DRC-2017-008021 - 0901a0688076953b

DRC-2017-008021 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

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director

October 26, 2017

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228

RE: Findings and Close-out Regarding the 2017 Division of Waste Management and Radiation
Control, Ground Water Module 65, Storm Water Inspection at the White Mesa Uranium Mill
Utah Groundwater Discharge Permit No. UGW370004

Dear Ms. Weinel:

Representatives of the Division of Waste Management and Radiation Control (DWMRC) conducted a
storm water inspection at the White Mesa Uranium Mill (Mill) on September 27, 2017. A copy of the
DWMRC Review Memorandum (2017 DWMRC Groundwater Module 65) is enclosed for your
information.

Based on findings during the inspection, a closeout meeting at the Mill, and follow up actions
documented in an October 2, 2017 e-mail from Energy Fuels Resources to DWMRC (included as
attachment 2 of the DWMRC Memorandum), it appears that the Mill is in compliance with the
Groundwater Permit Storm Water Requirements, including requirements of the Mill Spill Prevention
Control and Countermeasures Plan. Therefore, the inspection is hereby closed-out.

If you have any questions, please call Tom Rushing at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control

(Over)
STA/TR/ka

Attachment: 2017 DWMRC Groundwater Module 65 Memorandum (DRC-2017-008022)

c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Scott Hacking, P.E., DEQ District Engineer

Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

Inspection Year: 2017
Inspection Date: September 27, 2017

Module Reviewer Name:

Phil Goble, Compliance Section Manager

Module Prepared by/Date Prepared:

Tom Rushing, P.G./October 18, 2017

DWMRC Staff Present: Tom Rushing
Phil Goble

Energy Fuels Resources Staff Present: Garrin Palmer
David Turk

Energy Fuels Resources Staff Interviewed: Garrin Palmer
David Turk

Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements Inspected:

Part I.D.10 – Requires management of contact and non-contact storm water and control of
contaminant spills in accordance with the currently approved Storm Water Best Management
Practices Plan (SWBMPP), Spill Prevention Control and Countermeasures Plan (SPCC), and
applicable sections of the Utah Administrative Code.

Part I.D.11 – Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Area, including requirements for container integrity, storage on an engineered
impervious surface, and controls for storm water run-on and run-off.

Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm
Water Best Management Practices Plan (SWBMPP) for the White Mesa Uranium Mill:

Date: December 2016

Section I – Document Review

SWBMPP (Documentation Requirements):

SWBMPP Part 4.1.4. -- Diversion ditches, drainage channels and surface water control
structures in and around the Mill area will be inspected at least weekly. Areas
requiring maintenance or repair, such as excessive vegetative growth channel erosion or

pooling of surface water runoff, will be reported to appropriate departments and all
follow up actions are to be documented.

Findings:

The Utah Division of Waste Management and Radiation Control (“DWMRC”) conducted an
inspection of upland Diversion Ditch 1 and Diversion Berm 1.

DWMRC found Ditch 1 and berm needed some minor maintenance to remove vegetation on
the bottom of the ditch. Onsite Energy Fuels Resources Personnel addressed the comments
and sent photo follow up regarding the Ditch 1 maintenance on October 2, 2017 via e-mail.
Before and after maintenance photos are below:

Before Maintenance:

After Maintenance:

No standing water or wet spots were noted in Ditch 1 during the inspection. The ditch
appeared well graded. DWMRC notes that storm water entering Ditch 1 is draining toward
the west, fans out onto areas of Dakota/Burro Canyon Fm. Outcrop, and ultimately into the
Westwater Creek Drainage.

EFR inspects the diversion ditches and berms monthly and inspection “findings” fields are
included on the monthly inspection data form. DWMRC reviewed the April 29, 2017
monthly form and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion
Ditches 1, 2 and 3 showed no sloughing, erosion, undesirable vegetation or obstructions of
flow. Additionally the form notes that diversion berms show no stability issues or signs of
distress. The form notes that “Ditches are in good condition.” Per observations it appeared
that the ditches were in overall good condition and, except for moderate vegetation growth,
were being maintained during the inspection.

