DRC-2017-002207 - 0901a068806d9603

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.enersvfuels.com
Div of Waste Management
and Radiation Control
March 27, 2017
nm 2 9 2017
Sent VIA OVERNIGHT DELIVERY
drc-zoiT-oozzoYMr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Transmittal of Stamped and Signed Spill Prevention, Control, and Countermeasures Plan
(“SPCC”) Plan, White Mesa Uranium Mill
Dear Mr. Anderson:
By letter dated March 21, 2017, the Division of Waste Management and Radiation Control (“DWMRC”)
approved the proposed revisions to the White Mesa Mill SPCC Plan. Pursuant to the approval, attached please
find 2 copies of the stamped and signed SPCC for your records.
If you should have any questions regarding this report please contact me.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Mark Chalmers
Harold R. Roberts
David E. Turk
Logan Shumway
Scott Bakken
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
December 12, 2016
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S.HWY 191
BLANDING, UT 84511
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Contents
1.0 OBJECTIVE............................................................................................................................1
1.1 Plan Organization................................................................................................................1
2.0 RESPONSIBILITIES...............................................................................................................2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS........................................................2
4.0 DESCRIPTION OF BASINS...................................................................................................2
4.1 Basin A1.........................................................................................................................2
4.2 Basin A2.......................................................................................................'................2
4.3 Basin B1.........................................................................................................................2
4.4 Basin B2.........................................................................................................................3
4.5 Basin B3.........................................................................................................................3
4.6 Basin C...........................................................................................................................3
4.7 Basin D...........................................................................................................................3
4.8 Basin E...........................................................................................................................3
4.9 Basin F...........................................................................................................................3
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT............................3
5.1 Reagent Tanks (Tank list included in Table 2.0)............................................................4
5.2 Ammonia........................................................................................................................4
5.3 Ammonium Meta-Vanadate...........................................................................................4
5.4 Caustic Storage (Sodium Hydroxide).............................................................................4
5.5 Sodium Carbonate (Soda Ash)......................................................................................4
5.6 Sodium Chlorate.............................................................................................................4
5.7 Sulfuric Acid........................................................... 5
5.8 Vanadium Pentoxide.......................................................................................................5
5.9 Kerosene (Organic).........................................................................................................5
5.10 Used/Waste Oil..............................................................Error! Bookmark not defined.
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT.............................................5
6.1 Petroleum Tanks.............................................................................................................6
6.1.1 Diesel......................................................................................................................6
6.2 Aboveground Fuel Pump Tanks.....................................................................................6
6.2.1 Diesel......................................................................................................................6
6.2.2 Unleaded Gasoline.................................................................................................6
6.2.3 Pump Station...........................................................................................................6
6.2.4 Truck Unloading......................................................................................................7
7.0 SPILL DISCOVERY AND REMEDIAL ACTION.....................................................................7
8.0 SPILL INCIDENT NOTIFICATION.........................................................................................7
8.1 External Notification............................................................................................................8
8.2 Internal Notification..............................................................................................................8
9.0 RECORDS AND REPORTS..................................................................................................9
10.0 SPILL REPORTING REQUIREMENTS..............................................................................10
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES.............................10
11.1 Training Records..........................................................................................................10
11.2 Monitoring Reports........................................................................................................10
12.0 REVISION...........................................................................................................................10
13.0 MILL MANAGER APPROVAL.............................................................................................11
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER.................................11
15.0 SUMMARY..........................................................................................................................12
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN FOR
CHEMICALS AND PETROLEUM PRODUCTS
1.0 OBJECTIVE
The objective of the Spill Prevention, Control, and Countermeasures (SPCC) Plan is to serve
as a site-specific guideline for the prevention of and response to chemical and petroleum
spills. The plan outlines spill potentials, containment areas, and drainage characteristics of
the White Mesa Mill site. The plan addresses chemical spill prevention, spill potentials, spill
discovery, and spill notification procedures. Spills are reportable if the spill leaves the site.
Ammonia is the only chemical (as vapor) that has the potential to leave the site. In addition,
chemical and petroleum spills will be reported in accordance with applicable laws and
regulations.
