DRC-2012-001844 - 0901a06880305b31

DRC-2012-001844
EnErgy FUEIS RESourcES (U5RI Inc.
September 7,2012
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr Rusfy Lundberg
Director, Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P O Box 144850
Salt Lake City, UT 84114-4820
Re Response to Utah Division of Radiation Control ("DRC") August 8, 2012 Request for
Information, Notice of Enforcement Discretion and Confirmatory Action regarding June 21, 2012
Storm Water Inspection at White Mesa Uranium Mill
Dear Mr Lundberg
This letter responds to DRC's above-named letter dated August 8, 2012, which Energy Fuels Resources
(USA) Inc ("EFR") received on August 10, 2012, regarding the June 21, 2012 storm water inspection
at White Mesa Mill
For ease of review, this letter provides each of DRC's comments verbatim in italics, below, followed by
EFR's response
Request for Information
DRC Comment
1 Standing water was observed in the area of the clean water tank, from an overflow or line break
at a shed (pump house"^) south of the tank Please provide an explanation of the cause of the
standing water and verification that the issue is resolved and that the standing water is
eliminatedfrom that location within 30 calendar days from your receipt of this letter
\
EFR Response
The standing water which DRC observed outside a shed in the area near the clean water (service water)
tank resulted from drainage from the potable water treatment shed Overflow water from vessels in the
potable water building is channeled outside the building through a floor drain pipe which discharges at the
bottom of the west wall of the building The small volume of standing water was removed (evaporated)
within 24 hours of DRC's June 2012 inspection EFR proposes to construct an extension to the drain pipe
to gravity drain any overflow water to the concrete channel adjacent to the service water tank, which
flows to the tailings area
The pipe extension will be completed on or before September 9, 2012 (within 30 days of receipt of
DRC's inspection letter)
Energy Fuels Resources (USA) Inc 225 Union Boulevard, Suite 600
Lakewood, CO 80228 Phone [phone]
Letter to Rusty Lundberg
September 7, 2012
Page 2 of 11 .
DRCComment
2. The DUSA 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 Response:
Section 1.5 through 1.6.1 of EFR's Spill Prevention Control and Countermeasures ("SPCC") Plan was
intended to identify liquid reagent chemicals and solutions which contents would require management or
cleanup of liquids if spilled or leaked from the storage vessel. Per the Handbook of Thermodynamic
Tables and Charts (K. Raznjevic, 1976), the boiling temperature of propane at 760 mm ofHg is -42.6 DC
(-45DF), that is, propane is a gas at ambient conditions and would be immediately vaporized under all
foreseeable leakage conditions at the Mill. Moreover, no spill reportable quantity ("RQ") has been
identified for propane.
Since it is not meaningful to inspect the propane storage area for signs of liquid spills, EFR proposes as
agreed to in EFR's August 2,2012 telephone conversation with DRC, to remove the requirement from the
Spill Prevention Control and Countermeasures Plan.
The propane storage area will continue to be inspected each shift, as are other process equipment and
process areas, and any observations will continue to be recorded in the shifter's inspection report.
A revised version of the SPCC Plan in redline/strikeout format along with a clean copy are provided as
Attachment 1. The revisions include:
• the removal of propane from the SPCC Plan,
• minor grammatical changes to the SPCC Plan for clarity, and
• update of the plan to reflect the current operator of the Mill, Energy Fuels Resources (USA) Inc.,
along with current names and titles of responsible personnel.
Following DRC approval of the proposed revisions, EFR will provide a signed copy certified by a Utah
Registered Professional Engineer.
EFR has also identified an inconsistency in the Storm Water Best Management Practice Plan
("SWBMPP"). As discussed in Section 2 of the SWBMPP, the SWBMPP identifies practices to
prevent spills of chemicals and hazardous materials and minimize spread of particulates from
stockpiles and tailings management areas; and the requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are not part of the SWBMPP and
are addressed separately in other documents, specifically, the Spill Prevention Control and
Countermeasures ("SPCC") Plan, the Emergency Response Plan ("ERP"), and the housekeeping
procedures within Mill SOPs. Previous versions of the SWBMPP incorrectly included the SPCC
Plan and ERP as appendices. F or clarity and consistency, EFR proposes removing those
documents from the SWBMPP appendices and maintaining them as stand-alone documents. This
also eliminates the need to revise the SWBMPP when revisions are made to the SPCC or ERP.
Letter to Rusty Lundberg
September 7,2012
Page 3 of 11
A revised version of the SWBMPP in redline/strikeout format along with a clean copy are provided in
Attachment 2. The revisions include:
• The removal of the spec and ERP appendices, and
• update of the plan to reflect the current operator of the Mill, Energy Fuels Resources (USA) Inc.,
along with current names and titles of responsible personnel.
Notice of Enforcement Discretion
DRCComment
1. The Utah Ground Water Permit, Permit No. UGW370004, Part ID.10 requires that "the Permittee
will manage all contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Storm water Best Management Practices Plan." The approved
Best Management Practices Plan, Appendix 1, Part 1.11 Personnel Training and Spill Prevention
Procedures requires that "all new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and control. They are informed that
leaks in piping, valves, and sudden discharges from tanks should be reported immediately. Abnormal
flows from ditches or impoundments are of immediate concern. In addition, a safety meeting is presented
annually by the Environmental Health and Safety Manager to review the SPCC plan. " Additionally, Part
1.11.1 Training Records requires that "Employee training records on chemical and petroleum spill
prevention are maintained in the general safety training files. "
During the June 21, 2012 White Mesa Mill stormwater inspection, the DRC inspectors requested copies
of the training records required by the SWP P P as well as a course outline for the material presentations,
in response they received;
A. Copies of certification forms from the Environmental Protection Manual, Section 3.1, Appendix C
regarding certification that the undersigned received instruction of the tailings system including
documentation of daily tailings inspections, analysis of potential problems and notification
procedures and safety (3 forms total), and,
B. A Copy of Appendix B of the Environmental Protection Manual, Section 3.1 "Tailings Inspector
Training" which-includes an outline of the training program.
Per review of the provided documents DRC noted that the training did not provide instruction for items
required by the Permit Part ID.10 or any other topics related to spill prevention, control or storm water
pollution prevention. Additionally, it was noted that no records for new employees were provided, only
three forms were providedfor the following employees: David Turk, Tanner Holliday and Garrin Palmer.
DUSA is in violation of the Permit Part ID.1 0 for failing to provide employee training as required by the
SWPPP.
DRC is extending enforcement discretion regarding this violation based on:
A. This was the first time that DRC has reviewed the training syllabus, and,
B. DUSA will comply with the Confirmatory Action section, item 2 below which requires the
development of a training program in compliance with the Permit within the specified time-line.
Letter to Rusty Lundberg
September 7,2012
Page 4 of 11
EFR Response:
EFR has developed a training program in response to item B, above. EFR's response and description of
the training program are provided in our response to DRC Confirmatory Action Comment 2, below.
Confirmatory Actions:
Per an August 2, 2012 telephone close-out conference call, the following confirmatory actions and
timelines were agreed to:
DRCComment
1. Storm Water Best Management Practices Plan (SWBMPP) --DRC notes that a complete copy of
the October, 2011 Revised SWBMPP (including all appendices) in both hard copy and text
searchable electronic format (PDF) has not been received. This was requested per a DRC March
7, 2012 Request for Information Letter, which also provided approval of the October, 2011
SWBMP P. A full copy was requested since the attachments were not included; DRC noted that
the Spill Prevention, Control and Countermeasure Plan (Appendix 1 of the SWBMPP) was under
review; and that the Emergency Response Plan was not submitted due to there being no changes.
DUSA will submit a complete revised SWBMPP for DRC Files within 30 days of receipt of this
letter.
EFR Response
A complete copy of the SWBMPP as requested on March 7, 2011, including the SPCC Plan and
Emergency Response Plan appendices was submitted to DRC in hard copy and on CD ROM which were
delivered to DRC on April 12, 2012. EFR's duplicate copy of the printed document and of the CD ROM
indicates that all appendices and attachments were included. A copy of the UPS receipt indicating DRC's
signed acceptance of the document package is provided as Attachment 3.
An additional hard copy and CD ROM of the SWBMPP, with all attachments, was again transmitted by
UPS on August 28,2012.
DRCComment
2. Storm Water Inspector Training -DUSA will implement a training program in compliance with
the SWBMP P Appendix 1, Part 1.11 and will provide DRC a copy of the course syllabus, training
calendar, and commitment to maintain training logs/certificates at the Mill within 60 calendar
days of receipt of this letter.
DRC also notes that per a letter submitted to the Director by DUSA (dated October 17, 2011) in
response to a DRC RFI (dated September 1, 2011), page 2 Item 3. DUSA provides information
regarding the newly implemented internal notification process for small quantity spills and
commits that "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. "
Although the DUSA letter does not specify how the information will be provided to the Mill
employees, DUSA has agreed that this information will be provided during the newly
implemented SWBMP P training.
