DRC-2015-002403 - 0901a0688052ac67

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CON TROL
Rusty I.undberg
Director
GARY R HERBERT
Governor
SPENCER J. COX
Lieutenant Governor DRC-2015-002403
April 2,2015
Kathy Weincl, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
Subject: Transmittal of Findings of the Utah Division of Radiation Control March 24. 2015
Ground Water Module 65, Storm Water Inspection, at the White Mesa Uranium Mill,
Utah Ground Water Discharge Permit No. UGW370004: DRC Close-out
Dear Ms. Weinel:
Representatives of the Utah Division of Radiation Control ("DRC") conducted a storm water
inspection at the White Mesa Uranium Mill on March 24, 2015. A copy of the DRC Review
Memorandum (2015 DRC Groundwater Module 65) is attached for your information.
DRC notes that several issues regarding inspection findings were discussed with Energy Fuels
Resources (EFR) representatives during the inspection close out meeting held at the White Mesa
Mill on March 25, 2015. DRC subsequently received e-mails from EFR, dated 3/25/2015 and
3/30/2015, which documented follow up actions to these findings (including photographs of work
completed). Based on the inspection findings and EFR follow up actions, it appears that the
White Mesa Mill is in compliance with storm water requirements of the Facility Ground Water
Discharge Permit UGW370004, and the currently approved White Mesa Mill Storm Water Best
Management Practices Plan. Therefore, the 2015 DRC Groundwater Module 65 inspection is
hereby closed out.
Please contact Tom Rushing at [phone] if you have questions regarding this letter or the
attached DRC Memorandum.
Rusty Lundnerg, Director vJ
Attachment: DRC 2015 Groundwater Module 65
l l:\MON WAST\Trushing\Fnergy FuelsvStorm Waler Management\20l 5 SW InspcctionWVhite Mesa Mill 2015 SW Inspection l.tr docx
Sincerely,
195 North 1950 West • Salt Lake City, UT
Mailing Address: PO Box 144850 • Salt lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www tivq uloh
E>rimed on 100% recycled paper
Utah Division of Radiation Control (DRC)
Ground {ater Module 65, DRC Annual Storm Water Inspection
Energy Fuels Resources, white Mesa uranium Mill, Ground water Permit ucw370004
Inspection Year: 2015
Inspection Date: March 24, 2015
Module Reviewer Name/Initials :
Phil Goble, Compliance Section Manager
Module Prepared bv/I)ate Prepared:
A/
Tom Rushing, P.G./APtil2,2015 Ji-
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DRC Staff Present: Tom Rushing
Nuclear Resulatorv commission staff Present: Ron Linton
Enerw Fuels Resources Staff Present: Tanner Holliday
Ganin Palmer
David Turk
Enerw Fuels Resources Staff fnterviewed:Tanner Holliday
Garrin Palmer
David Turk
Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements
Inspected:
part I.D.l0 - Requires management of contact and non-contact storm water and control of
contaminant spi[ì in accordance with the currently approved Storm'Water Best Management
Practices Plarrand applicable sections of the Utah Administrative Code'
part I.D.1l - Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Area,inóluding requirements for container integrity, storage on an engineered
impeÃrious surface, and controls for storm water run-on and run-off.
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the
White Mesa Uranium Mill:
Date: September,2012
RevisionNo. 1.5
1
Section I - Document Review
SllB MPP (Doc umentstíon Req uirementù :
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, wilt 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 Ditches 1,2 and 3; and Diversion Berms as shown on the Energy Fuels Resources
("EFR") Storm Water Best Management Practices Plan, Figure 2. DRC also inspected the
outfall locations for Diversion Ditch I and2 to verify the directions of upland drainage
(ensure that drainage is directed to areas distant from the Mill Facility).
DRC found Ditch 1 and berms to be adequately maintained. Onsite EFR staff noted that
Ditch t had been re-graded to avoid standing water which was noted in the previous 2014
inspection. No standing water or wet spots were noted in Ditch 1 during the inspection. The
ditch appeared well graded and free of obstructions (tumbleweeds were noted in the ditch at
some locations but did not appear to be clogging the drainage). Photos of Ditch I and the
outfall location, taken during the day of the inspection are included the Memo Appendix 1.
