parts I.D. 10 and I.D.I 1. The 2013 Mill Storm Water
Inspection is therefore closed-out.
If you have any questions regarding this letter please contact Tom Rushing at [phone].
Rusty Lundberg
Director
RL:TR:tr
Enclosure: DRC Groundwater Module 65 Memo
F \Energy Fuels\Storm Water Management\2013 SW Inspection\White Mesa Mill 2013 SW Inspection Close-out Ltr docx
Sincerely,
. 195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D [phone]
www deg Utah gov
Printed on 100% recycled paper
Utah Division of Radiation Control (DRC)
Ground Water Module 65, DRC Annual Storm Water Inspection
Denison Mines, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2013
Inspection Date: June 4, 2013
Module Reviewer Name/Initials:
Phil Goble, Compliance Section Manager
Module Prepared by/Date Prepared:
Tom Rushing, P.G./June 17,2013 (>- /? - 2o )3
DRC Staff Present:
Tom Rushing
Denison Mines Staff Present: David Turk
Tanner Holliday
Denison Mines Staff Interviewed: David Turk
Tanner Holliday
Garrin Palmer
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the
White Mesa Uranium Mill:
Date: September, 2012
Revision No. 1.5
Section I - Document Review
SWBMPP (Documentation Requirements):
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.
Findings:
The Utah Division of Radiation Control ("DRC") conducted an inspection of upland
Diversion Ditch 1 and Berms as shown on the Energy Fuels Resources ("EFR") Storm Water
Best Management Practices Plan, Figure 2. DRC found Ditch 1 and berms to be well
I
maintained. Photos of Ditch 1, taken during the day of the inspection are included the memo
appendix 1, photos 39 and 40.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DRC reviewed the March 29, 2013 monthly
form and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion Ditches 1, 2
and 3 showed no sloughing, erosion, undesirable vegetation or obstructions of flow, and that
"diversion ditches are in good condition"
Spill Prevention* Control, and Countermeasures Plan (SPCC) (Documentation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
Findings: Per the EFR response to an 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 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. DRC concurred
with this action and this item has been removed from the storm water inspection at the mill.
1.9.1. - External Notification of "reportable quantity" spills.
Findings: No reportable quantity spills occurred during the period reviewed, DRC has no
additional comments.
1.9.2. Internal Notification of incidents, spills, and significant spills.
Performance Standards (list):
In response to a DRC Request for Information item by letter dated September 1, 2011,
regarding the findings of the DRC 2010 storm water inspection, EFR provided a change to
the small quantity spills protocols in the October 17, 2011 response letter, as follows:
"EFR has implanted an internal notification process for small quantity spills (less than
reportable quantities), with the following steps:
1) Mill environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size. The form will be amended to add spaces for this item.
2) In addition, all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day, and these will also be noted in the daily
inspection form.
3) If the spill is of a reportable quantity, environmental personnel will follow the procedures
in the Mill's SWBMPP plan.
2
4) For spills smaller than reportable quantities, the environmental inspector will record
information regarding the spill, and the nature and type of cleanup, on the form.
5) The information on the inspection form will be added to a database maintained at the Mill.
The database will be updated and maintained on site indefinitely. Cards are maintained for
no longer than one year."
These corrective actions were reviewed during the DRC June 21, 2012 storm water
inspection as well as the current June 4, 2013 inspection. Per the reviews DRC noted that a
process for internal reporting of spills less than reportable quantities was instituted during
2012 and underwent additional improvement during 2013.
The White Mesa Mill employees are using an orange 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. Per the 2013 orange cards, the following spills were recorded during 2013 at the
date of the inspection (6/4/2013).
Date of
Discovery
1/27/2013
2/7/2013
3/1/2013
3/6/2013
4/1/2013
4/3/2013
4/22/2013
5/2/2013
5/17/2013
5/20/2013
5/23/2013
5/26/2013
5/27/2013
5/31/2013
Material Spilled
CCD Fluid
Soda Ash
Ore Process Solution
Oil
Yellow Cake Liquor
VPL Liquor
Decant Material
Soda Ash
Sulfuric Acid
Vanadium Material
Product Return Solution
Uranium Hexafluoride
Ore Slurry
Hydraulic Fluid
Quantity Spilled
200 gallons
3 gallons
1,600 gallons
400 gallons
5 gallons
Vz bag
10 gallons
4 gallons
500-1,000 gallons
XA bucket
1,000 gallons
10+'gallons
DRC sees the new spill reporting process as very effective. EFR has additionally started
attaching photographs of the spill and clean-up activities to the orange card when deemed
appropriate and per DRC review of the follow up actions it is noted that mill personnel are
taking responsibility to clean-up spills.
