DRC-2022-000639 - 0901a06880ff8db9

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com P KC - 2.022 - GOO G39
January 10, 2022
Sent VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Div of Waste Management and Radiation Control
JAN 1 3 2022
Re: Transmittal of Revised Spill Prevention, Control and Countermeasures Plan ("SPCC"), Revised
Stormwater Best Management Practices Plan ("SWBMPP") and Revised Discharge Minimization
Technology ("DMT") Plan for White Mesa Uranium Mill
Dear Mr. Hansen:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI' s") proposed revisions to the White Mesa
Mill SPCC, SWBMPP and DMT. These revisions include changes made to:
1. Address the addition of HC1 tanks at the Mill pursuant to the DWMRC letter dated October 15, 2021.
2. Update personnel, contact, and storage information.
3. Correct typographical errors.
For ease of review we have provided both redline/strikeout (text and tables only) and clean versions (text,
tables, and figures) of each document.
If you should have any questions regarding these plans please contact me.
Yours very truly,
6tdif
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David Frydenlund
Logan Shumway Garrin Palmer
Scott Bakken
Steve Snyder
REDLINE
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
May 3, 2021January 10, 2022
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
ENERGY FUELS
Contents
1.0 OBJECTIVE 11-
1.1 Plan Organization 11-
2.0 RESPONSIBILITIES 2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS 2
4.0 DESCRIPTION OF BASINS 2
4.1 Basin Al 2
4.2 Basin A2 2
4.3 Basin B1 2
4.4 Basin B2 33
4.5 Basin B3 33
4.6 Basin C 33
4.7 Basin D 33
4.8 Basin E 33
4.9 Basin F 33
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT 33
5.1 Reagent Tanks (Tank list included in Table 2.0) 44
5.2 Ammonia 44
5.3 Ammonium Meta-Vanadate 44
5.4 Caustic Storage (Sodium Hydroxide) 44
5.5 Sodium Carbonate (Soda Ash) 44
5.6 Sodium Chlorate 44
5.7 Sulfuric Acid 55
5.8 Vanadium Pentoxide 55
5.9 Kerosene (Organic) 55
5.10 Hydrochloric Acid Tanks 55
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT 66
6.1 Petroleum Tanks 66

6.1.1 Diesel 66
6.2 Aboveground Fuel Pump Tanks 66

6.2.1 Diesel 66

6.2.2 Unleaded Gasoline 66

6.2.3 Pump Station 66
6.3 Used/Waste Oil 77
6. 4 Truck Unloading 77
7.0 SPILL DISCOVERY AND REMEDIAL ACTION 77
8.0 SPILL INCIDENT NOTIFICATION 99
8.1 External Notification 99
8.2 Internal Notification 99
9.0 RECORDS AND REPORTS 101-0
10.0 SPILL REPORTING REQUIREMENTS 1114
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES 1114
11.1 Training Records 1114
11.2 Monitoring Reports 11-14
12.0 REVISION 111-1-
13.0 MILL MANAGER APPROVAL 121-2
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER 1212
15.0 SUMMARY 1313
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 2.0 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4.0 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 typical quantities in stock, and their reportable
quantities.
Table 4.0 lists the reagent yard and bulk chemical list.
Table 5.0 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
3 and 4A, 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 tailings management system, in turn, is operated with sufficient freeboard (minimum
freeboard as required by the Groundwater Discharge Permit ["GWDP"]) to withstand 1 00%
of the Probable Maximum Precipitation ("PMP"). This allows for a maximum of 1 0 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.
4.0 DESCRIPTION OF BASINS
4.1 Basin Al
Basin Al 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 and a
portion of Cell 2. The basin covers 1 04.3 acres. Any overflow from this basin would be
contained within Cell 1 .
4.3 Basin B1
Basin B 1 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.
2
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 1 . The basin contains 64 acres. This basin has sufficient freeboard to
withstand 1 00% of the PMP. This allows 1 0 inches of rain for any given storm event.
4.6 Basin C
Basin C contains a portion of Cell 2. The basin consists of 60.4 acres. Areas in this basin
also include earth stockpiles and the heavy equipment shop. The direction of flow in this
basin is to the south-southwest. All overflows in this basin is channeled along the southern
edge of the basin. Overflow then flows into Cell 3 along the length of the boundary between
Cell 2 and 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
Routine monitoring is conducted of the reagent tanks and storage areas. Daily visual
monitoring of the reagent tanks and storage areas are conducted during the twice-daily shift
inspections. Weekly visual monitoring of the tank supports and foundations are conducted
by the Radiation Safety Officer ("RSO") or designee. The scope of the daily and weekly
visual monitoring includes an inspection for leaks or visual structural abnormalities. Any
issues identified during the routine visual monitoring would be noted as such on the
3
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
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.
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.
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 corner of the SX
building. The tank has a capacity of 19,904 gallons. The tank supports are mounted on a
concrete curbed catchment pad which directs spills into the sand filter sump in the northwest
corner of the SX building. The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located outside the
northeast corner 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. 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.
Integrity inspections will be conducted to minimize the hazard associated with sodium
chlorate.
4
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.
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.
5.140 Hydrochloric Acid Tanks
The hydrochloric acid storage tanks consist of two 13,650 gallon storage tanks with one 500
gallon scrubber tank. The tanks are located west of the Pre-Leach Thickener in the
northwestern portion of the mill area. All tThe tanks are installed in a concrete containment
designed to hold the all the contents of one storage tank plus the volume of a 25-year-yf 24-
hour storm event. The containment is placed where an overflow or failure of the containment
flows directly to Cell 1. The reportable spill quantity for hydrochloric acid is 5000 pounds.
5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
Routine inspections are conducted of the petroleum containment, tanks, and storage areas.
Daily visual monitoring of the petroleum containment, tanks, and storage areas are conducted
during the twice-daily shift inspections. Weekly visual monitoring of the tank supports and
foundations are conducted by the RSO. The scope of the daily and weekly visual monitoring
includes an inspection for leaks or visual structural abnormalities. Any issues identified
during the routine visual monitoring would be noted as such on the associated
documentation. If no issues are noted, the system, tanks or storage area condition was
considered acceptable.
Annual visual inspections of the used/waste oil and fuels tanks will be completed as
discussed in the Discharge Minimization and Technology Monitoring Plan, Revision 12.4,
Section 4.3.
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.
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
6
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.
6.3 Used/Waste Oil
Used/Waste oil 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 or sent to an EPA permitted recycling facility. 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. 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 RSO and the Environmental Coordinator.
• The Mill Manager will assess the spill and related damage and direct remedial
actions. The corrective actions may include repairs, clean-up, disposal, and
company notifications. Government notifications may be necessary in some
cases.
If a major spill continues uncontrolled, these alternatives will be considered:
7
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 RSO,
Quality Assurance Manager, the Vice President, Regulatory Affairs, and/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 RSO and the
Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
[phone]
459-94633545
Logan Shumway Mill Manager
Terry SladoGarrin Palmer RS 0 (435)
Environmental Garrin PalmerTanner Holliday Assistant-RSOIMill
Compliance [phone]/163
Coordinator
Thayne Holt Production Superintendent [phone]
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Mark Chalmers President and Chief Executive
Officer [phone]
Scott Bakken Vice President, Regulatory Affairs [phone]
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
The following reports and records are to be maintained in Central File by the Environmental
or Maintenance 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
d. Quarterly Tailings Inspection
e. Daily Operating Foreman and weekly RSO inspection reports