Letter to Rusty Lundberg
September 7,2012
Page 5 of 11
EFR Response
EFR has implemented a training program in compliance with the SWBMPP Appendix 1, Part 1.11 (Spill
Reporting Requirements), as discussed below.
General Employee SWBMPP training will be provided to all employees as one of the topics addressed
each year during one of the quarterly employee refresher training sessions. All employees, other than
Mill Environmental Personnel, will be instructed regarding the Mill's requirement to comply with the
SWBMPP, and that their reporting responsibilities require them to alert Mill Environmental Personnel
immediately regarding any spills, leaks, failures of storage or process equipment, or abnormal flows from
ditches or impoundments. A copy of the outline for SWBMPP General Employee Training is provided in
Attachment 3. Documentation of training topics and attendance is maintained with existing quarterly
refresher training records. SWBMPP training will be conducted during the second quarter refresher
training each year, except 2012, when it will be conducted during the third quarter refresher training
seSSIOn.
Mill Environmental Personnel will receive an additional level of SWBMPP training as well as the general
Employee SWBMPP Training. Mill Environmental Personnel will be trained to meet the requirements of
Part I.D.1 0 of the Permit, and to perform the reporting required for reportable quantity ("RQ") spills, as
well as the internal documentation of non-RQ spills. A copy of the course outline and training calendar
for Environmental Staff Training has been provided in Attachment 4. EFR will maintain training records
for the Mill Environmental Personnel at the Mill. Environmental Staff SWBMPP Training will be
conducted in January of each year.
DRCComment
3. Solvent Extraction (SX) Building Roof Drainage Improvements -Comments regarding needed
improvements to the SX building roof drain system have been ongoing since 2009. Per the 2012
inspection, issues related to the roof drainage and discharges into the alternate feed circuit have
not been addressed. DUSA agrees to upgrade the SX building roof drainage to prevent potential
standing water on the ground within 60 calendar days ofreceipt of this letter. Specifically, DUSA
will provide appropriate drainage control for roof areas depicted in photograph 30 of the Memo
(north-west section of the building) and will provide documentation to DRC regardingfollow-up
actions undertaken.
EFR Response
As requested, EFR agrees to construct modifications to the SX building roof drainage within 60 days of
receipt ofDRC's letter. EFR plans to install a concrete trench system to collect the water runoff from the
SX building roof and transfer it to the tailings cell area.
The roof edges of the Mill buildings in the SX area are subject to high winds. EFR expects that any
rainwater collection system built on the roof (such as a gutter and downspout) would be subject to the
same recurrent wind damage as currently affects other roof materials. Therefore EFR has chosen to
minimize construction of rooftop elements, in lieu of the proposed trench at ground level.
The trench will be designed large enough to ensure ease of access for sediment removal, and will be
constructed by October 9,2012 (within 60 days ofEFR's receipt ofDRC's inspection letter).
Letter to Rusty Lundberg
September 7, 2012
Page 6 of 11
DRCComment
4. Based on DRC review of the DUSA May 4, 2012 letter "Response to Claricone Solution Spill" it
was noted that confirmation soil sampling was not conducted to ensure that all contaminated soil
had been removed. Excavation of contaminated material was based on visual examination and
gamma surveying (microR meter) only. DUSA will submit to DRC either:
A. A work plan for the collection of confirmation soil samples to be collected and analyzed
for appropriate radiological parameters and total uranium within 45 days from DUSA
receipt of this letter. The work plan will detail the techniques to be used for sample
collection, number and locations of samples to be collected, methods to be used for soils
analysis, and will propose confirmation sample concentration thresholds to be used for
the evaluation. DUSA will propose applicable concentration standards to be used for
radiological parameters (per applicable guidance/regulations); and will propose a study
evaluation to determine an appropriate background concentration for total uranium
within the restricted area of the Mill. The total uranium soil concentration threshold to
be used for confirmation samples will be based on 2 times the average measured
background concentrations for total uranium as determined through the work plan study,
or;
B. A conservative basis for a larger three dimensional area of potentially contaminated soil
due to the claricone solution spill, in lieu of confirmation soil sampling, which will
include a calculated soil excavation volume (beyond the previous excavated soil volume).
DUSA will provide a Report which describes the justification for the calculated soil
volume and includes a surface map of the Mill and cross sections clearly depicting the
ultimate area of soil for excavation, removal and disposal (at site closure). DUSA will
provide a surety estimate, for Director review and approval, which includes line items for
all work associated with excavation, removal and disposal of the proposed soil volume.
The Report and Surety Estimate will be submitted within 45 days from DUSA receipt of
this letter.
EFR Response
EFR proposes to produce a conservative estimate of potentially contaminated soil resulting from the
Claricone spill, and calculation of additional soil excavation volume to be removed at reclamation,
consistent with Item B, above. EFR will provide a Report which describes the justification for the
calculated soil volume and includes a surface map of the Mill and cross sections clearly depicting the
ultimate area of soil for excavation, removal and disposal (at site closure). EFR will provide a surety
estimate, for review and approval by the Director of the Division of Radiation Control, which includes
line items for all work associated with excavation, removal and disposal of the proposed soil volume. As
agreed to in our telephone conversation of August 28,2012, and confirmed by DRC's letter of August 30,
2012, EFR will provide the required report by October 26,2012.
Letter to Rusty Lundberg
September 7, 2012
Page 7 of 11
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
~~
Jo Ann Tischler
Director, Compliance
cc: David C. Frydenlund
Daniel C. Hillsten
Harold R. Roberts
David E. Turk
Kathy A. Weinel
Attachments
ATTACHMENT 1
SPILL PREVENTION, CONTROL, AND
COUNTERMEASURES PLAN FOR CHEMICALS AND
PETROLEUM PRODUCTS
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
September 2012
Prepared by:
Energy Fuels Resources (USA) Inc.
1050 17th Street, Suite 950
Denver, CO 80265
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS
10 OBJECTIVE:
The objective of the Spill Prevention, Control, and Countermeasures (SPCC)
Plan is to serve as a site-specific guideline for the prevention of and
response to chemical and petroleum spills. The plan outlines spill potentials,
containment areas, and drainage characteristics of the White Mesa Mill site.
The plan addresses chemical spill prevention, spill potentials, spill discovery,
and spill notification procedures. Spills are reportable if the spill leaves the
site. Ammonia is the only chemical (as vapor) that has the potential to leave
the site. In addition, chemical and petroleum spills will be reported in
accordance with applicable laws and regulations.
Figure 1.0, Mill Site Layout,shows a map of the mill site including the
locations of the chemical tanks on-site. Figure 2 shows the basins and
drainage ditch areas for the mill site. Table 1.0 is an organization chart for
Mill operations. Table 2.0 lists the reagent tanks and their respective
capacities. Table 3.0 lists the laboratory chemicals, their amounts, and their
reportable quantities. Table 4.0 lists the operations chemicals. Table 5.0
lists the chemicals in the reagent yard, their amounts, and their reportable
quantities. Table 6.0 lists the petroleum products and solvents on site.
2.0 RESPONSIBILITIES:
Person in charge of facility responsible for spill prevention:
Mr. Dan Hilisten, Mill Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
Mr. David Turk, Manager, Environment, Health, and Safety
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Refer to Section 1.9 Spill Incident Notification for a list of personnel to be
notified in case of a spill. In addition, an organizational chart is provided in
Figure 3.0.
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS:
The main drainage pathways are illustrated in Figure 2. The map shows
drainage basin boundaries, flow paths, constructed diversion ditches, tailing
cells, the spillway between Cell 2 and 3, dikes, berms, and other relevant
features. The White Mesa Mill is a "zero" discharge facility for process liquid
wastes. The mill area has been designed to ensure that all spills or leaks
from tanks will drain toward the lined tailing cells.
The tailings cells, in turn, are operated with sufficient freeboard (minimum of
three feet) to withstand 100% of the PMP (Probable Maximum Precipitation).
This allows for a maximum of 10 inches of rain at any given time.
4.0 DESCRIPTION OF BASINS:
Precipitation and unexpected spills from the mill site are contained within
their prospective drainage basins. Overflow ultimately drains into one of the
four lined tailings cells .
. 4.1 Basin A1
Basin A 1 is north of Cell 1-1 and Diversion Ditch No.1. The basin
contains 23 tributary acres, all of which drain into Westwater Creek.
4.2 Basin A2
Basin A2 contains all of Cell 1-1 including an area south of the Diversion
Ditch No.1. The basin covers 84 acres. Any overflow from this basin
would be contained within Cell 1-1.
4.3 Basin B1
Basin B1 is north of the mill area. The basin contains 45.4 tributary
acres.
Overflow from this basin drains into a flood retention area by flowing
through Diversion Ditch NO.2. Diversion Ditch No.2 drains into
Westwater Creek.
4.4 Basin B2
Basin B2 is northeast of the mill area and contains only 2.6 tributary
acres. Overflow from this basin would drain into Diversion Ditch NO.3.