SWBMPP Appendix 1 – Spill Prevention, Control, and Countermeasures Plan (SPCC)
(Documentation Requirements):

1.6.1. – Daily monitoring of propane tanks required.

Findings: Per an EFR response to a DWMRC August 8, 2012 Request for Information which
stated as follows: “The EFR Spill Prevention, Control, and Countermeasures Plan, Part
1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include
the inspection findings with the daily inspection form used for storm water inspection
documentation within 30 days from your receipt of this letter,” EFR has removed the daily
inspection requirement on the basis that the propane is a gas at ambient conditions and would
be immediately vaporized under all foreseeable leakage conditions at the Mill. DWMRC
concurred with this action and this item is no longer inspected as part of the documentation
review or included on the site walkthrough.

1.9.1. – External Notification of “reportable quantity” spills.

Findings: No reportable quantity spills were reported by EFR during the period reviewed,
DWMRC has no additional comments.

1.9.2. Internal Notification of incidents, spills, and significant spills.

In response to a DWMRC Request for Information item by letter dated September 1, 2011,
regarding the findings of the DWMRC 2010 storm water inspection, EFR provided a change
to the small quantity spills protocols in the October 17, 2011 response letter, as follows:

“EFR has implanted an internal notification process for small quantity spills (less than
reportable quantities), with the following steps:

1) Mill environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size. The form will be amended to add spaces for this item.
2) In addition, all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day, and these will also be noted in the daily
inspection form.
3) If the spill is of a reportable quantity, environmental personnel will follow the procedures
in the Mill’s SWBMPP plan.
4) For spills smaller than reportable quantities, the environmental inspector will record
information regarding the spill, and the nature and type of cleanup, on the form.
5) The information on the inspection form will be added to a database maintained at the Mill.
The database will be updated and maintained on site indefinitely. Cards are maintained for
no longer than one year.”

The White Mesa Mill employees are using a formatted card to report the small quantity
spills; the card is titled “Non-Reportable Reportable Spillage.” The card provides the
following information: Name, Date of Discovery, Approximate Amount Spilled, Time of
Discovery, Location of Incident, Description of Material Spilled, Cleanup Activities Taken
and Signature. The reports additionally include photographs of the spill and follow up
actions in most cases.

Small quantity spill reports were reviewed since the last inspection (Inspection range 6/28/16
through 10/27/17. A total of 14 small quantity spills and follow up actions were reported
during that time frame. Per DWMRC review it appears that the spill are being adequately
reported and follow up actions are described, and in many cases photos of the spill and clean-
up are included.

EFR has implemented the training program in two parts; training is required for the
environmental personnel at the mill and is required of all employees at the mill. Per the
attendance logs, all environmental personnel (3 people) attended the training on
January 6, 2017. All other mill employees received the training as part of the annual Safety
Meeting on February 22, 2017 or February 24, 2017. A total of 49 employees were trained
during 2017.

DWMRC notes that the internal spill reporting processes and SWBMPP training activities
are very effective. The spill reporting provides records of identification and follow-up
procedures thereby making the chemical management at the mill transparent and supports
employee involvement in spill identification, reporting, and follow-up.

1.10 Records and Reports.

Period of Records Examined During Inspection:

Begin/Ending: 4/1/2017 through 4/30/2017
No. of On-site Records Required: Daily, Weekly, and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: April 2017
How Selected: DWMRC Inspected a random month of daily, weekly and monthly
forms completed since the last annual DWMRC Storm Water Inspection.

Daily Tailings Inspection Data:

Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-1 of the
Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport
system (Slurry pipeline, pipeline joints and supports, valves and point of discharge);
2. Operational systems (interior cell walls, water level, beach, liner and cover); 3. Dikes and
embankments (slopes and crest) to check for erosion and seepage; 4. Physical inspection of
the slurry lines, and; 5. Dust control and leak detection, are conducted daily and documented
on a daily inspection form. The forms additionally include fields for observations of
potential concerns and action required. Spills and clean up actions are noted in the text boxes
for these fields.

