DRC-2016-006718 - 0901a0688062ca30

ENERGY FUELS
Energy Fuels Resources (LISA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energvfuels.com
DRC- 20i6- 00671Q busses; t
May 2’2016 MAY - 4 2016
Sent VIA OVERNIGHT DELIVERY
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Transmittal of Revised Spill Prevention, Control and Countermeasures Pan (“SPCC”) and
Revised Stormwater Best Management Practices Plan (“SWBMPP”) for White Mesa Uranium
Mill
Dear Mr. Anderson:
This letter transmits Energy Fuels Resources (USA) Inc.’s (“EFRI’s”) proposed revisions to the White Mesa
Mill SPCC and SWBMPP. These revisions include changes made to:
1. Update personnel and contact information.
2. Correct typographical errors.
For ease of review we have provided both redline/strikeout (text only) and clean versions (text and all tables
and figures) of each document.
If you should have any questions regarding these plans please contact me.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Harold R. Roberts
David E. Turk
Logan Shumway
Scott Bakken
REDLINE
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
May 2,2016
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
ENERGY FUELS
Contents
1.0 OBJECTIVE.................................................................................................................................1
2.0 RESPONSIBILITIES.................................................................................................................24
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS........................................................32
4.1 Basin A1............................................................................................................................32
4.2 Basin A2............................................................................................................................32
4.3 Basin B1............................................................................................................................32
4.4 Basin B2............................................................................................................................32
4.5 Basin B3............................................................................................................................32
4.6 Basin C..............................................................................................................................32
4.7 Basin D..............................................................................................................................43
4.8 Basin E..............................................................................................................................43
4.9 Basin F..............................................................................................................................43
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT..........................43
5.1 Reagent Tanks (Tank list included in Table 2.0).............................................................43
5.2 Ammonia...........................................................................................................................43
5.3 Ammonia Meta-Vanadate................................................................................................43
5.4 Caustic Storage (Sodium Hydroxide)...............................................................................53
5.5 Sodium Carbonate (Soda Ash)........................................................................................54
5.6 Sodium Chlorate............................................................................................................... 54
5.7 Sulfuric Acid.....................................................................................................................54
5.8 Vanadium Pentoxide........................................................................................................64
5.9 Kerosene (Organic)..........................................................................................................65
5.10 Used/Waste Oil................................................................................................................. 65
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT.............................................65
6.1 Petroleum Tanks..............................................................................................................65
6.1.1 Diesel.........................................................................................................................65
6.2 Aboveground Fuel Pump Tanks.......................................................................................65
6.2.1 Diesel.........................................................................................................................66
6.2.2 Unleaded Gasoline...................................................................................................75
6.2.3 PumpStation.............................................................................................................75
6.2.4 Truck Unloading........................................................................................................75
7.0 SPILL DISCOVERY AND REMEDIAL ACTION.....................................................................75
8.0 SPILL INCIDENT NOTIFICATION...........................................................................................97
8.1 External Notification............................................................................................................93
8.2 Internal Notification.............................................................................................................93
9.0 RECORDS AND REPORTS...................................................................................................108
10.0 SPILL REPORTING REQUIREMENTS..............................................................................119
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES............................JM9
11.1 Training Records............................................................................................................119
11.2 Monitoring Reports.........................................................................................................119
12.0 REVISION.............................................................................................................................119
13.0 MILL MANAGER APPROVAL............................................................................................1240
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER...............................1240
15.0 SUMMARY...........................................................................................................................1344
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN FOR
CHEMICALS AND PETROLEUM PRODUCTS
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.
1.1 Plan Organization
This SPCC is organized as follows:
Section 1,0 Objective
Section 2 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4 Description of Basins
Section 5.0 Potential Chemical Spill Sources and Spill Containment
Section 6.0 Potential Petroleum Spill Sources and Containment
Section 7.0 Spill Discovery and Remedial Action
Section 8.0 Spill Incident Notification
Section 9.0 Records and Reports
Section 10.0 Spill Reporting Requirements
Section 11.0 Personnel Training and Spill Prevention Procedures
Section 12.0 Revision
Section 13.0 Mill Manager Approval
Section 14,0 Certification by Registered Professional Engineer
Section 15.0 Summary
Tables:
Table 1.0 is the Energy Fuels Resources (USA) Inc. (EFRI) personnel responsible for
implementing this SPCC.
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 reagent vard/small quantity 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.
1
Figures:
Figure lih shows the 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 mMill sSite.
Figure 3 shows the organization chart for Mill Operations. Table 1.0 is an organization chart
for Mill operations. Table 2.0 liste-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-pfoducts-and solvents
en-sker
2.0 RESPONSIBILITIES
Personnel responsible for spill prevention and follow-up spill reporting are included on Table
1 which is included in the Tables Tab of this SPCC.
Person in charge of facility responsible for spill prevention:
Mr. Dan Hillsten, Mill Manager
6-125 South Highway 191
Blanding, UT 84511
[phone] (work)
-------[phone] (home)
Person4n- eharge-of follow-up spill-reporting:
Mr. David Turk, EH&S Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
2
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 eefcmanagement system.
The tailings cellsmanagement system, in turn, are-is 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.
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 cellsthe
tailings management system.
4.1 Basin A1
Basin A1 is north of Cell 1-f 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 14.
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.
