DRC-2016-010503 - 0901a068806743d8

State of Utah
CARYR. HERBERT
Governor
SPENCERJ. COX
Lieutenant Governol
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Umon Blvd., Suite 600
Lakewood. CO 80228
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scoft T. Andenon
Director
October 13,2016
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
7003 2260 0003 2353 8372
RE: Request for Information Regarding the 2016 Division of Waste Management and Radiation
Control, Ground Water Module 65, Storm Water lnspection at the White Mesa Uranium Mill
Utatr Groundwater Discharge Permit No. UGW370004
Dear Ms. Weinel:
Representatives of the Division of Waste Management and Radiation Confol conducted a storm water
inspection at the White Mesa Uranium Mill on September 22,2016. A copy of the Division's Review
Memorandum (2016 Groundwater Module 65 Memorandum) is enclosed for your information.
Based upon the findings of the inspection and a telephone conference between Energy Fuels
representatives and Division representatives on October 11,2016, it was agreed that the following
actions would be completed on or before the stated timelines:
1. It was noted during the inspection that the White Mesa Mill Spill Prevention, Control, and
Countermeasures (SPCC) Plan includes a requirement for an annual bulk oil and fuel tank visual
inspection. During the annual storm water inspection, it was noted that this annual inspection
had not been conducted. It was also noted that the SPCC Plan does not provide an explanation
of the scope of activities performed during the inspections.
During the telephone conference, Energy Fuels Resources agreed to provide an updated SPCC
Plan which better reflects types, frequencies and scope of storm water inspections performed at
the White Mesa Mill, for the Director's review and approval, within 60 calendar days of the date
of this letter.
195 North 1950 West. Sdt Lake City, UT
Mailing Address: P.O. Box 144880 . Salt Lake City, UT 84114-4880
Telephone [phone]. Fax [phone]. T.D.D. (801) 5364414
mmt.ileq.utah.goo
hinted on l00P/o recycled paper
DRC-2016410503
(Over)
2. It was noted during the inspection that the storm water containment located at the southwest
comer of the ore storage pad was filled with sediment up to the discharge pipe and needed to be
cleaned out. During the telephone conference, Energy Fuels Resources agreed to clean out this
storm water containment within seven calendar days of the date of this letter.
If you have any questions, please call Tom Rushing at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STAITR/ka
Enclosure: 2016 Groundwater Module 65 Memorandum (DRC-2016-010504)
c: Rick Meyer, Acting, Health Offrcer/Environmental Health Director, San Juan Public Health
Scott Hacking, P.E., DEQ District Engineer
Utatr Division of Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water lnspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2016
Inspection Date: September 22, 2016
Module Reviewer Name/Initials :
Phil Goble, Compliance Section Manager PE e f1/o /. t,
Module Preoared bvfl)ate Preoared:
TomRushing, p.G.toctober I r,2016 # lo /tr /zat I
DWMRC Staff Present:Tom Rushing
Enerery Fuels Resources StaffPresenh Garrin Palmer
David Turk
Enerw Fuels Resources StaffInteniewed: Garrin Palmer
David Turk
Utah Ground Water Oualitv Discharee Permit No. UGW370004 Requirements
Inspected:
Part I.D.l0 - Requires management of contact and non-contact storm water and contol of
contaminant spills in accordance with the cunently approved Storm Water Best Management
Practices Plan (SWBMPP), Spill Prevention Control and Countenneasures Plan (SPCC), and
applicable sections of the Utah Administative Code.
Part I.D.l I - Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Alea, including requirements for container integrity, storage on an engineered
impervious surface, and contols for storm water run-on and run-off.
Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm
Water Best Management Practices Plan (SWBIVIPP) for the White Mesa Uranium Mill:
Date: May 2,2016
Section I - Document Review
SWBMPP (D oc umentation Req uirementd :
SWBMPP Pafi 4.1.4. - Diversion ditches, drainage channels and sur{ace water control
strucfures in and around the Mill aree will be inspected at least weekly. Areas
requiring maintenance or repeir, such as excessive vegetetive growth channel erosion or
pooling of surface water runofi, will be reported to appropriate departments and all
follow up actions are to be documented.