DRC notes that storm water entering Ditch 1 is draining toward the west, fans out onto areas
of Dakota/Burro Canyon Fm. Outcrop, and ultimately into the Westwater Creek Drainage.
DRC found Ditch 2 andberms to be adequately maintained (Photos included in Appendix 1).
The ditch appeared to be well graded and no excessive vegetative growth or obstructions
were noted. Drainage is towards the north and water is diverted to a vegetated area. It was
noted that the Mill property berms are ata higher elevation than the Ditch 2 outfall and water
is not expected to run away from the confines of the Mill'
DRC found Ditch 3 and berms to be adequately maintained (Photos included in Appendix 1).
The ditch appeared to be well graded and no excessive vegetative growth or obstructions
were noted. Upland drainage into the ditch is diverted either to the upland wildlife pond or to
Lawzy Lake.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DRC reviewed the February 25,2015
monthly form and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion
Ditches I,2 and3 showed no sloughing, erosion, undesirable vegetation or obstructions of
flow. Additionally the form notes that diversion berms show no stability issues or signs of
distress. The form notes that "ditches look good."
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(D o c umentatìon Re q uire mentù :
1.6.1. - Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DRC 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 inspectionfindings with the daily inspectionþrm usedfor storm water inspection
documentation within 30 days from your receipt of this letter," EFR has 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 is no longer inspected as part of the documentation
review or included on the site walkthrough.
1.9.1. - External Notification of "reportable quantity'o spills.
Findings: No reportable quantity spills were reported by EFR during the period reviewed,
DRC has no additional comments.
1.9.2. Internal Notification of incidents, spills, and signiflrcant spills.
Performance Standards (list):
In response to a DRC Request for Information item by letter dated September l,20ll,
regarding the findings of the DRC 2010 storin water inspection, EFR provided a change to
the small quantity spills protocols in the October 17,20ll response letter, as follows:
"EFR has implanted an internal notification process for small quantity spills (ess than
reportable quantities), with the following steps:
1) Mill environmental personnel will fill out on the daily inspectionform 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
inspectionform.
3) If the spill is of a reportable quantity, envirohmental personnel will þllow the procedures
in the Mill's SWBMPP plan.
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 inspectionform will be qdded to a database maintqined at the Mill.
The database will be updated and maintained on site indefinitely. Cards are maintainedfor
no longer than one year."
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,
J
Location of Incident, Description of Material Spilled, Cleanup Activities Taken and
Signature. Per review of the cards filled out since the last inspection it appears that EFR is
continuing the effort to report the spills, it was noted that cards reviewed since the beginning
of 2015 did not include photographs of the spill and clean-up as was included with previous
spill reports. DRC discussed this item with onsite personnel (Tanner Holliday) during the
inspection and additionally discussed the issue during the close-out meeting with Dave Turk
and Dan Hillsten, Plant Manager. Per discussion the Mill personnel agreed that the practice
should be continued and will instruct Mill staff of the need to include photographs during the
annual storm water training portion of the Mill Safety Meeting. EFR provided a copy of the
storm water management course syllabus which includes an item for internal spill reporting
using the cards.
EFR has implemented the training program in two parts, training is required for the
environmental personnel at the mill and is required of all employees at the mill. Per the
attendance logs, all environmental personnel (3 people) attended the training onll5l20I5 and
all other mill employees will receive the training as part of the annual Safety Meeting which
is scheduled for later in the year. Training record for other mill staff during 2015 will be
reviewed as part of the DRC 2016 inspection.
DRC notes that the internal spill reporting processes and SV/BMPP training activities are
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: 2l I 1201 5 through 212812015
No. of On-site Records Required: Daily, V/eekly (2l5l15,2ll2l15,2ll4l15,2125l15)
and Monthly (2125115) Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: February 2015
How Selected: DRC Inspected a month of daily, weekly and monthly forms
completed since the last annual DRC Storm Water Inspection. Note that the previous
inspection was conducted during September/October 2015.
Daily Tailings Inspection Data:
Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-l of the
Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport
system (Sluny pipeline, pipeline joints and supports, valves and point of discharge); 2.
Operational systems (interior cell walls, 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
4
potential concerns and action required. Spills and clean up actions are noted in the text boxes
for these fields
DRC randomly selected and reviewed the daily forms for the month of February 2015. The
forms appeared to be appropriate and inspections were conducted on all days. There are no
additional comments regarding the forms.
Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 andAttachment 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,48 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 | , 2, 3 , 4A and 48 as well as the potential blowing of tailings, and
condition of concrete at the new decontamination pad.
DRC inspected the February 2015 weekly forms dated 2l5ll5,2ll2lI5,2lI4lI5, and2l25ll5
Per the 2015 DRC storm water inspection, the inspection forms reviewed appeared to be
completed appropriately. There are no additional comments regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness:
Findings:
Monthly inspection data is documented on Appendix A-3 of the Environmental Protection
Manual, Section 3.1. The monthly inspection report includes; 1. A summary of the slurry
pipeline condition; 2. Inspection protocols and observations related to the diversion ditches,
berms, sedimentation pond and dust control.
DRC reviewed the EFR monthly inspection report dated February 25,2015. Note that the
monthly inspection reports include comments related to the upland diversion ditches which
noted that,"ditches look good." The form also noted that the slurry pipelines looked good
and that there were no activities around the sedimentation pond.
Tank to soil potential measurements:
Findings:
This item was included as part of a September 1,2011 DRC Request for Information
("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 2015 inspection, all concrete
foundations inspected appeared in good condition.
5
Annual bulk oil and fuel tank visual inspections:
Findings: The annual inspection form was not reviewed as part of the 2015 DRC inspection.
No concerns were noted during the DRC site walkthrough.
Tank and pipeline thickness tests:
Findings: During the inspection period, as noted on the EFR monthly inspection forms, the
slurry pipelines were noted to be in good condition by EFR.
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.
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 receive annual training regarding the
small quantity internal spill notification process.
Section II - Site Walk-through Inspectíon
Areas and Observations:
Ore Storage:
DRC reviewed areas of the ore storage pad noted in an October 20,2014 Request for
Information. Specific ally that,"erosion rills were present on the eqst side of the fueling
island (north ojthe new decontøminøtionpad) where itwas apparent that stormwater had
flowed eastfrom the pad areq." Per observations during the 2015 site walkthrough it was
noted that the berm has been extended in this area. It was noted that the soil behind the berm
was wet and that storm water had flowed to the area and appeared to have been contained by
the new berm. Per the observations no additional concerns were noted other than the berm
needs to be maintained in this area.
Per the walkthrough DRC noted two items at the ore pad that needed follow up:
1. Located east of the New Decontamination Pad, the eastern lined drainage trench
contained sediment and blown vegetation which needed to be cleaned out (Photo
included in Appendix 1).
2. The storm water containment located at the southwest corner of the ore storage pad
contained sediment which needed to be cleaned out (Photo included in Appendix 1).
6
Both of these items were discussed during the inspection close-out meeting on March 25,
2015. EFR subsequently provided follow up to the comments and provided photographs via
e-mail showing that corrective actions had been completed. The EFR photographs are
included below:
EFR Photo Submitted by E-mail on3l25l20l5 (See Appendix 2 for e-mail) - Showing clean
out ofthe eastern ore trench
EFR Photo Submitted by E-mail on313012015 (See Appendix 2 for e-mail) showing clean
out of the storm water containment at the southwest comer of the ore storage pad
Reagent Yard:
Per DRC observations no issues were noted regarding reagent storage.
Shop/Vehicle Maintenance Area :
DRC notes that areas inside of the vehicle maintenance shop and surrounding area have been
reconfigured to drain through the new pipeline to Cell l. DRC noted that hydraulic fluid and
7
oil drums were stored on pallets with secondary containment. The secondary containments
looked dry and the pallets appeared to be in good condition.
MiIl Processing Areas:
SX Building Roof Drainage:
Per discussion with EFR it was noted that the current SX building roof drainage flows into
Ce|| 1 with some of the drainage flowing over ground on the north and south end. Drainage
which currently flows over ground is allowed to accumulate in low areas and is then pumped
manually into Cell 1. Per discussion with EFR during the site walkthrough and during the
close-out meeting, EFR reported that all of the roof drainage will eventually be direct drained
into Cell 1. Per DRC observation it appeared that EFR was working to address all drainage
which was previously routed to Roberts Pond. DRC will follow up regarding the SX roof
drainage during the next storm water inspection.