2. Annual used/waste oil and fuel tank visual inspections
10
3. Tank thickness tests
4. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
5. Tank supports and foundation inspections
6. Spill Incident reports
7. 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.
Logan S humw ay
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.
Steve R. Snyder
Utah Registered Professional Engineer
No. 5049193-2202
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.
13
TABLES
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT CAPACITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 WEST SALT 17,635
1 SALT DILUTION 9,451
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
1 SODA ASH SILO 22,841
1 SODIUM CHLORATE 16,075
1 SODIUM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
2 HYDROCHLORIC ACID 13,650
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST'
ica iw Lab 1 Tyit *tý Stoch
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 L or 571 gal.) 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20 kg
Ammonium carbonate 5,000 lb (2,270 kg) 2 kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4 L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5 L
Ferric chloride 1,000 lb (454 kg) 2 kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) 1 L
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate 0.1N 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6 kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 4) 1 4, r
Chemical in Valatilei and 1
Flianntables Lockers (A,B,C)
•-•', ", ,: ', 4 2 • s'' * ' ' ' • ;''' , ''.. 4 , i t . '. e•-.." '," '
Typical Onantity in Stock 1
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2 L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) 1 L
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) 1 L
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2 L
Toluene 1,000 lb (454 kg) (aurox. 523 L) 12 L ...11.7.-1411,-":::• , .
Mai • ; n Stock c.
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 L or 501 gal.) 22 L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20 L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 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."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE 4.0
REAGENT YARD AND BULK CHEMICALS LIST'
Reagent RQ2 Typical Quantity In
Stock
Sulfuric acid 93 to 98% 1,000 lb (454 kg) (approx. 247 L) 4,000,000 lb
Ammonia - East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia - West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 1,000,000 lb
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
Barium Chloride None 15,000 lb
Hydrochloric Acid 5,000 lbs (2,270 kg) (approx. 1,894
L or 501 gal.) 25,000 gal
Rare Earth Carbonates3 None 200.000 lb.
1. This list identifies the bulk chemicals at the Mill 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. The Mill's products are not stored in the Reagent Yard itself, but are present in containers in the
Mill Buildings and/or Mill Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah regulations.
These values are used by the Mill for conservatism as Best Management Practices.
TABLE 5.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
a 16 Reagent 1.3 T pical Quaitty To.Siiick.
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg)
(approx. 13.9 gal) 50 gallons
Acetone 5,000 lb (2,270 kg)
(approx. 759 gal) 55 gallons (362 lbs)
Methyl Ethyl Ketone 5, 270 kg)000 lb (2,
(approx. 745 gal) 55 gallons (369 lbs)
Toluene 1000 lbs (454 kg)
(approx. 138 gal) 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates) 100 gal* 0 gallons
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 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."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
May 3, 2021January 10, 2022
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
Best Management Practices Plan
Revision -1,72.0: May 2021January 2022
TABLE OF CONTENTS
1.0 INTRODUCTION/PURPOSE
2.0 SCOPE 33
3.0 RESPONSIBILITY 44
4.0 BEST MANAGEMENT PRACTICES 55
4.1 General Management Practices Applicable to All Areas 55
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: 55
4.1.2 Keep Potential Pollutants from Contact with Precipitation 55
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels
within the Process and Reagent Storage Area
4.1.5 Recycle Fluids Whenever Possible.
55
4.2 Management Practices for Process and Laboratory Areas 55
4.2.1 Clean Up Spills Properly
4.2.2 Protect Materials Stored Outdoors 66
4.2.3 Management 66
4.2.4 Materials Management 66
4.3 Management Practices for Maintenance Activities 66
4.3.1 Keep a Clean Dry Shop 66
4.3.2 Manage Vehicle Fluids 66
4.3.3 Use Controls During Paint Removal 77
4.3.4 Use Controls During Paint Application and Cleanup 77
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment 77
4.4.1 Wash Down Vehicles and Equipment in Proper Areas 77
4.4.2 Manage Stockpiles to Prevent Windborne Contamination 77
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources 88
Figures
Figure I: 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 AND BULK CHEMICALS LIST
TABLE 5.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Page 1
Best Management Practices Plan Revision -142.0: May 2021January 2022
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 ("GWDP") 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
("UDEQ"). 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 -1,72.0: May 2021January 2022
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") ttUT1900479 UT 1 900479 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 -1,72.0: May 2021ianuary 2022
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 442.0: May 2021January 2022
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 the GWDP, 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.
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
Page 5
Best Management Practices Plan
Revision 442.0: May 2021January 2022
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (GWDP, 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. (GWDP, Section I.D.3.g.)
•
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
Page 6
Best Management Practices Plan
Revision -142.0: May 2021January 2022
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings 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.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and 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.
Page 7
Best Management Practices Plan
Revision 442.0: May 2021January 2022
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
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 folio up spill reporting:
Garrin Palmer
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
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:
Garrin Palmer
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT CAPACITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 WEST SALT 17,635
1 SALT DILUTION 9,451
1 soDrum HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
1 SODA ASH SILO 22,841
1 SODIUM CHLORATE 16,075
1 SODIUM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
2 HYDROCHLORIC ACID 13,650
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST' .
mica!: in Lab , _ -.
,
,Ft , L' ' 44. :A:
.
,14 lit Stock
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 L or 571 gal.) ' 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20 kg
Ammonium carbonate 5,000 lb (2,270 kg) 2 kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4 L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5 L
Ferric chloride 1,000 lb (454 kg) 2 kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) 1 L
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate 0.1N 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6 kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (4544) 1 k&
. Chemical ln Volatiles an
ftunmables Lockers (A,LI,C)
, . .,. g•
,,, • .: , f )
'' 2 y
' s- % ,-

