DRC-2013-003701 - 0901a068803eae1a

53
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
DRC-2013-003701
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
File C-2013-65
Phil Goble, Section Manager ' *~ ^ ' i J
Russell J. Topham, P.E.
December 16, 2013
Engineering Module 75D, Review of the 3rd Quarter, 2013 (July-September, 2013) DMT
Performance Standards Monitoring Report and Cell 4A and Cell 4B BAT Performance
Standards Monitoring Report (Report). Groundwater Discharge Permit (GWDP)
UG370004 - Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding, Utah
This is a summary of Utah Division of Radiation Control (DRC) staff review of the EFR DMT
Performance Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards Monitoring Report
dated November 25, 2013, and covering the 3rd Quarter, 2013 (July-September, 2013) monitoring period
(Report). DRC received the Report on November 26,2013 in both hard copy and soft copy CD formats.
Discussions in this document reference the White Mesa Mill Discharge Minimization Technology (DMT)
Monitoring Plan, Revision 12.1 (DMT Plan). The DMT Plan in force during the period in question was
executed on July 25, 2012.
After review of this report, DRC staff findings and recommendations are as follows:
Findings
1. Weekly monitoring of Cell 1 solution pool elevations occurred as required.
2. The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the DMT/BAT plan in force during the quarter, except as'noted in the discussion
of Cell 1.
3. Data provided in Attachment C to the Report supports a conclusion that EFR has met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
Independent analysis of the data using the prescribed methodology confirms this finding.
4. Monitoring results indicate that the feedstock storage areas were dry at the time of weekly
inspections, except as noted in the next item.
5. During September, the plant received unusually heavy rainfall. The monthly rainfall totaled 2.57
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inches, as measured at the plant. This heavy rain resulted in flooding of an electrical substation
and interruption of power. However, EFRI brought in portable generators in time to facilitate
completion of routine environmental monitoring. The heavy rain and hail on September 18
resulted in a breach of the containment dike at the southwest corner of the ore pad, damage to the
Cell 1 liner, and standing water in several areas of the ore pad over the next week. EFRI used
cleanup techniques appropriate for response to ore spills to address soils released from the secure
area when the dike breached. Liner repairs occurred on September 19 and 20 following approved
protocols. Standing water evaporated quickly once the clouds dissipated. The DRC should
continue to monitor storm water control features under more normal precipitation conditions to
form a better opinion of the efficacy of those features.
6. The storm event identified in Item 5 above revealed a drain line that existed at the plant prior to
DRC achieving agreement state status. The drain line transports fluid from a catchment at the
southwest corner of the ore pad along a path from the ore pad to the east margin of Cell 1,
traversing beneath the security fences and along the south side of the parking area outside the
secure area. This drain line could not transport water at a sufficient rate from the catchment to
prevent overtopping the containment berm during the September 18-19 storm event. In an action
separate from the quarterly DMT reporting process, EFRI proposed to mark the alignment of the
transfer pipe, leaving the pipe exposed for inspection, and adding weekly inspection of the pipe
for leakage for future DMT inspections.
7. EFR has met the requirements for inspecting the New Decontamination Pad, finding no indication
of leakage from secondary containment or other indicators of substandard performance.
8. EFR has met the requirements for inspecting the Old Decontamination Pad, finding no indications
of substandard conditions.
9. EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and detected no
failures to meet those standards for the quarter.
10. The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during the 3rd quarter of 2013.
Recommendations
1. The DRC should issue a closeout letter for the review of this report.
1.0 Tailings Wastewater Pool Elevation Monitoring and Roberts Pond Solution Level Monitoring
Part I.E.7(a) of the G WDP requires EFR to monitor and record weekly the elevation of the wastewater pool
in Tailings Cells 1 and 3 to ensure compliance with Condition 10.3 of the License. Part I.D.3(e) requires
EFR to operate Roberts Pond to provide a minimum two feet of freeboard at all times. Part 3.1(d) of the
DMT/BAT Plan requires EFR to measure the solution pool elevation in Cells 4A and 4B weekly, and the
tailings beach maximum elevation and area within Cells 4A and 4B monthly.
