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Home My WebLink AboutDRC-2024-007905ENERGY FUETS iJiv ol Waste Management nnd Kadratiorr Control OtC I 6 202Ir [irrergr F uels Resourccs (['S'\) Inc. 225 Lrnion l]lr d. Suite 6lXl [.alicuood" CO. t S. 8022ti ,t " tt,.,,i,']i il:i.:'liil Re: December 11,2024 Sent VIA OVERNIGHT DELMRY Mr. Doug Hansen Director Division of Waste Management and Radiation Control Utah Department of Environmental Quality 195 North 1950 West Salt Lake Citv. UT 84114-4880 Transmittal of the Energy Fuels Resources (USA) Inc. Standard Operating Procedures, Radioactive Materials License UT 1900479, White Mesa Uranium Mill Dear Mr. Hansen: The White Mesa Mill Radioactive Materials License ("RML"), Section 9.6,paragraph2 states: Up-to-date copies of all operational and non-operational SOPs shall be submitted electronically to the Director by December 31st of each year. Pursuant to the RML requirement stated above, Energy Fuels Resources (USA) Inc. ("EFRI") is submitting electronic copies of the Standard Operating Procedures ("SOPs") for the White Mesa Mill. Two CDs of the redacted SOPs and two CDs of the Unredacted SOPs, containing word- searchable. electronic versions of the SOPs are attached. One electronic copy of the enclosed SOPs is unredacted and complete for internal DWMRC review and use. One copy has been redacted in accordance with Utah Code 63G-2-101et seq. as noted below. EFRI is requesting that certain information enclosed with this letter be withheld from public disclosure because it is considered confidential business information ("CBI") pursuant to the provisions of the Utah Government Records Access and Management Act ("GRAMA"), Utah Code 63G-2-101 et seq. The information sought to be withheld is that information that has been redacted or "blacked out" on each page of the redacted transmittals. The redacted information is also indicated by an electronic marking "Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. All redactions were based on CB l/Proprietary Information. Pursuant to Section 63G-2-309(1)(a)(i) of GRAMA, EFRI hereby designates the redacted information identified above as CBI. The documents and information qualifu as CBI because they are not publicly available, and disclosure of the information therein likely would cause substantial harm to EFRI's competitive position. The documents and information have been provided for the exclusive use of the DWMRC on the express understanding that the information therein will be treated as confidential. Accordingly, the redacted information should be treated as confidential by DWMRC. Pursuant to Section 63G-2-305 of GRAMA, the DWMRC should maintain the redacted SOPs and information as protected and confidential, and exempt them from public records or disclosure laws, including but not limited to any subsequent requests under GRAMA or under the Freedom of Information Act ("FOIA"). If a request is made for public review of the documents or information, DWMRC must notifu EFRI and provide the company with a reasonable time in which to object to their disclosure or seek an injunction preventing disclosure. Pursuant to Section 63G-2-107 of GRAMA, Energy Fuels also invokes relevant U.S. Nuclear Regulatory Commission regulations and guidance that protect the redactions, including but not limited to the withholding of proprietary, personally identifiable and security-related information under 10 CFR 2.390 If you should have any questions regarding this submission please contact me. Yours very truly, {@tr*u4 ENnRcv Funls Rssouncns (USA) INc. Kathy Weinel Director, Regulatory Compliance CC: David Frydenlund Logan Shumway Scott Bakken Garrin Palmer Jordan App 12118124.8:10AM State of Utah Mail - RE: SOP Submission Thomas Ball <tball@utah.gov> RE: SOP Submission 1 message Kathy Weinel <KWeinel@energyfuels.com> To: Adam Wingate <awingate@utah.gov> Cc: Thomas Ball <tball@utah.gov> Adam, You are absolutely correct, there is a typo in the letter and the unredacted should be protect. My apologies for the typo. I can resend a corrected letter if that helps - just let me know and I will reprint and send an electronic version. Appreciate the help - again many apologies! Kathy Wed, Dec 18,2024 at7:30AM EF ,*rn ruels Resources (t!sA) tnc. Kathy Wdnel Di rector. Reg ul atory Cam 1tt ia nce t:303.389.41 34 | c: I f:303.389.4125 KWeinel@energyfuels.com 225 Union Blvd., Suite 600 Lakewood, CO 80228 Thise.mai|isintendedfortheexc|usiveuseofthep€rson(s)mentionedastherecipient(s).Thismessageandanyattachedfleswithitarenfdontia|a propri€tarinformation.|fyouar€nottheintendedrecipi€nt(s)p|easede|etethismessageandnotirthesender.Youmaynotuse,distributeprintorcopythis intended recipient(s). From: Adam Wingate <awingate@utah.gov> Sent: Tuesday, December !7,2024 4:26 PM To: Kathy Weinel <KWeinel@energyfuels.com> Cc: Thomas Ball <tball@utah.gov> Subject: SOP Submission Hey Kathy! Hope you had a good weekend! We received your SOP submissions and just had a quick question on the CBI claim. The cover letter says, "Pursuant to Section 63G-2-305 of GMMA, the DWMRC should maintain the redacted SOPs and information as protected and confidential..." httpsJ/mail.googfe.com/mail/u/Oi?ik=061cc38OaOUu;"ry=pt&search=all&permthid=thread-f:18'18731962249477858o/oTCmsg-f:18187888842419727'l'l&...112 1?/18124,8:10AM We think that it should read State of Utah Mail - RE: SOP Submission "...should maintain the unredacted SOPs and information as protected..." (i.e. redacted documents are public, unredacted documents are not). Could you confirm this for us? Thanks! Adam f *'i- t_tt-*- #-L w.r*1l, rrl.rgFrEt*Tt iAOrArlOt{ COilIICl" Adam Wingate Section Manager I Uranium Recovery He / Him Direct Line: (385) 4gg-o2gg Front Desk: (8or) 536-ozoo wasteand radiation.utah. gov r"\ r-\lrr'ltt Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Statements made in this email do not constitute the ofiicial position of the Direclor of the Division of Waste Management and Radiation Control. lf you desire a statement of the Division Directo/s position, please submit a written request to the Director, including copies of documents relevant to your request Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized toreceive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of thisinformation is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast, a leader in email security and cyoerresilience. Mimecast integrates email d€fenses with brand protection, security awareness training, web security, compliance and other essential capabilities. 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