Diversion Ditch NO.3 ultimately drains into Diversion Ditch No.2.
2
4.5 Basin B3
Basin B3 contains most of the mill area, buildings, ore stockpiles, process
storage tanks, retention ponds, spill containment structures, pipelines,
and roadways. The normal direction of flow in this basin is from the
northwest to the southwest. Any overflow from this basin would drain into
Cell 1-1. The basin contains 64 acres. This basin has sufficient
freeboard to withstand 100% of the PMP (Probable Maximum
Precipitation). This allows 10 inches of rain for any given storm event.
4.6 Basin C
Basin C contains all of Cell 2. The basin consists of 80.7 acres. Areas in
this basin include earth stockpiles and the heavy equipment shop. The
direction of flow in this basin is to the southwest. All overflows in this
basin is channeled along the southern edge of the basin. Overflow then
flows into Cell 3 via the spillway from Cell 2 to Cell 3.
4.7 Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including
a portion of the slopes of the topsoil stockpile and random stockpile. The
basin contains all flows, including those caused by the PMF.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows
including those caused by the PMF will be contained within the basin and
will flow directly into Cell 4A.
4.9 Basin F
Basin F will contain Cell 4B, if and when constructed. The area consists
of 44 acres at a relatively low elevation. Direction of flow in this basin is
towards the southwest.
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL
CONTAINMENT
5.1 Reagent Tanks (Tank list included in Table 2.0)
5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of
31,409 gallons each. The tanks are located southeast of the Mill building.
Daily monitoring of the tanks for leaks and routine integrity inspections will be
conducted to minimize the hazard associated with ammonia. The reportable
qu~ntity for an ammonia spill is 7 gallons.
3
Ammonia spills should be treated as gaseous. Ammonia vapors will be
monitored closely to minimize the hazard associated with inhalation. If
vapors are detected, efforts will be made to stop or repair the leak
expeditiously. Ammonia is the only chemical (as vapor) that has the potential
to leave the site.
5.3 Ammonia Meta-Vanadate
Ammonia meta-vanadate is present in the SX building as the process
solutions move through the circuit to produce the vanadium end product.
Spills would be contained in the process sump within the SX building. The
reportable spill quantity for ammonia meta-vanadate is 1,000 pounds.
5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner
of the SX building. The tank has a capacity of 19,904 gallons. The tank
supports are mounted on a concrete curbed catchment pad which directs
spills into the sand filter sump in the northwest corner of the SX building.
The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located in
the northeast corner of the SX building. The smaller soda ash shift tank has
a capacity of 8,530 gallons and is located in the SX building. Spills will be
diverted into the boiler area, and would ultimately drain into Cell 1-1. There is
no reportable spill quantity associated with sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of two fiberglass tanks located within a dike
east of the SX building. The larger tank is used for dilution purposes and has
a maximum capacity of 17,700 gallons. The smaller tank serves as a
storage tank and has a capacity of 10,500 gallons. Daily monitoring of the
tanks for leaks and integrity inspections will be conducted to minimize the
hazard associated with sodium chlorate.
Sodium chlorate that has dried and solidified becomes even more of a safety
hazard due to its extremely flammable nature. The reportable spill quantity
for sodium chlorate is 400 gallons.
5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of
1,600,000 gallons and two smaller tanks with capacities of 269,160 gallons
each.
The large tank is located in the northwest corner of mill area basin 83 and is
primarily used for acid storage and unloading. The tank support for the large
tank is on a mound above a depression which would contain a significant
spill. All flows resulting would be channeled to Cell 1-1. The tank is equipped
4
with a high level audible alarm which sounds prior to tank overflows. A
concrete spill catchment with a sump in the back provides added
containment around the base of the tank. However, the catchment basin
would not be able to handle a major tank failure such as a tank rupture. The
resulting overflow would flow towards Cell 1-1.
The two smaller storage tanks are located within an equal volume spill
containment dike east of the mill building. The tanks are not presently in
use, but are equipped with high level audible alarms.
The reportable spill quantity for sulfuric acid is 65 gallons.
5.8 Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the
drying and fusing circuits and is not present in the vanadium circuit until after
the deammoniator. Efforts will be made to minimize leaks or line breaks that
may occur in processes in the circuit that contain vanadium pentoxide.
Special care will be taken in the transportation of this chemical. The
reportable spill quantity for vanadium pentoxide is 1000 pounds.
5.9 Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a
combined capacity of 10,152 gallons in three tanks. Any overflow from these
three tanks would flow around the south side of the SX building and then into
Cell 1-1. These tanks have drain valves which remain locked unless
personnel are supervising draining operations. The reportable spill quantity
for kerosene is 100 gallons.
5.10 Usedl Waste Oil
Used/ Waste oil for parts washing is located north of the maintenance shop
in a tank and has a capacity of 5,000 gallons. The tank is contained within a
concrete containment system. Ultimate disposal of the used oil is to an EPA
permitted oil recycler. Any oil escaping the concrete containment system will
be cleaned up. Soil contaminated with used oil will be excavated and
disposed of in Cell 2.
6.0 POTENTIAL PETROLEUM SPILL SOURCES AND
CONTAINMENT
6.1 Petroleum Tanks
6.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The
tanks have capacities of 250 gallons each. One of the diesel tanks is for the
emergency generator. The other tank is located in the pumphouse on an
5
elevated stand. Spillage from either tank would ultimately flow into Cell 1-1.
The reportable spill quantity for diesel is 100 gallons. The spill is also
reportable if the spill has the potential for reaching any nearby surface waters
or ground waters.
6.2 Aboveground Fuel Pump Tanks
6.2.1 Diesel
The diesel tank is located on the east boundary of Basin B3 and has a
capacity of 6,000 gallons. The tank is contained within a concrete catchment
pad. The reportable spill quantity for diesel is 100 gallons. A diesel spill is
also reportable if the spill has the potential for reaching any surface waters or
ground waters.
6.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded
gasoline tank has a capacity of 3,000 gallons and is contained within the
same containment system as the diesel tank. Spills having the potential for
reaching any surface waters or ground waters will need to be reported. The
reportable spill quantity for unleaded gasoline is 100 gallons.
6.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling
company vehicles used around the mill site. The pump station is equipped
with an emergency shut-off device in case of overflow during fueling. In
addition, the station is also equipped with a piston leak detector and
emergency vent. Check valves are present along with a tank monitor
console with a leak detection system. The catchment is able to handle a
complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a
temporary berm would need to be constructed. Absorbent diapers or floor
sweep would be used in an effort to limit and contain the spill. The soil would
have to be cleaned up and placed in the authorized dump in Cell 2.
6. 2.4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill
area, proper reporting and containment procedures will be followed when
warranted, such as when oil or diesel fuel is spilled. Proper clean-up
procedures will be followed to minimize or limit the spill. The spill may be
temporarily bermed or localized with absorbent compounds. Any soils
contaminated with diesel fuel or oil will be cleaned up and placed in Cell 2.
6
7.0 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take
measures to limit additional spillage and contain the spill that has already
occurred. Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, if
possible, to limit further release.
The Shift Foreman will also secure help if operators are requiring
additional assistance to contain the spill.
The Shift Foreman is also obligated to initiate reporting procedures.
Once control measures have begun and personal danger is
minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will notify the Mill
Manager, who in turn will notify the Department Head of ENHS
and/or the Environmental Coordinator.
The Mill Manager will assess the spill and related damage and direct
remedial actions. The corrective actions may include repairs, clean-
up, disposal, and company notifications. Government notifications
may be necessary in some cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
8.0 SPILL INCIDENT NOTIFICATION
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies
should be notified:
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
1-800-424-8802
301/816-51 00
801/538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301/816-5100
7
2. State of Utah, Natural Resources 801/538-7200
8.2 I nternal Notification
Internal reporting requirements for incidents, spills, and significant spills are
as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement
actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by
management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits
operations or assesses penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated
with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-
product
In the event of a spill requiring reporting, the Mill Manager is required to call
the Corporate Director, Compliance. The Executive Vice President and Chief
Operating Officer, or the President and Chief Executive Officer. The spill will
first be reported to the Shift Foreman. The Shift Foreman will then report the
spill to the Mill Superintendent, Maintenance Superintendent, or Mill
Manager.
8
The Mill or Maintenance Superintendent will report to the Mill Manager. The
Manager, Environment, Health and Safety, and the Corporate Director,
Compliance will be contacted by the Mill Manager.
Name
Mill Personnel:
Dan Hillsten
David Turk
Garrin Palmer
Scot Christensen
Wade Hancock
David Lyman
Thayne Holt
Denver Personnel:
Stephen P. Antony
Harold R. Roberts
Jo Ann Tischler
Mill Manager
Manager, Environment,
Health and Safety
Mill Environmental
Compliance Coordinator
Production Superintendent
Maintenance Superintendent
Mill Foreman
Mill Foreman
President and
Chief Executive Officer
Executive Vice President
and Chief Operating Officer
Director, Compliance
Home Phone
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
In the event the next person in the chain-of-command cannot be reached,
then proceed up the chain-of-command to the next level. Figure 3.0 shows
the organizational chart for the mill site.
