DRC-2023-003115 - 0901a068811d3e3d

DRC-2023-003115 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. 711 www.deq.utah.gov Printed on 100% recycled paper
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director M E M O R A N D U M

TO: File C-2023-28 THROUGH: Phil Goble, Section Manager
FROM: Heather Mickelson, P.E. and P.G.
DATE: April 16, 2023 SUBJECT: 2022 Annual Technical Evaluation Report; Radioactive Materials License UT1900479

On February 28, 2023, the Utah Division of Waste Management and Radiation Control (DWMRC) received the Annual Technical Evaluation of the White Mesa Uranium Mill Tailings Management System for the Period of January 1, 2022 through December 31, 2022, dated February 27, 2023 (ATER). This report was submitted in both hard copy and CD formats.

Summary Staff findings and recommendations from the review of the ATER are:

It appears that Energy Fuels Resources (EFR) actively evaluated plant conditions and operations throughout the year to comply with requirements in its Radioactive Material License #UT 1900479 Amendment #10, dated July 27, 2021 (RML).
Finally, the DWMRC should monitor performance of the tailings management system closely as
Impoundment 4A fills, Impoundment 3 closes, and tailings begin to be deposited in Impoundment 4b for problems maintaining freeboard. There were historical problems maintaining freeboard in 2011. This comment has been carried forward since 2012.
Requirements The conditions used to evaluate the ATER from the RML are:
April 17, 2023
04/18/2023
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Condition 12.2 Annual Technical Evaluation Report (ATER) - starting 2021, the licensee shall submit an ATER for Director approval no later than March 1, of each year. Each ATER shall incorporate all
documents and attachments, including applicable updates to previously submitted documents with
attachments that support information presented in the ATER, including, but not limited to maps, drawings, tables, and figures. The licensee shall include, as part of the ATER, results of tailings cell temporary cover settlement and dike displacement monitoring activities. The content of the tailings cell temporary cover
settlement and displacement monitoring program related information shall include those records required in
License Conditions 11.7 and 11.8. [Applicable UDRC Amendment: 4] [Applicable UDWMRC Amendment:10]
Condition 10.3 includes freeboard limits, stormwater and wastewater management for the tailings
conventional and unconventional impoundments. Condition 10.5 limits the disposal of 11e.(2) byproduct material in volume, burial requirements and location, documentation, and reporting requirements. The ATER includes the disposed 11e.(2)
byproduct material requirements. This is the second year that it has been included in this report. Condition 11.1 requires that documentation shall be maintained for at least 5 years, unless otherwise specified. This includes documentation related to sampling, analyses, surveys and monitoring, the results of calibration of equipment, reports on audits and inspections, all meetings and training courses
required by this license and any subsequent reviews, investigations, and corrective actions, Condition 11.7 includes the Standard Operating Procedure for settlement monitoring. Reporting of this monitoring effort is found in the ATER.
Condition 11.8 includes the Standard Operating Procedure for movement (vertical and horizontal displacement) monitoring in the constructed dike portions of the impoundments. Reporting of this monitoring effort is included in the ATER.
Diversion Channels Energy Fuels Resources (EFR) is actively maintaining Diversion Channels 1, 2, and 3. They note that water is not ponding in the channels even with the heavy precipitation and snow with the 2022 to 2023 winter. Observed erosion in Diversion Channel 2 was noted and EFR has planned maintenance
activities planned to repair the channel. Maintaining Freeboard
EFR added sands or liquids to impoundments 1, 4a, and 4b had material during 2022. The mill
processed Monzanite Sands, Cameco KF, and Cameco calcine. Also, EFR covered the bottom surface of Impoundment 4b with water to cover crystals formed with liquid evaporation. Water was added to Impoundment 1 to cover crystals.
The maximum freeboard limit was not exceeded for Impoundments 1 and 4B. Impoundment 4A does
not have a freeboard limit, as Impoundment 4B is the final downstream impoundment.
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Monitoring the freeboard is not necessary for Impoundment 2 and 3. Impoundment 2 was determined to be full and has been covered with random fill, is being dewatered, and monitored for settling. Impoundment 3 is currently used for 11e.(2) disposal only and 85 % of it has been covered with random
fill.
The 2011 ATER contained detailed instances where EFR failed to maintain appropriate freeboard in various impoundments involved in the tailings management system. Although, the 2012 to 2022 ATERs show that EFR successfully maintained fluid levels without exceeding freeboard during this time.
However, as processing of ore and alternative feed continues, the tailings beach in Impoundment 4a will
expand and it is more likely that the freeboard will be exceeded in liquid containing impoundments. Therefore, the freeboard should be closely monitored.
Monitoring Lateral Displacement
Movement monitors for Impoundments 4A and 4B show no evidence of horizontal displacement.
Monitoring Vertical Displacement
Impoundment 2 has had cover placed over it to limit radon emissions and is being dewatered. Settlement occurs as the impoundment is dewatered. However, settlement is occurring at a slower pace than previously observed.

Impoundment 3 has observed differential settling. This is expected as only a portion of the impoundment is covered and the portion that is not covered receives 11e.(2) material. In areas receiving material, settlement is occurring. In other areas, heaving has occurred. Once dewatering begins, settling should occur over the entire cell.

Impoundment 4A embankment monitors show no motion. The toe is stable. 11e.(2) Byproduct Disposal

The quantity of 11e.(2) byproduct material disposed of, 477 cubic yards, is within the allowable limit. All material was buried in Impoundment 3 and the approved Standard Operating Procedure (PBL-10) was used to bury the material. Inspections of these burial activities occur in separate inspection reports prepared by UDWMRC.

Tailings Transport System EFR uses HDPE pipe to carry tailings slurry to Impoundment 4A. Solution lines also run between the
mill and impoundments 1 and 4B for fluid management. These pipelines are inspected daily for leakage
and repaired, as necessary, to prevent a release.