1.1 Plan Organization
This SPCC is organized as follows:
Section 1.0 Objective
Section 2.0 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4.0 Description of Basins
Section 5.0 Potential Chemical Spill Sources and Spill Containment
Section 6.0 Potential Petroleum Spill Sources and Containment
Section 7.0 Spill Discovery and Remedial Action
Section 8.0 Spill Incident Notification
Section 9.0 Records and Reports
Section 10.0 Spill Reporting Requirements
Section 11.0 Personnel Training and Spill Prevention Procedures
Section 12.0 Revision
Section 13.0 Mill Manager Approval
Section 14.0 Certification by Registered Professional Engineer
Section 15.0 Summary
Tables:
Table 1.0 is the Energy Fuels Resources (USA) Inc. (EFRI) personnel responsible for
implementing this SPCC.
Table 2.0 lists the reagent tanks and their respective capacities.
Table 3.0 lists the laboratory chemicals, their amounts, and their reportable quantities.
Table 4.0 lists the reagent yard/small quantity chemicals.
Table 5.0 lists the chemicals in the reagent yard, their amounts, and their reportable
quantities.
Table 6.0 lists the petroleum products and solvents on site.
1
Figures:
Figure 1 shows the Mill Site Layout, shows the mill site including the locations of the
chemical tanks on-site.
Figure 2 shows the basins and drainage ditch areas for the Mill Site.
Figure 3 shows the organization chart for Mill Operations.
2.0 RESPONSIBILITIES
Personnel responsible for spill prevention and follow-up spill reporting are included on Table
1 which is included in the Tables Tab of this SPCC.
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS
The main drainage pathways are illustrated in Figure 2. The map shows drainage basin
boundaries, flow paths, constructed diversion ditches, tailing cells, the spillway between Cell
2 and 3, dikes, berms, and other relevant features. The White Mesa Mill is a “zero”
discharge facility for process liquid wastes. The mill area has been designed to ensure that
all spills or leaks from tanks will drain toward the lined tailing management system.
The management system, in turn, is operated with sufficient freeboard (minimum of three
feet) to withstand 100% of the PMP (Probable Maximum Precipitation). This allows for a
maximum of 10 inches of rain at any given time.
Precipitation and unexpected spills from the mill site are contained within their prospective
drainage basins. Overflow ultimately drains into the tailings management system.
4.0 DESCRIPTION OF BASINS
4.1 Basin A1
Basin A1 is north of Cell 1 and Diversion Ditch No. 1. The basin contains 23 tributary acres,
all of which drain into Westwater Creek.
4.2 Basin A2
Basin A2 contains all of Cell 1 including an area south of the Diversion Ditch No. 1. The
basin covers 84 acres. Any overflow from this basin would be contained within Cell 1.
4.3 Basin B1
Basin B1 is north of the mill area. The basin contains 45.4 tributary acres.
Overflow from this basin drains into a flood retention area by flowing through Diversion
Ditch No. 2. Diversion Ditch No. 2 drains into Westwater Creek.
2
4.4 Basin B2
Basin B2 is northeast of the mill area and contains only 2.6 tributary acres. Overflow from
this basin would drain into Diversion Ditch No. 3. Diversion Ditch No. 3 ultimately drains
into Diversion Ditch No. 2.
4.5 Basin B3
Basin B3 contains most of the mill area, buildings, ore stockpiles, process storage tanks,
retention ponds, spill containment structures, pipelines, and roadways. The normal direction
of flow in this basin is from the northwest to the southwest. Any overflow from this basin
would drain into Cell 1. The basin contains 64 acres. This basin has sufficient freeboard to
withstand 100% of the PMP (Probable Maximum Precipitation). This allows 10 inches of
rain for any given storm event.
4.6 Basin C
Basin C contains all of Cell 2. The basin consists of 80.7 acres. Areas in this basin include
earth stockpiles and the heavy equipment shop. The direction of flow in this basin is to the
southwest. All overflows in this basin is channeled along the southern edge of the basin.
Overflow then flows into Cell 3 via the spillway from Cell 2 to Cell 3.
4.7 Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including a portion of the
slopes of the topsoil stockpile and random stockpile. The basin contains all flows, including
those caused by the PMP.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4A.