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 14. 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
3
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 PMFP.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows including those
caused by the PMFP will be contained within the basin and will flow directly into Cell 4A.
4.9 Basin F
Basin F wvH-contains Cell 4B, and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4B.if
and when constructed. The area consists of 44 acres at a relatively low elevation. Direction
of flow in ■this-basln4s~tewafds 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 quantity for an ammonia spill
is 7 gallons.
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.
i Meta-Vanadate
Ammonium meta-vanadate is present in the vanadium precipitation area of the Mill 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 vanadium precipitation area. The
reportable spill quantity for ammonium meta-vanadate is 1,000 pounds.Ammonia meta
vanadate is present in the SX building as the process solutions move through the circuit to
produce the vanadium-end-produetr -Spills-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 comer 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
comer 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-outside the
northeast comer of the SX building. Spills from the soda ash solution tank are contained in
the North SX impound and run to Cell 1. 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-f. There is no reportable spill quantity associated with
sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of three fiberglass tanks located within a dike east of the SX
building. Tank maximum volumes of the three tanks are 16,075. 21,057 and 28,788 gallons.
Daily monitoring of the tanks for leaks and integrity inspections will be conducted to
minimize the hazard associated with 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-oTthe-tanks for leaks
and integrity inspections will be conducted to minimize the hazard ■ass<reiated-wlth-sedium
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 twe-one smaller tanks with capacities a capacity of 269.16011,000 gallons-eaeh.
The large tank is located in the northwest comer of mill area basin B3 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 IT. The tank is equipped 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-
I.
The twe-smaller storage tanks are-is located within an equal voltime-spifl ■ containment dike
east of the millon the north side of the SX building. The tanks are not presently in use, but
are-isequipped with ahigh level audible alarms.
The reportable spill quantity for sulfuric acid is 65 gallons.
5
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 14. 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 Used/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 uUsed oil is to an EPA permitted oil rccvolerwill be disposed of on
site. 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 the Cell currently
used for the disposal of solid Mill wastes.
6.0 POTENTIAL PETROLEUM 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 elevated stand. Spillage from either
tank would ultimately flow into Cell 14. 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
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 Cell currently used for the disposal of solid Mill wastesthe 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 the Cell
currently used for the disposal of solid Mill wastesCeU-3.
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 EH&S Manager 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
7
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 1-800-424-8802
2. US Nuclear Regulatory Commission 301-816-5100
3. State of Utah 801-538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301-816-5100
2. State of Utah, Natural Resources 801-538-7200
8.2 Internal 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
9
In the event of a spill requiring reporting, the Mill Manager is required to call the Quality
Assurance Manager, 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.
The Mill or Maintenance Superintendent will report to the Mill Manager. The EH&S
Manager and the Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Dan HillstenLoean Shumwav Mill Manager (435)
939459-98783044
David Turk EH&S Manager
3803
Garrin Palmer Mill Environmental Compliance
Coordinator
Scot ChristensenThayne Holt Production Superintendent
-1783
(435) 038459-9786-
[phone]
(435)
Wade Hancock Maintenance Superintendent [phone]
David Lyman---------------Mill Foreman-----------------------------------------[phone]
Thayne Holt----------------Mill Foreman-----------------------------------------[phone]
Denver Lakewood Personnel:
Stephen P. Antony President and Chief Executive
Officer [phone]
Harold R. Roberts Executive Vice President
and Chief Operating OfficerConventional Operations
[phone]
Scott BakkenSr. Director, Regulatory Affairs(303) 389-4132
Kathy Weinel Quality Assurance Manager [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
10
The following reports and records are to be maintained in Central File by the Environmental
Coordinator-Department for inspection and review for a minimum of thfee-five 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
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.
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.
11
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.
E)an HillstenLogan Shumway
Mill Manager
14.0 CERTIFICATION BY 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
12
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. Each spill will
be assessed and reported as required by the applicable regulations. Reportable quantities are
shown in the attached tables.Below ■-is a table listing the specific reportable quantities
associated with the major chemical and petroleum products on site.