Tailings have nearly completely filled Cell 3. Recognizing this, letters from the Executive Secretary dated
January 27, 2011 and March 14, 2011 formally eliminated the need for solution pool elevation
measurement in Cell 3. The previously cited January 27, 2011 letter and another letter from the Executive
Secretary dated March 15, 2011 concluded a process ending the need for freeboard-related solution pool
elevation monitoring in Cell 4A. However, Part 3.1(a) of the DMT/BAT Plan requires monitoring solution
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pool elevations in Cells 4A and 4B to facilitate determination of compliance with FML leakage rate
limitations.
Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with the
prescribed freeboard requirements.
As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed during
the monitoring period. Attachment A to the report reflects no measurements for the reported quarter.
Attachment A to the Report contains weekly pool elevations for Roberts Pond indicating compliance with
the prescribed freeboard requirements.
Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of calculating
acceptable leak rates for the liner system
Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance
with the prescribed freeboard requirements.
Findings: The data presented in the report demonstrate EFR compliance with the solution pool operational
requirements of the DMT/BAT plan in force during the quarter.
2.0 Slimes Drain Water Level Monitoring
Part I.F.2 of the GWDP requires EFR to include in the Report, all DMT performance standards monitoring
detailed in Parts I.D.3 and I.E.7 of the GWDP. Part I.D.3(b)(l) of the GWDP requires EFR to maintain the
fluid level in the slimes drain of Cells 2 and 3 as low as reasonably achievable at all times, and to
demonstrate that performance through adherence to the current DMT Monitoring Plan. Part I.E.7(b) of the
GWDP requires monthly monitoring and recording of the depth to wastewater in the slimes drain access
pipe as described in Part I.D.3 of the GWDP and the current DMT Monitoring Plan. Part 3.1(b)(v) of the
DMT Monitoring Plan requires EFR to monitor and record weekly the depth to wastewater in the Cell 2
slimes drain access pipe to determine maximum and minimum head before and after a pumping cycle,
respectively.
Section 4.1 of the Report asserts that the above discussed monitoring requirements only pertain to Cell 2
for the reporting period, as dewatering operations have not commenced in Cell 3.1 concur with this
assessment.
Weekly water level monitoring of the Cell 2 slimes drain is not required as part of the DMT plan, but is
required under Part I.D.3(b)(l) of the GWDP. EFR retains records of Cell 2 slimes drain monitoring at the
mill.
Attachment C to the Report contains data from the quarterly recovery head measurements (discussed in the
next paragraph). The recovery head monitoring data provides indirect evidence that EFR has maintained
the fluid level in the Cell 2 slimes drain as low as reasonably achievable, as required in GWDP, Part
I.D.3(b)(l).
Finding: Data provided in Attachment C to the Report supports a conclusion that EFR has met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
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3.0 Feedstock Storage Monitoring
This section addresses both bulk conventional feedstock (ore) and alternate feed stored onsite. Ore is stored
on the ore pad. Part 1 .D.l 1 of the GWDP anticipates and governs storage of alternate feed outside the
confines of the ore pad.
Weekly inspection revealed no evidence of ore beyond the boundaries of the ore pad. Storage practices for
alternate feeds appeared compliant with GWDP requirements. No standing water was noted in feedstock
storage areas during the quarter, except as discussed below.
The plant experienced heavy precipitation during September, accumulating 2.57 inches at the site. All
facilities performed well except during the period from September 18 through 20. While a storm on
September 10 recorded a higher total rainfalfthan the storm on September 18, precipitation fell for much of
the day on September 10. By contrast, the September 18 storm contributed most of its precipitation during
a 30-minute period.
Drainage from roughly the southern half of the ore pad collects in a catchment at the southwest corner of
the ore pad. The catchment consists of a concrete structure. A HDPE pipe conveys water from the
catchment, beneath the security fence, along the south side of the plant parking area, and back into the
secure area south and west of the parking lot. EFRI had constructed a berm to aid in directing water to, and
retaining water in the catchment. This storm water control system dates back to a time prior to Utah
receiving agreement state status.