Alternate Feed Circuit South of the SX Building:
Observations: Per DRC observations it appeared that all concrete used for storage of
alternate feed storage and staging was being maintained. No concerns regarding concrete
integrity or drainage were noted. DRC did not note issues related to run-on from SX
building roof drainage onto the alternate feed processing areas as noted in previous
inspections. (Photos are included in Appendix 1)
Old Decontamination Pad:
Observations: The old decontamination pad is rarely used due to construction of the new
decontamination facility and access gate althe southeast corner of the ore pad. No comments
were noted during the site walkthrough.
New Decontamination Pad:
Observations: The pump back system and concrete containment box appeared in good
condition. DRC noted that alot of water was present in the stoiage/baffle boxes used by the
decontamination process likely due to current transport of ore (Pine Nut Mine) into the Mill.
DRC noted no issues regarding concrete integrity or seepage'
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 Vy'ater 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 Decemb er 2004 Statement of Basis for the site
Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit. No issues were
noted during the 2015 inspection.
8
Kerosene Tanks (West of Shop) - The kerosene tanks and concrete platforms appeared in
good condition.
Ammonia Tanks - Secondary containment is earthen per the same agreement as the sodium
chloride tanks. Per observations no comments were noted.
Used Oil Tank (shop) -
Observations: DRC noted standing water inside of the secondary containment for the used
oil tank and noted that the water and debris needs removal. The issue was discussed during
the site walk through and during the close out. EFR agreed that the containment needed
maintenance and sent verification of follow up to DRC via e-mail as below:
Photo of Used Oil Tank follow up maintenance sent via e-mail on312512015 (See Appendix
2 for e-
Kerosene Tank (shop) - The shop kerosene tank sits in the same secondary containment as
the used oil tank. DRC did not note any problems regarding taps and valves on the tank.
Fuel Tanks - Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks - The tanks were essentially empty at the time of the 2015
inspection as viewed from the platform above. Concrete under the tanks appeared adequately
maintained.
Vanadium Pregnant Liquor (VPL) Tanks - The VPL tank steam condensate containment
area, tanks and foundations appeared to be in good condition. It was noted that the concrete
around the tanks was recently expanded as part of the Nitrate Corrective Action Plan and that
containment to manage tank condensate appeared to be adequate. Condensate is disposed of
in Cell 1 via the new drain line.
9
Clean Water Tank - Standing water was not observed in the vicinity of the tank. DRC
observed the drain line for tank overflow is discharged to Cell I via a drain line discharging
at the northeast cornef (Photo of drain line included in Attachment l).
Sulfuric Acid Tank - The tank, concrete platform, and transformer berm appeared in
adequate condition. Discharge of storm water around the tank is directly discharged into Cell
I through a separate drain line (Photo of drain line at the northeast comer of Cell 1 is
included in Attachment 1).
Caustic Soda Tank - Tank and secondary ôontainment appeared to be in adequate
condition. (2015 Photo included in Attachment 1)
Soda Ash Tanks - The Soda Ash Tanks and Secondary Containment appeared to be
adequately maintained. DRC noted some dripping from the eastern tank valve (Photo
Appendix 1). Fluid in the secondary containment flows into the SX building containment
alea.
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC toured the tailings cell areas (Cells 4A and 48) 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 included in Appendix 1).
Summary of Onsite Closeout Meeting:
Date/Time: March 25, 201518: I 5 A.M.
EFR Representatives Present -Dan Hillsten - Site Radiation Safety Offrcer
David Turk - Plant Manager
NRC Representatives Present -Linda Gersey
Ron Linton
Jim Lynch
DRC Representatives Present -Kevin Carney
Tom Rushing
An onsite close-out meeting took place to discuss preliminary findings of the storm water
inspection. Specifically, the following issues were presented by DRC:
Documentation: Itwas discussed that overall the EFR documentation looked good' It was
noted that the current inspection was only 5 months after the previous storm water inspection
and therefore the document review focused primarily on daily and weekly forms. The forms
appeared to be appropriately filled out and the record appeared complete. It was discussed
ttràt ttre small quantity spill records reviewed since the beginning of 2015 did not have
10
photographs included which were previously provided. EFR reported that the photographs
would be continued and that Mill staff review of reporting procedures would be included
during the next storm water training (Included as part of the Mill Safety Training).