CHEMICAL REPORTABLE
QUANTITY (RQ)
AMMONIA
AMY
SODIUM
HYDROXIDE
SODA ASH
SODIUM
CHLORATE
SULFURIC
AG©
VANADIUM
PENTOXIDE
KEROSENE
©&
PROPANE
DIE-SEL--&
UNLEADED
FUEL
100 POUNDS
Ne------Reportable
Quantity
400 GALLONS
1,000 POUNDS
1000 POUNDS
100 GALLONS
Ne------Reportable
Quantity
Ne------Reportable
Quantity
100 GALLONS
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13
TABLES
FIGURES
CLEAN
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
May 2,2016
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
ENERGYFUELS
Contents
1.0 OBJECTIVE.........................................................................................................................................................................1
2.0 RESPONSIBILITIES......................................................................................................................................................2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS...........................................................................2
4.1 Basin A1....................................................................................................................................................................2
4.2 Basin A2....................................................................................................................................................................2
4.3 Basin B1....................................................................................................................................................................2
4.4 Basin B2....................................................................................................................................................................2
4.5 Basin B3....................................................................................................................................................................3
4.6 Basin C......................................................................................................................................................................3
4.7 Basin D.......................................................................................................................................................................3
4.8 Basin E.......................................................................................................................................................................3
4.9 Basin F.......................................................................................................................................................................3
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT....................................3
5.1 Reagent Tanks (Tank list included in Table 2.0).................................................................................3
5.2 Ammonia...................................................................................................................................................................3
5.3 Ammonia Meta-Vanadate................................................................................................................................4
5.4 Caustic Storage (Sodium Hydroxide)........................................................................................................4
5.5 Sodium Carbonate (Soda Ash).....................................................................................................................4
5.6 Sodium Chlorate...................................................................................................................................................4
5.7 Sulfuric Acid.............................................................................................................................................................4
5.8 Vanadium Pentoxide...........................................................................................................................................5
5.9 Kerosene (Organic)..............................................................................................................................................5
5.10 Used/Waste Oil........................................................................................................................................................5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT.............................................................5
6.1 Petroleum Tanks...................................................................................................................................................5
6.1.1 Diesel................................................................................................................................................................5
6.2 Aboveground Fuel Pump Tanks...................................................................................................................5
6.2.1 Diesel................................................................................................................................................................5
6.2.2 Unleaded Gasoline....................................................................................................................................6
6.2.3 Pump Station................................................................................................................................................6
6.2.4 Truck Unloading...........................................................................................................................................6
7.0 SPILL DISCOVERY AND REMEDIAL ACTION.............................................................................................6
8.0 SPILL INCIDENT NOTIFICATION.........................................................................................................................7
8.1 External Notification................................................................................................................................................7
8.2 Internal Notification..................................................................................................................................................7
9.0 RECORDS AND REPORTS.....................................................................................................................................9
10.0 SPILL REPORTING REQUIREMENTS.............................................................................................................9
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES..........................................9
11.1 Training Records..................................................................................................................................................9
11.2 Monitoring Reports...............................................................................................................................................9
12.0 REVISION..........................................................................................................................................................................9
13.0 MILL MANAGER APPROVAL..............................................................................................................................10
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER.............................................10
15.0 SUMMARY......................................................................................................................................................................11
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN FOR
CHEMICALS AND PETROLEUM PRODUCTS
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.
1.1 Plan Organization
This SPCC is organized as follows:
Section 1.0 Objective
Section 2 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4 Description of Basins
Section 5.0 Potential Chemical Spill Sources and Spill Containment
Section 6.0 Potential Petroleum Spill Sources and Containment
Section 7.0 Spill Discovery and Remedial Action
Section 8.0 Spill Incident Notification
Section 9.0 Records and Reports
Section 10.0 Spill Reporting Requirements
Section 11.0 Personnel Training and Spill Prevention Procedures
Section 12.0 Revision
Section 13.0 Mill Manager Approval
Section 14.0 Certification by Registered Professional Engineer
Section 15.0 Summary
Tables:
Table 1.0 is the Energy Fuels Resources (USA) Inc. (EFRI) personnel responsible for
implementing this SPCC.
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 reagent yard/small quantity 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.
1
Figures:
Figure 1 shows the Mill Site Layout, shows 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.
Figure 3 shows the organization chart for Mill Operations.
2.0 RESPONSIBILITIES
Personnel responsible for spill prevention and follow-up spill reporting are included on Table
1 which is included in the Tables Tab of this SPCC.
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 management system.
The management system, in turn, is 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.
Precipitation and unexpected spills from the mill site are contained within their prospective
drainage basins. Overflow ultimately drains into the tailings management system.
4.1 Basin A1
Basin A1 is north of Cell 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 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.
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. 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 PMP.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4A.
4.9 Basin F
Basin F contains Cell 4B, and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4B.
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 quantity for an ammonia spill
is 7 gallons.
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.
3
5.3 Ammonium Meta-Vanadate
Ammonium meta-vanadate is present in the vanadium precipitation area of the Mill 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 vanadium precipitation area. The
reportable spill quantity for ammonium 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 comer 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
comer 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 outside the
northeast corner of the SX building. Spills from the soda ash solution tank are contained in
the North SX impound and ran to Cell 1. 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. There is no reportable spill quantity associated with
sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of three fiberglass tanks located within a dike east of the SX
building. Tank maximum volumes of the three tanks are 16,075, 21,057 and 28,788 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 one smaller tank with a capacity of 11,000 gallons.
The large tank is located in the northwest corner of mill area basin B3 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. The tank is equipped 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.
The smaller storage tank is located on the north side of the SX building. The tank is
equipped with a high level audible alarm.
4
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. 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 Used/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.
Used oil will be disposed of on site. Any oil escaping the concrete containment system will
be cleaned up. Soil contaminated with used oil will be excavated and disposed of in the Cell
currently used for the disposal of solid Mill wastes.
6.0 POTENTIAL PETROLEUM 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 elevated stand. Spillage from either
tank would ultimately flow into Cell 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.
5
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 Cell currently used for the disposal of solid Mill wastes.
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 the Cell
currently used for the disposal of solid Mill wastes.
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 EH&S Manager 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
6
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 1 -800-424-8802
2. US Nuclear Regulatory Commission 301-816-5100
3. State of Utah 801-538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301-816-5100
2. State of Utah, Natural Resources 801-538-7200
8.2 Internal 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
7
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 Quality
Assurance Manager, 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.
The Mill or Maintenance Superintendent will report to the Mill Manager. The EH&S
Manager and the Quality Assurance Manager will be contacted by the Mill Manager.
