DAQ-2024-008283

1
DAQC-CI112050002-24
Site ID 11205 (B1)

MEMORANDUM

TO: FILE – ENERGY FUELS RESOURCES (USA) INC. – White Mesa Mill

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: May 24, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, San Juan County

INSPECTION DATE: April 18, 2024

SOURCE LOCATION: 6 Miles south of Blanding on Highway 191
San Juan County, UT 84511
SOURCE CONTACTS: Garrin Palmer, Environmental Coordinator
435-678-4114; [e-mail]

Scott Bakken, Vice President - Regulatory Affairs
303-389-4132; [e-mail]

OPERATING STATUS: Partially Operating. The source just resumed processing material
and is not at full operational capacity.

PROCESS DESCRIPTION: The White Mesa Mill processes ore from mines in southeastern
Utah and northern Arizona using conventional milling methods
including: grinding, two stage acid leaching, solvent extraction,
precipitation, thickening, drying, and packaging of processed
uranium and vanadium. The mill capacity is 2,000 tons per day.
Ore contains on average 0.2% U308 (2.6 lbs. U308/ton).
Processing yields a yellow cake product containing 90% U308.
The vanadium circuit operates intermittently, depending on ore
content and vanadium prices, producing V205 black flake
vanadium and ammonia metavanadate.

Since 1993 the mill has been reprocessing contaminated
materials from dismantled mill sites and depositing tailings in an
impoundment. Following grinding and leaching, the sand portion
of the ore tailings are pumped to an impoundment (cell) and
covered. Cell 2 is closed and is now covered by fill material. The
tailings cells 1-3 are compacted clay-lined ponds constructed
below grade. Cells 4a and 4b have a synthetic liner and are
constructed in accordance to 40 CFR 61 Subpart W. The entire
tailings area has up and down gradient monitoring wells, leak
detection systems, and a particulate monitoring network
regulated by the Nuclear Regulatory Commission (NRC).

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2
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN112050024-21, dated
December 23, 2021
NSPS (Part 60) Dc: Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,
NESHAP (Part 61) - W: National Emission Standards for Radon
Emissions from Operating Mill Tailings,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Energy Fuels Resources (USA) Inc. - White
Mesa Mill

Independence Plaza 1050 17th Street, Suite 950 6 Miles south of Blanding on Highway 191
Denver, CO 80265 San Juan County, UT 84511

SIC Code: 1094: (Uranium-Radium-Vanadium Ores)

Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

3
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

Status: In Compliance. The conditions listed in Section I were found to be in compliance.
The source submitted notification of installation for the newly permitted HCL tanks and
Scrubbers (II.A17 and II.A.18). The 2023 Emission Inventory was submitted by the
required date.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Uranium Mill
Source-wide

II.A.2 Uranium Drying
One (1) Yellowcake South Dryer
Capacity: 3.0 MMBtu/hr
Fuel Type: Propane or liquefied natural gas

II.A.3 Uranium Drying/Pollution Control
Air Pollution Equipment for the South Dryer
One (1) dry cyclone followed by one (1) scrubber with a cyclonic separator after the scrubber
Flow Rate: 3,800 acfm (150 degrees Fahrenheit)

II.A.4 Uranium Drying
One (1) Yellowcake North Dryer
Capacity: 2.4 MMBtu/hr
Fuel Type: Propane or liquefied natural gas

II.A.5 Uranium Drying/Pollution Control
Air Pollution Equipment for the North Dryer
One (1) scrubber with packed demister
Flow Rate: 3,160 acfm (140 degrees Fahrenheit)

II.A.6 Vanadium Drying
One (1) Ammonium Meta-Vanadate (AMV) Dryer
Controlled by the scrubber system listed in I.A.10
Heat Input Capacity: 7.74 MMBtu/hr
Fuel Type: Propane or liquefied natural gas

II.A.7 Vanadium Drying
Two (2) Fusion Furnaces and casting wheels
Controlled by the scrubber system listed in I.A.10
Capacity: 1.8 MMBtu/hr each
Fuel Type: Propane or liquefied natural gas

