DRC-2014-007023 - 0901a068804c0b77

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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-2014-007023
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File C-2014-78
Phil Goble, Section Manager PUG
Russell J. Topham, P.E.
November 26, 2014
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Compliance: 2014 Engineering Module 76, Annual Technical Evaluation Report;
Radioactive Materials License UTI900479 (RML): Findings and Closeout
On November 12, 2014, the Utah Division of Radiation Control (DRC) received the 2014 Annual
Technical Evaluation Report (ATER) dated November 6, 2014 (with cover letter dated November 10,
2014) and covering the November 1, 2013 to October 31,2014 monitoring period. DRC received the
Report in both hard copy and soft copy CD formats.
Summary
After review of the ATER, DRC staff findings and recommendations are as follows:
1. The DRC should monitor performance of the tailings management system closely as Cell 4A fills,
and Energy Fuels Resources (EFR) closes Cell 3 and begins depositing tailings in Cell 4B,
looking for recurrence of historic problems maintaining freeboard. This comment repeats a
notation in the 2012 and 2013 ATER reviews.
General Requirements
2. 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 (the most recent revision) in the preparation of the 2014 ATER. The report
as prepared and submitted meets the requirements for content and timeliness.
Maintaining Freeboard
3. The 2011 ATER contained detail of instances where EFR failed to maintain appropriate freeboard
in the various cells involved in the TMS. The 2012, 2013, and 2014 ATERs contains data
showing that EFR successfully maintained fluid levels without exceeding freeboard during the
2012, 2013, and 2014 monitoring periods. Thus, EFR appears to have resolved the problems that
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historically caused the fluid level to exceed established limits. As processing of ore and alternate
feeds continues, the tailings beach in Cell 4A expands. Given the problems maintaining freeboard
during the 2011 monitoring period, the DRC should monitor freeboard performance closely as
Cell 4A fills, and as EFR retires Cell 3 from actively receiving tailings in favor of Cell 4B.
Monitoring of Lateral Displacement
Movement monitors for Cells 4A and 4B showed no evidence of disturbance.