...,.. ,
Typical Qu tiiy in StoCk

f • t i _ '
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2 L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) 1 L
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) 1 L
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2 L
Toluene 1,000 lb (454 is ) (gprox. 523 L)
•
12 L
Chemical i - ci4 . • s R -. , ' T Qtantty $tock
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 L or 501 gal.) 22 L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20 L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 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."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE 4.0
REAGENT YARD AND BULK CHEMICALS LIST'
Reagent RQ2 Typical Quantity In
Stock
Sulfuric acid 93 to 98% 1,000 lb (454 kg) (approx. 247 L) 4,000,000 lb
Ammonia - East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia - West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 1,000,000 lb
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
Barium Chloride None 15,000 lb
Hydrochloric Acid 5,000 lbs (2,270 kg) (approx. 1,894
L or 501 gal.) 25,000 gal
Rare Earth Carbonates' None 200,000 lb.
1. This list identifies the bulk chemicals at the Mill 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. The Mill's products are not stored in the Reagent Yard itself, but are present in containers in the
Mill Buildings and/or Mill Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah regulations.
These values are used by the Mill for conservatism as Best Management Practices.
TABLE 5.0
PETROLEUM PRODUCTS AND SOLVENTS USTI
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg)
(approx. 13.9 gal) 50 gallons
Acetone 5,000 lb (2,270 kg)
(approx. 759 gal) 55 gallons (362 lbs)
Methyl Ethyl Ketone 5, 270 kg)000 lb (2,
(approx. 745 gal) 55 gallons (369 lbs)
Toluene 1000 lbs (454 kg)
(approx. 138 gal) 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates) 100 gal* 0 gallons
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 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."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 12.113.0
Devember-20-16January 2022
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill — Discharge Minimization Technology Monitoring Plan -1-24-1-601/22 Revision: EFRI I2A13.0
Page 2 of 27
WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. INTRODUCTION 3
1.1. Background 3
2. DAILY TAILINGS INSPECTIONS 4
2.1. Daily Inspection 4
3. WEEKLY TAILINGS AND DMT INSPECTION 5
3.1. Weekly Tailings Inspections 5
Northing 9
Easting 9
3.2. Weekly Feedstock Storage Area Inspections 1212
4. ANNUAL EVALUATIONS 12
4.1. Annual Leak Detection Fluid Samples 12
4.2. Annual Inspection of the Decontamination Pads 12
4.4 Annual Inspection of Waste Oil and Fuel Tanks 13
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA 1413
6. OTHER INSPECTIONS 14
7. REPORTING REQUIREMENTS 14
7.1. DMT Reports 14
ATTACHMENTS
Attachment A Forms
Attachment B Feedstock Storage Area Map
Attachment C Tables
1
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 4-2/4-601/22 Revision: EFRI 12A13.0
Page 3 of 27
1. INTRODUCTION
This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
White Mesa Mill' s (the "Mill' s") Groundwater Discharge Permit ("GWDP") Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT1900479 (the "RML") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the Mill' s Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of the feedstock storage areas at the Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill' s Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill' s
Environmental Protection Manual, under the Mill' s NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill' s Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill' s Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill's Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill' s Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
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This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1, 2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1, 2, 3, 4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer ("RSO") or his designee is responsible for performing these daily
tailings inspections. The RSO may designate other individuals with training, as described in Section
2.4 below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-1 to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2.1q).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
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elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge
PermitGWDP must be adhered to when the solution level trigger for Cell 4A or
4B has been exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell' s LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1, 2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-1 of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill' s environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
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For Cells 1, 2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C of the
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table 1 A and 1B (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 closed and Phase
1 cover activities have commenced. Each cell has a slimes drain system which aids
in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in 2011 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the 2011 re-
grading of the interim cover and the placement of an additional 62,000 cubic yards of
fill material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe was 6.97 feet in length and the measuring point was 37.97 feet from
the bottom of the slimes drain. This value was used in all calculations from 4th
quarter 2011 through the 3rd quarter 2016. In April 2016, Phase 1 cover placement
and construction commenced. The Pahse Phase 1 cover activities include the
placement and compaction of approximately 4.5 feet of soil materials. During the 3rd
quarter 2016, the slimes drain access pipe was extended 5.44 feet as a result of the
Phase 1 cover activities. The measuring point on the extension pipe was surveyed by
a Utah-Certified Land Surveyor. The measuring point elevation is now 5624.17 fmsl.
For the quarterly recovery test described in section vi below, this extension has no
effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
43.41 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. . This means that the bottom of the slimes drain pool
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and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 44.31 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5624.17 fmsl), and made to the nearest 0.01 foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5624.17 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11, 2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii)lf-ar-any-time-the-mest-feeeiit-average-armuftl-head-in-the-Ce11-2-sliines-dr-aifr-is-feund
to have increased above the average head for thc previous calendar year, the
Licensee will comply with the requirements of Part LG.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 21
heur-s-f-ellewed-byfit-ten-netifieatienIn accordance with GWDP Part I.F. 1 1 an
Annual Slimes Drain Recovery Head Report will be submitted with the annual DMT
report for fourth quarter. The Annual Slimes Drain Recovery Head Report will be
submitted on or before of March 1 of each year. The report will conform to Part
I.D.3, I.E.7 and ILG of the GWDP;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
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kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 4A, and 4B are to be taken by survey on a weekly
basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a
monthly basis when beaches are first observed, as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee (the
"Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.0 1 feet, such as a Sokkai No. B2 1, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.0 1 foot increments;
(iii)The Reference Points for Cells 1, Cell 4A, and 4B, are known points established by
professional survey. For Cell 1 , the Reference Point is a wooden stake with a metal
disk on it located on the southeast corner of Cell 1 . The elevation of the metal disk