Name
Mill Personnel:
Logan Shumway
David Turk
Garrin Palmer
Thayne Holt
Wade Hancock
Lakewood Personnel:
Stephen P. Antony
Harold R. Roberts
Scott Bakken
Kathy Weinel
Title
Mill Manager
EH&S Manager
Mill Environmental Compliance
Coordinator
Production Superintendent
Maintenance Superintendent
President and Chief Executive
Officer
Executive Vice President
Conventional Operations
Sr. Director, Regulatory Affairs
Quality Assurance Manager
Home 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.
8
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the Environmental
Department for inspection and review for a minimum of five 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
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.
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.
9
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 REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
hite Mesa Mill
Logan Shumway
Mill Manager
:ordance with good
10
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. Each spill
will be assessed and reported as required by the applicable regulations. Reportable
quantities are shown in the attached tables.
11
TABLES
TABLE 1.0
__________________RESPONSIBILITIES________________
Person in charge of facility responsible for spill prevention:
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
David Turk
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)___________________________________
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT CAPACITY (GAL)
AMMONIUM SULFATE 24,366
DIESEL 250
KEROSENE 10,152
USED/WASTE OIL 5,000
DIESEL 6,000
UNLEADED 3,000
PROPANE 30,000
LNG 30,000
AMMONIA 31,409
SODIUM HYDROXIDE 19,904
SODA ASH SOLUTION 16,921
SODA ASH SHIFT 8,530
SODIUM CHLORATE 16,075
SODIUM CHLORATE 21,057
SODIUM CHLORATE 28,788
SULFURIC ACID 1,600,000
SULFURIC ACID 11,000
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
Chemical in Lab RQ2 Quantity In Stock
Aluminum nitrate 2,270 kg 1.8 kg
Ammonium carbonate 2,270 kg 11-3 kg
Ammonium bifluoride 45.4 kg 2.27 kg
Ammonium chloride 2,270 kg 2,27 kg
Ammonium oxalate 2,270 kg 6.8 kg
Ammonium thiocyanate 2,270 kg 7.8 kg
Antimony potassium tartrate 45.4 kg 0.454 kg
n-Butyl acetate 2,270 kg 4 L
Calcium acetate 4.54 kg 0.454 kg
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.810 kg
Ferric nitrate 454 kg 0.454 kg
Ferrous ammonium sulfate 454 kg 0.57 kg
Ferrous sulfate 454 kg 0.454 kg
Lead nitrate 4.54 kg 2.7 kg
Potassium chromate 4.54 kg 0.114 kg
Sodium hydrosulfide 2,270 kg 1.0 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2,270 kg 1.4 kg
Zinc acetate 454 kg 0.91 kg
Chemical in Volatiles and
Flammables Lockers (A,B,C)RQ2 Quantity In Stock
Chloroform 4.54 kg 1L
Formaldehyde 45.4 kg <1L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ2 Quantity In Stock
Hydrochloric acid 2,270 kg 58 gal
Nitric acid 454 kg 5 L
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.”
TABLE 4.0
REAGENT YARD/SMALL QUANTITIY CHEMICALS LIST 1
CHEMICAL RQ2
QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1000 lbs 4 gal
Ammonium Hydroxide 1000 lbs 5L
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kg (1 libs)
Hydrochloric Acid 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanganate 0.1 N 32 gal 5 kg (11 lbs)
Silver Nitrate 1 lb 2.6 kg
Trichloroethylene 1001b 2 L
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 in 40 CFR Part 117 Table 117.3: “Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water
Act.”
TABLE 5.0
REAGENT YARD AND BULK CHEMICALS LIST1
REAGENT RQ QUANTITY ON SITE
Sulfuric Acid 1,000 lbs 2,719,680 lbs
Floe #301 None 0 lbs
Hyperfloc 102 None 1,500 lbs
Ammonia - East Tank 100 lbs 113,600 lbs
Ammonia - West Tank 100 lbs 93,720 lbs
Kerosene 100 gal approx. 5,100 gal
Salt (Bags)None 19,600 lbs
Ammonium Hydrogendifluoride None 20,450 lbs
Soda Ash Dense (Bag)None 2,000 lbs
Phosphoric Acid 5,000 lbs 6,300 lbs
Hydrogen Peroxide None 3,600 gal
Polyox None 560 lbs
Millsperse None 1,410 lbs
Nalco TX760 None 9 barrels
Nalco 7200 None 1,590 lbs
Tributyl phosphate None 9,450 lbs
Distillates None 110 gal
Diesel 100 gal approx. 6,000 gal
Gasoline 100 gal approx. 3,000
Alamine 336 drums None 0 lbs
Floe 109 None 7,750 lbs
Floe 208 None 1,500 lbs
Floe 904 None 1,500 lbs
Hyperfloc 624 None 4,230 lbs
Salt (Bulk solids)None Total of 70,000 lbs
Salt (Bulk solutions)None on site in all forms
Caustic Soda 1,000 lbs 24,000 lbs in
40% solution
Ammonium Sulfate None 21,300 lbs
Sodium Chlorate None 66,000 gal
Alamine 335 Bulk None 310 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide 1,000 lbs 500,000 lbs
Yellowcake None < 10,000 lbs
1. This list identifies the bulk chemicals and the 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.
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1 2
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1,540 gallons
Transmission Oils 100 gal 0 gallons
Dielectric fluids 5 gallons
Antifreeze None 55 gallons
Greases 1,787 lbs
Water Soluble Oils 100 gal 30 gallons
Xylene (mixed isomers)100 lbs 0 gallons
Lacquer thinner 0 gallons
Acetone None 55 gallons
Methyl Ethyl Ketone None 55 gallons
Toluene 1000 lbs 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates)100 gal 0 gallons
Resin None 10 gallons
Epoxy Paints None 55 gallons
Epoxy Catalyst None 30 gallons
Oil Base paints None 15 gallons
Paint thinners None 0 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
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.”