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the
Environmental Coordinator for inspection and review for a minimum of three
years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
9
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thickness
d. Quarterly Tailings Inspection
2. Tank to soil potential measurements
3. Annual bulk oil and fuel tank visual inspections
4. Tank and pipeline thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer
contains PCBs)
6. Tank supports and foundation inspections
7. Spill Incident reports
8. Latest revision of SPCC plan
10.0 SPILL REPORTING REQUIREMENTS
1. Report to applicable government agency as required by laws and
regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of
spill impacts
4. Report release of 5,000 pounds or more of any process material or
waste product
11.0 PERSONNEL TRAINING AND SPILL PREVENTION
PROCEDURES
All new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and
control. They are informed that leaks in piping, valves, and sudden
discharges from tanks should be reported immediately. Abnormal flows from
ditches or impoundments are of immediate concern. In addition, a safety
meeting is presented annually by the Environmental Coordinator to review
the SPCC plan.
11.1 Training Records
Employee training records on chemical and petroleum spill prevention are
maintained in the general safety training files.
11.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
10
12.0 REVISION
This procedure is to be reviewed by the mill staff and a registered
professional engineer at least once every three years, and updated when
circumstances warrant a revision.
13.0 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Energy Fuels Resources
(USA) Inc. White Mesa Mill facilities, and attest that this SPCC plan has been
prepared in accordance with the Standard Operating Procedures currently in
effect.
14.0 CERTIFICATION BY
Dan Hillsten
Mill Manager
REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Energy Fuels Resources
(USA) Inc. White Mesa Mill facilities, and attest that this SPCC plan has been
prepared in accordance with good engineering practices.
Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
11
15.0 Summary
Chemical and petroleum spills will be reported in accordance with applicable
laws and regulations. Spills that leave the property need to be reported
immediately. Below is a table listing the specific reportable quantities
associated with the major chemical and petroleum products on-site.
CHEMICAL REPORTABLE
QUANTITY (RQ)
AMMONIA 100 POUNDS
AMV 1,000 POUNDS
SODIUM 1,000 POUNDS
HYDROXIDE
SODA ASH No Reportable
Quantity
SODIUM 400 GALLONS
CHLORATE
SULFURIC ACID 1,000 POUNDS
VANADIUM 1000 POUNDS
PENTOXIDE
KEROSENE 100 GALLONS
OIL No Reportable
Quantity
PROPANE No Reportable
Quantity
DIESEL & 100 GALLONS
UNLEADED
FUEL
12
SPILL PREVENTION, CONTROL, AND
COUNTERMEASURES PLAN FOR CHEMICALS AND
PETROLEUM PRODUCTS
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
September 2012
Prepared by:
Energy Fuels Resources (USA) Inc.
1050 17th Street, Suite 950
Denver, CO 80265
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS
1.1-0 OBJECTIVE:
The objective of the Spill Prevention, Control, and Countermeasures (SPCC)
Plan is to serve as a site-specific guideline for the prevention of and
response to chemical and petroleum spills. The plan outlines spill potentials,
containment areas, and drainage characteristics of the White Mesa Mill site.
The plan addresses chemical spill prevention, spill potentials, spill discovery,
and spill notification procedures. Spills are reportable if the spill leaves the
site. Ammonia is the only chemical (as vapor) that has the potential to leave
the site. In addition, chemical and petroleum spills will be reported in
accordance with applicable laws and regulations.
Figure 1~, Mill Site LayoutJ.~shows a map of the mill site including the
locations of the chemical tanks on-site. Figure 2 shows the basins and
drainage ditch areas for the mill site. Table 1.0 is an organization chart for
Mill operations. Table 2.0 lists the reagent tanks and their respective
capacities. Table 3.0 lists the laboratory chemicals, their amounts, and their
reportable quantities. Table 4.0 lists the operations chemicals. Table 5.0
lists the chemicals in the reagent yard, their amounts, and their reportable
quantities. Table 6.0 lists the petroleum products and solvents on site.
4-.2.0 RESPONSIBILITIES:
Person in charge of facility responsible for spill prevention:
Mr. Dan Hilisten, Mill Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
Mr. David Turk, Department FieadManager , Environment. Health, and
Safety, and Environmental
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Refer to Section 1.9 Spill Incident Notification for a list of personnel to be
notified in case of a spill. In addition, an organizational chart is provided in
Table Figure 34.0.
4.3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS:
The main drainage pathways are illustrated in P-tate--Figure 4-:-Q~. The map
shows drainage basin boundaries, flow paths, constructed diversion ditches,
tailing cells, the spillway between Cell 2 and 3, dikes, berms, and other
relevant features. The White Mesa Mill is a "zero" discharge facility for
process liquid wastes. The mill area has been designed to ensure that all
spills or leaks from tanks will drain toward the lined tailing cells.
The tailings cells, in turn, are operated with sufficient freeboard (minimum of
three feet) to withstand 100% of the PMP (Probable Maximum Precipitation).
This allows for a maximum of 10 inches of rain at any given time.
4.4.0 DESCRIPTION OF BASINS:
Precipitation and unexpected spills from the mill site are contained within
their prospective drainage basins. Overflow ultimately drains into one of the
four lined tailings cells.
4.4.1 Basin A1
Basin A 1 is north of Cell 1-1 and Diversion Ditch NO.1. The basin
contains 23 tributary acres, all of which drain into Westwater Creek.
4-.4.2 Basin A2
Basin A2 contains all of Cell 1-1 including an area south of the Diversion
Ditch NO.1. The basin covers 84 acres. Any overflow from this basin
would be contained within Cell 1-1.
4-.4.3 Basin B1
Basin B1 is north of the mill area. The basin contains 45.4 tributary
acres.
Overflow from this basin drains into a flood retention area by flowing
through Diversion Ditch NO.2. Diversion Ditch No.2 drains into
Westwater Creek.
4-.4.4 Basin B2
Basin B2 is northeast of the mill area and contains only 2.6 tributary
acres. Overflow from this basin would drain into Diversion Ditch NO.3.
Diversion Ditch NO.3 ultimately drains into Diversion Ditch No.2.
2
4.4.5 Basin B3
Basin B3 contains most of the mill area, buildings, ore stockpiles, process
storage tanks, retention ponds, spill containment structures, pipelines,
and roadways. The normal direction of flow in this basin is from the
northwest to the southwest. Any overflow from this basin would drain into
Cell 1-1. The basin contains 64 acres. This basin has sufficient
freeboard to withstand 100% of the PMP (Probable Maximum
Precipitation). This allows 10 inches of rain for any given storm event.
4.4.6 Basin C
Basin C contains all of Cell 2. The basin consists of 80.7 acres. Areas in
this basin include earth stockpiles and the heavy equipment shop. The
direction of flow in this basin is to the southwest. All overflows in this
basin is channeled along the southern edge of the basin. Overflow then
flows into Cell 3 via the spillway from Cell 2 to Cell 3.
4.4.7 Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including
a portion of the slopes of the topsoil stockpile and random stockpile. The
basin contains all flows, including those caused by the PMF.
4.4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows
including those caused by the PMF will be contained within the basin and
will flow directly into Cell 4A.
4.4.9 Basin F
Basin F will contain Cell 4B, if and when constructed. The area consists
of 44 acres at a relatively low elevation. Direction of flow in this basin is
towards the southwest.
4-.5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL
CONTAINMENT
4.5.1 Reagent Tanks (Tank list included in Table 2.0)
4.5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of
31,409 gallons each. The tanks are located southeast of the Mill building.
Daily monitoring of the tanks for leaks and routine integrity inspections will be
conducted to minimize the hazard associated with ammonia. The reportable
quantity for an ammonia spill is 7 gallons.
3
Ammonia spills should be treated as gaseous. Ammonia vapors will be
monitored closely to minimize the hazard associated with inhalation. If
vapors are detected, efforts will be made to stop or repair the leak
expeditiously. Ammonia is the only chemical (as vapor) that has the potential
to leave the site.
4.5.3 Ammonia Meta-Vanadate
Ammonia meta-vanadate is present in the SX building as the process
solutions move through the circuit to produce the vanadium end product.
But, the primary fOGUS 'Nill be on the transportation of this GhemiGalSpilis
would be contained in the process sump within the SX building. The
reportable spill quantity for ammonia meta-vanadate is 1,000 pounds.
4.5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner
of the SX building. The tank has a capacity of 19,904 gallons. The tank
supports are mounted on a concrete curbed catchment pad which directs
spills into the sand filter sump in the northwest corner of the SX building.
The reportable spill quantity for sodium hydroxide is 85 gallons.
4.5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located in
the northeast corner of the SX building. The smaller soda ash shift tank has
a capacity of 8,530 gallons and is located in the SX building. Spills will be
diverted into the boiler area, and would ultimately drain into Cell 1-1. There is
no reportable spill quantity associated with sodium carbonate.