Site Watkthrough; It was discussed that the items included in the previous year's inspection
findings appeared to have been addressed. These items included: 1. The need for a berm at
the east area of the ore pad in the area of the refueling island, and,2.Information regarding
how discharges previously directed to Roberts Pond would be handled. Per information
above, EFR has installed a new drainage line into Cell 1.
DRC reported that no areas of standing water were noted during the inspection. DRC noted
that water needed to be pumped out of the secondary containment for the used oil tank. DRC
noted that the drainage channel located on the southeast side ofthe ore pad needed to be
cleaned of sediment.
DRC included one additional item to the close-out meeting by e-mail to EFR dated 312612015
(See Attachment2) and notiffing EFR that the storm water containment at the southwest
corner of the ore pad was full of sediment and needed to be cleaned out.
Per discussion above, EFR responded to the close-out meeting comments and provided e-
mails with photographs verifying that follow up work had been completed (EFR e-mails
dated 312512015 and 313012015, See Attachment2).
Conclusions
A close-out letter regarding the 2015 storm water inspection is recommended be sent to EFR.
A copy of the review memorandum will be attached to the letter. DRC notes that overall, the
Mill facility storm water management and spill training and reporting have significantly
improved in recent years.
U:\MON_WAST\Trushing\Energy Fuels\Storm Water ManagementV0l5 SW Inspection\White Mesa Mill 2015 SW Inspection Memo
Final.docx
11
2015 Ground V/ater Module 65, DRC Annual Storm Water Inspection
Appendix 1-PhotoPages
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo I - Sodium Chlorate Tank and Containment
Photo 2 - Kerosene Tanks and Earthen Containment
Photo 3 - Uranium Raffinate Tank on Concrete Pedestal.
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 5 - Drummed Yellowcake Storage Pad
Photo 6 - Storm Water Containment at Southwest Corner of the Ore Storage Pad (Note: Sediment
Accumulation)
I
I
Photo 7 - Sothern Boundary of the Ore Storage Pad (Note Berm)
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 8 - Southeast Corner of Ore Pad Storm Water Collection Area
Photo 9 - Eastern Storm Water Drainage Lined Ditch (Note: Full of Sediment)
Photo l0 - Eastern Margin of Ore Storage Pad (by Fueling Island) Area of New Berm (Note: Wet Soil
Indicating Drainage Containment)
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo I I - Northern Boundary of Ore Storage Pad
Photo 12 - Ore Being Stockpiled on in Feedstock Management Area North of the Mill Building (Pine Nut
Mine, Arizona)
Photo 13 - Vanadium Liquor Tanks (Note: Newly Configured and Enlarged Concrete Pad/Containment)
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
t\ [¡ i¡ l\1 lil lt lr
Photo 14 - Used Oil and Kerosene Secondary Containment (Note: Water and Debris in Containment)
Photo 15 - Used Oil Secondary Containment
¡¡
Photo l6 - Hydraulic Fluid on Containment Pallets (Per observation the containments were empty)
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water lnspection
White Mesa Uranium Mill
Photo Pages
Photo 17 - Shop Containrnent Baffle Box (Discharges to Cell I Drain)
;J li+.-.
I
jI
Photo 1B - Arnmoniurn Sulfate Crystal Concrete Pad (Nitrate CAP) (Note Storrn Drain Inlet in Center of
Pad, Drains to Cell l, New Drainage Line to Cell I Connects to this Storm Drain)
Ì.
t
Photo l9 - Nitrate Concrete Cover, East Side of Mill Building, Looking North towards the Grizzly
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa lJranium Mill
Photo Pages
Photo 20 - Ammonium Sulfate Crystal Tank Concrete Cover (CAP) Seam Crack where New Concrete
Joins with Older Concrete
Photo 21 - Ammonium Sulfate Crystal Tank Concrete Cover (CAP) Seam Nonconformance where New
Concrete Joins with Older Concrete
Photo 22 - Older Concrete under the Ammonium Sulfate Crystal Tank
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 23 - Concrete Cut for Installation of New Drainage Line to Cell I Looking West Between Mill
Building and SX Building.