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Energy Fuels Resources (US/
225 Union Blvd. Suite 60C
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SHOP WHITE MESA MILLREVISIONS
County: gan Juan State: UtahDateBy
Location\WVA 10-11 GM
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v\
» M /0. ' i- *
%§kte,< o
z <Xw *»A *
\
*. *—,t-.j S3
* 'f 4>Q K.
■T0 “ fo*•*
X /<>f\ *._/
V ■»’.XXm “T\i
0 U
ST Y U <p*2r io
X ,'r
1r )
-if XU o*A'60-3-r £ sjn^AsC3M0\TSwWlW«n\^>oiwnVft
Figure 3
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Organizational Structure
President & CEO
Executive VP Conventional Operations
Sr. Director Regulatory Affairs
Mill Manager Manager, Environmental Health and Safety
and RSO Quality Assurance Manager
Mill Operations
Personnel Radiation Technicians Environmental Technicians Safety Supervisor
REDLINE
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.0. Box 809
Blanding, Utah
May 2, 2016
Prepared by:
Energy Fuels Resources (USA) Inc.
105047th Street, Suite 950
Denver. CO 80265225 Union Blvd., Suite 600
Lakewood. CO 80228
Best Management Practices Plan
TABLE OF CONTENTS
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.....................................................................................................................1847
Figure_2: White Mesa Mill Site Drainage Basins.....................................................................................................1948
Figure 3: Energy Fuels Resources (USA) Inc.- White Mesa Mill Management Organization Chart.....................2128
Figure 4: Energy Fuels Resources (USA) Inc.—Corporate Management Organizational-Chart...........................2322
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP.....................1148
TABLE 2.0: REAGENT YARD LIST......................................................................................................................1244
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST 1.......................................................................13H
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1.....................................................1448
TABLE 5.0: REAGENT YARD/BULK CHEMICALS LIST 1.............................................................................1544
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST 1...................................................................1648
Page 1
Best Management Practices Plan
Revision 1.5: September 2Q120ctober 2()15Mav 2016
1.0 INTRODUCTION/PURPOSE
Energy Fuels Resources (USA) Inc. ("EFRI") 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 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 EFRI on March 8,
2005. As a part of compliance with the Permit, EFRI is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Executive- Seeretar-vDirector of the Division of
Waste Management and Radiation Control (“DWMRC”). 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
Best Management Practices Plan
Revision 1.5: September 2012Oetober 2015Mav 2016
2.0 SCOPE
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 mnoff, 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 cellstailings management impoundments in accordance
with the Mill's NRC licenseRadioactive Materials License (“RML”) #UT1900479 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 RML NRG-lieense-to manage some spills via draining
or wash down to the process sewers, and ultimately the tailings management 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
EFRI 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
Best Management Practices Plan
Revision 1.5: September2Q ISOctoher 2015Mav 2016
3.0 RESPONSIBILITY
All Mill personnel are responsible for implementation of the practices in this BMPP. EFRI White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The EFRI Corporate Management and Mill Management Organization is presented in Figure 3.
The EFR Corporate Management Organization is presented-in Figure A.
An updated spill prevention and control notification list is provided in Table 1.
Page 4
Best Management Practices Plan
Revision 1.5: September 2012Qctober 2015Mav 2016
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 #UT1900479the RML. 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 areamanagement system for disposal.
Page 5
Best Management Practices Plan
Revision 1.5: September 2012Qctober 2015Mav 2016
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. •* ( Formatted: Indent: Left: 0"
• (Groundwater Discharge Permit No. UGW370004, Section I.D.lO.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.)
4.2 Management Practices for Process and Laboratory Areas
Page 6
Best Management Practices Plan
Revision 1.5: September-2&l-3Qetober SOl-SMav 2016
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 windbome 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 management system.
• Paint out bmshes 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 areamanagement system.
4.3 Management Practices for Maintenance Activities
Page 7
Best Management Practices Plan
Revision 1.5: September 20120ctober 20 PS-Mav 2016
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 stationdecontamination pads).