4.5.6 Sodium Chlorate
Sodium chlorate tanks consist of two fiberglass tanks located within a dike
east of the SX building. The larger tank is used for dilution purposes and has
a maximum capacity of 17,700 gallons. The smaller tank serves as a
storage tank and has a capacity of 10,500 gallons. Daily monitoring of the
tanks for leaks and integrity inspections will be conducted to minimize the
hazard associated with sodium chlorate.
Sodium chlorate that has dried and solidified becomes even more of a safety
hazard due to its extremely flammable nature. The reportable spill quantity
for sodium chlorate is 400 gallons.
4.5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of
1,600,000 gallons and two smaller tanks with capacities of 269,160 gallons
each.
The large tank is located in the northwest corner of mill area basin 83 and is
primarily used for acid storage and unloading. The tank support for the large
tank is on a mound above a depression which would contain a significant
4
4.6.01 POTENTIAL PETROLEUM SPILL SOURCES AND
CONTAINMENT
4.2-1.1 Petroleum Tanks
4.2-1.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The
tanks have capacities of 250 gallons each. One of the diesel tanks is for the
emergency generator. The other tank is located in the pumphouse on an
elevated stand. Spillage from either tank would ultimately flow into Cell 1-1.
The reportable spill quantity for diesel is 100 gallons. The spill is also
reportable if the spill has the potential for reaching any nearby surface waters
or ground waters.
4.61.2 Aboveground Fuel Pump Tanks
4.2-1.2.1 Diesel
The diesel tank is located on the east boundary of Basin B3 and has a
capacity of 6,000 gallons. The tank is contained within a concrete catchment
pad. The reportable spill quantity for diesel is 100 gallons. A diesel spill is
also reportable if the spill has the potential for reaching any surface waters or
ground waters.
4.2-1.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded
gasoline tank has a capacity of 3,000 gallons and is contained within the
same containment system as the diesel tank. Spills having the potential for
reaching any surface waters or ground waters will need to be reported. The
reportable spill quantity for unleaded gasoline is 100 gallons.
4.2-1.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling
company vehicles used around the mill site. The pump station is equipped
with an emergency shut-off device in case of overflow during fueling. In
addition, the station is also equipped with a piston leak detector and
emergency vent. Check valves are present along with a tank monitor
console with a leak detection system. The catchment is able to handle a
complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a
temporary berm would need to be constructed. Absorbent diapers or floor
sweep would be used in an effort to limit and contain the spill. The soil would
have to be cleaned up and placed in the authorized dump in Cell 2.
6
4.§1-. 2.4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill
area, proper reporting and containment procedures will be followed when
warranted, such as when oil or diesel fuel is spilled. Proper clean-up
procedures will be followed to minimize or limit the spill. The spill may be
temporarily bermed or localized with absorbent compounds. Any soils
contaminated with diesel fuel or oil will be cleaned up and placed in Cell 2.
4.7.03 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take
measures to limit additional spillage and contain the spill that has already
occurred. Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, if
possible, to limit further release.
The Shift Foreman will also secure help if operators are requiring
additional assistance to contain the spill.
The Shift Foreman is also obligated to initiate reporting procedures.
Once control measures have begun and personal danger is
minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will notify the Mill
Manager, who in turn will notify the Department Head of EAlHS
and/or the Environmental Coordinator.
The Mill Manager will assess the spill and related damage and direct
remedial actions. The corrective actions may include repairs, clean-
up, disposal, and company notifications. Government notifications
may be necessary in some cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
4.8.09 SPILL INCIDENT NOTIFICATION
4.89.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies
should be notified:
7
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
1-800-424-8802
301/816-5100
801/538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission
2. State of Utah, Natural Resources
4.89.2 I nternal Notification
301/816-5100
801/538-7200
Internal reporting requirements for incidents, spills, and significant spills are
as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement
actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by
management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits
operations or assesses penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated
with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-
product
8
In the event of a spill requiring reporting, the Mill Manager is required to call
the Corporate Environmental ManagerDirector. Compliance. The Executive
Vice President and Chief Operating Officer. or the President and Chief
Executive Officer. The spill will first be reported to the Shift Foreman. The
Shift Foreman will then report the spill to the Production Mill Superintendent,
Maintenance Superintendent, or Mill Manager.
The Production Mill or Maintenance Superintendent will report to the Mill
Manager. The Department Head of ENHSManager. Environment. Health
and Safety. and the Environmental Corporate Director. Compliance
Coordinator will be contacted by the Mill Manager.
Name
Mill Personnel:
Dan Hillsten
David Turk
678-7802
Garrin Palmer
Mill Manager
RSGManager. Environment.
Health and Safety
Mill Environmental
Compliance Coordinator
Scot Christensen Production Superintendent
Wade Hancock Maintenance Superintendent
Jeremy GagonDavid Lyman Mill Foreman
678-3202678 7805
Thayne Holt Mill Foreman
Denver Personnel:
Home Phone
[phone]
---(435)
[phone]
[phone]
[phone]
(435)
[phone]
Ronald F. HochsteinStephen P. Antony President and
Harold R. Roberts
David C. Frydenlund
Jo Ann Tischler
[phone]
Chief Executive Officer
Executive Vice President
(303) 986 d6d4974-2142
and Chief Operating Officer [phone]
Vice President and General Counsel (dOd) 221 0098
Environmental ManagerDirector. Compliance
9
In the event the next person in the chain-of-command cannot be reached,
then proceed up the chain-of-command to the next level. Table 1 Figure 3.0
shows the organizational chart for the mill site.
4.9.040 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the
Environmental Coordinator for inspection and review for a minimum of three
years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thickness
d. Quarterly Tailings Inspection
2. Tank to soil potential measurements
3. Annual bulk oil and fuel tank visual inspections
4. Tank and pipeline thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer
contains PCBs)
6. Tank supports and foundation inspections
7. Spill Incident reports
8. Latest revision of SPCC plan
4.10.04-SPILL REPORTING REQUIREMENTS
1. Report to applicable government agency as required by laws and
regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of
spill impacts
4. Report release of 5,000 pounds or more of any process material or
waste product
4.1 1.0~PERSONNEL TRAINING AND SPILL PREVENTION
PROCEDURES
All new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and
control. They are informed that leaks in piping, valves, and sudden
discharges from tanks should be reported immediately. Abnormal flows from
ditches or impoundments are of immediate concern. In addition, a safety
meeting is presented annually by the Environmental Coordinator to review
the SPCC plan.
10
4.11:2.1 Training Records
Employee training records on chemical and petroleum spill prevention are
maintained in the general safety training files.
4.11:2.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
11
4.13.04 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Denison MinesEnergy Fuels
Resources (USA) Gafplnc. White Mesa Mill facilities, and attest that this
SPCC plan has been prepared in accordance with the Standard Operating
Procedures currently in effect. ./
4.14.05CERTIFICATION BY
Dan Hillsten
Mill Manager
REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Denison MinesEnergy Fuels
Resources (USA) IncGeft3. White Mesa Mill facilities, and attest that this
SPCC plan has been prepared in accordance with good engineering
practices.
Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
13
4.15.0iSummary
Chemical and petroleum spills will be reported in accordance with applicable
laws and regulations. Spills that leave the property need to be reported
immediately. Below is a table listing the specific reportable quantities
associated with the major chemical and petroleum products on-site.
CHEMICAL REPORTABLE
QUANTITY (RQ)
AMMONIA 100 POUNDS
AMV 1,000 POUNDS
SODIUM 1,000 POUNDS
HYDROXIDE
SODA ASH No Reportable
Quantity
SODIUM 400 GALLONS
CHLORATE
SULFURIC ACID 1,000 POUNDS
VANADIUM 1000 POUNDS
PENTOXIDE
KEROSENE 100 GALLONS
OIL No Reportable
Quantity
PROPANE No Reportable
Quantity
DIESEL & 100 GALLONS
UNLEADED
FUEL
14
r-----
... -----I
I
I
f
\..
Sr. VP Regulatory
Affairs & General
Counsel
~1;..jl~t~~.;:~B!tli?i.+itJ}~~~~t;J5;t~j~11i~~~~;~.~lii\>i~~1:,;:,r.;:~~
Director, Compliance
~~~~1rf@1jfil~~
Manager,
Environment, Health,
and Safety
~~r~u~i1~f~~~~~~§J~_W~
"
...I.
tlil .~~ i~m I"~: il
Figure 3
Energy Fuels Resources (USA) Inc.
White Mesa Mill Management
Organizational Structure
/
\..
\..