(the "Reference Point Elevation") for Cell 1 is at 5,623. 14 feet above mean sea level
("FMSL"). For Cell 4A and 4B, the Reference Point is a piece of stamped metal
monument located next to the transformer on the south side of Cell 4A and 4B. The
elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A
and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a
location where both the applicable Reference Point and pond surface are visible.
(iv)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and
4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by
gently rocking the rod back and forth until the Surveyor has established a level
reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1 , Cell 4A, or Cell 4B, or
the area of the beach in Cell 4B with the highest elevation, as the case may be. These
designated locations, and the methods to be used by the Assistant to consistently use
the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
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For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
I. Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
II. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
IR Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are:
Northing Easting
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
B. Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
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elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.0 1 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.0 1 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed O. 10 foot above the concrete floor in
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any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6 2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amse, and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill's maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
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3.2. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Annual Leak Detection Fluid Samples
-Pursuant to Part I.E.10(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
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of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
4.3. Annual Inspection of Waste Oil and Fuel Tanks
During the second quarter of each year, the used/waste oil tank and fuel tanks will be inspected to
ensure the integrity of the tanks and support structures. The tanks and any associated piping will be
visually inspected for signs of corrosion or leaking. Any concrete structures, containments and
supports will be inspected to ensure the integrity of the exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the surface, repairs will be made within 7 days. All
inspection findings and any repairs required shall be documented on the Annual Inspection form.
The documentation of the inspection findings, any repairs required and repairs completed will be
maintained at the Mill.
4.4. /1.5 Annual Inspection of Hydrochloric Acid ("HC1") Secondary Containment Concrete
During the second quarter of each year, the HC1 secondary containment concrete will be inspected.
Any associated piping will be visually inspected for signs of corrosion or leaking. Any concrete
structures, containments and supports will be inspected to ensure the integrity of the exposed
concrete surface. If any abnormalities are identified, i.e. cracks in the concrete with greater than 1/8
inch separation (width) or any significant deterioration or darnage of the surface, repairs will be made
within 7 days. All inspection findings and any repairs required shall be documented on the Annual
Inspection form included as Attachment A-7. The documentation of the inspection findings, any
repairs required and repairs completed will be maintained at the Mill.
1
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5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1 /8 inch separation (width) or any significant deterioration or damage of the concrete
pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7. 1 . DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1 .F.2 of the GWDP
relating to the inspections described in Section 3. 1 (a) (Leak Detection Systems
Monitoring), Section 3. 1 (b) (Slimes Drain Water Level Monitoring), 3. 1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3. 1 (d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
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including any repairs required, and repairs completedp;
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
e) With respect to the annual inspection (after the completion of 8 quarterly
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
0 An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report.
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ATTACHMENT A
FORMS
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ATTACHMENT A-1
DAILY INSPECTION DATA
Inspector:
Date:
Accompanied by:
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked Checked
Wet Dry Wet Dry Wet Dry Wet Dry Wet Dry
Initial level Initial level Initial level Initial level Initial level
Final
level
Final
level
Final
level
Final
level
Final
level
Gal. pumped Gal. pumped Gal. pumped Gal. pumped Gal. pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-1)
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Page 18 of 27
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date: Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation
elevations (msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b))
(d)Elevation of Beach Area with Highest Elevation
(monthly)
2. Leak Detection Systems
Observation:
New Decon Pad, Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
wet dry wet dry wet dry
If wet, Record liquid
level:
Ft to Liquid Ft to Liquid Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
White Mesa Mill — Discharge Minimization Technology Monitoring Plan I-24601/22 Revision: EFRI 12.413.0
Page 19 of 27
ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no:
comments:
Are there any alternate feedstock materials stored outside the ore storage pad?
yes: no:
If yes, Aare all the alternate feedstock materials located outside the area indicated on the attached
diagramore storage pad maintained within water-tight containers:
yes: no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No:
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Page 20 of 27
Comments:
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Page 21 of 27
Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes: No:
Comments:
Is there any evidence of breakage, spillage or leakage?
Yes: No:
Comments:
Other comments:
Ore Pad Southwest Stormwater Containment (Kiva):
Is there sediment or debris in the bottom of the Kiva?
Yes: No:
Comments:
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes: No:
Comments:
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 4-24601/22 Revision: EFRI 12.413.0
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ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? Yes No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September
1 of each calendar year.
1 White Mesa Mill — Discharge Minimization Technology Monitoring Plan 12/1601/22 Revision: EFRI 12.413.0
Page 23 of 27
ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection:
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the asphalt surface? Yes No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
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ATTACHMENT A-6
ANNUAL USED/WASTE OIL AND FUEL TANK INSPECTION
Date of Inspection:
Are there any anomalies on tanks including dents or rusty areas?
_Yes No
Comments:
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:
Valves:
Point(s) of Discharge:
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
_Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
Yes No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):
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ATTACHMENT A-7
ANNUAL HCI SECONDARY CONTAINMENT CONCRETE INSPECTION
Date of Inspection:
Are there any anomalies on tanks?
Yes No
Comments:
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:
Valves:
Point(s) of Discharge:
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
Yes No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):
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Page 26 of 27
ATTACHMENT B
FEEDSTOCK STORAGE AREA