Findings:
The Utah Division of Radiation Contol C'DWMRC') conducted an inspection of upland
Diversion Ditch I and Diversion Berm l.
DWMRC found Ditch I and berm to be adequately maintained. No standing water or wet
spots were noted in Ditch I during the inspection. The ditch appeared well graded and free
of obstnrctions. Photos of Ditch I are included the Memo Appendix l. DWMRC notes that
storm water entering Ditch I is draining toward the west, fans out onto areas of Dakota/Burro
Canyon Fm. Outcrop, and ultimately into the Westwater Creek Drainage.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data forrr. DWMRC reviewed the May 31,2016
monthly form and noted that the EFR lnspector (Ganin Palmer) noted that the Diversion
Ditches 1,2 and 3 showed no sloughing erosion, undesirable vegetation or obstnrctions of
flow. Additionally the form notes that divenion bemrs show no stability issues or signs of
disress. The form notes that "Ditches are in good condition. Some vegetation growtng in
ditch 1. Utility crev, will clean out ditchwlun time allows." Per observations by the
DWMRC duing the 2016 inspection, the diversion ditch had been cleaned out.
SWBMPPAooendix I -SoiA Prevention, Control ond Countemeasares PIan (SPCCI
(Doc ume ntdtion Reo uiremc n&,l :
1.6.1. - Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DWMRC August 8,2012 Request for Infonnation which
stated as follows: "The EFR Spill Prevention Control, and Countermeasures Plan, Part
1.6.1 requires the documentation of a darly inspection of the propane tanks. Please include
the inspectionlindings with the daily inspectionform usedfor stormwater 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 trnder all foreseeable leakage conditions at the Mill. DWMRC
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 Notilication of 'reportable quantity, spills.
Findings: No reportable quantity spills were reported by EFR during the period reviewed
DWMRC has no additional comments.
1.9.2. Intemal Notification of incidents, spills, md significant spills.
In response to a DWMRC Request for Information item by letter dated September l,20ll,
regarding the findings of the DWMRC 2010 storm water inspectioq EFR provided a change
to the small quantity spills protocols in the October 17,20ll response letter, as follows:
"EFR tas imptanted an internal notification process for small quantity spills (ess than
reportable quantities), with the following steps :
I) Milt erwironmental personnelwillfill out on the daily inspectionform obsemations of
spitls of reagent chemicals of any size. Theformwill be amended to add spacesfor this item
i1 n iaamor, alt Mitl employees will be trained to advise Mill environmental personnel of
ary spills that they obseme &tring the doy, otd these will also be noted in the daily
inspectionform.
il|f tne spill is of a reportable quantity, environmental personnel willfollat, the procedures
in the Mill's SWMPP plan.
4) For spitls smaller thanreportable quantities, the ewironmental inspectorwill record
tnformition regarding the spill, and the noture and type of cleanup, on theform-
S) fhe information on the inspectionform will be added to a database maintained at the Mill.
7he datibase will be updated and maintained on site indefinitely. Csds ue maintainedfor
no longer than one year."
The White Mesa Mill employees are using an orange card to reprt the small quantity spills;
the card is titled "Non-Reportable Reportable Spillage." The card provides the following
inforrration: Narne, Date of Discovery, Approximate Amount Spilled, Time of Disoovery'
Location of Incideng Description of Materid Spilled, Cleanup Activities Taken and
Signature. The reports additionally include photographs of the spill and follow up actions in
most cases.
EFR has implemented the taining prognm in two parts; taining 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 ttre taining on l/l ln0l6-
All othermill employees will received the training as part of the annual Safety Meeting on
Febnrary 25,2}l6,March l,2016orMarch 7,2016. Atotalof46employeesweretrained
dnring 2016.
DWMRC notes that the internal spill reporting processes and SWBMPP training activities
are very effective. The spill reporting provides records of identification and follow-up
procedgres thereby making the chemical management at the mill transparent and supports
employee involvement in spill identification, reporting, and follow-up.
