DRC-2023-073784 - 0901a06881293028

October 4, 2023
Div of Waste Managemen,
and Radiation Control
OCT 1 O 2023
Sent VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 841 16
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Re: Transmittal of Revised Spill Prevention, Control and Countermeasures Plan ("SPCC") for White
Mesa Uranium Mill
Dear Mr. Hansen:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI's") proposed revisions to the White Mesa
Mill SPCC. This revision was made to update the Division of Waste Management and Radiation Control
("DWMRC") phone numbers.
For ease of review we have provided both redline/strikeout (text and tables only) and clean versions (text,
tables, and figures) of the document.
If you should have any questions regarding these plans please contact me.
Yours very truly,
cf(~ XrtuuJ
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Director, Regulatory Compliance
CC: David Frydenlund
Logan Shumway
Garrin Palmer
Scott Bakken
Jordan App
DRC-2023-073784
REDLINE
8.1 External Notification ........................................................................................................ 8
8.2 Internal Notification ......................................................................................................... 8
9.0 RECORDS AND REPORTS ............................................................................................... 10
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 typical quantities in stock, and their reportable
quantities.
Table 4.0 lists the reagent yard and bulk chemical list.
Table 5.0 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
3 and 4A, 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 tailings management system, in turn, is operated with sufficient freeboard (minimum
freeboard as required by the Groundwater Discharge Permit ["GWDP"]) to withstand 100%
of the Probable Maximum Precipitation ("PMP"). 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 Al
Basin Al 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 and a
portion of Cell 2. The basin covers 104.3 acres. Any overflow from this basin would be
contained within Cell 1.
4.3 Basin Bl
Basin B 1 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. This allows 10 inches of rain for any given storm event.
4.6 Basin C
Basin C contains a portion of Cell 2. The basin consists of 60.4 acres. Areas in this basin
also include earth stockpiles and the heavy equipment shop. The direction of flow in this
basin is to the south-southwest. All overflows in this basin is channeled along the southern
edge of the basin. Overflow then flows into Cell 3 along the length of the boundary between
Cell 2 and 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 Radiation Safety Officer ("RSO") or designee. 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
3
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
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 comer 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
comer 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 comer 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 comer 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.
5.10 Hydrochloric Acid Tanks
The hydrochloric acid storage tanks consist of two 13,650 gallon storage tanks with one 500
gallon scrubber tank. The tanks are located west of the Pre-Leach Thickener in the
northwestern portion of the mill area. The tanks are installed in a concrete containment
designed to hold the all the contents of one storage tank plus the volume of a 25-year 24-hour
storm event. The containment is placed where an overflow or failure of the containment
flows directly to Cell 1. The reportable spill quantity for hydrochloric acid is 5000 pounds.
5
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
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.J 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.J 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
6
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 Used/Waste Oil
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 or sent to an EPA permitted recycling facility. 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 tum will notify the RSO and 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.
7
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
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. -State of Utah
4. State of Utah 24-hour Reporting
1-800-424-8802
301-816-5100
801-538--1±000200
801-536-4123
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission
2. State of Utah, Natural Resources
8.2 Internal Notification
301-816-5100
801-538-7200
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. Substantial media coverage
8
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
In the event of a spill requiring reporting, the Mill Manager is required to call the RSO,
Quality Assurance Manager, the Vice President, Regulatory Affairs, and/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 RSO and the
Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Logan Shumway Mill Manager [phone]
Garrin Palmer RSO ( 435) 459-9463
Tanner Holliday Mill Environmental Compliance ( 435) 459-9826
Coordinator
Thayne Holt Production Superintendent ( 435) 459-1783
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Mark Chalmers President and CEO [phone]
Scott Bakken Vice President, 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
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.
a.
b.
c.
d.
e.
2.
3.
4.
5.
6.
7.
Record of site monitoring inspections
Daily Tailings Inspection Data
Weekly Tailings Inspection and Survey
Monthly Tailings Inspection
Quarterly Tailings Inspection
Daily Operating Foreman and weekly RSO inspection reports
Annual used/waste oil and fuel tank visual inspections
Tank thickness tests
Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
Tank supports and foundation inspections
Spill Incident reports
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 prepared in accordance with good
engineering practices.