DWMRC randomly selected and reviewed the daily forms for the month of April 2017. The
forms appeared to be appropriate and inspections were conducted on all days. There are no
additional comments regarding the forms.

Weekly Tailings Inspections and Survey:

Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection
Manual Section 3.1.). The forms include sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, 4B and
Roberts Pond, as well as slimes drain liquid levels in Cell 2, Existing Decontamination Pad
and general tailing area. The form also includes information regarding the leak detection
systems for Cells 1, 2, 3, 4A and 4B as well as the potential blowing of tailings, and
condition of concrete at the decontamination pad.

DWMRC inspected the April 2017 weekly forms. Per the 2017 DWMRC storm water
inspection, the inspection forms reviewed appeared to be completed appropriately. There are
no additional comments regarding the forms.

Monthly Tailings Inspection, Pipeline Thickness:

Findings: Monthly inspection data is documented on Appendix A-3 of the Environmental
Protection Manual, Section 3.1. The monthly inspection report includes; 1. A summary of
the slurry pipeline condition; 2. Inspection protocols and observations related to the diversion
ditches, berms, sedimentation pond and dust control.

DWMRC reviewed the EFR monthly inspection report dated April 29, 2017. Note that the
monthly inspection reports include comments related to the upland diversion ditches which
noted that, “Ditches are in good condition.” The form also noted that the slurry pipelines
looked good and that there were no activities around the sedimentation pond which has been
filled in.

Tank to soil potential measurements:

Findings: This item was included as part of a September 1, 2011, DWMRC Request for
Information (“RFI”), RFI # 2. DWMRC had concerns regarding on-grade tanks (tanks where
the bottom is in contact with soil). Per DWMRC communication with EFR it was clarified
that tanks which sit on the ground must have cathodic protection or sit on a concrete
foundation.

Per DWMRC inspection of the tank foundations during the 2017 inspection, all concrete
foundations inspected appeared in good condition.

Annual bulk oil and fuel tank visual inspections:

Findings: Per the 2016 inspection it was noted that EFR is not conducting an annual
inspection of the oil and fuel tanks. It appeared that these inspections were conducted at a
different frequency than annual. It was also noted that the scope of the inspection was not
explained in the SPCC Plan. Per the 2016 review it appeared that the SPCC Plan needs to be
updated to reflect the current storm water inspection forms and inspection frequencies.
Additionally, it was noted that it would be appropriate to include more detail in describing
the scope of the inspections performed. This item was included in a confirmatory action
letter (CAL) to EFR.

In response, EFR updated the SPCC (Rev12.4, December 2016) to address the items in the
CAL. Specifically regarding annual inspections of the waste oil and fuel tanks the SPCC
now clarifies that this inspection will be done during the 2nd quarter of each year and will be
documented on the annual inspection form. The form was included as Attachment A-6 of the
Discharge Minimization Technology Monitoring Plan, including specific inspection items.
Per review of the response the actions are appropriate to address the CAL.

Tank and pipeline thickness tests:

Findings: During the inspection period, as noted on the EFR monthly inspection form, the
slurry pipelines were noted to be in good condition by EFR.

Spill Incident Reports:

Findings: This item is discussed above in the section related to reportable and small quantity
spills. DWMRC notes that an effective spill reporting and tracking system has been
implemented at the Mill.

1.11 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files):

Personnel training for spill prevention are discussed in the internal notification of spills
section of this module above. Per DWMRC findings the personnel training has been
implemented and appears to be effective. Mill staff attends annual training regarding the
small quantity internal spill notification process.

Section II -- Site Walk-through Inspection

Areas and Observations:

Ore Storage:

Per the DWMRC walk through of the ore storage pad it was noted in general that the pad
berms were in good condition and no standing water was noted on the pad at the time of the
inspection. The storm water containment located at the southwest corner of the ore storage
pad was cleaned out and fully functional. Photos included of ore storage pads in attachment
1.

Reagent Yard:

Per DWMRC observations no issues were noted regarding reagent storage.

Shop/Vehicle Maintenance Area:

DWMRC notes that areas inside of the vehicle maintenance shop and surrounding area drain
through the pipeline to Cell 1. DWMRC noted that hydraulic fluid and oil drums were stored
on pallets with secondary containment. The secondary containments looked dry and the
pallets appeared to be in good condition.