4.9 Basin F
Basin F contains Cell 4B, and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4B.
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT
Routine monitoring is conducted of the reagent tanks and storage areas. Daily visual
monitoring of the reagent tanks and storage areas are conducted during the twice-daily shift
inspections. Weekly visual monitoring of the tank supports and foundations are conducted
by the RSO. The scope of the daily and weekly visual monitoring includes an inspection for
leaks or visual structural abnormalities. Any issues identified during the routine visual
monitoring would be noted as such on the associated documentation. If no issues are noted,
the system, tanks or storage area condition was considered acceptable.
3
5.1 Reagent Tanks (Tank list included in Table 2.0)
5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of 31,409 gallons each. The
tanks are located southeast of the Mill building.
Integrity inspections will be conducted to minimize the hazard associated with ammonia.
The reportable quantity for an ammonia spill is 7 gallons.
Ammonia spills should be treated as gaseous. Ammonia vapors will be monitored closely to
minimize the hazard associated with inhalation. If vapors are detected, efforts will be made
to stop or repair the leak expeditiously. Ammonia is the only chemical (as vapor) that has the
potential to leave the site.
5.3 Ammonium Meta-Vanadate
Ammonium meta-vanadate is present in the vanadium precipitation area of the Mill building
as the process solutions move through the circuit to produce the vanadium end product.
Spills would be contained in the process sump within the vanadium precipitation area. The
reportable spill quantity for ammonium meta-vanadate is 1,000 pounds.
5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner of the SX
building. The tank has a capacity of 19,904 gallons. The tank supports are mounted on a
concrete curbed catchment pad which directs spills into the sand filter sump in the northwest
corner of the SX building. The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located outside the
northeast corner of the SX building. Spills from the soda ash solution tank are contained in
the North SX impound and run to Cell 1. The smaller soda ash shift tank has a capacity of
8,530 gallons and is located in the SX building. Spills will be diverted into the boiler area,
and would ultimately drain into Cell 1. There is no reportable spill quantity associated with
sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of three fiberglass tanks located within a dike east of the SX
building. Tank maximum volumes of the three tanks are 16,075, 21,057 and 28,788 gallons.
Integrity inspections will be conducted to minimize the hazard associated with sodium
chlorate.
4
Sodium chlorate that has dried and solidified becomes even more of a safety hazard due to its
extremely flammable nature. The reportable spill quantity for sodium chlorate is 400
gallons.
5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of 1,600,000
gallons and one smaller tank with a capacity of 11,000 gallons.
The large tank is located in the northwest corner of mill area basin B3 and is primarily used
for acid storage and unloading. The tank support for the large tank is on a mound above a
depression which would contain a significant spill. All flows resulting would be channeled
to Cell 1. The tank is equipped with a high level audible alarm which sounds prior to tank
overflows. A concrete spill catchment with a sump in the back provides added containment
around the base of the tank. However, the catchment basin would not be able to handle a
major tank failure such as a tank rupture. The resulting overflow would flow towards Cell 1.
The smaller storage tank is located on the north side of the SX building. The tank is
equipped with a high level audible alarm.
The reportable spill quantity for sulfuric acid is 65 gallons.
5.8 Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the drying and fusing
circuits and is not present in the vanadium circuit until after the deammoniator. Efforts will
be made to minimize leaks or line breaks that may occur in processes in the circuit that
contain vanadium pentoxide. Special care will be taken in the transportation of this chemical.
The reportable spill quantity for vanadium pentoxide is 1000 pounds.
5.9 Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a combined capacity of
10,152 gallons in three tanks. Any overflow from these three tanks would flow around the
south side of the SX building and then into Cell 1. These tanks have drain valves which
remain locked unless personnel are supervising draining operations. The reportable spill
quantity for kerosene is 100 gallons.
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
Routine inspections are conducted of the petroleum containment, tanks, and storage areas.
Daily visual monitoring of the petroleum containment, tanks, and storage areas are conducted
during the twice-daily shift inspections. Weekly visual monitoring of the tank supports and
foundations are conducted by the RSO. The scope of the daily and weekly visual monitoring
includes an inspection for leaks or visual structural abnormalities. Any issues identified
during the routine visual monitoring would be noted as such on the associated
5
documentation. If no issues are noted, the system, tanks or storage area condition was
considered acceptable.