1.10@
Period of Records Examined During Inspection:
Begin/Ending : 5llA016 through 513112016
No. of On-site Records Required: Daily, Weekly, and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: lvlay 2016
How Selected: DWMRC Inspected a month of daily, weekly and monthly forms
completed since the last annual DWMRC Storm Water Inspection.
DaW Teilings Inspection Data:
Findings: Daily Inspections are documented on Appendix A-l and Attachment A-l ofthe
Environmental Protection Manual Section 3.1. EFR inspects: l. Tailings slurry transport
system (Slurry 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
potential conoenrs and action required. Spills and clean up actions are noted in the text boxes
for these fields.
DWMRC randomly selected and reviewed the daily forms for the month of May 2016. The
forms appeared to be appropriate and inspections were conducted on all days. 'itere are no
additional comments regarding the forms.
Weekly fsilings Inspections and Suruey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection fonns (Appendix A-2 and Attachment 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 fUf) for Cells l, 3,4A,48 and
Roberts Pond, as well as slimes drain liquid levels in Cell2, Existing Decontamination pad
and general tailing area. The fomr also includes information regarding the leak detection
systems for Cells 1,2,3,4A and 48 as well as the potential blowing oftailings, and
condition of concrete at the new decontamination pad.
DWMRC inspected the May 2016 weekly forms. Per the 2016 DWMRC storm wateriotpt:I9t, 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; l. A summary of the slurry
pipeline condition; 2. Inspection protocols and observations related to the diversion ditches,
berms, sedimentation pond and dust control.
DWMRC reviewed the EFR monthly inspection report dated May 31, 2016. Note that the
monthly inspection reports include comments related to the upland diversion ditches which
noted that"*Ditches are in good condition. Some vegetation growtng in ditch l. Utility crew
will clean out ditchwhen time allows." The form also noted that the slurry pipelines looked
good and that there were no activities around the sedimentation pond which has been filled
in.
Tank to soil potential measurements:
pfudings:
This item was included as part of a September l,20ll DWMRC Request for Information
C'MI"), RFI # 2. DWMRC had concerns regarding on-grade tanks (tanks where the bottom
is in contact with soil). Per DWMRC communication with EFR it was clarified that tanks
which sit on the ground must have cathodic protection or sit on a concrete foundation.
Per DWMRC inspection of the tank foundations during the 2016 inspection, all concrete
foundations inspected appeared in good condition.
Annual bulk oil and frrel tankvisual inspections:
Findings: Per the 2016 inspection it was noted that EFR is not conducting an annual
inspection of the oil and fuel tanks. It appears that these inspections are conducted at a
different frequency than annual. It was also noted that the scope of the inspection is not
explained in the SPCC Plan. Per review it appears that the SPCC Plan needs to be updated to
reflect the current storm water inspection forms and inspection frequencies. Additionally, it
would be appropriate to include more detail in describing the scope ofthe inspections
performed. This item will be included in a confirmatory action letterto EFR.
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. DWMRC notes that an effective spill reporting and tacking 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 liles):
Personnel training for spill prevention are discussed in the internal notification of spills
section of this module above. Per DWMRC findings the personnel taining has been
implemented and appears to be effective. Mill staffattend annual training regarding the
small quantity internal spill notification process.
Section II - Site Walhahrough Inspection
Areas and Obseryations:
Ore Storage:
Perthe DWMRC walkthrougb ofthe ore storage pad it was noted in general that the pad
berms were in good condition and no standing water was noted on the pad at the time of the
inspection.
It was noted that the storm water containment located at the southwest comer of the ore
storage pad contained sediment up to the discharge pipe. This sediment needs to be
inspecting regularly and cleaned out (Photo included in Appendix l). This item was
discussed during the inspection close-out meeting on September 22,2016.
Reagent Yard:
Per DWMRC observations no issues were noted regarding reagent storage.
