DRC-2015-003073 - 0901a0688053fd3c

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Acting Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2015-003073
MEMORANDUM
TO:
THROUGH
FROM:
DATE:
SUBJECT:
File C-2015-56 , A 1 A f
Phil Goble, Section Manager / 1
Russell J. Topham, P.E.
June 23,2015
Engineering Module 75B, Review of the lsl Quarter, 2015 (January-March, 2015) DMT
Performance Standards Monitoring Report and Cell 4A and Cell 4B BAT Performance
Standards Monitoring Report (Report). Groundwater Discharge Permit (GWDP)
UGW370004 - 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 January 27, 2015, and covering the lsl Quarter, 2015 (January-March, 2015) monitoring period
(Report). DRC received the Report on May 14, 2015 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 12.3 (DMT Plan), dated April, 2015.
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, and the solution pool
elevation remained below the specified limit.
2. Weekly monitoring of Cell 4A solution pool elevations occurred as required to calculate
acceptable leakage rates, and the leakage rate thus determined remained below the specified limit
3. Weekly monitoring of Cell 4B solution pool elevations occurred as required, and the solution
pool elevation remained below the specified limit.
4. Data provided in Attachment C to the Report supports a conclusion that EFR has generally met
the requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable.
However, the data also supports a hypothesis that the effectiveness of the current practice may be
at an end without making changes in the cover system.
5. Monitoring of the feedstock storage area occurred as required. The data support a conclusion that
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no feedstock existed outside the designated feedstock storage areas. Standing water appears to be
an issue.
6. EFR met the requirements for inspection of the liner systems. No damage was detected, and no
repairs were undertaken.
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 corrected all
mechanical failures the same day as detected. The fluid level in the Cell 4B leak detection system
rose to 11 inches above the limit specified in the Ground Water Discharge Permit due to pump
failure detected on March 30. The fluid level was reduced immediately upon replacing the pump.
10. The leak detection systems in Cells 1, 2, and 3 appear to have operated properly, and no fluids
were detected therein during the 1st Quarter of 2015.
Recommendations
1. The DRC should issue a closeout letter for the review of this report.
2. The DRC should encourage installation of final cover to prevent recharge. In conjunction with this
effort, the DRC may encourage the licensee to cease the practice of head recovery monitoring in
favor of maximizing the available time for fluid extraction through the pumping system. If this
course of action is selected, the licensee should install piezometers at select settlement monitor
locations to measure directly the drop in water surface with withdrawal of slimes.
3. 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 appears to be
an issue.
4. The DRC should issue a Notice of Enforcement Discretion to document the violation of Section
I.E.12.a.2 of the Ground Water Discharge Permit with respect to the pump failure in the Cell 4B
leak detection system and the associated rise in fluid levels.
1.0 Tailings Wastewater Pool Elevation 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) 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.
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Cell 1
Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with the
prescribed freeboard requirements.
Cell 3
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.
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.
Cell 4A
Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of calculating
acceptable leak rates for the liner system
Cell 4B
Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating compliance
with the prescribed freeboard requirements.
Roberts Pond
The following repeats the assessment made for Roberts Pond during review ofthe 4,h Quarter 2014 Report.
Roberts Pond was dry during the quarter; therefore, no monitoring of water surface elevation was reported.
Roberts Pond has been taken out of service following discovery of tears in the pond liner on March 13,
2014. EFRI has redirected all fluid flows previously destined for Roberts Pond to Cell 1. EFRI has
completed cleanup of contaminants released from the pond as a result of the breached liner, and is
preparing plans to backfill the pond with clean soil. The pond will remain permanently out of service.
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
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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
l.D.3(b)(l). From the graph of slimes drain recovery head data in Appendix D, it is apparent that the
downward trend that has occurred since May of 2011 did not continue through to September, 2014. The
downward trend resumed during the 4th Quarter of 2014, but reversed again during the 1st Quarter of 2015.
The last three quarters' measurements all fall above the running average, and reflect elevations more in line
with the 4th Quarter of 2013 than the lower values measured during the first and second Quarters of 2014.
More information is required to understand whether equilibrium has been reached with approximately 7.5
feet of hydraulic head (approximately 22.5 feet from the surface of the temporary cover on the cell) at the
pumping point Report, Appendix D). Table 2-1 on p. 7 of the Tailings Data Analysis Report (TDAR,
April, 2015) presents a water table at a depth of between 0.2 feet and 12.3 feet ofthe surface ofthe
temporary cover. Likewise, Table 4-1 indicates the depth to top of saturated tailings varying from 3.92 feet
to 11.58 feet below the temporary cover surface, with the greater depths occurring closer to the slimes
drain alignment (TDAR, p. 17). This indicates a substantial volume of fluid yet to be removed from the
cell.
The TDAR postulates the presence of gypsum in the interstices within the tailings mass (p. 11). This
condition would reduce hydraulic conductivity within the tailings. The temporary cover is composed of
random fill, which on visual inspection appears to be a sandy gravel or gravelly sand with cobbles and
boulders. The porosity of this cover would allow surface water to penetrate into the tailings below. While
the region in which the mill is sited has experienced drought conditions, significant storms have occurred.
Those may have recharged the cell, offsetting the withdrawal through the slimes drain.
Given the above hypotheses and the data presented in Attachment D to the report, I question whether the
current practice of withdrawing slimes will prove effective in reducing the fluid level in the cell.
Installation of final cover, with a liner system and grading to shed precipitation may be required in order to
achieve the desired fluid reduction.
