DRC-2024-007569

M E M O R A N D U M

TO:Project File C-2024-40
THROUGH:Adam Wingate, Uranium Recovery Section Manager
FROM:Heather Mickelson, PE, PG
DATE:November 12, 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 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 # 09, 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 # 09, 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 # 09, 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 will be seen in the accompanying
photolog TheMill 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 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 Decon Padwere 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 on 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).
It is noted that while the Licensee sealed the cracks in the concrete of the HCl secondary containment, the concrete has been significantly degraded with exposure to the HCl. As the
secondary containment was full of rain water it was impossible to determine if cracks were missed during the repair effort during the 2024 second quarter.
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 Decon Pad, the decon pad was immediately removed from service and will be put back in service after the leak has been repaired.
Activities that to actively collect rainwater 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.
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