DATE:
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Page 27 of 27
ATTACHMENT C
TABLES
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table 1B
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
CLEAN
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
January 10, 2022
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
FENE RGY FUELS
Contents
1.0 OBJECTIVE 1
1.1 Plan Organization 1
2.0 RESPONSIBILITIES 2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS 2
4.0 DESCRIPTION OF BASINS 2
4.1 Basin A1 2
4.2 Basin A2 2
4.3 Basin B1 2
4.4 Basin B2 3
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) 4
5.2 Ammonia 4
5.3 Ammonium 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 5
5.8 Vanadium Pentoxide 5
5.9 Kerosene (Organic) 5
5.10 Hydrochloric Acid Tanks 5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT 6
6.1 Petroleum Tanks 6

6.1.1 Diesel 6
6.2 Aboveground Fuel Pump Tanks 6

6.2.1 Diesel 6

6.2.2 Unleaded Gasoline 6

6.2.3 Pump Station 6
6.3 Used/Waste Oil 7
6.4 Truck Unloading 7
7.0 SPILL DISCOVERY AND REMEDIAL ACTION 7
8.0 SPILL INCIDENT NOTIFICATION 8
8.1 External Notification 8
8.2 Internal Notification 8
9.0 RECORDS AND REPORTS 10
10.0 SPILL REPORTING REQUIREMENTS 10
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES 10
11.1 Training Records 10
11.2 Monitoring Reports 10
12.0 REVISION 10
13.0 MILL MANAGER APPROVAL 11
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER 11
15.0 SUMMARY 12
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 2.0 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4.0 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 typical quantities in stock, and their reportable
quantities.
Table 4.0 lists the reagent yard and bulk chemical list.
Table 5.0 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
3 and 4A, 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 tailings management system, in turn, is operated with sufficient freeboard (minimum
freeboard as required by the Groundwater Discharge Permit ["GWDP"]) to withstand 1 00%
of the Probable Maximum Precipitation ("PMP"). 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.
4.0 DESCRIPTION OF BASINS
4.1 Basin Al
Basin A 1 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 and a
portion of Cell 2. The basin covers 104.3 acres. Any overflow from this basin would be
contained within Cell 1 .
4.3 Basin B1
Basin B 1 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.
2
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 1. The basin contains 64 acres. This basin has sufficient freeboard to
withstand 1 00% of the PMP. This allows 10 inches of rain for any given storm event.
4.6 Basin C
Basin C contains a portion of Cell 2. The basin consists of 60.4 acres. Areas in this basin
also include earth stockpiles and the heavy equipment shop. The direction of flow in this
basin is to the south-southwest. All overflows in this basin is channeled along the southern
edge of the basin. Overflow then flows into Cell 3 along the length of the boundary between
Cell 2 and 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
Routine monitoring is conducted of the reagent tanks and storage areas. Daily visual
monitoring of the reagent tanks and storage areas are conducted during the twice-daily shift
inspections. Weekly visual monitoring of the tank supports and foundations are conducted
by the Radiation Safety Officer ("RSO") or designee. The scope of the daily and weekly
visual monitoring includes an inspection for leaks or visual structural abnormalities. Any
issues identified during the routine visual monitoring would be noted as such on the
3
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
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.
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.
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 corner of the SX
building. The tank has a capacity of 19,904 gallons. The tank supports are mounted on a
concrete curbed catchment pad which directs spills into the sand filter sump in the northwest
corner of the SX building. The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located outside the
northeast corner 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. 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.
Integrity inspections will be conducted to minimize the hazard associated with sodium
chlorate.
4
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.
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 Hydrochloric Acid Tanks
The hydrochloric acid storage tanks consist of two 13,650 gallon storage tanks with one 500
gallon scrubber tank. The tanks are located west of the Pre-Leach Thickener in the
northwestern portion of the mill area. The tanks are installed in a concrete containment
designed to hold the all the contents of one storage tank plus the volume of a 25-year 24-hour
storm event. The containment is placed where an overflow or failure of the containment
flows directly to Cell 1. The reportable spill quantity for hydrochloric acid is 5000 pounds.
5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
Routine inspections are conducted of the petroleum containment, tanks, and storage areas.
Daily visual monitoring of the petroleum containment, tanks, and storage areas are conducted
during the twice-daily shift inspections. Weekly visual monitoring of the tank supports and
foundations are conducted by the RSO. The scope of the daily and weekly visual monitoring
includes an inspection for leaks or visual structural abnormalities. Any issues identified
during the routine visual monitoring would be noted as such on the associated
documentation. If no issues are noted, the system, tanks or storage area condition was
considered acceptable.
Annual visual inspections of the used/waste oil and fuels tanks will be completed as
discussed in the Discharge Minimization and Technology Monitoring Plan, Revision 12.4,
Section 4.3.
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.
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
6
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.
6.3 Used/Waste Oil
Used/Waste oil 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 or sent to an EPA permitted recycling facility. 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.
6.4 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 RSO and the Environmental Coordinator.
• The Mill Manager will assess the spill and related damage and direct remedial
actions. The corrective actions may include repairs, clean-up, disposal, and
company notifications. Government notifications may be necessary in some
cases.
7
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
8
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 RSO,