Finding: Data provided in Attachment C to the Report supports a conclusion that EFR has generally met
the requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable. However,
the data also supports a hypothesis that the effectiveness of the current practice may be at an end without
making changes in the cover system.
Recommendation: The DRC should encourage installation of final cover to prevent recharge. In
conjunction with this effort, the DRC may encourage the licensee to cease the practice of head recovery
monitoring in favor of maximizing the available time for fluid extraction through the pumping system. If
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this course of action is selected, the licensee should install piezometers al select settlement monitor
locations to measure directly the drop in water surface associated with withdrawal of slimes.
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 I.D. 11 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.
During the reporting period, inspectors noted standing water in quantities I would characterize as
significant in two areas. This water persisted long enough that I have concern about percolation and
contaminant transport. Attachment H to the Report presents observations made by the field inspectors
during weekly inspections. The standing water is represented by three dimensions: a length, a width, and a
depth. Two areas on these maps concern me. The first comprises an area about 500 feet square, located in
the northeast corner of the ore pad. The following table presents the data depicted on the maps for this area.
Because the boundaries of these areas are likely irregular, I have not attempted to estimate a volume of
fluid; I did, however, use the lateral dimensions as the lengths of the axes of a rhombus to compute a
conservative estimate the surface area of the ponding. Duration of ponding and depth seem more critical in
contributing to infiltration. An inspection of Table 1 reveals that from the time of the storm preceding
January 16 to sometime after February 5, a period of nearly a month, 2,000 square feet or more of this
limited segment of the ore pad was inundated. This area was again inundated for three weeks from late
February to mid-March. A similar condition, not presented in the same level of detail in this analysis,
persisted on the segment of the ore pad immediately west of this one.
I visited the mill site on June 16, 2015 to perform an inspection of burial of in-situ leach facility
decommissioning rubble. I took the opportunity while onsite to assess conditions on the portion of ore pad
discussed in this section. I collected two photographs from the ore pad that document conditions similar to
those I visualized while reviewing the Report. Those photographs, which appear below, document that
standing water on the ore pad remains a problem. Nobody was onsite managing this condition at the time
of the June 16 inspection.
I conversed with Thomas Rushing regarding his storm water-related inspection performed March 24, 2015.
He indicated that the ore pad was dry on March 24, but that he could observe where water had pooled from
recent rains. When presented with Photographs 1 and 2, the data from the Report presented in Table 1, and
the maps in Attachment H to the Report, he expressed an opinion that EFRI should manage the drainage of
the ore pad better than the Report or the June 16 inspection indicate.
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January 9 Dry
January 16
50
50
15
20
40
80
30 3285
January 22
60 40
10 10
20 30
20 30
20 20 1750
January 30
15 20
20 40
15 25
15
15 20
30 40 1548
February 5
20 20
20 30
20 30
30 1025
February 13
20 22
12 15 310
February 19 15 20 170
February 26 Entire ore pad covered with snow and ice 250,000
March 5
10
10
30
18
10
30
70 1519
March 13
10 12
12 20
25 80
1212
March 19
12 16
15 15 317
March 27 Dry 0
Table 1: Estimated areal coverage of the northeast 250, 000 square feet of the ore pad by standing water on dates of
inspection for the 1st Quarter of 2015.
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~ . ••••" •
Photo 1: Water pooling on the ore pad. Photo taken June 16, 2015 at a point about 325 feet south of the north ore pad
boundary fence and about 170 feet west of the east ore pad boundary fence looking generally northward.
if
Photo 2: Water pooling on the ore pad. Photo taken June 16, 2015 at a point about 65 feet south of the north ore pad
boundary fence and about 100 feet west of the east ore pad boundary fence looking generally southward.
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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 appears to be an
issue.
Recommendation: The DRC should require EFRI to address the persistent standing water on the ore pad.
4.0 Tailings Cells and Pond Liner System Repairs
Inspection of all cells 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.
Finding: EFR met the requirements for inspection of the liner.
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.
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.
Cell 4A
The flow meter attached to the leak detection system pumping equipment malfunctioned during pumping
on February 19. The meter was repaired immediately. Actual data for the quantity of fluid pumped was
lost, but sufficient information remained to make an educated estimate of the quantity of fluid pumped.
Cell 4B
The Cell 4B leak detection system control unit failed on or about February 25. Mill maintenance personnel
replaced the control unit immediately. Subsequently, on February 30 during inspection, mill personnel
noted that the pump was alarming, indicating fluid in the system requiring pumping, but the pump would
not operate. Maintenance personnel replaced the pump.
During these events involving the Cell 4B leak detection equipment, the fluid level in the leak detection
system reached a level 11 inches above the limit specified in Section I.E.12.a.2 of the Ground Water
Discharge Permit. While this is a violation condition, the company's rapid response to correct the violation
should be considered. EFRI provided written notice to the DRC by letter on April 3.
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Finding: EFR has met the monitoring requirements for Cell 4A and 4B BAT performance. One failure to
meet those standards for the quarter was noted, but was corrected immediately upon discovery. The
violation occurred because of mechanical failure, and involved a failure of a pump lhat could not have
been foreseen or prevented under reasonable inspection protocols.
Recommendation: The DRC should issue a Notice of Enforcement Discretion to document the violation of
Section I.E. 12.a.2 of the Ground Water Discharge Permit, and to acknowledge the responsible manner in
which EFRI responded to the situation.
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.
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 2014.