Annual visual inspections of the used/waste oil and fuels tanks will be completed as
discussed in the Discharge Minimization and Technology Monitoring Plan, Revision 12.4,
Section 4.3.
6.1 Petroleum Tanks
6.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The tanks have
capacities of 250 gallons each. One of the diesel tanks is for the emergency generator.
The other tank is located in the pumphouse on an elevated stand. Spillage from either
tank would ultimately flow into Cell 1. The reportable spill quantity for diesel is 100
gallons. The spill is also reportable if the spill has the potential for reaching any nearby
surface waters or ground waters.
6.2 Aboveground Fuel Pump Tanks
6.2.1 Diesel
The diesel tank is located on the east boundary of Basin B3 and has a capacity of 6,000
gallons. The tank is contained within a concrete catchment pad. The reportable spill
quantity for diesel is 100 gallons. A diesel spill is also reportable if the spill has the
potential for reaching any surface waters or ground waters.
6.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded gasoline tank
has a capacity of 3,000 gallons and is contained within the same containment system as
the diesel tank. Spills having the potential for reaching any surface waters or ground
waters will need to be reported. The reportable spill quantity for unleaded gasoline is 100
gallons.
6.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling company
vehicles used around the mill site. The pump station is equipped with an emergency
shut-off device in case of overflow during fueling. In addition, the station is also
equipped with a piston leak detector and emergency vent. Check valves are present along
with a tank monitor console with a leak detection system. The catchment is able to
handle a complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a temporary berm
would need to be constructed. Absorbent diapers or floor sweep would be used in an
effort to limit and contain the spill. The soil would have to be cleaned up and placed in
the Cell currently used for the disposal of solid Mill wastes.
6.3 UsedAVaste Oil
6
Used/ Waste oil is located north of the maintenance shop in a tank and has a capacity of
5.000 gallons. The tank is contained within a concrete containment system. Used oil will be
disposed of on site. Any oil escaping the concrete containment system will be cleaned up.
Soil contaminated with used oil will be excavated and disposed of in the Cell currently used
for the disposal of solid Mill wastes.
6. 4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill area, proper
reporting and containment procedures will be followed when warranted, such as when oil or
diesel fuel is spilled. Proper clean-up procedures will be followed to minimize or limit the
spill. The spill may be temporarily bermed or localized with absorbent compounds. Any
soils contaminated with diesel fuel or oil will be cleaned up and placed in the Cell currently
used for the disposal of solid Mill wastes.
7.0 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take measures to
limit additional spillage and contain the spill that has already occurred. Chemical or
petroleum spills will be handled as follows:
• The Shift Foreman will direct efforts to shut down systems, if possible, to limit
further release.
• The Shift Foreman will also secure help if operators are requiring additional
assistance to contain the spill.
• The Shift Foreman is also obligated to initiate reporting procedures.
• Once control measures have begun and personal danger is minimized, the Shift
Foreman will notify the Production Superintendent, Maintenance Superintendent,
or Mill Manager.
• The Production or Maintenance Superintendent will notify the Mill Manager, who
in turn will notify the EH&S Manager and/or the Environmental Coordinator.
• The Mill Manager will assess the spill and related damage and direct remedial
actions. The corrective actions may include repairs, clean-up, disposal, and
company notifications. Government notifications may be necessary in some
cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
8.0 SPILL INCIDENT NOTIFICATION
7
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
1. EPA National Response Center 1-800-424-8802
2. US Nuclear Regulatory Commission 301-816-5100
3. State of Utah 801-538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301-816-5100
2. State of Utah, Natural Resources 801-538-7200
8.2 Internal Notification
Internal reporting requirements for incidents, spills, and significant spills are as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits operations or assesses
penalties of $100,000 or more
4. Publicity resulted or anticipated
5. $ubstantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-product
8
In the event of a spill requiring reporting, the Mill Manager is required to call the Quality
Assurance Manager, the Executive Vice President Conventional Operations, or the President
and Chief Executive Officer. The spill will first be reported to the Shift Foreman. The Shift
Foreman will then report the spill to the Mill Superintendent, Maintenance Superintendent, or
Mill Manager.
