DRC-2024-003007

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director
M E M O R A N D U M
TO: Project File C-2024-40
THROUGH: Adam Wingate, Uranium Recovery Section Manager

Ryan Johnson, PG, Uranium Recovery Section Health Physicist
Chris Leahy, PG, Uranium Recovery Section
FROM: Heather Mickelson, PE, PG, Uranium Recovery Section
DATE: November 19, 2024
SUBJECT: 2024 BAT/DMT Field Inspection; Radioactive Materials License Number UT1900479,
Amendment # 10 and Ground Water Discharge Permit UG37004, dated March 8, 2021;
Energy Fuels Resources (USA) Inc, White Mesa Uranium Mill, Blanding, Utah
Authority
UAC R317-6-4 Issuance of a Discharge Permit
“A. The Director may issue a ground water discharge permit for a new facility if the Director
determines, after reviewing the information provided under R317-6-6.3, that:...3. the applicant is using
best available technology to minimize the discharge of any pollutant; ...”

UAC R313-15-406(2) Minimization of Contamination
“Licensees shall, to the extent practical, conduct operations to minimize the introduction of residual
radioactivity into the site, including the subsurface, in accordance with the existing radiation protection
requirements in Section R313-15-101 and radiological criteria for license termination in Sections R313-
15-1401 through R313-15-1406.”
Permit and License Conditions
The data collected during the BAT/DMT inspections is used to generate reports for the quarterly DMT
Performance Standards Monitoring Report and Cell 4A BAT Performance Standards Monitoring Report
and Annual Technical Evaluation Report of the White Mesa Tailings Management System. These
2024 BAT/DMT Field Inspection
November 19, 2024
Page 2

reports are used to demonstrate compliance with the following conditions in the Radioactive Materials
License and the Ground Water Discharge Permit.

Radioactive Materials License #UT1900479, Amendment #10, Condition 11.3
“The licensee shall implement a monitoring program of the leak detection systems for disposal Cells 4A
and 4B in accordance with requirements of the Permit. The licensee shall implement an operation,
maintenance, and monitoring program of the leak detection systems for disposal Cells 1, 2, and 3…”
Radioactive Materials License #UT1900479, Amendment # 10, Condition 11.7
“Settlement Monitoring Standard Operating Procedure - the licensee shall perform settlement monitoring for
vertical settlement in the tailings management cell area in accordance with the currently Director approved
Settlement Monitoring Standard Operating Procedure (SOP) The Licensee shall document settlement
monitoring data and compare such data to previous data to track potential settlement. All data collected by
the Licensee for these purposes shall be included in an annual report to be submitted to the Director, pursuant
to License Condition 12.2. …”
Radioactive Materials License #UT1900479, Amendment # 10, Condition 11.8
“Movement (Displacement) Monitoring Standard Operating Procedure - the Licensee shall perform
monitoring for potential vertical and horizontal movements in the constructed dike portions of the tailings
management cells in accordance with the currently Director approved Movement Monitoring Standard
Operating Procedure (SOP). The Licensee shall document displacement monitoring data and compare such
data to previous data to track potential movement (displacement). …”

Ground Water Discharge Permit #UGW370004, Part I.E.7
“DMT Performance Standards Monitoring - the Permittee shall perform technology performance
monitoring in accordance with the currently approved DMT Monitoring Plan to determine if DMT is
effective in minimizing and controlling the release of contaminants…”

Ground Water Discharge Permit #UGW370004, Part I.E.8
“Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the currently
approved Cell 4A BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall immediately
implement all monitoring and recordkeeping requirements therein….”

Ground Water Discharge Permit #UGW370004, Part I.E.12
“Cell 4B BAT Performance Standards Monitoring and Maintenance - immediately following Director
approval of the Cell 4B BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall
immediately implement all monitoring and recordkeeping requirements therein….”

Observations

Heather Mickelson, PE, PG, of the Utah Division of Waste Management and Radiation Control (the
Division), inspected the White Mesa Uranium Mill (Mill) during data collection activities on October
29, 2024. It should be noted that a large rainfall event occurred a couple of hours prior to the inspection.
Water from this rain event is noted in the accompanying photolog The Mill is owned and operated by
Energy Fuels Resources (USA) Inc (Licensee).

This inspection was specific to the Licensee’s Standard Operating Procedures, Discharge Minimization
Plan (DMP), dated August 23, 2023, and Tailings Management System (TMS), dated March 2017, for
2024 BAT/DMT Field Inspection
November 19, 2024
Page 3

the time period since the previous inspection last performed by Heather Mickelson on May 5, 2023. The
Licensee provided copies of the current revision of the field report forms used to perform the daily,
weekly, and annual inspections for the DMP and the daily, weekly, monthly, and quarterly inspections
for the TMS.

The DMP and TMS have daily, weekly, monthly, and quarterly inspections. Heather Mickelson
accompanied Tanner Holiday as he performed the daily and weekly inspections of the DMP and the
TMS.

All individual inspections components of the inspection are not reviewed in this narrative. During the
collection of the data, I agreed with the data collected and the staff’s evaluation of the status of the
Mill’s components. The Licensee’s staff demonstrated an appropriate understanding the data collected
and its further use. Specific components of the onsite inspection are discussed further.

It was confirmed that cracks in the Old Decontamination Pad were sealed in the second quarter
of 2024. (Photo 1.)
The fuel tank and pump area was in good condition with no obvious signs of leakage and cracks
in the concrete were filled (Photos 2). The tanks were repainted following the 2023 Field
Inspection.
Diversion ditches were free of debris to allow for water movement away from the site.
Minimal erosion had occurred on the downstream slopes of 4A and 4B (Photo 3) following the
day’s rain event.
It is noted that while the Licensee sealed the cracks in the concrete of the HCl secondary
containment, the concrete has been significantly degraded following exposure to HCl. As the
secondary containment was full of rainwater it was impossible to determine if cracks were
missed during the repair effort during the 2024 second quarter. (Photo 4)
A records review of the data collected since the last inspection was performed following the site
inspection. I specifically reviewed the daily, weekly, monthly, and quarterly reports for
September 2024 and March 2024. I also reviewed the daily, weekly, and monthly reports for
November 2023. The records show similar conditions for the previous months.
In addition to appropriate data collection techniques and site evaluation, the records review
demonstrated ongoing maintenance to protect human health and the environment. For instance,
when water was noted in the leak detection system of the New Decontamination Pad, it was
immediately removed from service and will be put back in service after the leak has been
repaired. Rainwater collection activities were observed throughout the inspection. The water
was being pumped to cell 2.

A close out meeting to discuss observations from the inspection included with Heather Mickelson, Ryan
Johnson, Adam Wingate, Terry Slade, and Tanner Holiday.

Conclusions and Recommendations

The Licensee appears fully compliant with applicable laws, standards, requirements with respect to
DMT/BAT data collection and evaluation. The Licensee’s personnel appear to understand the
significance of the data being collected and provide accurate and comprehensive records. In addition,
the correct forms are being used to record the data.

2024 BAT/DMT Field Inspection
November 19, 2024
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As the concrete that comprises the secondary containment for the HCl tanks has degraded, I recommend
continued monitoring and evaluation.

Attachments: 2024 Annual BAT/DMT Inspection Photolog
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