Quality Assurance Manager, the Vice President, Regulatory Affairs, and/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 RSO and the
Quality Assurance Manager will be contacted by the Mill Manager.
Name
Mill Personnel:
Logan S humw ay
Garrin Palmer
Tanner Holliday
Thayne Holt
Wade Hancock
Lakewood Personnel:
Mark Chalmers
Scott Bakken
Kathy Weinel
Home Phone
Mill Manager [phone]
RSO [phone]
Mill Environmental Compliance [phone]
Coordinator
Production Superintendent [phone]
Maintenance Superintendent [phone]
President and CEO [phone]
Vice President, Regulatory Affairs [phone]
Quality Assurance Manager [phone]
Title
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
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the Environmental
or Maintenance Department for inspection and review for a minimum of five years:
1.
a.
Record of site monitoring inspections
Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection
d. Quarterly Tailings Inspection
e. Daily Operating Foreman and weekly RSO inspection reports
2. Annual used/waste oil and fuel tank visual inspections
3. Tank thickness tests
4. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
5. Tank supports and foundation inspections
6. Spill Incident reports
7. 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.
10
Logan Shumway
Mill Manager
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
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.
Steve R. Snyder
Utah Registered Professional Engineer
No. 5049193-2202
11
15.0 SUMMARY
Chemical and petroleum spills will be reported in accordance with applicable laws and
regulations. Spills that leave the property need to be reported immediately. Each spill will
be assessed and reported as required by the applicable regulations. Reportable quantities are
shown in the attached tables.
12
TABLES
TABLE 1.0
RESPONSIBILITIES
Person in charge of faCilitr responsible for spill prevention: _ Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge o follow-iap spall reportin -'1,,..''''
Garrin Palmer
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
Q1JÀNTrY REÄGET . CAPAcITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 WEST SALT 17,635
1 SALT DILUTION 9,451
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 8,530 SODA ASH SHIP 1
1 SODA ASH SILO 22,841
1 SODIUM CHLORATE 16,075
1 SODRJM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
2 HYDROCHLORIC ACID 13,650
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
, Chemical in Lab Ti kat Quantity In Stock la
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 L or 571 gal.) 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20 kg
Ammonium carbonate 5,000 lb (2,270 kg) 2 kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4 L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5 L
Ferric chloride 1,000 lb (454 kg) 2 kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) 1 L
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate 0.1N 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6 kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 kg) 1 kg
Chemical in Volatiles and
Flanunables Lockers (A,B,C)
, • . ;,; .
' • ' . .., v , ,7 Typ" al Quantity in Stock
.I. 4 ' ' • I
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2 L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) 1 L
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) 1 L
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2 L
Toluene 1,000 lb (454 kg) (approx. 523 L) 12 L
.. i i Acid R '3 TypQuty io Stock
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 L or 501 gal.) 22 L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20 L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 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."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE 4.0
REAGENT YARD AND BULK CHEMICALS LIST1
. ag RC ent , R Typical Quantity In
Simi.*
Sulfuric acid 93 to 98% 1,000 lb (454 kg) (approx. 247 L) 4,000,000 lb
Ammonia - East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia - West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 1,000,000 lb
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
Barium Chloride None 15,000 lb
Hydrochloric Acid 5,000 lbs (2,270 kg) (approx. 1,894
L or 501 gal.) 25,000 gal
Rare Earth Carbonates3 None 200,000 lb.
1. This list identifies the bulk chemicals at the Mill 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. The Mill's products are not stored in the Reagent Yard itself, but are present in containers in the
Mill Buildings and/or Mill Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah regulations.
These values are used by the Mill for conservatism as Best Management Practices.
TABLE 5.0
PETROLEUM PRODUCTS AND SOLVENTS LIST'
,
i At,'
.roo
•
,
, • i
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg)
(approx. 13.9 gal) 50 gallons
Acetone 5,000 lb (2,270 kg)
(approx. 759 gal) 55 gallons (362 lbs)
Methyl Ethyl Ketone 5, 270 kg)000 lb (2,
(approx. 745 gal) 55 gallons (369 lbs)
Toluene 1000 lbs (454 kg)
(approx. 138 gal) 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates) 100 gal* 0 gallons
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thirmers None 40 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."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
SAMPLE PLANT
5646
5640
5630
po
X
>k
o o 000
0-0
El o°o 0
ALTERNATE FEED CIRCUIT
5620 DRY REAGENT STORAGE
ri rm WATER
TANK -(7
5630
GRIZZLY
0 OLD
DECONTAMINATION
PAD
AMMONIUM SULFATE
• 0 PROCESS WATER o 0VPL STOR;\1GE
AMMONIA
SHOP
00 O „ r==t SODIUM
CHLORATE
ORE PAD
SCAL E HOUSE e nc
NEW
DEC ONTAMINATION PAD
X
LNG
SUBSTATION
PI NE-7--
SODA
00 00 ASH
0
KEROSENE 0
50"4
c:=3
REAGENT YARD 100 50 0 100 200 5630
SCALE IN FEET
X
5620
TOPSOIL REVISIONS
Energy Fuels Resources (USA) inc. 225 Union Blvd. Suite 600
Lakewood, CO 80228
WHITE MESA MILL TRUCK SHOP
Energy Fuels
Date By
10-1 1 Gm
5-14 DLS
4-16 RE
1-22 SS
County.
Location:
San Juan State: Utah
Figure 1
MILL SITE LAYOUT
Co'5°
Scale: 1=200 Date: May 12, 2000 Drafted By: D.Sledd
Mill Site Layout 1 5 22 dwg Agure 11
E N
BERM 2
D A AGE
BASIN
104.27 AC.
DRAINAGE BASIN "D"
78.3 AC.
DRAINAGE BASIN "F"
44.67 AC. CELL 4A
PMF CONTAINED
WITHIN BASIN DRAINAGE BASIN
42.14 AC.
ENERGY FL/ELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
Lakewood, CO 80228
Project: Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
White Mesa Mill
County: State ur San Juan
Location:
1000 0 1000 2000
REVISIONS
Date By
10/24/07 BM
5/16/08 BM
6/11/08 BM
12/9/08 DLS
1/7/09 BM
11/15/11 GM
5/29/19 SH
MILL SITE
DRAINAGE BASINS
FIGURE 2
Date: 2005 j Drafted By:
Figure 3
ENERGYFUELS President/CEO (M Chalmers)
Sr. V.P. General Cott-mei/
Corp. Secretary/CFO
(D Frydenlund)
Harold Roberts
Consultant
Su pery iscr, Corp