President & CEO
Executive VP and Chief
Operating Officer
Mill Manager
\qITh1fm~11r~grinm~~~
L _______________________ ~---
---------------------l--i----------------r--t----------------j
--------~---~--------, / '/ ,/--------~---------~,
Mill
Radiation Safety
Officer
Radiation
Technician
1l>c I~l
Mill
Safety Coordinator
Safety Technician
~~~iH~~iit.~l~~~ili~~·;J:~~k:u~@IDi~~ffil
Mill
Environmental
Compliance
Coordinator
..).
j;;. I~~ Mill
Environmental
Monitoring
Coordinator
'--.-1
/
Mill Operations
Personnel
;·~Elj~ti~kjt;~~h:Jlttffi~1~~~~'
,
'~~
ATTACHMENT 2
TABLE OF CONTENTS
Best Management Practices Plan
Revision 1.5: September 2012
1.0 INTRODUCTION/PURPOSE ............................................................................................................................... 2
2.0 SCOPE ................................................................................................................................................................... 3
3.0 RESPONSIBILITy ................................................................................................................................................ 4
4.0 BEST MANAGEMENT PRACTICES .................................................................................................................. 5
4.1 General Management Practices Applicable to All Areas ......................................................................... 5
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: ............................................ 5
4.1.2 Keep Potential Pollutants from Contact with Precipitation .............................................................. 5
4.1.3 Keep Paved Areas from Becoming Pollutant Sources ...................................................................... 5
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area .................................................................................................................. 5
4.1.5 Recycle Fluids Whenever Possible: .................................................................................................. 5
4.2 Management Practices for Process and Laboratory Areas ....................................................................... 6
4.2.1 Clean Up Spills Properly .................................................................................................................. 6
4.2.2 Protect Materials Stored Outdoors .................................................................................................... 6
4.2.3 Management ..................................................................................................................................... 6
4.2.4 Materials Management ..................................................................................................................... 6
4.3 Management Practices for Maintenance Activities .................................................................................. 7
4.3.1 Keep a Clean Dry Shop .................................................................................................................... 7
4.3.2 Manage Vehicle Fluids ..................................................................................................................... 7
4.3.3 Use Controls During Paint Removal ................................................................................................ 7
4.3.4 Use Controls During Paint Application and Cleanup ....................................................................... 7
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment ............................................ 8
4.4.1 Wash Down Vehicles and Equipment in Proper Areas .................................................................... 8
4.4.2 Manage Stockpiles to Prevent Windbome Contamination ............................................................... 8
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources .................................................... 8
Figures
Figure 1: White Mesa Mill Site Layout.. .................................................................................................................... 17
Figure2: White Mesa Mill Site Drainage Basins ........................................................................................................ 18
Figure 3: Energy Fuels Resources (USA) Inc.-White Mesa Mill Management Organization Chart ........................ 20
Figure 4: Energy Fuels Resources (USA) Inc. -Corporate Management Organizational Chart ............................... 22
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP ........................ 10
TABLE 2.0: REAGENT YARD LIST ....................................................................................................................... 11
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST 1. ......................................................................... 12
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1 ........................................................ 13
TABLE 5.0: EAGENT YARDIBULK CHEMICALS LIST 1 ................................................................................... 14
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST 1 ...................................................................... 15
Page 1
1.0 INTRODUCTIONIPURPOSE
Best Management Practices Plan
Revision 1.5: September 2012
Energy Fuels Resources (USA) Inc. ("EFR") operates the White Mesa Uranium Mill (lithe Mill)
in Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect
to water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to EFR on March 8,
2005. As a part of compliance with the Permit, EFR is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Executive Secretary of the Division of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
management practices to minimize or prevent spills of chemicals or hazardous materials, which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes. Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements these practices in a good faith effort to minimize all sources of
pollution at the site.
Page 2
2.0 SCOPE
Best Management Practices Plan
Revision 1.5: September 2012
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC license
conditions. All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments. A site map of the Mill is provided in Figure 1. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
wash down to the process sewers, and ultimately the tailings system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of stormwater, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
EFR White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP") , and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs").
Page 3
3.0 RESPONSmILITY
Best Management Practices Plan
Revision 1.5: September 2012
All Mill personnel are responsible for implementation of the practices in this BMPP. EFR White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The Mill Management Organization is presented in Figure 3. The EFR Corporate Management
Organization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table 1.
Page 4
Best Management Practices Plan
Revision 1.5: September 2012
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
by product Materials License #UT19004 79. Areas requiring maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be reported to site management and maintenance departments for necessary action to
repair damage or perform reconstruction in order for the control feature to perform as
intended. Status of maintenance or repairs will be documented during follow up
inspections and additional action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
Page 5
Best Management Practices Plan
Revision l.5: September 2012
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D.I0.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE ") near the areas where they may be needed for spill response.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 6
Best Management Practices Plan
Revision 1.5: September 2012
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings area
Page 7
Best Management Practices Plan
Revision 1.5: September 2012
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and tile truck wash station).
• At the truck wash station, make sure the water collection and recycling system is working before
turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Wind borne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep surfaces moist but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
Personnel
Dan Hillsten
Wade Hancock
Scot Christensen
David E. Turk
Garrin Palmer
Personnel
Stephen P. Antony,
Harold R. Roberts
David C. Frydenlund
Jo Ann Tischler
TABLE 1
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Staff
Title Work Phone
Mill Manager 435-678-4105
Maintenance 435-678-4166
Superintendent
Mill Superintendent 435-678-2221
Manager, Environment, 435-678-4113
Health and Safety
Mill Environmental
Compliance
Coordinator 435-678-4115
Corporate Management Staff
Title Work Phone
President and Chief 303-974-2142
Operating Officer
Executive Vice 303-389-4160
President and Chief
Operating Officer
Sr. Vice President 303-389-4130
Regulatory Affairs and
General Counsel
Director, Compliance 303-389-4132
HomePhonel
Other Contact Number
Cell: 435-979-3041
435-678-2753
Cell: 435-979-0410
435-678-2015
435-678-7802
Cell: 435-459-9786
Cell: 435-459-9463
Home Phone I
Other Contact
Number
Cell: 303-378-8254
Cell: 303-902-2870
303-221-0098
Cell: 303-808-6648
Cell: 303-501-9226
Page 10
REAGENT
AMMONIUM
SULFATE(BULK)
AMMONIUM
SULFATE(BAGS)
ANHYDROUS AMMONIA
TRIDECYLALCOHOL
DIESEL FUEL
GRINDING BALLS
KEROSENE
POLOX
PROPANE
SALT (BAGS)
SALT (BULK)
SODA ASH (BAGS)
SODA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
TABLE 2
REAGENT YARD LIST
QUANTITY NUMBER OF
(LBS) . STORAGE
TANKS
54,000 2
26,000 ---
107,920 2
45,430 ---
2
1
72,000 ---
1,344 1
2
10,360 ---
1
39,280 ---
0 1
1
39,280 ---
84,100 1
1
101,128 1
1
1
0 1
4,801,440 1
1
1
CAPACITY
(GALLONS)
24,366
31,409
250
6,000
10,315
10,095
25,589
13,763
18,864
16,921
8,530
16,921
22,561
29,940
19,905
1,394,439
3,000
5,000
Page 11
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST 1
Chemical In Lab RQ2 Quantitv in Stock
Aluminum nitrate 2270 kg 1.8 kg
Ammonium bifluoride 45.4 kg 2.27 kg
Ammonium chloride 2270 kg 2.27 kg
Ammonium oxalate 2270 kg 6.8 kg
Ammonium thiocyanate 2270 kg 7.8 kg
Antimony potassium tatrate 45.4 kg 0.454
n-8utyl acetate 2270 kg 4L
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.81 kg
Ferrous ammonium sulfate 454 kg 0.57
Potassium chromate 4.54 kg 0.114 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2270kg 1.4
Zinc acetate 454 kg 0.91 kg
Chemical. in Volatiles and RQ2 Quantit~ in Stock
Flammables Lockers
(A.B.C)
Chloroform 4.54 kg 8L
Formaldehyde 45.4 kg < 1 L of 37%) solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ2 Quantity in Stock
Chloroform 4.54 kg 55 gal
Hydrochloric acid 2,270 kg 58 gal
Nitrate acid 454 kg 5L
PhosRhoric Acid 2,270 kg 10 L
Sulfuric acid 454 kg 25 L
Hydrofluoric acid 45.4 kg 1 L
Ammonium hydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above
regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act."
Page 12
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
CHEMICAL RQz QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1,0001bs 4 gal
Ammonium Hydroxide 1,0001bs 5L
Calcium Hypochlorite 10lbs 2 kg (4.4 Ibs)
Chlorine 10lbs o Ibs
Ferrous Sulfate Heptahydrate 1,0001bs 5 kg (11Ibs)
Hydrochloric 5,0001bs 60 gal of 40% solution
Nitric Acid 1,0001bs 10 L
Potassium Permanganate 0.1 N 32 gal 5 kg (11Ibs)
Sodium Hypochlorite 5.5% 100lbs 2 kg (11 Ibs) of 5.5%
solution
Silver Nitrate 1 Ib Olbs
Trichloroethylene 100lb 2L
1. This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Materials in this list are stored in a locked storage
compound near the bulk storage tank area. The Mill also stores small
quantities of other materials that are not hazardous substances per
the above regulation.