• At the truck wash-station decontamination pads, 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.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Page 8
Best-Management Practices Plan
Revision 1 .^-September 2012Qctober 2944
Page 9
TABLES
Page 10
TABDRl
White- Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill-Staff
Personnel ¥itle Work Phene Home Phene/
Other Contact Number
Dan HillstenLogan
V nn mil m\ i jJlTUTliW uy
Thayne Holt
Mill Manager
Maintenance
Superintendent
Mi-H-Superintendent
135 678 11051119
135 678 1166
435-678 4130
Cell:-135 97459
30119878
43-5-678-2753
Gellr-4-35 -979 04-10
435 459 1783
David E. Turk Manager, Environment, 435-6-78-41-13
Health and Safety
Garrin-Palmer Mill Environmental 135 678 1115
Compliance
Coordinator
435 678 7802
Gell:-435 459-9786
Cell:-435 459 9463
Personnel
Corporate-Management Staff
Title Work Phene
Harold R. Roberts
David C. Frydenlund
President and Chief 30-3 974- 2142
Operating Officer
Executive Vice 303 389 1160
President Conventional
Operations
Sr. Vice President 303 389 1130
Regulatory-Affairs-and
General Counsel
Home Phone /
Other Contact
1\IiiiviKn»«nuinucr
Cell: 303 378 8254
Cell: 303 902 2870
303 221 0098
Cell: 303 808 6648
Jo Ann TischlerKathv Weinel-----------------Director. ComplianceOualitv Assurane-e-Manager--------303
389 11321134------------Cell: 303 501489 92269182
Page 11
TABLE 2
REAGENT YARD LIST
QUANTITY (LBS)
STORAGE
TANKS
(GALLONS)
AMMONIUM
SULFATE(BUL-K)
SULFATE(BAGS)
ANHYDROUS AMMONIA
TRIDEOYLALGOHQL
DIESEL FUEL
GRINDING BALLS
KEROSENE
POLOX
PROPANE
SALT (BAGS)
SALT (BULK)
SODA ASH (BAGS)
SODA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
5-1,000
26,000
107,920
4E430
72,000
■\ 3/|/]
1 n 9KfiIVjUUv/
09.280
0
39.280
84,100
101,128
0
4.801838.440840
2
4
+
2
UNLEADED GASOUNE
USED OIL
4
4
4
4
4
4
4
4
42
4
4
24,366
31,409
25Q
64)0©
10,315
10,095
25,589
13,763
18,864
16,921
8^30
46,-924
22,561
29,940
19,905
1.394405.439
3.000
5.000
Page 12
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST4
Chemical In Lab RQ Quantity in Stock
Aluminum-nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassiumdatrate
n-8utyl acetate
Cyclohexane 454
Ferrous ammonium suifate
Potassium chromate
Sodium nitrite
Sodium phosphate tribasic
Zinc acetate
2270 kg
45.4 kg
2270 kg
227-Q-kg
2270 kg
45.4 kg
2270 kg
kg 24
454 kg
454-k§
4.54 kg
45.4 kg
2270kg
/| j^g
4=8-kg
2.27 kg
2.27 kg
6=8-kg
7r8-k§
0=454
44=
L
6.81 kg
0 57
Q. ~] 1 /| fcg
2=54<g
4=4
Q=94-kg
Chemical, in Volatiles and
Flammables Lockers
4A.B.C)
RQ Quantity in Stock
Chloroform 4-54-kg 8-4=
Formaldehyde 45.4 kg <1L of 37% solution
Nitrobenzene 454 kg 42-4=
Toluene 454 kg 424=
Chemical in Acid Shed RQ Quantity in-Stock
Chloroform 4.54 kg 55 gal
Flydrochloric acid 2,270 kg 58 gal
Nitrate acid 454 kg 54=
Phosphoric Acid 2,270 kg 404=
Sulfuric acid 454 kg 254=
Hydrofluoric-acid 45:4 kg 4-4=
Ammonium hydroxide 454 kg 484=
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.
2r.—Reportable Quantities are those identified in 40 CFR Part t17-Table~417:3f
''Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act."
Page 13
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 4
CHEMICAL« lunimnc-----------------------------------------RQ'
STORAGE
Acetic Acid, Glacial 4,000 lbs A1 HaiAmmonium Hydroxide 1,000 lbs
Calcium Hypochlorite 404bs kg (4.4 lbs)
Chlorine 464bs 0 |[-)g
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kg (11 lbs)
Hydrochloric 5=000 lbs 60 gal oMO%-solutioft
Nitric Acid 1 non ihrt jWUU I uo 404=
Potassium Permanganate 0.1 -N 32-dal 5 kg (11 lbs)
Sodium-Hypoohlerite-5.5%1 on lh^2 kg (11 lbs) of 6.5%
solution
Silver Nitrato 44b Q | fog
Trichloroethylene 4004b 24=
1. This list identifies chemicals whicb 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-GFR Part 147-Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act:"
Page 14
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST*
REAGENT
Sulfuric Acid
RQi
1,000 lbs
QUANTITY IN REAGENT
YARD
IMDOQ.OOO-tbs
Hyperfloe 102
Ammonia - East Tank
Ammonia—Westfank
Kerosene
Salt (Bags)
None
400-lbs
100 lbs
mo mli uu uaiNone
1,500 lbs
Q [fog
105,000 lbs
500 n.nl
Soda Ash Dense (Bag)None 50,000 lbs
Polyox None 490 lbs
Tributyl phosphate MnnpI 1WI I w
Diesel
Gasoline
Alamine 336 drums
100 gal
100 gal
MonorwTTv7
Approx. 3300 gal
Approx. 6000 gal
8,250 gal
Salt(Bulk Solids)
Saft(Bulk Solutions)
Caustic Soda
Ammonium Sulfate
Sodium Chlorate
MnnpI IWI I Ks
MnnprtunU
1,000 lbs
Mnnp
None
9-QOQ-gal
16.000 lbs
460r000lbs
350.000 lbs
Isodecanol
Vanadium-Pentoxide3
Yellowcake3
Ammonia Meta Vanadate
Boo-655
Floe 712
MnnpFrUTTUNone
1000 lbs
MnnprtxTnu-1000 lbs
Q Hjg
30.000 lbs
<-100,000 lbs
0 ||jo
21.000 lbs
1,250 lbs
-T—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-Porsuant to-Section 311 of the Clean
Water Act."