II.A.8 Vanadium Drying
Two (2) Multi Hearth Dryers serve as back up for the fusion furnaces.
Controlled by the scrubber system listed in I.A.10

II.A.9 Vanadium Drying
One (1) Rotary Calciner.
Controlled by the scrubber system listed in I.A.10
Capacity: 4.0 MMBtu/hr
Fuel Type: Propane or liquefied natural gas
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II.A.10 Vanadium Drying/Pollution Control
Air Pollution Equipment for AMV dryer & furnaces: includes one (1) dry cyclone, two (2) venturi
scrubbers, and one (1) mist eliminator which discharges to the one (1) stack.
Scrubber Flow: 27,800 acfm (440 degrees Fahrenheit)

II.A.11 Boilers
One (1) Boiler - Pre-NSPS (Manufactured in 1987)
Capacity: 23.5 MMBtu/hr
Fuel Type: Propane or liquefied natural gas

One (1) Boiler
Capacity: <5.0 MMBtu/hr
Fuel Type: Propane or liquefied natural gas

One (1) Low NOx Boiler (Superior Boiler Works)
Capacity: 25.2 MMBtu/hr
Fuel Type: Propane or liquefied natural gas

II.A.12 Baghouses
One (1) Grizzly Baghouse (ore or Alternate Feed)
Capacity: 5,000 acfm (68 degrees Fahrenheit)

One (1) Uranium Packaging Area Baghouse
Both dryers (south & north) discharge into a common hopper located in the enclosed packing area.
The packing area is under negative pressure and all the generated dust discharges through a
baghouse.
Flow Rate: 5,000 acfm (68 degrees Fahrenheit)

II.A.13 Baghouses
One (1) Dry Soda Ash Silo Bin Baghouse
Capacity: 5,000 acfm

One (1) Sample Preparation Room (Bucking Room) Baghouse
Capacity: 1,000 acfm

One (1) Vanadium Area Cartridge Filter Baghouse
Capacity: 12,500 acfm

II.A.14 Uranium Leaching Mist Eliminators
Two (2) mist eliminators in parallel tied to one (1) common mist eliminator at the stack discharge
(total of three (3)). The vanadium precipitation area also vents through the same mist eliminator on
the uranium leach area stack discharge.
Process Rate: 250 tons/year
Design Rate: 0.07 lb/hr of SO2

II.A.15 Fire Pump
Capacity: 273 kW (365 bhp)
Fuel Type: Diesel

II.A.16 Emergency Generator
Capacity: 1,100 kW (1,475 bhp)
Fuel Type: Diesel

II.A.17 Three (3) Hydrogen Chloride Tanks (new)
Capacity: 14,000 gallons each

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II.A.18 Scrubber (new)
For scrubbing fumes from all three HCL tanks
Capacity: 710 gallons
Rating: 970 acfm

Status: In Compliance. No unapproved equipment was observed during the inspection. Only
two of the HCL Tanks (II.A.17) have been installed.

II.B Requirements and Limitations

II.B.1 Uranium Mill

II.B.1.a The owner/operator shall not process more than 720,720 tons of ore per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 The owner/operator shall:

A. Determine amount of ore processed by feed records

B. Record amount of ore processed on a daily basis

C. Use the processing data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months

D. Keep the processing records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. Calculations are made according to this condition. The source
produced 0 tons of ore for the rolling 12-month period from April 2023 - March 2024. The
source recently started processing ore at the beginning of April and it is not yet reflected
for the rolling monthly totals. Refer to the attachments for more details.

II.B.1.b The owner/operator shall not consume more than:

1. 267960 MMBtu heat input per rolling 12-month total for the entire source except the
Superior Boiler Works outlined below, and

2. 220,752 MMBtu heat input per rolling 12-month total for the Superior Boiler Works.

