DRC-2018-013399 - 0901a0688097555b

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
December 18, 2018
Sent VIA OVERNIGHT DELIVERY
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4880
Div of Waste Management
and Radiation Control
DEC 21 2018 7F-eZ0/6?-01 ,3399
Re: Transmittal of the Energy Fuels Resources (USA) Inc. ("EFRI") to Response to
Notice of Enforcement Discretion ("NOED"), Radioactive Materials License
("RML") UT 1900479, White Mesa Uranium Mill
Dear Mr. Anderson:
This letter serves as the by Energy Fuels Resources (USA) Inc. ("EFRI") response to the
Division of Waste Management and Radiation Control ('DWMRC") NOED letter dated
December 5, 2018 which EFRI received on December 12, 2018. As noted in the DWMRC letter,
the Radioactive Materials License ("RML") No. UT 1900479 Section 10.5.F, states:
The Licensee shall notify the Director in writing at least seven calendar days prior to the
proposed scheduled date for disposal of any byproduct material generated at ISL facilities
in the tailings cells.
An annual summary of the amounts of waste disposed of from off-site ISL generators
shall be sent to the Director on or before November 1 of each calendar year.
It is important to note that EFRI has submitted all seven calendar day notices as required with no
issues noted by DWMRC in the NOED. DWMRC noted that EFRI has submitted the required
annual summary report of waste disposed of from off-site ISL generators as required, however,
EFRI submissions were not received by the November 1 deadline. EFRI erroneously interpreted
the requirement as the annual report is due to DWMRC by November 1 of the following year for
the previous calendar year. EFRI' s annual reports were based on a calendar year and thus
submitted the reports after the end of the reported calendar year.
EFRI will comply with the request in the NOED that the 2018 report be addressed by January 1,
2019 by submitting the 2018 annual report under separate cover on or before December 31,
2018. EFRI respectfully requests that the RML be modified such that the due date for future
reports be changed to February 1 of each year and the reporting period be adjusted to a calendar
year basis. Future reports will be submitted by the due date of November 1 each year until
directed otherwise through an RML modification or a formal denial of this change request.
If you should have any questions regarding this submission please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David Frydenlund
Paul Goranson
Logan Shumway
Scott Bakken
Teny Slade
Garrin Palmer
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