The Mill or Maintenance Superintendent will report to the Mill Manager. The EH&S
Manager and the Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Logan Shumway Mill Manager [phone]
David Turk EH&S Manager [phone]
Garrin Palmer Mill Environmental Compliance
Coordinator
[phone]
Thayne Holt Production Superintendent [phone]
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Stephen P. Antony President and Chief Executive
Officer [phone]
Harold R. Roberts Executive Vice President
Conventional Operations [phone]
Scott Bakken Sr. Director, Regulatory Affairs [phone]
Kathy Weinel Quality Assurance Manager [phone]
In the event the next person in the chain-of-command cannot be reached, then proceed up the
chain-of-command to the next level. Figure 3.0 shows the organizational chart for the mill
site.
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the Environmental
or Maintenance Department for inspection and review for a minimum of five years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thickness
d. Quarterly Tailings Inspection
9
e. Daily Operating Foreman and weekly RSO inspection reports
2. Tank to soil potential measurements
3. Annual used/waste oil and fuel tank visual inspections
4. Tank thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
6. Tank supports and foundation inspections
7. Spill Incident reports
8. Latest revision of SPCC plan
10.0 SPILL REPORTING REQUIREMENTS
1. Report to applicable government agency as required by laws and regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of spill
impacts
4. Report release of 5,000 pounds or more of any process material or waste product
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES
All new employees are instructed on spills at the time they are employed and trained. They
are briefed on chemical and petroleum spill prevention and control. They are informed that
leaks in piping, valves, and sudden discharges from tanks should be reported immediately.
Abnormal flows from ditches or impoundments are of immediate concern. In addition, a
safety meeting is presented annually by the Environmental Coordinator to review the SPCC
plan.
11.1 Training Records
Employee training records on chemical and petroleum spill prevention are maintained in the
general safety training files.
11.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
12.0 REVISION
This procedure is to be reviewed by the mill staff and a registered professional engineer at
least once every three years, and updated when circumstances warrant a revision.
10
13.0 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with the Standard
Operating Procedures currently in effect.
Logan Shumway
Mill Manager
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prej^jecLir^ accordance with good
engineering practices.
Harold R. Roberts
Registered Professional Eh
State of Utah No. 165838
11
15.0 SUMMARY
Chemical and petroleum spills will be reported in accordance with applicable laws and
regulations. Spills that leave the property need to be reported immediately. Each spill
will be assessed and reported as required by the applicable regulations. Reportable
quantities are shown in the attached tables.
12
TABLES
TABLE 1.0
RESPONSIBILITIES
Person in charge of facility responsible for spill prevention:
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
David Turk
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT CAPACITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USEDAVASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
1 SODIUM CHLORATE 16,075
1 SODIUM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
Chemical in Lab RQ2 Quantity In Stock
Aluminum nitrate 2,270 kg 1.8 kg
Ammonium carbonate 2,270 kg H-3 kg
Ammonium bifluoride 45.4 kg 2-27 kg
Ammonium chloride 2,270 kg 2.27 kg
Ammonium oxalate 2,270 kg 6.8 kg
Ammonium thiocyanate 2,270 kg 7.8 kg
Antimony potassium tartrate 45.4 kg 0.454 kg
n-Butyl acetate 2,270 kg 4 L
Calcium acetate 4.54 kg 0.454 kg
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.810 kg
Ferric nitrate 454 kg 0.454 kg
Ferrous ammonium sulfate 454 kg 0.57 kg
Ferrous sulfate 454 kg 0.454 kg
Lead nitrate 4.54 kg 2.7 kg
Potassium chromate 4.54 kg 0.114 kg
Sodium hydrosulfide 2,270 kg 1.0 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2,270 kg L4kg
Zinc acetate 454 kg 0.91 kg
Chemical in Volatiles and
Flammables Lockers (A,B,C)RQ2 Quantity In Stock
Chloroform 4.54 kg 1 L
Formaldehyde 45.4 kg <1L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ2 Quantity In Stock
Hydrochloric acid 2,270 kg 58 gal
Nitric acid 454 kg 5 L
Phosphoric acid 2,270 kg 10 L
Sulfuric acid 454 kg 25 L
Hydrofluoric Acid 45.4 kg 1 L
Ammonium hydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution
Control Act 40 CFR Part 117. The lab also stores small quantities of other materials that are not hazardous
substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: “Reportable Quantities of
Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act.”