[R307-401-8]

II.B.1.b.1 The owner/operator shall:

A. Determine propane or liquefied natural gas consumption with purchase order
receipts and monthly inventories

B. Record fuel consumption on a daily basis

C. Calculate the annual total heat input by using heat value of 82,265 Btu per gallon for
liquid natural gas and 90,500 Btu per gallon for propane

D. Use the consumption data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months

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E. Keep the consumption records for all periods the plant is in operation. [R307-401-8]

Status: In Compliance. Calculations are made according to this condition. It was confirmed
the source calculates the annual total heat input using the heat value of 82,265 Btu per
gallon for liquid natural gas and 90,500 Btu per gallon for propane.

The rolling 12-month totals ending March 2024 are as follows:

17,452 MMBtu heat input for the entire source except the Superior Boiler Works
297 MMBtu heat input for the Superior Boiler Works

II.B.1.c Visible emissions from the following emission points shall not exceed the following values:

1) Ore loading Areas - 15% opacity

2) Vanadium Circuit - 15% opacity

3) All baghouses - 10% opacity

4) All diesel engines - 20% opacity

5) Conveyor drop points - 20% opacity

6) Propane or liquefied natural gas-fired, low NOx boiler - 10% opacity

7) All other points - 20% opacity. [R307-201-3]

II.B.1.c.1 Opacity observations of emission from stationary sources shall be conducted in accordance with
40 CFR Part 60, Appendix A, Method 9. [R307-401-8]

Status: In Compliance. No visible emissions were observed from any of the emission points
listed above. Refer to the VEO Form in the attachments for more details.

II.B.2 Engine Requirements

II.B.2.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

1) The date the emergency engine was used

2) The duration of operation in hours

3) The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ]

II.B.2.a.2 Records of hours of operation shall be determined by installing a non-resettable hour meter for
each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

Status: In Compliance. The emergency engine and fire pump engine operated 2.5 hours
and 8 hours, respectively, for the rolling 12-month period for non-emergency usage. The
date, duration, and reason for engine usage are recorded. Non-resettable hour meters are
present on both engines. Refer to the generator spreadsheet in the attachments for more
details. The fire pump engine usage form was not available to print but was verified at the
time of inspection.

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II.B.2.b The owner/operator shall install a 1,100 kW diesel-fired, emergency generator engine that is
certified to meet a CO emission rate of 8.5 g/hp-hr. [R307-401-8]

II.B.2.b.1 The owner/operator shall keep and maintain the emission rate certification for the life of the
equipment. [R307-401-8]

Status: In Compliance. The emergency engine owner's manual states that the emission's
rate of CO shall remain below 8.5 g/hp-hr. The corresponding specifications sheet
indicating compliance with this requirement was observed with the owner's manual of this
equipment.

II.B.3 Stack Testing Requirement

II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from the
indicated emissions units:

Source: Vanadium Circuit scrubbers

grains/dscf
Pollutant lb/hr (68 degrees Fahrenheit, 29.92 mm Hg)

PM10 2.5 each 0.02 each

Source: Yellowcake Dryer scrubbers

grains/dscf
Pollutant lb/hr (68 degrees Fahrenheit, 29.92 mm Hg)

PM10 0.4 each 0.03 each.

[R307-401-8]

II.B.3.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]

II.B.3.a.2 Initial Test
The owner/operator shall conduct stack tests on the emission units within 180 days after startup
of the emission units. [R307-165-2]

II.B.3.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within five years after the date
of the most recent stack test of the emission unit. The Director may require the owner/operator to
perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.3.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.3.b.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.3.b.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

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II.B.3.b.3
Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.3.b.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.3.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.3.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.3.c.1 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.3.c.2 PM10
Total PM10 = Filterable PM10

Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10.

Condensable PM shall also be tested using 40 CFR 51, Appendix M, Method 202 or other EPA-
approved testing method as acceptable to the Director. The Condensable PM shall not be used for
compliance demonstration but shall be used for inventory purposes. [R307-401-8]

Status: In Compliance. The most recent stack test was performed October 24-26, 2022, and
submitted to the DAQ for review on November 23, 2022. The preliminary stack test results
appear to be in compliance. A full evaluation will be conducted at a later date.