Safety & N AZ Standby
(S Hancock)
Mgr. Technical
Services (D Kapostasy)
Director ISR
Operations (B Bonifas)
Director
Conventional
Operations
(L Shumwav)
VP HR &
Administration (D Nazarenus)
VP Marketing &
Corp. Development
(C Mcore)
VP Regulatory Affairs
(S Bakken)
Staff Attomey
(J Hoffmeier)
Controller
(S Luksch)
AF/AUM Project New position TX Operations Asset M. IT Mgr ISR Permitting Mgr. Controller Management Director Colorado Plateau (L Graham) (D Kolkman)
d
Assistant New Position (P Luthiger) (R Fisher)
Director, Geology
Land
(Bruce Larsen)
Mine Geologist
Canyon Mine
(M Germalsen)
Quality Assurance
Mgr.
(K Weinel)
Ta< Mgr.
(K Beck PT)
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
January 10, 2022
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
Best Management Practices Plan
Revision 2.0: January 2022
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 5
4.2.1 Clean Up Spills Properly 5
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 6
4.3.1 Keep a Clean Dry Shop 6
4.3.2 Manage Vehicle Fluids 6
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 7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas 7
4.4.2 Manage Stockpiles to Prevent Windborne Contamination 7
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 AND BULK CHEMICALS LIST
TABLE 5.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Page 1
Best Management Practices Plan
Revision 2.0: January 2022
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 ("GWDP") 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
("UDEQ"). 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 2.0: January 2022
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") #UT 1 900479 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 2.0: January 2022
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 2.0: January 2022
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 the GWDP, 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.
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
Page 5
Best Management Practices Plan
Revision 2.0: January 2022
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (GWDP, 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. (GWDP, Section I.D.3.g.) •
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
Page 6
Best Management Practices Plan
Revision 2.0: January 2022
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings 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.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and 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.
Page 7
Best Management Practices Plan
Revision 2.0: January 2022
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
TABLES
TABLE 1.0
RESPONSIBILITIES
mu in charge:of farility responsible tofspill.preyeinionv '
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person n diargeof folio -Up spill kep
Garrin Palmer
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
R1W1. , (GÅL
AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 WEST SALT 17,635
1 SALT DILUTION 9,451
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
1 SODA ASH SILO 22,841
1 SODIUM CHLORATE 16,075
1 SODIUM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
2 HYDROCHLORIC ACID 13,650
TABLE 3.0
LABORATORY CHEMICAL INVENTORY USTI
tP7 Chemical in Lab t • ,.,' •• t ' pica ii S
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 L or 571 gal.) 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20 kg
Ammonium carbonate 5,000 lb (2,270 kg) 2 kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4 L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5 L
Ferric chloride 1,000 lb (454 kg) 2 kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) 1 L
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate 0.1N 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6 kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 kg) 1 kg
Che cat in %An :
amintibles Lechers A
. . .v . R ,
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2 L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) 1 L
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) 1 L
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2 L
Toluene _ 1,000 lb (454 kg) (approx. 523 L) 12 L
Chemical in Outside Acid . 32 ,:‘
: ., c .''''.: T)ipicai Q tity In Stock
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 L or 501 gal.) 22 L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20 L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 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."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE 4.0
REAGENT YARD AND BULK CHEMICALS LIST1
Reagent RQ2 Typical Quantitv ln
Stock
Sulfuric acid 93 to 98% 1,000 lb (454 kg) (approx. 247 L) 4,000,000 lb
Ammonia - East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia - West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 1,000,000 lb
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Ye11owcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
Barium Chloride None 15,000 lb
Hydrochloric Acid 5,000 lbs (2,270 kg) (approx. 1,894
L or 501 gal.) 25,000 gal
Rare Earth Carbonates3 None 200,000 lb.
1. This list identifies the bulk chemicals at the Mill 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. The Mill's products are not stored in the Reagent Yard itself, but are present in containers in the
Mill Buildings and/or Mill Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah regulations.
These values are used by the Mill for conservatism as Best Management Practices.
TABLE 5.0
PETROLEUM PRODUCTS AND SOLVENTS LIST' . „ Reagent . • , ... • ,RQ's 0 . . Typical Quantity In Stock
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg)
(approx. 13.9 gal) 50 gallons
Acetone 5,000 lb (2,270 kg)
(approx. 759 gal) 55 gallons (362 lbs)
Methyl Ethyl Ketone 5, 270 kg)000 lb (2,
(approx. 745 gal) 55 gallons (369 lbs)
Toluene 1000 lbs (454 kg)
(approx. 138 gal) 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates) 100 gal* 0 gallons
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 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."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
TOPSOIL
00
DRY REAGENT STORAGE
Energy Fuels
A
LNG
5630
ACID • TANK /
SUBSTATIONI
0 WATER TANK
ORE PAD ° 5630
8'
- - 5620
5620
ALTERNATE FEED CIRCUIT
HCL TANKS
=3
REAGENT YARD
0 0000
0°0
000 0
C2
401'1-
1=1 GRIZZLY
OLD DECONTAMINATION
(Th PAD
AMMONIUM SULFATE
O n PROCESS WATER
O (Th 5
▪ VPL STORAGE
SODA 0
ASH AMMONIA
o 0. KEROSENE
\-1 '
•
00 0
SODIUM
CHLORATE
U1 I--
— IZ
• 0 < 0 — CC >. (/) a.
100 50 0 100
SCALE IN FEET
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO 80228
REVISIONS WHITE MESA MILL
Date By County: San Juan State: Utah
10-11 Gm Location
5-14 DLS
4-16 RE
1-22 SS
Figure 1
MILL SITE LAYOUT