TABLE 4.0
REAGENT YARD/SMALL QUANTITIY CHEMICALS LIST 1
CHEMICAL RQ2
QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1000 lbs 4 gal
Ammonium Hydroxide 1000 lbs 5L
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kg (1 libs)
Hydrochloric Acid 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanganate 0.1 N 32 gal 5 kg (11 lbs)
Silver Nitrate 1 lb 2.6 kg
Trichloroethylene 100 lb 2 L
]. This list identifies chemicals which are regulated as hazardous substances under the Federal
Water Pollution Control Act 40 CFR Part 117. Materials in this list are stored in a locked
storage compound near the bulk storage tank area. The Mill also stores small quantities of
other materials that are not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: “Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water
Act.”
TABLE 5.0
REAGENT YARD AND BULK CHEMIC4VLS LIST1
REAGENT RQ2 QUANTITY ON SITE
Sulfuric Acid 1,000 lbs 2,719,680 lbs
Floe #301 None 0 lbs
Hyperfloe 102 None 1,500 lbs
Ammonia - East Tank 100 lbs 113,600 lbs
Ammonia - West Tank 100 lbs 93,720 lbs
Kerosene 100 gal approx. 5,100 gal
Salt (Bags)None 19,600 lbs
Ammonium Hydrogendifluoride None 20,450 lbs
Soda Ash Dense (Bag)None 2,000 lbs
Phosphoric Acid 5,000 lbs 6,300 lbs
Hydrogen Peroxide None 3,600 gal
Polyox None 560 lbs
Millsperse None 1,410 lbs
Nalco TX760 None 9 barrels
Nalco 7200 None 1,590 lbs
Tributyl phosphate None 9,450 lbs
Distillates None 110 gal
Diesel 100 gal approx. 6,000 gal
Gasoline 100 gal approx. 3,000
Alamine 336 drums None 0 lbs
Floe 109 None 7,750 lbs
Floe 208 None 1,500 lbs
Floe 904 None 1,500 lbs
Hyperfloe 624 None 4,230 lbs
Salt (Bulk solids)None Total of 70,000 lbs
Salt (Bulk solutions)None on site in all forms
Caustic Soda 1,000 lbs
24,000 lbs in
40% solution
Ammonium Sulfate None 21,300 lbs
Sodium Chlorate None 66,000 gal
Alamine 335 Bulk None 310 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lbs 500,000 lbs
Yellowcake3 None < 10,000 lbs
1. This list identifies the bulk chemicals and the chemicals in the reagent yard whether
or not they are regulated as hazardous substances under the Federal Water Pollution
Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
“Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act.”
3. Vanadium Pentoxide and Yellowcake, the Mill’s products, are not stored in the
Reagent Yard itself, but are present in closed containers in the Mill Building and/or Mill
Yard.
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1,540 gallons
Transmission Oils 100 gal 0 gallons
Dielectric fluids 5 gallons
Antifreeze None 55 gallons
Greases 1,787 lbs
Water Soluble Oils 100 gal 30 gallons
Xylene (mixed isomers)100 lbs 0 gallons
Lacquer thinner 0 gallons
Acetone None 55 gallons
Methyl Ethyl Ketone None 55 gallons
Toluene 1000 lbs 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates)100 gal 0 gallons
Resin None 10 gallons
Epoxy Paints None 55 gallons
Epoxy Catalyst None 30 gallons
Oil Base paints None 15 gallons
Paint thinners None 0 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
“Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act.”
FIGURES
N
SCALE IN FEET
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600^wSmEnergy Fuels Lakewood, CO 80228
REVISICDNS WHITE MESA MILL
Date By County: San Juan I State: utah
10-11 GM Location:
5-14 DLS Figure 1
MILL SITE LAYOUT4-16 RE
Scale: r=200' | Date: May 12, 2000 | Drafted By: D.SIedd
Mill Site Layout 4.28.16.dwg Figure 11
Figure 3
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Organizational Structure