Steve R. Snyder
Utah Registered Professional Engineer
No. 5049193-2202
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
FIGURES
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
Septem her 8, 2023
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
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 BasinA1 ....................................................................................................................... 2
4.2 Basin A2 ....................................................................................................................... 2
4.3 Basin 81 ....................................................................................................................... 2
4.4 Basin 82 ....................................................................................................................... 3
4.5 Basin 83 ....................................................................................................................... 3
4.6 Basin C ......................................................................................................................... 3
4.7 Basin 0 ......................................................................................................................... 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 Hydrochloric Acid Tanks ................................................................................................ 5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT ............................................. 6
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
6.3 Used/Waste Oil ................................................................................................................ 7
6.4 Truck Unloading ................................................................................................................ 7
7.0 SPILL DISCOVERY AND REMEDIAL ACTION .................................................................... 7
8.0 SPILL INCIDENT NOTIFICATION ........................................................................................ 8
8.1 External Notification ........................................................................................................ 8
8.2 Internal Notification ......................................................................................................... 8
9.0 RECORDS AND REPORTS ............................................................................................... 10
10.0 SPILL REPORTING REQUIREMENTS ............................................................................ 10
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES ............................. 10
11.1 Training Records ........................................................................................................ 10
11.2 Monitoring Reports ..................................................................................................... 1 O
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 typical quantities in stock, and their reportable
quantities.
Table 4.0 lists the reagent yard and bulk chemical list.
Table 5.0 lists the petroleum products and solvents on site.
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
3 and 4A, 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 tailings management system, in turn, is operated with sufficient freeboard (minimum
freeboard as required by the Groundwater Discharge Permit ["GWDP"]) to withstand 100%
of the Probable Maximum Precipitation ("PMP"). 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 Al
Basin Al 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 and a
portion of Cell 2. The basin covers 104.3 acres. Any overflow from this basin would be
contained within Cell 1.
4.3 Basin Bl
Basin Bl 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. This allows 10 inches ofrain for any given storm event.
4.6 Basin C
Basin C contains a portion of Cell 2. The basin consists of 60.4 acres. Areas in this basin
also include earth stockpiles and the heavy equipment shop. The direction of flow in this
basin is to the south-southwest. All overflows in this basin is channeled along the southern
edge of the basin. Overflow then flows into Cell 3 along the length of the boundary between
Cell 2 and 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 Radiation Safety Officer ("RSO") or designee. 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
3
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
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 comer 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
comer 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 comer 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 comer 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.
5.10 Hydrochloric Acid Tanks
The hydrochloric acid storage tanks consist of two 13,650 gallon storage tanks with one 500
gallon scrubber tank. The tanks are located west of the Pre-Leach Thickener in the
northwestern portion of the mill area. The tanks are installed in a concrete containment
designed to hold the all the contents of one storage tank plus the volume of a 25-year 24-hour
storm event. The containment is placed where an overflow or failure of the containment
flows directly to Cell 1. The reportable spill quantity for hydrochloric acid is 5000 pounds.
5
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
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
6
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 Used/Waste Oil
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 or sent to an EPA permitted recycling facility. 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 RSO and 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.
7
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
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
4. State of Utah 24-hour Reporting
1-800-424-8802
301-816-5100
801-538-0200
801-536-4123
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. Substantial media coverage
8
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
In the event of a spill requiring reporting, the Mill Manager is required to call the RSO,
Quality Assurance Manager, the Vice President, Regulatory Affairs, and/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 RSO and the
Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Logan Shumway Mill Manager ( 435) 459-9878
Garrin Palmer RSO ( 435) 459-9463
Tanner Holliday Mill Environmental Compliance ( 435) 459-9826
Coordinator
Thayne Holt Production Superintendent [phone]
Wade Hancock Maintenance Superintendent ( 435) 678-2753
Lakewood Personnel:
Mark Chalmers President and CEO [phone]
Scott Bakken Vice President, 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
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.
a.
b.
C.
d.
e.
2.
3.
4.
5.
6.
7.
Record of site monitoring inspections
Daily Tailings Inspection Data
Weekly Tailings Inspection and Survey
Monthly Tailings Inspection
Quarterly Tailings Inspection
Daily Operating Foreman and weekly RSO inspection reports
Annual used/waste oil and fuel tank visual inspections
Tank thickness tests
Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
Tank supports and foundation inspections
Spill Incident reports
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.
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.
6 ~ ~umway
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 prepared in accordance with good
engineering practices.
Steve R. Snyder
Utah Registered Professional Engineer
No. 5049193-2202
.-·~· ····• . . .
.. 5<)4~193-22
V .