II.B.4 Fuel Requirements

II.B.4.a The owner/operator shall use propane or liquefied natural gas as fuel in the two yellowcake
dryers, vanadium multi hearth dryer, rotary calciner, AMV dryer, fusion furnaces and boilers.
[R307-401-8]

Status: In Compliance. Natural gas is used as fuel with propane as backup fuel.

II.B.4.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the
emergency generator, and fire pump engine. All diesel burned shall meet the definition of ultra-
low sulfur diesel (ULSD), and contain no more than 15 ppm sulfur. [R307-401-8]

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II.B.4.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the
owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall
indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain
certification of sulfur content from the fuel supplier. [R307-401-8]

Status: In Compliance. Diesel #2 is used in both the emergency generator and fire pump
engine. The fuel was verified as an ULSD containing no more than 15 ppm sulfur. This was
determined from the fuel purchase invoice from RelaDyne.

II.B.5 Roads & Fugitive Dust

II.B.5.a The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive
Emission and Fugitive Dust sources. [R307-205]

Status: In Compliance. No fugitive emissions were observed during the inspection.

II.B.5.b Visible fugitive dust emissions from paved and unpaved haul/access road traffic; soil and
overburden stockpiles; tailing retention areas; and mobile equipment in operational areas shall
not exceed 20% opacity. All unpaved haul/access roads shall have at least one inch of gravel as
road-base surface or will be watered and/or chemically treated. The owner/operator shall
periodically sweep or spray clean any section of paved road on site, as dry conditions warrant or
as determined necessary by the Director. The soil and overburden stockpiles shall be sprayed
with water between stockpiling and vegetation periods. [R307-205]

Status: In Compliance. No visible emissions were observed. A water truck is present on site
to wet down roads and stockpiles as necessary.

II.B.5.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal requirement
for observations to be made at 15-second intervals over a six-minute period, however, shall not
apply. Visible emissions shall be measured at the densest point of the plume but at a point not
less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height of the vehicle.
[R307-401-8]

Status: In Compliance. No fugitive emissions were observed from mobile equipment.

II.B.5.c The owner/operator shall use water application or other control options contained in R307-205 to
minimize emissions from fugitive dust and fugitive emissions sources, including haul roads,
storage piles, and disturbed areas. Controls shall be applied to ensure the opacity listed in this
AO is not exceeded. [R307-205, R307-401-8]

Status: In Compliance. A designated water truck is present and no visible emissions were
observed.

II.B.5.c.1 All records of treatment of the unpaved and paved haul roads shall include the following items:

1) Date of treatment

2) Number of treatments made

3) Rainfall received, if any, and approximate amount

4) Time of day treatments were made. [R307-205]

Status: In Compliance. Water logs were viewed on site. Each log included the date and time
of treatments, number of treatments, and rainfall received.

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II.B.5.d The owner/operator shall periodically sweep or spray clean any section of the paved road to
ensure the opacity listed in this AO is not exceeded. [R307-205-7]

Status: In Compliance. The source indicated that paved roads are washed when necessary.

II.B.5.e The grizzly baghouse shall be used at the ore grizzly and apron feeder tunnel. The ore grizzly
shall be enclosed on three sides and have wetting agents applied at the apron feeder and the
conveyor discharge. [R307-401-8]

Status: In Compliance. The grizzly baghouse is used at the ore grizzly and apron feeder
tunnel. It is enclosed on three sides and wetting agents are available when operating.

II.B.5.f The mill area shall be graveled and/or shall be sprayed with water to minimize fugitive dust.
[R307-401-8]

Status: In Compliance. The mill area is graveled and sprayed with water to minimize
fugitive dust when necessary.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.

NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units

Status: In Compliance. This subpart applies to the low NOx boiler (II.A.11). Compliance is met through
the use of natural gas as primary fuel and propane as a backup fuel.

NESHAP (Part 61) - W: National Emission Standards for Radon Emissions from Operating Mill Tailings

Status: In Compliance. No solids were observed above the liquid surface in Cell 4B according to
61.252(b). Record keeping and digital pictures are taken according to 61.255. The 2023 Annual Radon
Flux Monitoring Report for Cell 3 was submitted March 2, 2024. Refer to pictures submitted on March
28, 2024, in the attachments for more details.

MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. This subpart applies to both the emergency generator and fire pump engine. The
requirements for ULSD, installation of a non-resettable hour meter and a maximum 100hr/calendar
year for maintenance are satisfied in Section II above. The emergency generator is tested once every
three months for 30 minutes. Regular maintenance is performed and a log of operating
hours/maintenance conducted is maintained for both the generator and fire pump.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]

Status: In Compliance. No fugitive emissions were observed during the site visit. This rule is
discussed in more detail and satisfied in Section II.B.5.

Standards of Performance for New Stationary Sources [R307-210]

Status: In Compliance. This area source rule is satisfied through compliance with NSPS Subpart Dc.
Refer to the Federal Requirements section for more details.

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. This area source rule is satisfied through compliance with MACT Subpart
ZZZZ. Refer to the Federal Requirements section for more details.

EMISSION INVENTORY:

Listed before are the 2020 Actual Emissions Inventory provided from Energy Fuels Resources (USA) Inc.
- White Mesa Mill. The 2023 Emission Inventory was submitted by the required date but is still under
review. A comparison of the estimated total potential emissions (PTE) on Approval Order (AO)
DAQE-AN112050024-21, dated December 23, 2021. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 32877.00 N/A
Carbon Monoxide 10.69 2.97
Nitrogen Oxides 40.46 6.42
Particulate Matter - PM10 34.09 0.04
Particulate Matter - PM2.5 17.10 0.04
Sulfur Dioxide 2.91 0.26
Volatile Organic Compounds 4.06 2.32

Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Formaldehyde (CAS #50000) 60 N/A
Hexane (CAS #110543) 1260 N/A
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 132 N/A

12
PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory (C-1359-21) dated October 27, 2021, and
Modified Early Settlement Agreement (C-981-23) dated
September 15, 2023.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN112050024-21,
dated December 23, 2021: In Compliance. The source appears to
be well maintained and operated. Records are current and were
provided at the time of inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the regular interval. Schedule inspection ahead of
time. Hardhat, steel-toe boots, safety glasses, and high visibility
clothing are required for a site visit.

NSR RECOMMENDATIONS: None.