2. Reportable Quantities are those identified in40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 13
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
REAGENT RQI QUANTITY IN REAGENT
YARD
Sulfuric Acid 1,0001bs 9,000,000 Ibs
Hyperfloc 102 None 1,5001bs
Ammonia -East Tank 100lbs Olbs
Ammonia -West Tank 100lbs 105,0001bs
Kerosene 100 gal 500 gal
Salt (Bags) None 20,0001bs
Soda Ash Dense (Bag) None 50,0001bs
Polyox None 490lbs
Tributyl phosphate None 9,4501bs
Diesel 100 gal Approx. 3300 gal
Gasoline 100 gal Approx. 6000 gal
Alamine 336 drums None 8,250 gal
Salt(Bulk Solids) None 50,0001bs
Salt(Bulk Solutions) None 9,000 gal
Caustic Soda 1,0001bs 16,0001bs
Ammonium Sulfate None 150,0001bs
Sodium Chlorate None 350,0001bs
Alamine 310 Bulk None Olbs
Isodecanol None 2,420 gal
Vanadium Pentoxide3 1000lbs 30,0001bs
Yellowcake3 None <100,000Ibs
Ammonia Meta Vanadate 1000lbs Olbs
Floc 655 21,0001bs
Floc 712 1,2501bs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building and/or Mill Yard
Page 14
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1 ,540 gallons
Transmission Oils 100 gal 110 gallons
Water Soluble Oils 100 gal 110 gallons
Xylene (mixed isomers) 100 gal o gallons
Toluene 1000 gal o gallons
Varsol Solvent 100 gal o gallons
(2% trimethyl benzene in petroleum
distillates)
1. This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 15
FIGURES
Page 16
Figure 2
White Mesa Mill
Mill Site Drainage Basins
Page 18
r-----
Sr. VP Regulatory
Affairs & General
'\
t~
: Counsel
I ~
I
I r-----
I
I
I
Director, Compliance
·~~1t~~fif~lfu~~~~lW1~~
f : I Manager, ~ - - - - -Environment, Health, J~~~
'l& 1ti~ i~~~
and Safety ~ ~~ '-j!llll
I L _______________________ ~---
\..
Mill
Radiation Safety
Officer
Radiation
Technician
;;:~~~~~$iZ,
:g-I'
..I,
Figure 3
Energy Fuels Resources (USA) Inc.
White Mesa Mill Management
Organizational Structure
/
Mill
President & CEO
Executive VP and Chief
Operating Officer
Mill Manager
·i!tr~Hftlii;;i~~gt~Jl~#.mki~~;
Safety Coordinator
Mill
Environmental
Compliance
Coordinator
I
Safety Technician
A
Mill
Environmental
Monitoring
Coordinator
'-.de ~I&i~
Mill Operations
Personnel
-;tnJIffi~~mMJmmllmt1i~IJWril~:l~i~~mit~R!;itf.~HW~~lirr¥J.~mill
Figure 4
Energy Fuels Resources (USA) Inc.
Organizational Structure
President & CEO
Sr. VP Regulatory
Affairs & General
Counsel
Director, Compliance
'"
Executive VPand Chief
Operating Officer
·~1Tt!~f.g~~t!ft~h~~~~,
Mill Manager
'\ I
Manager,
Environmental, Health,
and Safety
A
TABLE OF CONTENTS
Best Management Practices Plan
Revision 1.~4: Oetober September 2012+
1.0 INTRODUCTION/PURPOSE ............................................................................................................................. 1-1
2.0 SCOPE ................................................................................................................................................................. ,2,-2-
3.0 RESPONSIBILITy .............................................................................................................................................. ,13
4.0 BEST MANAGEMENT PRACTICES ................................................................................................................ ~4
4.1 General Management Practices Applicable to All Areas ....................................................................... ~4
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: .......................................... ~4
4.1.2 Keep Potential Pollutants from Contact with Precipitation ............................................................ ~4
4.1.3 Keep Paved Areas from Becoming Pollutant Sources .................................................................... ~4
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area ................................................................................................................ ~4
4.1.5 Recycle Fluids Whenever Possible: ................................................................................................ ~4
4.2 Management Practices for Process and Laboratory Areas ..................................................................... §.~
4.2.1 Clean Up Spills Properly ................................................................................................................ §.~
4.2.2 Protect Materials Stored Outdoors .................................................................................................. §.~
4.2.3 Management ................................................................................................................................... §.~
4.2.4 Materials Management ................................................................................................................... §.~
4.3 Management Practices for Maintenance Activities ................................................................................ 16
4.3.1 Keep a Clean Dry Shop .................................................................................................................. 16
4.3.2 Manage Vehicle Fluids ................................................................................................................... 16
4.3.3 Use Controls During Paint Removal .............................................................................................. 16
4.3.4 Use Controls During Paint Application and Cleanup ..................................................................... 16
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment .......................................... !P
4.4.1 Wash Down Vehicles and Equipment in Proper Areas .................................................................. ,a+
4.4.2 Manage Stockpiles to Prevent Windbome Contamination ............................................................. ,a+
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources .................................................. ,a+
Figures
Figure 1: White Mesa Mill Site Layout .................................................................................................................. 17-16
Figure2: White Mesa Mill Site Drainage Basins .................................................................................................... 18-1+
Figure 3: DeBisoB }'4inesEnergy Fuels Resources (USA) Inc~.-White Mesa Mill Management
Organization Chart .................................................................................................................................................. 20±9
Figure 4: DeBisoB }'4iBesEnergy Fuels Resources (USA) Inc~. -Corporate Management
Organizational Chart ............................................................................................................................................... 22-2-G
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP ...................... 109
TABLE 2.0: REAGENT YARD LIST ........................................ · ........................................................................... 11±G
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST 1 ...................................................................... 12-1-1
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1 .................................................... 13-1-2-
TABLE 5.0: EAGENT YARD/BULK CHEMICALS LIST 1 ............................................................................... 14-13
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST 1 .................................................................. 15-±4
Page 1
1.0 INTRODUCTIONIPURPOSE
Best Management Practices Plan
Revision 1.~4: Oetober September 2012+
DeBisoB ~4iBesEnergy Fuels Resources (USA) GeFplnc. ("I+Y-SAEFR") operates the White Mesa
Uranium Mill ("the Mill) in Blanding, Utah. The Mill is a net water consumer, and is a zero-
discharge facility with respect to water effluents. That is, no water leaves the Mill site because the
Mill has:
• no outfalls to public storm water systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to DUSt\: EFR on
March 8, 2005. As a part of compliance with the Permit, I+Y-SAEFR is required to submit a
Stormwater Best Management Practices Plan ("BMPP") to the Executive Secretary of the
Division of Radiation Control, Utah Department of Environmental Quality. This BMPP presents
operational and management practices to minimize or prevent spills of chemicals or hazardous
materials, which could result in contaminated surface water effluents potentially impacting
surface waters or ground waters through runoff or discharge connections to stormwater or surface
water drainage routes. Although the Mill, by design, cannot directly impact stormwater, surface
water, or groundwater, the Mill implements these practices in a good faith effort to minimize all
sources of pollution at the site.
Page 2
2.0 SCOPE
Best Management Practices Plan
Revision 1.~4: Oeteber September 2012.+
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC license
conditions. All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments. A site map of the Mill is provided in Figure 1. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
wash down to the process sewers, and ultimately the tailings system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of stormwater, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed r-Requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
f)Y8AEFR White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP");, and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs"). The latest revisioBS of the SPCC Vltlfl tlfld
the BRP are vrovided iB their eB-tirety iB AvveBdiees 1 tlfld 2, resveetively.
Page 3
Best Management Practices Plan
Revision 1.~4: Oetober September 2012+
3.0 RESPONSmILITY
All Mill personnel are responsible for implementation of the practices in this BMPP. DU8A EFR
White Mesa Mill management is responsible for providing the facilities or equipment necessary
to implement the practices in this BMPP.
The Mill Management Organization is presented in Figure 3. The DUSAEFR Corporate
Management Organization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table l.
Page 4
Best Management Practices Plan
Revision 1 . .5.4: October September 2012+
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
by product Materials License #UT19004 79. Areas requiring maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be reported to site management and maintenance departments for necessary action to
repair damage or perform reconstruction in order for the control feature to perform as
intended. Status of maintenance or repairs will be documented during follow up
inspections and additional action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
. Page 5
Best Management Practices Plan
Revision 1.~4: Oetober September 2012+
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D.I0.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE ") near the areas where they may be needed for spill response.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 6
Best Management Practices Plan
Revision 1.~4: Oetober September 201 2-1-
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings area
Page 7
Best Management Practices Plan
Revision 1.24: Oeteber September 2012.+
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and tile truck wash station).