DRC notes that the spill reporting training program required under the requirements of the
Spill Prevention, Control, and Countermeasures Plan for Chemicals and Petroleum Product,
Section 1.11., and also outlined in the EFR response as a corrective action, has been
implemented since the last inspection findings and confirmatory action letter (August 8,
2012).
EFR has implemented the training program in two parts, one training is required for the
environmental personnel at the mill and a second has been required of all employees at the
mill. Per the attendance logs, all environmental personnel attended the training on 1/7/2013
and all other mill employees received the training as follows:
4/26/2013 - 25 employees
4/29/2013 T 24 employees
5/1/2013 - 66 employees
5/3/2013 - 31 employees
5/8/2013-10 employees
Total employees trained - 156
The employee training is 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: 10/1/2012 to 10/31/2012 and 3/1/2013 through 3/31/2013
No. of On-site Records Required: Daily, Weekly and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: 10% (Percent of Total)
How Selected: DRC Inspected two full months of daily, weekly and monthly forms
requested at random
Daily Tailings Inspection Data:
Findings:
EFR inspection of: 1. Tailings slurry transport system (Slurry pipeline, pipeline joints and
supports, valves and point of discharge); 2. Operational systems (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.
DRC randomly selected and reviewed all of the daily forms for the months of October 2012
and March 2013. The forms appeared to be appropriate and inspections were conducted on
all days. There are no additional comments regarding the forms.
4
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.
Per the 2013 DRC storm water inspection, the inspections were completed, there are no
additional comments regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness:
Findings:
The monthly inspection report includes; 1. A summary of the slurry pipeline condition and
measurement of pipe thickness, which is applicable only when the Mill is operational; 2.
Inspection protocols and observations related to the diversion ditches, berms, sedimentation
pond, dust control, settlement monitors, and slimes drain static head measurements for Cells
2 and 3.
DRC reviewed the monthly inspection report dated March 29, 2013. Note that the monthly
inspection reports include comments related to the upland diversion ditches which noted that
the "ditches are in good condition." Per inspection findings DRC confirmed that the ditches
were well maintained. DRC has no additional comments related to the reviewed monthly
inspection report.
Tank to soil potential measurements:
Findings:
This item was included as part of the September 1, 2011 RFI, RFI # 2. DRC had concerns
regarding on-grade tanks (tanks where the bottom is in contact with soil. Per DRC
communication with EFR it was clarified that tanks which sit on the ground must have ^
cathodic protection or sit on a concrete foundation.
Per DRC inspection of the tank foundations during the 2013 inspection, all concrete
foundations appeared in good condition.
Annual bulk oil and fuel tank visual inspections:
Findings:
In response to a DRC request for information, EFR reviewed the White Mesa Mill Spill
Prevention Countermeasure and Control ("SPCC") Plan for the mill to ensure that all
5
inspection processes and oil containers are in conformance with those Federal (40CFR112)
regulations. In response (EFR September 7, 2012 letter), EFR removed the SPCC Plan as an
appendix to the SWBMPP. EFR additionally removed the Emergency Response Plan as an
appendix to the SWBMPP. The removal of these documents was done in order to maintain
each plan as a stand-alone document. EFR states in the September 7,2012 letter that "the
requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are not part of the SWBMPP and are addressed separately in other
documents, specifically, the Spill Prevention control and Countermeasures Plan, the
Emergency Response Plan, and the housekeeping procedures within Mill SOP's" Per
comments related to inspection of the propane tanks and applicability of those requirements
in the SPCC Plan, a revised copy was submitted with the September 7, 2012 letter (SPCC
Plan dated September, 2012).
DRC has no additional comments regarding the SPCC Plan, and future storm water
inspections will focus on insuring that the SWTBMPP adequately addresses all requirements
of the Permit, including spill reporting requirements in Part I.D. 10, which specifically
requires actions for identification and cleanup of reagent and chemical spills for non-
reportable quantities and procedures for reportable quantity spills in conformance with Utah
Administrative Code 19-5-1J4.