Photo 24 - Concrete Secondary Containment for the Soda Ash Tanks
Photo 25 -Drainlnlet in the Soda Ash Secondary Containment, Drains to SX Building Interior
Utah Division of Radiation Control
2015 Ground Water Module 65 : Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 26 - Secondary Containment for the Caustic Soda Tank
Photo 27 -Northwest Corner of SX Building Roof Drainage
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 28 - Picture Shows the West End of the Counter Curent Decantation Tank Secondary
containment. Solution was being pumped to cell4A from this Location.
Photo 29 - Roberts Pond Excavation Pit (Note: Roberts Pond has been Permanently Taken Out of
Service).
Photo 30 - Sulfuric Acid Tank and Surounding Area.
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 31 - Foreground shows a Berm Constructed to keep Potential Spill from the Acid Tank Away from
the Substation.
Photo 32 - Feedstock Storage next to the Alternate Feed Processing Circuit.
I
Photo 33 - Alternate Feed Processing Circuit Interior
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 34 -Drainage Channel which receives Storm Water from Portions of the South End of the SX
Building and Mill Area.
Photo 35 - Diversión Ditch I looking South towards the Mill. Ditch was well maintained, Storm Water
is diverted to Wildlife Pond 1 and the Lawzy Lake Detention Pond.
Photo 36 - Runoff Area for Diversion Ditch 1 to the Westwater Creek Drainage.
Photo 37 - Diversion Ditch 2, Well Maintained. Drainage is to Northern Lower Areas
Photo 38 - Diversion Ditch 1, Well Maintained'
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
--¿gç
Photo 39 - Northeast Corner of Cell l. Pipes shown on the left side of the Photo Drain Storm Water from
the Sulfuric Acid Tank Area and Overflow from the Clean Water Tank.
Photo 40 - New Drain Line into Cell 1. Pipe Carries Multiple Sources of Storm Water and Process Water
which Previously Drained to Roberts Pond.
Photo 41 - Boneyard (Note Berm in the Picture Background)
Utah Division of Radiation Control
2015 Ground Water Module 65 -- Annual Storm Water Inspection
White Mesa Uranium Mill
Photo Pages
Photo 42 -Toe of Dike for Cell 44. Dike was well maintained.
Photo 43 - Settlement Monitoring Located on Dike of Cell4A.
2015 Ground V/ater Module 65, DRC Annual Storm Water Inspection
Appendix 2 - DRC and EFR E-mails
David Turk Mar 30
to me, Kathy, Dan, Phillip
Sir,
Attached is a photograph of the cleanout impound from this morning. Let me know if there is anything
else.
David
From: Thomas Rushing
Sent: Thursday, March 26,2075 9:22 AM
To: David Turk
Cc: Kathy Weinel; Dan Hillsten; Phillip Goble
Subject: Re: White Mésa Mill Stormwater Inspection - Photographs
Thanks David.
There was one other item that I forgot to mention cluring the close-out meeting at the mill, It was
noted during the site rvalk through that the storm water containnrent at the southwest corner of
the ore storage pad r,vas full of secliment and needecl to be cle¿rnecl out.
A picture of the containment taken cluring the inspection is attached
Please let me know if you have concerns.
Thanks,
Tom
On Wed, Mal25, 2015 at 3:19 PM, Davicl Turk <DTurklßieqqrgyÍtç1s.eq> wlote:
Mr. Rushing,
Attachecl are tlu'ee photographs showing the changes to the tlvo areas you reÇommended this
morning from the annual Stormwater inspection of the White Mesa Mill. One is the tJsed Oil
concrete impound and having the rain water pumped out. The solution was pumped into and
over pack and then discharged into Cell 1.
'the other two photographs show the east collection trench near the new decontamiuation
pad. The sediment was removed fiom the trench and tumble,*'eeds were als<l removcd.
If there is anything else you neecl. let ne know.
Regards,
David
Energy Fuels Resources (USA) lnc.
David Turk
Manager Environmental HeaÌth and Safefy
l: 435-67 8 -2221 x1 1 3 1 c: 435-4s9:l9zlq l t: 43 5-67 8:2224
6425 S. Highway 191 PO Box809
Blanding, UT, US, 84511
http://www.enerqvfuels. com