DRC-2018-010077 - 0901a068808ea532

DRC-2018-010077 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 5, 2018 Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228 RE: Findings and Request for Information Regarding the 2018 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 conducted a storm water inspection at the White Mesa Uranium Mill on September 25, 2018. A copy of the Division’s Review Memorandum (2018 DWMRC Groundwater Module 65) is enclosed for your information. Based on the inspection, the following issues and recommendations were identified and discussed during the
inspection close-out meeting. Please provide the requested information in 30 calendar days of receipt of
this letter. Also, note that photos of onsite issues identified are included with the enclosed memorandum. Request for Information
1. Berms on the north and east margins of the ore storage pad need to be repaired and reconstructed in some areas. The ore storage pad on the east side of the fuel island (between the fuel island and the perimeter fence) needs to be re-graded to avoid ponding/pooling in that area. Please provide confirmation of repair of these berms.
2. The storm water detention tank at the south side of the ore storage pad needs to be cleaned out. It was noted that the detention tank was being used for operational purposes other than storm water management and that water and sediment were being pumped to the tank. In cases where storm water management controls are being used for purposes other than storm water management, the control should be maintained and returned for storm water management as soon
as possible. Please provide confirmation that the detention tank has been cleaned out. (Over)

3. It was noted that the pumps at both decontamination pads were leaking (photos 13 and 32).
During the close-out inspection, it was reported that the pumps could not be repaired to prevent the leakage, although it is unclear why this would be the case. The eastern new decontamination pad pump was leaking into a concrete sump and accumulated water was then pumped back to the water storage boxes. In the case of the older existing decontamination pad, the pump was
leaking onto the nitrate corrective action pad concrete cover and was left to evaporate. Leaks
from these pumps need to be repaired to minimize leakage or the pumps need to be replaced to manage potential discharges to storm water. 4. During the inspection, solid powder material was noticed on the pavement around the soda ash
tanks and ammonium sulfate tanks. Please provide confirmation that these areas are swept and
will be routinely swept and kept clean. In accordance with the Storm Water Best Management Practices Plan Part 4.1.3, areas should be swept regularly to prevent paved areas from becoming pollutant sources.
Recommended Action It was noted during the inspection that contractors are not required to undergo storm water management training, including spill reporting training. In some cases, contractors may be working at the site for an extended period of time and may be unsupervised by Mill personnel (e.g. well drilling). In these cases,
it would be appropriate to provide training/briefing to the individuals to notify them of the spill reporting
procedures implemented at the Mill and of the importance of maintaining the integrity of storm water control measures installed and implemented at the Mill. If you have any questions, please call Tom Rushing at [phone].

Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control STA/TR/ka
Enclosure: 2018 DWMRC Groundwater Module 65 Memorandum (DRC-2018-010078)
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
Logan Shumway, White Mesa Mill Plant Manager