Shop/Vehicle Maintenance Area:
DWMRC notes that areas inside of the vehicle maintenance shop and sturounding area have
been reconfigured to drain through the new pipeline to Cell l. DWMRC noted that hydraulic
fluid and oil dnrms were stored on pallets with secondary containment. The secondary
containments looked dry and the pallets appeared to be in good condition.
Mill Processing Areas:
S'Y Building Roof Drainage:
Per discussion with EFR it was noted that the current SX building roof drainage flows onto
the 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 l. Per discussion
with EFR during the site walkttrough and during the close-out meeting, EFR reported that all
ofthe roof drainage will eventually be directly drained into Cell l. Per DWMRC observation
it appeared that EFR was working to address all drainage which was previously routed to
Roberts Pond. DWMRC follow up regarding the SX roof drainage is ongoing.
Altemate X'eed Circuit South of the SX Building:
Observations: Per DWMRC observations it appeared that all concrete pad areas and berms
used for storage of altemate feed storage and staging was being maintained. No concerns
regarding concrete integrity or drainage were noted. @hotos are included in Appendix l)
Old Decontamination Pad:
Observations: The old decontamination pad is rarely used due to constnrction of the new
decontamination facility and access gate at the southeast comer of the ore pad. No comments
were noted during the site walkttrough
New l)econtamination Pad:
Observations: The pump back system and concrete containment box appeared in good
condition. DWMRC noted no issues regarding concrete integrity or seepage.
Reagent Tanks:
Sodium Chloride Tanks - Per past agreements benreen DWMRC 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 Water Pemrit (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 December 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 2016 inspection.
Kerosene Tanks (West of Shop) - The kerosene tanks and concrete plaforms appeared in
good condition.
Ammonia Tanks - Secondary containment is earthen per the same agreement as the sodium
chloride tanls. Per observations no comments were noted.
Used Oil Tank Ghop) - The used oil tank and secondary containment appeared in good
condition. Per observations no comments were noted.
Kerosene Tank (shop) - The shop kerosene tank sits in the same secondary containment as
the used oil tank. DWMRC did not note any problems regarding taps and valves on the tank.
Fuel Tanks - Above ground tanks and containment appeared maintained, no additional
cornments.
Uranium Liquor Tanks - Per observations, no comments were noted.
Vanadium Pregnant Liquor $ryL) Tanks - Concrete and secondary containment appeared
in good condition, no cornments were noted.
Clean \tater Tank- Standing water was not observed to be pooled in the vicinity of the
tank. DWMRC observed the drain line fortank overflow is discharged to Cell I via a drain
line discharging at the northeast corner.
Sulfuric Acid Tank - The tank, concrete platform, and transformer berm appeared in
adequate condition. Discharge of stomr water around the tank is directly discharged into Cell
I through a separate drain line. No comments were noted
Caustic Soda Tank- Tank and secondary containment appeared to be in adequate
condition.
Soda Ash Tenks - The Soda Ash Tanks and Secondary Containment appeared to be
adequately maintained. Fluid in the secondary containrnent flows into the SX building
containment area
Tailings Cells Arees (Note that uplrrnd drainage was included in comments ebove) -
DWMRC toured the tailings cell areas (Cells 4A and 48) and observed the condition of the
outer toe areas of the dikes to erunrne that excessive erosion or damage (e.g. burrowing
animal intnrsion or rooting darnage) was not present. The dikes appeared to be in overall
good condition (Photos included in Appendix l).
Summary of Onsite Closeout Meeting:
Dateffime: September 22, 2016112:00 P.M.
EFR Representatives Present - David Turk - Plant Manager
Garrin Palmer - Ground Water Compliance
DWMRC Representatives Present - Tom Rushing - Environmental Scientist
An onsite close-out meeting took place to discuss preliminary findings of the stonn water
inspection. Specifically, the following issues were presented by DWMRC:
Documentatlbw DWMRC reported that the perreview of the documentation and discussion
it was noted that the annual bulk oil and fuel tank visual inspections were not conducted on
an annual inspection form and may be covered on other forms and at different frequencies. It
was reported that this needed to be revised in the SPCC Plan, as well as inclusion of the
scope of inspections performed.
