DRC-2014-003683 - 0901a068804423c9

Department of
Environmental Quality
Amanda Smith
Execuiive Director
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director DRC-2014-003683
SPENCER J. COX
Lieutenant Governor
MEMORANDUM
TO: File C-2014-74
THROUGH Phil Goble, Section Manager
FROM: Russell J. Topham, P.E.
DATE: June 2,2014,2014
SUBJECT: Engineering Module 75B, Review ofthe 1st Quarter, 2014 (January-March, 2014) 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 May 13, 2014, and covering the 1st Quarter, 2014 (January-March, 2014) monitoring period
(Report). DRC received the Report on May 15, 2014 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), executed on July 25, 2012.
After review of this report, DRC staff findings and recommendations are as follows:
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.
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 within a short time following precipitation events.
5. EFR met the requirements for inspection of the liner systems and appropriately repaired all
detected damage, except for the ongoing work at Roberts Pond. In the case of Roberts Pond, the
repair effort is ongoing, and involves radiological surveys and cleanup of radiological and
195 North 1950 West • Salt Lake City, UT
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Findings
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chemical releases prior to placing new liner.
6. 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.
7. EFR has met the requirements for inspecting the Old Decontamination Pad, finding no indications
of substandard conditions.
8. EFR has met the monitoring requirements for Cell 4A and 4B BAT performance and detected no
failures to meet those standards for the quarter.
9. The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during the 4th quarter of 2013.
Recommendations
1. The DRC should continue monitoring quarterly reports, and review in the field the drainage
performance of the ore storage pad during more normal precipitation conditions. From those
observations, the DRC can refine its conclusions.
2. The DRC should complete hydrogeologic review of the remediation design at Roberts Pond and
determine whether to add a line item to surety for removal of residual contamination at the time of
decommissioning. This can be done as a separate action item.
3. 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 GWDP 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) ofthe
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
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. Note that operators at the mill discovered damage to the Roberts
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Pond liner on March 13, 2014, and withdrew all water from the pond at that time to facilitate investigation
and repair. The pond remains empty of fluids at the time of this writing.
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 ofthe 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. I 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.
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.
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The Report covers a period of time characterized by winter storms. Thus, small amounts of standing water
may remain on the day of any given inspection if preceded by storm events. In reports covering monitoring
periods prior to the 4th Quarter of 2013, EFR had noted a "small amount" of standing water from time to
time. In a letter dated July 23, 2013, the DRC requested that EFR provide more complete estimates of the
"small" amounts of water identified. In response, EFR has included as Appendix H to the Report maps
which detail the location, size and maximum depth of the storm water encountered at each inspection.
These maps make clear that the remaining storm water represents trivial remnants of storm runoff captured
in local imperfections in the grading, and that routine maintenance prevents these low spots from
remaining for long; the same pool rarely occurs in consecutive reports. From this evidence I conclude that
EFR has met the intent of the requirement to eliminate standing water. Standing water generally dissipates
in two to three days, except when cold temperatures prevent evaporation or subsequent storms replenish
the pool.
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 a short time following a storm event and did
not remain long, corrective action appears unnecessary.
Finding: Monitoring of the feedstock storage area occurred as required. The data support a conclusion
that no feedstock existed outside the designated feedstock storage areas. Standing water collects in shallow
pools during storm events, but dissipates rapidly with sunny weather.
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, the DRC can refine its conclusions.
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 report indicated no case of liner damage in the tailings cells discovered or repaired during the
quarter. However, crews did detect liner damage in Roberts Pond on March 13, 2014. EFR notified the
DRC verbally on March 13, 2014 of the damage, and followed that notice with a letter on March 18, 2014.
EFR believes that the damage is undetected tears from a 2012 attempt to clean sediment from the pond.
Crews at that time (2012) repaired the damage that was detected. The pond has been drained, and full
replacement of the liner is anticipated based on previous conversations with EFR.
Without belaboring the details of the cleanup effort EFR proposes, EFR will establish a grid pattern with
points on ten foot centers spanning an area a little larger than that encompassed by the liner anchor trench.
Soils measuring gamma contamination more than 10% over background will be removed to cell 3 for
disposal prior to regrading. EFR has attempted to quantify the volume of fluid released through visual and
laboratory (moisture content) methods, with a conservative bounding estimate using theoretical modeling.
The estimates provided to the DRC seem reasonable. EFR has proposed to complete the cleanup to
physical limits established and modified during the cleanup effort to reflect observations and measurements
made during excavation. I recommend having a hydrogeologist review the cleanup design, and discussing
the findings of that review with EFR to determine whether to seek an increment of funding for surely to
cover responding to a discovery during decommissioning of residual contamination from this release.
Finding: EFR met the requirements for inspection of the liner systems and appropriately repaired all
detected damage, except for the ongoing work at Roberts Pond. In the case of Roberts Pond, the repair
effort involves radiological surveys and cleanup of radiological and chemical releases prior to placing
new liner.
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Recommendation: Complete hydrogeologic review of the remediation design and determine whether to add
a line item to surety for removal of residual contamination at the time of decommissioning.
5.0 Decontamination Pads
Weekly inspection of the New Decontamination Pad occurred as required under Part I.F. 12 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 BA T 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 I, 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.
Finding: The leak detection systems in Cells 1, 2 and 3 appear to have operated properly, and no fluids
were detected therein during the 4'1' quarter of 2013.