The storm water control systems at the southwest corner of the ore pad could not handle the storm peak.
Water overtopped the containment berm, carrying soil from the ore pad beneath the security fence, and
depositing it along the pipe alignment. EFRI personnel used protocols designed for cleanup of an ore spill,
including radiation surveys, to prosecute and verify effectiveness of the cleanup of released soils. All soil
thus recovered was deposited in tailings Cell 3.
Following each of the September storms, it took two to three days for standing water to dissipate.
Inspectors report standing water no deeper than 3 inches at its deepest. Once sunny conditions returned, the
water evaporated rapidly. Minor regrading of the ore pad surface could improve drainage. However, that
fine grading would change with every new load of ore brought in or transported to the grizzly for
processing. Inasmuch as the incidents where inspectors detected standing water occurred within a day or
two after a storm event, I cannot yet formulate a recommendation for corrective action.
Finding: Monitoring of the feedstock storage area occurred as required. The data support a conclusion
that no feedstock existed outside the designatedfeedstock storage areas. Unusually wet weather
contributed to detecting much more standing water than would normally occur.
Recommendation: The DRC should continue monitoring quarterly reports, and review in the field the
drainage performance of the ore pad during more normal precipitation conditions. From those
observations, better conclusions can be drawn.
4.0 Tailings Cells and Pond Liner System Repairs
Weekly inspection of all cells and of Roberts Pond occurred weekly during the period covered in the
report. The only liner damage identified during routine inspections occurred during the storm event of
September 18. Either hail or rolling rocks left several star-shaped punctures in the Cell 1 liner. These
punctures occurred well above the solution level, in areas of liner exposed as a result of erosion during an
intense storm event. Crews performed repairs on September 19 and 20 following approved protocols.
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Finding: EFR met the requirements for inspection of the liner systems and appropriately repaired all
detected damage.
5.0 Decontamination Pads
Weekly inspection of the New Decontamination Pad occurred as required under Part I.F.I 2 of the GWDP.
The monitoring portals were dry during all inspections, indicating no leakage from primary containment.
Annual inspections for both decontamination pads occurred during the second quarter of 2013, on April 9
and 10, resulting in no requirements for remedial action. EFR performed preventive crack sealing even
though no cracks exceeded the 1/8-inch limit.
Finding: EFR has met the routine and annual requirements for inspecting both the Old and New
Decontamination Pads, finding no indication of leakage from secondary containment.
6.0 Cells 4A and 4B BAT Performance Standards Monitoring
Requirements for measuring BAT performance for Cells 4A and 4B include verifying that leak detection
system equipment operates appropriately, verifying that fluid head in the leak detection system sumps does
not exceed 1 foot above the lowest point in the secondary (lower) flexible membrane liner, and recording
the volume of fluid pumped from the leak detection systems for the two cells. EFR must also record the
fluid head in Cell 4B for compliance purposes, and in Cell 4A for computation of acceptable leakage rate
in Cell 4A. The data provided in the report and its attachments provide evidence of compliance with the
Cells 4A and 4B BAT performance monitoring standards in place during the monitoring period.
Finding: EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and detected no
failures to meet those standards for the quarter.
7.0 Cells 1,2 and 3 Leak Detection System Monitoring
Leak detection system monitoring requirements for Cells 1, 2 and 3 appear in the Radioactive Materials
License rather than the GWDP. For consistency, the DRC requested that this monitoring be included as
part of the quarterly report, and EFR has consented to do so.
The report and its attachments contain weekly monitoring data for the operational status of the leak
detection system equipment, fluid levels detected in the leak detection systems, and volumes of fluid
pumped. From the data, EFR represents that no failures of the monitoring equipment occurred that were
not corrected within 24 hours. Leak detection systems for the three cells measured dry; therefore, no fluids
were pumped therefrom.
This storm overtopped conveyance controls within the plant, forcing plant personnel to shut down the
electrical substation north of the main process building. Ultimately, several feet of water flooded the
substation. EFRI brought in portable generators, and all required monitoring occurred on schedule.
Finding: The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during the 3rd quarter of 2013.