&—Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard-itself; but-are present in-otosed-containers in the Mill Building and/or Mill Yard
Page 15
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST4
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums
Transmission Oils
Water-Soluble-Oils
Xylene (mixed isomers)
Tnil ipnp
Varsol Solvent
(3%—trimethyl—benzene—in—petroleum
distillates)
100 gal
100 gal
100-gal
100 gal
1000-gal
100 gal
1,510 gallons
110 gallons
110 gallons
0 gallons
0 gallons
0 gallons
T—This list includes all solvents-and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
S-.—Reportable Quantities are those identified in 10 CFR Part 4-4-7 Table
117.3: "Reportable Quantities of-Hazardous Substances Designated
Pursuant-to-Seetion 311 of the Clean Water-Act."
Page 16
FIGURES
Page 17
Figure 1
White Mesa Mill
Mill Site Layout
Figure 2
Mill Site Drainage Basins
Page-17
Figure 3
White Mesa Mill
Mill-Management Organization Chart
Figuf-e-3
Energy Fuels -Resoarees (USA) Inc.
White Mesn Mill Management
Organizational Structure
President & CEO
Executive VP and Chief
Operating Officer
Sr. VP Regulatory
Affairs & General
Counsel
Director, Compliance
Mill Manager
Manager,
Environment, Health,
and Safety
Mill
Safety
Mill
Environmental
Compliance
Coordinator
Mill
Environmental
Monitoring
Coordinator
Mi
Radiation Safety
Officer
Safety TechnicianRadiation
Technician
Mill Operations
Personnel
Page 17
Pa
g
e 17
Figure 4
White Mesa Mill
Energy Fuels Resources (USA) Inc-
Organizational Structure
Figure 4
Energy Fuels Resources (USA) Inc.
Organizational Structure
President & CEO
Executive VP and Chief
Operating Officer
Sr. VP Regulatory
Affairs & General
Counsel
Mill Manager Manager,
Environment, Health, and
Safety
Director, Compliance
Page 17
Page 17
Page 17
Page 17
—
CLEAN
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.0. Box 809
Blanding, Utah
May 2, 2016
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
Best Management Practices Plan
Revision 1.5: May 2016
TABLE OF CONTENTS
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 Windborne Contamination.............................8
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources...................8
Figures
Figure 1: White Mesa Mill Site Layout
Figure 2: White Mesa Mill Site Drainage Basins
Figure 3: Energy Fuels Resources (USA) Inc.- White Mesa Mill Management Organization Chart
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP
TABLE 2.0: REAGENT YARD LIST
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST
TABLE 5.0: REAGENT YARD/BULK CHEMICALS LIST
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Page 1
Best Management Practices Plan
Revision 1.5: May 2016
1.0 INTRODUCTION/PURPOSE
Energy Fuels Resources (USA) Inc. ("EFRI") 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 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 EFRI on March 8,
2005. As a part of compliance with the Permit, EFRI is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Director of the Division of Waste Management and
Radiation Control (“DWMRC”), 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
Best Management Practices Plan
Revision 1.5: May 2016
2.0 SCOPE
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 management impoundments in accordance with the
Mill's Radioactive Materials License (“RML”) #UT1900479 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 RML to manage some spills via draining or wash down
to the process sewers, and ultimately the tailings management 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
EFRI 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
Best Management Practices Plan
Revision 1.5: May 2016
3.0 RESPONSIBILITY
All Mill personnel are responsible for implementation of the practices in this BMPP. EFRI White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The EFRI Corporate Management and Mill Management Organization is presented in Figure 3.
An updated spill prevention and control notification list is provided in Table 1.
Page 4
Best Management Practices Plan
Revision 1.5: May 2016
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
the RML. 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 management system for disposal.
Page 5
Best Management Practices Plan
Revision 1.5: May 2016
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.10.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.)
4.2 Management Practices for Process and Laboratory Areas
Page 6
Best Management Practices Plan
Revision 1.5: May 2016
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 windbome 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 bmshes and containers only at sinks and stations that drain to the process sewer to the
tailings management 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 management system.
4.3 Management Practices for Maintenance Activities
Page 7
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 decontamination pads).