Mill Processing Areas:

SX Building Roof Drainage:

Per discussion with EFR it was noted that the current SX building roof drainage flows onto
the ground on the north and south end. Drainage which currently flows over ground is
allowed to accumulate in low areas and is then pumped manually into Cell 1. Per discussion
with EFR during the site walkthrough and during the close-out meeting, EFR reported that all
of the roof drainage will eventually be directly drained into Cell 1. DWMRC follow up
regarding the SX roof drainage is ongoing.

Alternate Feed Circuit South of the SX Building:

Observations: Per DWMRC observations it appeared that all concrete pad areas and berms
used for storage of alternate feed storage and staging was being maintained. No concerns
regarding concrete integrity or drainage were noted. (Photos are included in Appendix 1)

Old Decontamination Pad:

Observations: The old decontamination pad is rarely used due to construction of the new
decontamination facility and access gate at the southeast corner of the ore pad. No comments
were noted during the site walkthrough.

New Decontamination Pad:

Observations: The pump back system and concrete containment box appeared in good
condition. DWMRC noted no issues regarding concrete integrity or seepage.

Reagent Tanks:

Sodium Chloride Tanks – Per past agreements between DWMRC and EFR (Agreements
made in 2005) the secondary containment for these tanks is earthen. Per the agreement, all
reagent tanks that pre-existed the Ground Water Permit (3/05) would be acceptable as is –
and that as upgrades or replacements were installed, EFR would work to meet BAT
requirements. More detail regarding this agreement is in the December 2004 Statement of
Basis for the site Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit.
No issues were noted during the 2016 inspection.

Kerosene Tanks (West of Shop) – The kerosene tanks and concrete platforms appeared in
good condition.

Ammonia Tanks – Secondary containment is earthen per the same agreement as the sodium
chloride tanks. Per observations no comments were noted.

Used Oil Tank (shop) – The used oil tank and secondary containment appeared in good
condition. Per observations no comments were noted.

Kerosene Tank (shop) – The shop kerosene tank sits in the same secondary containment as
the used oil tank. DWMRC did not note any problems regarding taps and valves on the tank.

Fuel Tanks – Above ground tanks and containment appeared maintained, no additional
comments.

Uranium Liquor Tanks – Per observations, no comments were noted.

Vanadium Pregnant Liquor (VPL) Tanks – Concrete and secondary containment appeared
in good condition, no comments were noted.

Clean Water Tank – Standing water was observed to be pooled in the vicinity of the tank
due to overflow from filling of water tanks. This issue was discussed during the closeout
meeting and an advisory of the finding will be included in the inspection closeout letter.

Sulfuric Acid Tank – The tank, concrete platform appeared in adequate condition. A breach
was noted in the earthen berm on the east side of the tank. This issue was reported during the
closeout conference and EFR provided maintenance and photos of the berm repair.
Discharge of storm water around the tank is directly discharged into Cell 1 through a separate

drain line. Based on the observation and EFR timely repair of the berm, no additional
comments or actions are needed.

Caustic Soda Tank – Tank and secondary containment appeared to be in adequate
condition.

Soda Ash Tanks – The Soda Ash Tanks and Secondary Containment appeared to be
adequately maintained. Fluid in the secondary containment flows into the SX building
containment area. It was noted that trucks were using the secondary containment to
discharge some fluid, however due to the containment drainage the containment was not
holding water and appeared adequate.

Tailings Cells Areas (Note that upland drainage was included in comments above) –

DWMRC toured the tailings cell areas (Cells 4A and 4B) and observed the condition of the
outer toe areas of the dikes to ensure that excessive erosion or damage (e.g. burrowing
animal intrusion or rooting damage) was not present. Two areas of large rills were noted and
reported to EFR representatives during the closeout meeting. EFR provided follow-up
regrading in the areas of the two rills and provided follow up photos on October 2, 2017
showing the repairs. Based on the timely EFR follow up, no additional actions are warranted
regarding the erosion.