Site Walhhrough: DWMRC reported that the storm water containment at the southwest
corner of the ore pad was full of sediment and needed to be cleaned out.
Conclusions
A request for inforrration letter regarding the 2016 storm water inspection is recommended
be sent to EFR regarding; 1. Clarification in the SPCC Plan regarding inspection fiequencies
and descriptions of the activities conducted duing storm water inspections,and;2.
Notification and confimration that the storm water containment on the southwest corner of
the ore pad needs to be cleaned-out.
2016 Grotrnd Water Module 65, DWMRC Annual Storm Water Inspection
Appendix I -PhotoPages
DWMRC 2016 lnspection
Energy Fuels Resources, White Mesa Uranium Mil!
Ground Water Module 65, September 22,2OL6
t- -"
Photo 1- Ore Storage Pad, Looking Southeast Towards Decontamination Pad
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Photo 2 - Western Margin of Ore Storage Pad, Looking South, Note Berm
J;!7...*
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Photo 3 - Sediment Trap at the Southwest Corner of the Ore Storage Pad, Needs Clean-out
Photo 5 - East Margin of the Ore Storage Pad, Diversion Ditch Drains to South Sump
Photo 6 - Decontamination Pad Pump Back, Note Concrete Containment
Photo 7 - Decontamination Pad Baffle Containment
*.
'&..
Photo 8 - Eastern Margin of the Ore Storage Pad at Fuel Tank (Refueling Area), Note that the Berm was
Extended Repaired at this Location.
Photo 9 - Eastern Ore Pad Margin, Berm was Constructed/Repaired at this Location
Photo 10 - Eastern Ore Pad Margin
Photo 11- North Ore Pad Margin, Surface Drainage is to the West
Photo L2 - Ore Pad looking West Toward the Clean Water Tank and Sulfuric Acid Tank
-jc'*:rff
Photo 13 - Area around the Clean Water Tank and Pump House
Photo 14 - Roberts Pond, Note has Been Back Filled
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Photo 15 - Sulfuric Acid Tank Looking West
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Photo 15 - Sulfuric Acid Tank Foundation
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Photo 17 - Caustic Tank Foundation and Secondary Containment
Photo 18 - Secondary Containment Under CCD Tanks, Blowdown Discharge
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Photo 19 - Drainage Channel , Note that the Northern portion of the SX Building Roof (Background)
Drains through this Channel and is Pumped out into Mill Return (Makeup water)
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Photo 20 - Concrete Patch at the Alternate Feed Stating Area
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Photo 21-Alternate Feed Concrete, Note Patch/Sealant
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Photo 22 -Alternate Feedstock Storage Concrete Pad Staging Area, Note Patch/Sealant
"g
Photo 23 - Ammonia Crystal Sulfate Tanks and Nitrate Concrete Pad Area
Photo 24 - Used Oil and Kerosene Tanks in Secondary Containment
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,
Photo 25 - Sodium Chlorate Tanks, Secondary Containment
Photo 25 - Shop Drum Storage on Containment Pallets
Photo 27 - Cell4A Embankment $lope, Note Repaired Area in Middle of Photo
Photo 28 - Upland Drainage Ditch 1, Well Maintained
Photo 29 - Upland Drainage Ditch 1, Well Maintained
DEN\iER
UNITED STATES f~T;,~~RVICE
::L? OCT '16 J~1L First-Class Mail
Postage & Fees Paid
USPS
P~'l 3 t:TATE t'IAIL No. G-10
• Sender: Please print your name, address, and ZIP+4 in this box •
-------------------------~----------
DEPARTMENT OF ENVIRONMENl:AL. 0' IALITY 1
DIVISION OF WASTE MANAGEMENT--
AND RADIATION CONTROL '
PO BOX 144880
SALT LAKE CITY, UT 84114-4880 -~---~
J.! jill",, I,, Ill II IIIIJIJI" ljl .I!JJIIIIJII' IJIIIJII 11111111 'Ill
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If YES, enter delivery address below:
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA~)~In~c~. --:--:----=========
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