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
Logan Shumway
TABLE 1.0
RESPONSIBILITIES
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
Garrin Palmer
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
• •
TABLE2.0
REAGENT TANK LIST
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
I PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
I WEST SALT 17,635
1 SALT DILUTION 9,451
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
I SODA ASH SHIFT 8,530
I SODA ASH SILO 22,841
1 SODIUM CHLO RA TE 16,075
1 SODIUM CHLO RA TE 21,057
1 SODIUM CHLO RA TE 28,788
1 SULFURIC ACID 1,600,000
I SULFURIC ACID 11,000
2 HYDROCHLORIC ACID 13,650
" • TABLE3.0
LABO RA TORY CHEMICAL INVENTORY LIST1
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 Lor 571 gal.) 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20kg
Ammonium carbonate 5,000 lb (2,270 kg) 2kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6kg
Ammonium hydroxide 1,000 lb ( 454 kg) ( approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) SL
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) SL
Ferric chloride 1,000 lb (454 kg) 2kg
Ferric nitrate 1,000 lb ( 454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb ( 454 kg) IO kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) IL
Lead nitrate 10 lb (4.54 kg) I kg
Potassium chromate 10 lb (4.54 kg) I lb
Potassium Permanganate O.IN 100 lb (45.4 kg) (32 gal) 5 kg(ll lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
1,000 lb (454 k I k
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) IL
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) IL
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 2L
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 Lor 501 gal.) 22L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 L
I. 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."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE4.0
REAGENT YARD AND BULK CHEMICALS LIST1
Sulfuric acid 93 to 98% 1,000 lb (454 kg) (approx. 247 L) 4,000,000 lb
Ammonia -East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia-West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 1,000,000 lb
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb ( 454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
Organic Phosphinic/Phosphoric Acid None 5000 gal
Barium Chloride None 15,000 lb
Hydrochloric Acid 5,000 lbs (2,270 kg) (approx. 1,894 25,000 gal Lor 501 gal.)
Rare Earth Carbonates3 None 200,000 lb.
1. This list identifies the bulk chemicals at the Mill 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. The Mill's products are not stored in the Reagent Yard itself, but are present in containers in the
Mill Buildings and/or Mill Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah regulations.
These values are used by the Mill for conservatism as Best Management Practices.
TABLE5.0
PETROLEUM PRODUCTS AND SOL VENTS LIST1
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg) 50 gallons (approx. 13.9 gal)
Acetone 5,000 lb (2,270 kg) 55 gallons (362 lbs) (approx. 759 gal)
Methyl Ethyl Ketone 5,000 lb (2,270 kg) 55 gallons (369 lbs) (approx. 745 gal)
Toluene 1000 lbs ( 454 kg) 0 gallons (approx. 138 gal)
Varsol Solvent (2% trimethyl 100 gal* 0 gallons benzene in petroleum distillates)
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 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."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
5620
5630
5620
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-cgy Fuels
REVISIONS
Date By I County: San Juan
10-11 GM I Location:
5-14 DLS
4-16 RE
1-22 ss
Scale: 1 "=200'
fa
s
100 200
SCALE IN FEET
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL
tale: Utah
Figure 1
MILL SITE LAYOUT
Date: May 12, 2000 Drafted By: D.Sledd
Mill Site Layout 1.5.22.dwg Figure 11
0 r 0
DRAINAGE )
BASIN1"A" I ----= / 1 231\C.
~ :r--t=-=-----==;L~=-=
J +
DR AGE
BASIN "A" 2 104.27 AC.
+
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DRAINAGE BASIN "D"
~ 78.3AC.
. --...:::
CELL 4B --
DRAINAGE BASIN "F" CELL 4A r -::------::::::
44.67 AC. \
WITHIN BASIN / DRAINAGE BASIN "E"
42 .14 AC.
I
PMF CONTAINED t
--= :,,....c:
r ~ ;e( (~ { ]/\
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
1000 1000 2000
□ 0
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0
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5
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ENERGY FUELS
REVISIONS Project:
Date By County:
10/24/07 BM Locat1on:
5/16/08 BM
6/11/08 BM
12/9/08 DLS
1/7/09 BM
11/15/11 GM
I
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
Lakewood, CO 80228
White Mesa Mill
San Juan late: UT
MILL SITE
DRAINAGE BASINS
FIGURE 2
· 5/29/19 SH Author: HRR Date: 2005 Drafted By:
. ' •
Harold Roberts
Consultant
T
AF/AUM Project I
Management
,r.
~NERGYFUELS
Supervisor, Corp
Safety & NAZ
Standby
(S Hancock)
y
Mgr. Technical
Services
(D Kapostasy)
New position I H
Director ISR
Operations
(B Bonifas)
TX Operations
Director
(P Luthiger)
~ Director, Geolcgy I
& Land
fBruce Larsen)
Figure 3
President/CEO
(M Chalmers)
TITrecfor
Conventional
Operations
(L Shumwav)
Asset Mgr. ~ 1
Colorado Plateau J
(R Fisher)
Mine Geologist
Canyon Mine
(M Germansen)
y
VPHR&
Administration
(D Nazarenus)
IT Mgr.
(L Graham)
VP Marketing &
Corp. Development
(C Moore)
I
VP Regulatory Affair~
(S Bakken)
l
1-------1 ISR Permitting Mgr.
(D Kolkman)
Quality Assurance
-------1 Mgr.
(K Weinel)
Sr. V.P. General Counsel/
Corp. Secretary/CFO
(D Frydenlund)
Staff Attorney
(J Hoffmeier)
l
Controller
(S Luksch)
1
f---l Assistant Controller
New Position
.__ Tax Mgr.
(K Beck PT)