DRC-2021-024001 - 0901a068810471dc

Department of
Environmental Quality
L Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L Howard
Director
DP\ C- 202 - 0240 I
y.;\
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
MEMORANDUM
TO: Project File C-2021-48
THROUGH: Phil Goble, Uranium Mill Section Manager 122. 6 V/
FROM: Russell J. Topham, PE 1/
DATE: November 22, 2021
SUBJECT: Inspection of Secondary Containment for Hydrochloric Acid Storage Tanks
Ground Water Discharge Permit (GWDP) UGW370004
On October 15, 2021, the Division extended conditional approval to construct secondary containment
for hydrochloric acid tanks that Energy Fuels intends to construct on the former Roberts Pond site. The
hydrochloric acid would not be part of the licensed uranium milling operation but would support a
broadening of the mill's mission to include extraction of rare earth minerals. Therefore, Energy Fuels'
radioactive materials license is not impacted by this construction. However, protection of ground water
is necessary. Therefore, the plans for the construction underwent plan approval. The conditions upon
which the approval was extended are contained in the letter dated October 15, 2021, from the Division
to Energy Fuels (file number DRC-2021-015342).
The waste stream from the rare earth mineral extraction process would become feed for uranium
extraction, qualifying the tailings for disposal as 11e.(2) byproduct material in the mill's tailings
disposal system.
The conditional approval called for the Division to have opportunity to inspect the construction from the
Division to Energy Fuels. The Division availed itself of that opportunity on Nov ember 9, 2021. At the
time, the pedestals for the hydrochloric acid tanks had been poured, and the construction crew had
commenced excavating footing trenches for the containment structure.
The construction techniques employed by the construction crew were appropriate. Day-to-day quality
control oversight was done by the facility engineer, Steve Snyder. During inspection, I saw nothing to
which to object.
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.0 Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T D D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
HC1 Tank Secondary Containment Construction Inspection
November 9, 2021
Page 2
Conclusions and Recommendations
The Licensee appears fully compliant with the plans as approved and with good construction practice.
The inspection should be closed out.
Photo 1. Looking south-southwest across tank foundation pedestals. Photo taken November 9, 2021