Tank and pipeline thickness tests:
Findings: During the inspection period the slurry pipelines were noted to be in good
condition. DRC has no additional comments related to the pipeline tests.
Quarterly and annual PCB transformer inspections (currently PCB only):
Findings: The Mill currently does not currently inspect the transformers based on all
transformers containing non-PCB based oil.
Spill Incident Reports:
Findings: This item is discussed above in the section related to reportable and small quantity
spills. DRC notes that an effective spill reporting and tracking system has been implemented
at the Mill.
Latest revision of SPCC plan (onsite and available?):
Findings: The SPCC plan was not requested during the inspection.
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 DRC findings the personnel training has been
implemented and appears to be effective. All Mill staff received training regarding the small
6
quantity spill notification process. DRC has no additional comments related to personnel
training.
Section II — Site Walk through Inspection
Areas and Observations:
Ore Storage:
Observations: All berms appeared to be in good condition, there was no ore stored on the
pad at the time of the inspection (Photos 3, 5 and 6). There are no additional comments
regarding the ore storage area.
Reagent Yard:
Observations: Per DRC inspection of the reagent yard and storage building, it appeared that
drum storage was appropriate. No degraded or tapped drums were noted in those areas.
Shop/Vehicle Maintenance Area:
Observations:
Oil Drum Storage Rack:
Per the 2013 inspection all drums were stored on the pallets and no observable fluid
accumulation was seen in the pallet secondary containments. (Photo 13)
Shop Building Drain to Baffle Box:
Per DRC inspection of the shop baffle box, no comments were noted (Photo 16).
Used Oil/Kerosene Tank North of Shop Building:
v
Per DRC inspection of the used oil tank and kerosene tank containment, it appeared that
previous violations concerning spills outside of the containments were addressed; no
additional issues/comments were noted. (Photo 14,15)
Mill Processing Areas:
SX Building Roof Drainage:
Per the 2013 inspection, issues related to the roof drainage and discharges into the alternate
feed circuit have been addressed. DRC communicated to the EFR staff that the drainage
needs to be inspected during a storm event to ensure that all roof drainage is diverted in the
directions intended. Specifically, the roof drainage is intended to divert either to cell 1 (south
side of building drainage) or to Roberts Pond (roof north side of building). (Photos 31
through 35) c
Alternate Feed Circuit South of SX Building:
Observations:
All feedstock at the alternate feed circuit was stored and managed on the new concrete pads.
The concrete pads appeared to be in good condition. DRC has no additional
comments/observations regarding the alternate feed area. (Photos 26 through 30)
Old Decontamination Pad:
DRC has no comments regarding the old decontamination pad.
New Decontamination Pad:
Observations:
The pump back system and east apron drainage appeared to be in good condition (Photos 7,
8). DRC staff had no additional comments.
Reagent Tanks:
Sodium Chloride Tanks - Per past agreements between DRC 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, and in Part
I.D.3(g). No issues were noted during the 2013 inspection.
Kerosene Tanks (West of Shop) - Appeared in good condition, no additional comments.
Note: Secondary containment is earthen under the same agreement as the sodium chloride
tanks.
Ammonia Tanks - DRC noted that the tank was undergoing maintenance/refurbishing at the
time of the inspection (sandblasting and re-painting). Secondary containment is earthen per
the same agreement as the sodium chloride tanks. (Photo 4)
Used Oil Tank (shop) - Appeared in good condition, no additional comments.
Kerosene Tank (shop) - Appeared in good condition, no additional comments.
Fuel Tanks - Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks - Secondary containment appeared to be in good condition (Photo
22). DRC had no additional comments regarding tanks or secondary containment.
8
(
Vanadium Pregnant Liquor (VPL) Tanks - The VPL tank steam condensate containment
area, tanks and foundations appeared to be in good condition. (Photo 17)
Clean Water Tank - DRC noted that a new water treatment house is being constructed
which should eliminate the leaks previously observed at the old chlorination house (Photos
23,24). No additional comments.
Sulfuric Acid Tank - The tank and berm appeared in good condition. No additional
comments.
Caustic Soda Tank - Per the 2013 inspection it was noted that, in response to Confirmatory
Actions, the caustic acid secondary containment area has been re-poured and that a new tank
has been installed (Photo 36). No additional comments.