ATTACHMENTS: VEO Form, Ore Production Totals, Generator Operating Hours,
Cell 4B Pictures
I I I I i
'
----iih, _______________________________________ _
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Page of --
EPA METHOD 9 -VISIBLE EMISSION OBSERVATION FORM
Source Name: Q\tryi4 -h(IS RcsQ(Jc«S -wvi·lt(... Me.sq Mill
Street Address: fo M;,,s sc-vk,, of: Bw,~ of\ \\u,_1 l9\
City/County: f:>I~,"~ / SoQ Jvcic
Phone: 30 3 -3f:9 -4 \32
Site ID: )\:Z,CJS:
Facility: Ora/\iuM l/W)~,·~ ,(½1'1 I
Equipment/Process: (b011,O / Dcv(rs
Control Equipment: Be~ wevGc-/ Sc.cv'obu s:
Emission Point: 0 ~c''S Vrok £¼ • . 1 I I-bl,<,..
Sky Conditions: Clear I ] Partly Cloudy [ ] Overcast [ ]
Precipitation: No [ ] Yes I ]
Wind: Direction: ___ Speed: __ _ mph
Ambient Temp: °F RH: ___ %
Height Relative to Observer: ---
Distance From Observer: ---
Condensed Water Vapor Present: No [ ] Yes I ]
Attached I ] Detached I ]
Length of Condensed Water Vapor Plume: _____ _
Background: ______________ _
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
0
IJ,.,w ntinh Urlf1'-'
• observer
Sun Wind Emission Point with Plume ( ...... ).....__.
Observer Position X
Observer's Signature:
Distrib: white•file; canary•inspector; if
OBSERVATION DATE: -~Y-+-)_._I <r=--=-J_z_j..__
Start time: ___ Stop time: __ _
sec 0 15 30 45 min
1 '-
i---2
3 > V
4 / "' / , .... "' 5
6 7 " r-,..__
7
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9
10
11
12
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COMMENTS:
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I have received a copy of these observations:
SIGNATURE: 6~
Printed Name: Ge-,,..· k R_ (
Title: iZSQ
-----.........-..-.A ................ ~------'-,~----~----------
Month/veal Mar-23 I Apr-23 Mav-23 Jun-23 Jul-23 Auo-23 I Sep-23 I Oct-23 I Nov-23 I Dec-23 I Jan-24 I Feb-24 I Mar-24
Ore Fed I O I O 0 0 0 o I o I o I o I o I o I o I o
!12 Month j 0
I = I
I I I I
GENERATOR TESTS 2023
Date Run time FUEL Load hours Description
2/18/2023 1 hr 51% 10,589 Generator ran for power outage
used as
1.st quarter check
all ATS Switches checked good
5/4/2023 .5 hr 51% 10,590 Generator ran for Quarterly check
.5 hr second test after troubleshooting
2nd quarter check
ATS #1 had an issue
found an issue with the UPS system and fixed
second test everything worked
8/23/2023 2hrs 50% 10,593 Generator ran due to power loss
Rocky Mtn. Power has some issues and the
power was down for 2 hours
3rd quarter check
all ATS Switches checked good
9/6/2023 1hr 49% 10,594 Generator ran due to power loss
Rocky Mtn. Power has some issues and the
power was down for 1 hour
4th quarter check
all ATS Switches checked good
I I I r I I !
Date Run time
3/20/2024 0.5
GENERATOR TESTS 2024
FUEL Load hours Description
49% 10,594 Generator ran for Quarterly Check
tripped breaker to enable Test
1st quarter check
all ATS Switches checked good
2nd quarter check
3rd quarter check
4th quarter check
Subpart W Impoundment Photographic Reporting
Organization Point of Contact (POC)Information
CDX User:KATHY.WEINEL
Organization:Energy Fuels Resources (USA)Inc
Facility Impoundments Information
Impoundment Name:CELL 4B
Impoundment Address:4899 S HIGHWAY 191 BLANDING UT,84511
Registry ID:110070049802
Program ID:SWIPR10005081
Upload Information
Attachment Name Attachment Description Attachment Thumbnail
4B NW.JPG
Cell 4B from northwest
corner;Date &Time:
3/6/2024 2:08 PM
4B NE.JPG
Cell 4B from northeast
corner;Date &Time:
3/6/2024 2:06 PM
4B SE.JPG
Cell 4B from southeast
corner;Date &Time:
3/6/2024 2:15 PM
4B SW.JPG
Cell 4B from southwest
corner;Date &Time:
3/6/2024 2:10 PM
4B NE.JPG
Cell 4B from northeast
corner;Date &Time:
3/14/2024 12:22 PM
4B NW.JPG
Cell 4B from northwest
corner;Date &Time:
3/14/2024 12:24 PM
4B SE.JPG
Cell 4B from southeast
corner;Date &Time:
3/14/2024 12:29 PM
4B SW.JPG
Cell 4B from southwest
corner;Date &Time:
3/14/2024 12:25 PM
4B NE.JPG
Cell 4B from northeast
corner;Date &Time:
3/19/2024 12:04 PM
4B NW.JPG
Cell 4B from northwest
corner;Date &Time:
3/19/2024 12:06 PM
4B SE.JPG
Cell 4B from southeast
corner;Date &Time:
3/19/2024 12:13 PM
4B SW.JPG
Cell 4B from southwest
corner;Date &Time:
3/19/2024 12:08 PM
4B NE.JPG
Cell 4B from northeast
corner;Date &Time:
3/27/2024 9:26 AM
4B NW.JPG
Cell 4B from northwest
corner;Date &Time:
3/27/2024 9:29 AM
4B SE.JPG
Cell 4B from southeast
corner;Date &Time:
3/27/2024 9:34 AM
4B SW.JPG
Cell 4B from southwest
corner;Date &Time:
3/27/2024 9:30 AM
Additional Notes
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