• At the decontamination pads, 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.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Page 8
TABLES
TABLE 1.0
RESPONSIBILITIES
Person in charge of facility responsible for spill prevention:
Logan Shumway _______________
6425 South Highway 191
B landing, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
David Turk
6425 South Highway 191
Blanding,UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT
AMMONIUM SULFATE
DIESEL
KEROSENE
USED/WASTE OIL
DIESEL
UNLEADED
PROPANE
LNG
AMMONIA
SODIUM HYDROXIDE
SODA ASH SOLUTION
SODA ASH SHIFT
SODIUM CHLORATE
SODIUM CHLORATE
SODIUM CHLORATE
SULFURIC ACID
SULFURIC ACID
CAPACITY (GAL)
24,366
250
10,152
5,000
6,000
3,000
30,000
30,000
31,409
19,904
16,921
8,530
16,075
21,057
28,788
1,600,000
11,000
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
Chemical in Lab RQ2 Quantity In Stock
Aluminum nitrate 2,270 kg 1.8 kg
Ammonium carbonate 2,270 kg 11-3 kg
Ammonium bifluoride 45.4 kg 2,27 kg
Ammonium chloride 2,270 kg 2.21 kg
Ammonium oxalate 2,270 kg 6-8 kg
Ammonium thiocyanate 2,270 kg 7.8 kg
Antimony potassium tartrate 45.4 kg 0.454 kg
n-Butyl acetate 2,270 kg 4 L
Calcium acetate 4.54 kg 0.454 kg
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.810 kg
Ferric nitrate 454 kg 0.454 kg
Ferrous ammonium sulfate 454 kg 0.57 kg
Ferrous sulfate 454 kg 0.454 kg
Lead nitrate 4.54 kg 2.7 kg
Potassium chromate 4.54 kg 0.114 kg
Sodium hydrosulfide 2,270 kg 1.0 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2,270 kg 1.4 kg
Zinc acetate 454 kg 0.91 kg
Chemical in Volatiles and
Flammables Lockers (A,B,C)RQ2 Quantity In Stock
Chloroform 4,54 kg 1L
Formaldehyde 45.4 kg <1L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ2 Quantity In Stock
Hydrochloric acid 2,270 kg 58 gal
Nitric acid 454 kg 5 L
Phosphoric acid 2,270 kg 10 L
Sulfuric acid 454 kg 25 L
Hydrofluoric Acid 45.4 kg 1L
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.”
TABLE 4.0
REAGENT YARD/SMALL QUANTITIY CHEMICALS LIST 1
CHEMICAL RQ2
QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1000 lbs 4 gal
Ammonium Hydroxide 1000 lbs 5L
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kg (1 libs)
Hydrochloric Acid 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanganate 0.1 N 32 gal 5 kg (11 lbs)
Silver Nitrate 1 lb 2.6 kg
T richloroethy lene 100 lb 2 L
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 in 40 CFR Part 117 Table 117.3: “Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water
Act.”
TABLE 5.0
REAGENT YARD AND BULK CHEMICALS LIST1
REAGENT
Sulfuric Acid
Floe #301
Hyperfloe 102
Ammonia - East Tank
Ammonia - West Tank
Kerosene
Salt (Bags)
Ammonium Hydrogendifluoride
Soda Ash Dense (Bag)
Phosphoric Acid
Hydrogen Peroxide
Polyox
Millsperse
Nalco TX760
Nalco 7200
Tributyl phosphate
Distillates
Diesel
Gasoline
Alamine 336 drums
Floe 109
Floe 208
Floe 904
Hyperfloe 624
Salt (Bulk solids)
Salt (Bulk solutions)
Caustic Soda
Ammonium Sulfate
Sodium Chlorate
Alamine 335 Bulk
Alamine 310 Bulk
Isodecanol
Vanadium Pentoxide
Yellowcake
RQ
1,000 lbs
None
None
100 lbs
100 lbs
100 gal
None
None
None
5,000 lbs
None
None
None
None
None
None
None
100 gal
100 gal
None
None
None
None
None
None
None
1,000 lbs
None
None
None
None
None
1,000 lbs
None
QUANTITY ON SITE
2,719,680 lbs
0 lbs
1,500 lbs
113,600 lbs
93,720 lbs
approx. 5,100 gal
19,600 lbs
20,450 lbs
2,000 lbs
6,300 lbs
3,600 gal
560 lbs
1,410 lbs
9 barrels
1,590 lbs
9,450 lbs
110 gal
approx. 6,000 gal
approx. 3,000
0 lbs
7,750 lbs
1,500 lbs
1,500 lbs
4,230 lbs
Total of 70,000 lbs
on site in all forms
24,000 lbs in
40% solution
21,300 lbs
66,000 gal
310 lbs
0 lbs
0 lbs
500,000 lbs
< 10,000 lbs
1. This list identifies the bulk chemicals and the 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.
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 0 gallons
Dielectric fluids 5 gallons
Antifreeze None 55 gallons
Greases 1,787 lbs
Water Soluble Oils 100 gal 30 gallons
Xylene (mixed isomers)100 lbs 0 gallons
Lacquer thinner 0 gallons
Acetone None 55 gallons
Methyl Ethyl Ketone None 55 gallons
Toluene 1000 lbs 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates)100 gal 0 gallons
Resin None 10 gallons
Epoxy Paints None 55 gallons
Epoxy Catalyst None 30 gallons
Oil Base paints None 15 gallons
Paint thinners None 0 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
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.”
FIGURES
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SCALE IN FEET
Energy Fuels
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO 80228
REVISIONS
Date
10-11
5-14
4-16
By
WHITE MESA MILL
County: San Juan State:Utah
Location:
Figure 1
MILL SITE LAYOUT
Scale: y=200' | Date: May 12,2000 [ Drafted By: p.siedd
Mill Site Layout 4.28.16.dwg Figure 11
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Figure 3
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Organizational Structure
President & CEO
Executive VP Conventional Operations
Sr. Director Regulatory Affairs
Mill Manager Manager, Environmental Health and Safety
and RSO
u
Quality Assurance Manager
Mill Operations
Personnel Radiation Technicians Environmental Technicians Safety Supervisor