Soda Ash Tanks - The Soda Ash Tanks and Secondary Containment appeared to be
maintained. DRC noted that water from the chloroform pump system was being discharged
into the containment area drain. DRC has no comments regarding this area. (Photos 37, 38)
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC 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. The dikes appeared to be in overall good
condition. (Photos 41,42,43)
Summary of Onsite Closeout Meeting:
Date/Time: June 21, 2012/11:30 P.M.
EFR Representatives Present — Daniel Hillsten, Mill Manager
David Turk
Tanner Holiday
DRC Representatives Present - Tom Rushing
An onsite close-out meeting took place amongst Tom Rushing (DRC), Dan Hillsten (EFR
Mill Manager), David Turk (EFR) and Tanner Holliday (EFR). During this meeting, DRC
informed the EFR representative of the inspection findings above.
Conclusions
A close-out letter regarding the 2013 storm water inspection will be sent to EFR. DRC notes
that overall, the Mill facility storm water management and spill training and reporting has
significantly improved in recent years.
F \Energy Fuels\Storm Water Management\2013 SW InspectiorAWhite Mesa Mill 2013 SW Inspection Memo docx
9
InsPection
2013
APPendix l
10
Utah Division of Radiation Control
2013 Annual Storm Water Inspection
Inspection Date June 4, 2013
Photo Pages
w
Photo 1 - Kerosene tanks on cement platforms
1
St
Photo 2 - Sodium chlorate tanks in cement containment
1 J
Photo 3 - Berm along the western margin of the ore pad
Photo 4 - Storm water detention southwest corner of ore pad - drains to cell 1
Photo 5 - Ore pad and south berm, photo looking southeast
Photo 6 - Ore pad, No ore piles
Photo 7 -southeast ore pad berm and lined drainage ditch
Photo 8 - New Decontamination pad pump back system in cement containment
Photo 9 - Ore Pad east side (note that the ore pad is graded to drain to the west)
\
Photo 10-Ore pad east margin berm looking north
Photo 11 - Ore pad looking northwest
Photo 12 - Drum storage at maintenance shop (drums on containment pallets)
£- -
V
sr
Photo 13 - Containment under drum storage at the maintenance shop
Photo 14 - Used oil and kerosene tanks and containment (north side of maintenance shop)
Photo 15 - Kerosene tank valve (note stain was from previous noted leak, tank has been moved further into
containment area since that time)
•LA
Photo 16 - North side of maintenance building baffle box containment (box is pumped to Roberts Pond)
Photo 17 - Vanadium Pregnant Liquor (VPL) Tanks on concrete platforms
Photo 18 - Mill building looking southwest
Photo 19 - Grizzly (Ore in drums to be used for stack tests)
Photo 20- Mill building east side (foreground corner marker for Phase III ammonium sulfate crystal tank geoprobe
investigation)
Photo 21 - Chemical storage building
Photo 22 - Tank containment east side of Mill Building
Photo 23 - New water treatment building (clean water treatment and chlorination)
Photo 24 - Old clean water chlorination building will be removed
Photo 25 - Clean water tank overflow drains to underground pipe system
Photo 26 - Alternate feed storage pad
Photo 27 - Alternate feed processing area
—IIII In I IHMillBW|Bar|MIEffl3j
Photo 28-Alternate Feed storage pad looking southeast
Photo 29 - Alternate feed storage pad looking northeast (note puddle low spot on pad)
Photo 30 - Alternate feed pad, drums waiting to go on processing rack
Photo 31 - SX building roof drainage gutter, drains to cell 1
Photo 32 - underground pipe for roof drainage from SX building
Photo 33 - SX building roof drainage, west side of building drains to Roberts Pond
Photo 34 - Drainage from SX roof to Roberts Pond
mmim
Photo 35 - SX building and drainage
Photo 36 - Caustic Soda Tank containment (new containment)
" mi
• I
Photo 37 - Soda ash tank containment, note that containment has been patched. Water in containment is from
groundwater pumping well for chloroform ground water contamination
•...
Photo 38 - Caustic soda tank containment drainage into SX building
Photo 39 - Upland diversion ditch 1 well maintained
Photo 40 - Upland diversion ditch 1
Photo 41 - Berm and toe for cell 4A well maintained, note vegetation
Photo 42 - Cell 4A well maintained, note vegetation • Photo 43 - Cell 4A berm well maintained
Photo 44 - Cell 4A/4B spillway
Photo 45 - Surplus storage area, note berm in background
Photo 46 - Surplus storage area, note berm in background