DRC-2014-006334 - 0901a068804ac388

DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
Department of
Environmental Quality
Amanda Smith
Executive Director
GARY R. HERBERT
Governor
DRC-2014-006334 SPENCER J. COX
Lieutenant Governor
MEMORANDUM
TO: File C-2014-99
THROUGH: Phil Goble, Section Manager
FROM: Russell J. Topham, P.E. f DATE: October 20, 2014
SUBJECT: Roberts Pond Remediation Update, Energy Fuels Resources (EFRI), White Mesa Mill,
On March 18, 2014 Energy Fuels Resources Inc. (EFRI) notified the DRC by mail that it had discovered
perforations in the liner to Roberts Pond. Fearing that perforations might exist below the water level, the
company chose to remove the liner and any contaminated soil it encountered. The company created an
action plan to guide the remedial work, submitting that plan to the DRC on May 12, 2014. The DRC
extended approval of the remediation plan on June 16, 2014. This document brings up to date the DRC file
for this project. The accompanying photo log provides visual reference at three points in the remediation
process, from early efforts to remove the sediments on the liner while preserving the liner, to the nearly-
completed excavation as it existed on September 23, 2014.
Energy Fuels has removed the liner from the pond in its entirety. From the photos, it is apparent that a
considerable amount of soil has been removed. The licensee took gamma surveys for real-time project
monitoring, and split soil samples between its in-house laboratory and an external commercial laboratory
for documentation of completion of the remedial excavation. EFRI has not received the laboratory results
as of the date of this memorandum.
EFRI removed all soils exhibiting gamma emissions above background. This effort included removing 12
to 18 inches more soil from the pond bottom at the south side of the pond following the reconnaissance
completed by the DRC on September 23, 2014. The rim of the excavation has been barricaded and/or
cordoned off to prevent entry while EFRI awaits receipt of soil sample results to verify successful removal
of contaminated soil.
Details of the sampling protocol actually employed (as compared with the protocol promised in the
approved plan) will be included in the report once EFRI receives the laboratory data. As a partial update, I
acquired a copy of the random sample location plot used to select sample locations, and have attached that
document to this report. The sample map includes gamma levels at the sample locations.
No action is required until receipt of the final remedial action report from EFRI.
Bianding, Utah.
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.deq. ulah.gov
Printed on 100% recycled paper
Photo 1: Example of identified damage to pond liner. Photo taken March 20,
2014.
•
Photo 3: Workers attempting to remove sludge from pond bottom. Photo taken
March 20, 2014
Photo 2: Workers attempting to remove sludge from pond bottom. Photo taken
March 20, 2014.
V:-
Photo 4: Workers attempting to remove sludge from pond bottom. Photo taken
March 20,2014.
Photo 5: Excavation in progress. Photo provided to the DRC July 29, 2014.
Safe*,
mm 2E£
_
Photo 7: Excavation in progress. Photo provided to the DRC July 29, 2014.
Photo 6: Excavation in progress. Photo provided to the DRC July 29, 2014.
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2
54
Photo 8: Excavation in progress. Photo provided to the DRC July 29, 2014.
Photo 9: East wall of excavation showing foundation of process tank above the
excavation and exposed water pipe. Photo taken September 23, 2014.
Photo 11: Excavation looking toward southwest corner. Dark gray area is
bedrock. Photo taken September 23, 2014.
Photo 10: South wall of excavation showing exposed water pipe. Photo taken
September 23,2014.
....
Photo 12: Excavation looking at west wall and at access ramp constructed in
northwest corner of pond. Photo taken September 23, 2014.
Roberts Pond Remediation
3
4
5
6
7
8
9
10
17
IS
19
Areas listed as NA, are areas not Identified as survey locations In Figure 2.
Background - cardinal Direction
Waist/Contact
North _
East
South
West
15,15
17,17
17.17
Average | 16,16 I
Completed Soil Sample location
Random Generated Soli Sample Location
Outside Pond - Surface Edge
Not Identified As A Sample Location
* All numbers are in pfl/hr
5 ^
cr
5 "il