• At the truck wash station, make sure the water collection and recycling system is working before
turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep surfaces moist but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
.• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
Personnel
Dan Hillsten
I Wade Hancock
Scot Christensen
David E. Turk
Gaffin Palmer
Personnel
Roa Ii. HoehsteiaStephen
P. Antony,
Harold R. Roberts
David C. Frydenlund
I Jo Ann Tischler
TABLE 1
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Staff
Mill Manager
Maintenance
Superintendent
Mill Superintendent
Ritdiatioa Safety
OffieerManager,
Environment, Health
and Safety
Mill Environmental
Compliance
Coordinator
Work Phone
435-678~4105
E~(t. 105
435-678~
E~ct.l664166
435-678-2221
435-678~4113
E~ct. 113
435-678-4115
Corporate Management Staff
Title Work Phone
President andl Chief 604 689 +84~303-974-
Operating Officer 2142
Executive Vice 303-389-4160
President and Chief
Operating Officer
Sf. Vice President 303-389-4130
Regulatory Affairs and
General Counsel
Director~ Compliance 303-389-4132
HomePhonel
Other Contact Number
Cell: 435-979-3041
435-678-2753
Cell: 435-979-0410
435-678-2015
435-678-7802
Cell: 435-459-9786
Cell: 435-459-9463
Home Phone I
Other Contact
Number
Cell: 604 3++ 116+303-
378-8254
Cell: 303-902-2870
303-221-0098
Cell: 303-808-6648
Cell: 303-501-9226
Page 10
REAGENT
AMMONIUM
SULFATE(BULK)
AMMONIUM
SU LFA TE(BAGS)
ANHYDROUS AMMONIA
TRIDECYLALCOHOL
DIESEL FUEL
GRINDING BALLS
KEROSENE
POLOX
PROPANE
SALT (BAGS)
SALT (BULK)
SODA ASH (BAGS)
SODA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
TABLE 2
REAGENT YARD LIST
QUANTITY NUMBER OF
(LBS) STORAGE
TANKS
54,000 2
26,000 ---
107,920 2
45,430 ---
2
1
72,000 ---
1,344 1
2
10,360 ---
1
39,280 ---
0 1
1
39,280 ---
84,100 1
1
101,128 1
1
1
0 1
4,801,440 1
1
1
CAPACITY
(GALLONS)
24,366
31,409
250
6,000
10,315
10,095
25,589
13,763
18,864
16,921
8,530
16,921
22,561
29,940
19,905
1,394,439
3,000
5,000
Page 11
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST 1
Chemical In Lab RQ2 Quantitv in Stock
Aluminum nitrate 2270 kg 1.8 kg
Ammonium bifluoride 45.4 kg 2.27 kg
Ammonium chloride 2270 kg 2.27 kg
Ammonium oxalate 2270 kg 6.8 kg
Ammonium thiocyanate 2270 kg 7.8 kg
Antimony potassium tatrate 45.4 kg 0.454
n-8utyl acetate 2270 kg 4L
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.81 kg
Ferrous ammonium sulfate 454 kg 0.57
Potassium chromate 4.54 kg 0.114 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2270kg 1.4
Zinc acetate 454 kg 0.91 kg
Chemical. in Volatiles and RQ2 Quantit~ in Stock
Flammables Lockers
(A.B.C)
Chloroform 4.54 kg 8L
Formaldehyde 45.4 kg <1 L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ2 Quantity in Stock
Chloroform 4.54 kg 55 gal
Hydrochloric acid 2,270 kg 58 gal
Nitrate acid 454 kg 5L
Phosphoric Acid 2,270 kg 10 L
Sulfuric acid 454 kg 25 L
Hydrofluoric acid 45.4 kg 1 L
Ammonium hydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above
regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act."
Page 12
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
CHEMICAL RQ2 QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1,0001bs 4 gal
Ammonium Hydroxide 1,0001bs 5L
Calcium Hypochlorite 10lbs 2 kg (4.4 Ibs)
Chlorine 10lbs Olbs
Ferrous Sulfate Heptahydrate 1,0001bs 5 kg (11Ibs)
Hydrochloric 5,0001bs 60 gal of 40% solution
Nitric Acid 1,0001bs 10 L
Potassium Permanganate 0.1 N 32 gal 5 kg (11Ibs)
Sodium Hypochlorite 5.5% 100lbs 2 kg (11 Ibs) of 5.5%
solution
Silver Nitrate 1 Ib Olbs
Trichloroethylene 100lb 2L
1. This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Materials in this list are stored in a locked storage
compound near the bulk storage tank area. The Mill also stores small
quantities of other materials that are not hazardous substances per
the above regulation.
2. Reportable Quantities are those identified in40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 13
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
REAGENT RQ' QUANTITY IN REAGENT
YARD
Sulfuric Acid 1,0001bs 9,000,000 Ibs
Hyperfloc 102 None 1,5001bs
Ammonia -East Tank 100lbs Olbs
Ammonia -West Tank 100lbs 105,0001bs
Kerosene 100 gal 500 gal
Salt (8ags) None 20,0001bs
Soda Ash Dense (8ag) None 50,0001bs
Polyox None 490lbs
Tributyl phosphate None 9,4501bs
Diesel 100 gal Approx. 3300 gal
Gasoline 100 gal Approx. 6000 gal
Alamine 336 drums None 8,250 gal
Salt(8ulk Solids) None 50,0001bs
Salt(8ulk Solutions) None 9,000 gal
Caustic Soda 1,0001bs 16,0001bs
Ammonium Sulfate None 150,0001bs
Sodium Chlorate None 350,0001bs
Alamine 310 8ulk None Olbs
Isodecanol None 2,420 gal
Vanadium Pentoxide3 1000lbs 30,0001bs
Yellowcake3 None <100,000 Ibs
Ammonia Meta Vanadate 1000lbs Olbs
Floc 655 21,0001bs
Floc 712 1,2501bs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building and/or Mill Yard
Page 14
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1,540 gallons
Transmission Oils 100 gal 110 gallons
Water Soluble Oils 100 gal 110 gallons
Xylene (mixed isomers) 100 gal o gallons
Toluene 1000 gal o gallons
Varsol Solvent 100 gal o gallons
(2%) trimethyl benzene in petroleum
distillates)
1. This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 15 n
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Sr. VP Regulatory
Affairs & General
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Director, Compliance
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Environment, Health,
and Safety
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Energy Fuels Resources (USA) Inc.
White Mesa Mill Management
Organizational Structure
President & CEO
Executive VP and Chief
Operating Officer
Mill Manager
'~illiG'ffi~!Nm1i1~g,~iIT{m~~r~i$
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Mill
Radiation Safety
Officer
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Technician
Mill
Safety Coordinator
" Safety Technician "
Mill
Environmental
Compliance
Coordinator
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Monitoring
Coordinator
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Mill Operations
Personnel
'-ii~llin1f~~1flf~l~~~Ji~~T~!mJfFi~~m~~it~iill
Figure 4
Energy Fuels Resources (USA) Inc.
I
Organizational Structure
President & CEO
'l!~8ilmImmjJ~~t¥.L~~1Wiffitf
Sr. VP Regulatory
Affairs & General
Counsel
Director, Compliance
~
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Executive VPand Chief
Operating Officer
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Environmental, Health,
and Safety
APPENDICES
Page 24
Appeadix 1
~lhite l\lesft l\lill Spill PFe¥eati9a, C9atF91, ftad C9HateFIHeftSHFeS Plfta
Page 25
A(i(ieBdix 2
"'bite l\lestl l\lill EmepgeBey Res(i6BSe PltlB
Page 26
ATTACHMENT 3
ATTACHMENT 4
Storm Water Best Management Practices Plan ("SWBMPP") Training -
General Employee Training
Outline
• Potential Chemical Spill Sources
• Potential Petroleum Spill Sources
• Spill Discovery and Remedial Action
• Spill Incident Notification
o Internal-Spill Cards
• Discuss how to fill out the cards
• Discuss who is to get the cards
• Discuss the timeliness of receiving the cards
o External -Who is responsible for reporting
Schedule
SWBMPP General Employee Training will be conducted during the 2nd Quarter Radiation
Refresher training session except in 2012, when it will be conducted during the third quarter.
Storm Water Best Management Practices Plan ("SWBMPP") Training -
Environmental Staff Training
Outline
• Line of Authority
• Potential Chemical Spill Sources
• Potential Petroleum Spill Sources
• Containment Areas
• Spill Discovery and Remedial Action
• Spill Incident Notification
o Internal -Spill Cards
• Discuss how to fill out the cards
• Discuss who is to get the cards
• Discuss the timeliness of receiving the cards
o External -Who is responsible for reporting
• Records and Reports
• Protection of groundwater quality
• Prevent, control and containment of spills
• Remediation of spills of reagents and chemicals
• Reporting criteria
Schedule
SWBMPP Environmental Staff Training will be conducted in January of each year.
SWBMPP General Employee Training will be conducted during the 2nd Quarter Radiation
Refresher training session, except in 2012, when it will be conducted during the third quarter.