Summary of Onsite Closeout Meeting:

Date/Time: September 27, 2017/12:00 P.M.

EFR Representatives Present – Garrin Palmer – Ground Water Compliance
Tanner Holliday – Ground Water Compliance

DWMRC Representatives Present – Tom Rushing – Environmental Scientist
Phil Goble – Manager

An onsite close-out meeting took place to discuss preliminary findings of the storm water
inspection. Specifically, the following issues were presented by DWMRC:

Documentation: DWMRC reported that based on site review the documentation provided
looked to be adequately filled out and was maintained on site in compliance with the Permit
and SPCC.

Site Walkthrough: DWMRC reported the following:

 Standing water was noted at the clean water tanks due to truck overflow.
 A breach in the earthen berm was observed at the sulfuric acid tank.
 Two areas of large rills were noted on the Cell 4A dike.
 Excessive vegetation was noted in the bottom of diversion ditch 1.
 A process water spill was observed from the tailings slurry hose on the west side of
the CCD circuit tanks.

Conclusions

Based on an e-mail from Garrin Tanner, including follow up photos (Attachment 2) it
appears that the issues observed during the walkthrough have been repaired and/or reported.
DWMRC will conduct additional follow up during future inspections to insure that long term
pooling of water at the clean water tank are not occurring. A close-out letter regarding the
2017 storm water inspection will be provided to EFR.

2017 Ground Water Module 65, DWMRC Annual Storm Water Inspection

Appendix 1 – Photo Pages

DWMRC 2017 Inspection
Energy Fuels Resources, White Mesa Uranium Mill
Ground Water Module 65, September 27, 2017

Photo 1 – West margin of ore pad, berm in place and maintained

Photo 2 – Settling tank on southwest corner of ore pad, well maintained

Photo 3 – Settling tank and berm on the southwest margin of the ore storage pad

Photo 4 – Lined drainage ditch on east side of ore storage pad
Photo 5 – Berm on east side of ore storage pad, maintained
Photo 6 – Eastern margin of ore storage pad

Photo 7 – Ore storage pad looking west towards equipment storage building
Photo 8 – Northern margin of ore storage pad
Photo 9 – Northern margin of ore storage pad, looking west towards bears ears

Photo 10 – Clean water tank showing water truck overfill puddles on ground
Photo 11 – Storm drain inlet beside transformer and sulfuric acid tank
Photo 12 – Breach in berm around sulfuric acid tank

Photo 13 – Process solution spill below CCD tanks
Photo 14 – Caustic soda tank and secondary containment
Photo 15 – Soda ash tanks and secondary containment

Photo 16 – Tanks and pad on eastern side of ore leach building
Photo 17 – Inlet inside of VPL tank secondary containment
Photo 18 – Ammonium sulfate crystal tanks and concrete

Photo 19 – Used oil storage tank and secondary containment
Photo 20 – Shop containment baffle box, discharges to cell 1drain
Photo 21 – VPL tanks, secondary containment

Photo 22 – Kerosene tank secondary containment
Photo 23 – Shop barrel storage, barrels on secondary containment pallets
Photo 24 – Shop barrel storage

Photo 25 – Drainage on south side of the SX building
Photo 26 – Alternate feed storage pad
Photo 27 – Alternate feed storage dad

Photo 28 – Alternate feed storage pad
Photo 29 – Cell 4A berm
Photo 30 – Cell 4A berm drainage rill

Photo 31 – Upland drainage ditch 1, vegetation growing on bottom of ditch
Photo 32 – Upland drainage ditch 2, maintained

Appendix 2 – E-Mail Correspondence and Photos (dated October 2, 2017)
Documenting EFR Follow-up Action to the September 27, 2017 Groundwater Module 65
Closeout Meeting

Garrin Palmer

Oct
2

to me, pgoble
Hi Mr. Rushing,

Attached are photos of the repair work that has been completed since your latest storm water inspection. Let me
know if you have any questions or need anything else at this time. Thanks

Garrin Palmer
Environmental Technician

6425 S. Highway 191
Blanding, UT 84511

http://www.energyfuels.com
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