po

BOILERS

0
0
CAUSTIC
NEW SCAL DEOONTAMINATION HOUSE PAD
SAMPLE PLANT
5646
5640-
° SHOP
C=I
5630
TRUCK SHOP
200
Drafted By D Sledd Scale: 1"-=200' Date. May 1Z 2000
Mill Site Layout 1.5 22.dwg Figure 11
r--
)RAINAG
ASIN "B
5.4 AC
r
D---
BASH\L"
2.6 AC. rr
-----cZ;f7"z; -
BERIVI 1r/
D AGE BASIN
104.27 AC.
DRAINAGE BASIN "D" 78.3 AC.
SPILLWAY
DRAINAGE BASIN "F"
44.67 AC.
CELL 4A
PMF CONTAINED
WITHIN BASIN
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
Lakewood, CO 80228
Sufrace Water Flow
Drainage Basins
commum. Diversion Ditches
Diversion Berm
White Mesa Mill Project: REVISIONS
State County: San Juan
Location: 10/24/07
5/16/08
6/11/08
12/9/08
1000 1000 2000
MILL SITE
DRAINAGE BASINS
FIGURE 2
5/29/19 Date Author. SH Drafted By 2005 HRR
1/7/09
/15/11
Figure 3
ENERGY FUELS President/CEO
(M Chalmers)
Sr. V.P. General ComseV
Corp. Secretary/CFO
(D Frydenlund)
Harold Roberts Consultant
Supery iscr, Corp Safety & N AZ
Standby (S Hancock)
Mgr. Technical Services
(D Kapostasy)
Director ISR
Operations
(B Bonifas)
Director Conventional Operations
(L Shumwav)
VP HR &
Administration
(D Nazarenus)
VP Marketing & Corp. Development
(C Moore)
VP Regulatory Affairs
(S Bakken)
Staff Attorney
(J Hoffmeier)
Controller
(S Luksch)
AF/AUM Project New position TX Operations Asset Mg. IT Mgr. ISR Permitting Mgr. Controller Management Director
d
Colorado Platew (L Graham) (D Kolkman)
d
Assistant
New Position (P Luthiger) (R Fisher)
Director, Geolcgy
Land
(Bruce Larsen)
Mine Geologist
Canyon Mine
(M Germansen)
aual ity Assurance
Mgr. (K Weinel)
Tax Mgr. (K Beck PT)
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 13.0
January 2022
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 2 of 26
WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITOIUNG PLAN
TABLE OF CONTENTS
1. INTRODUCTION 3
1.1. Background 3
2. DAILY TAILINGS INSPECTIONS 4
2.1. Daily Inspection 4
3. WEEKLY TAILINGS AND DMT INSPECTION 5
3.1. Weekly Tailings Inspections 5
Northing 9
Easting 9
3.2. Weekly Feedstock Storage Area Inspections 11
4. ANNUAL EVALUATIONS 12
4.1. Annual Leak Detection Fluid Samples 12
4.2. Annual Inspection of the Decontamination Pads 12
4.3. Annual Inspection of Waste Oil and Fuel Tanks 13
4.4. Annual Inspection of Hydrochloric Acid ("HC1") Secondary Containment Concrete 13
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA 13
6. OTHER INSPECTIONS 14
7. REPORTING REQUIREMENTS 14
7.1. DMT Reports 14
ATTACHMENTS
Attachment A Forms
Attachment B Feedstock Storage Area Map
Attachment C Tables
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 3 of 26
1. INTRODUCTION
This DMT Monitoring Plan ("DMT Plan") sets out the procedures to demonstrate compliance with
Discharge Minimization Technology ("DMT") as specified throughout Parts I.D, I.E and I.F of the
White Mesa Mill' s (the "Mill' s") Groundwater Discharge Permit ("GWDP") Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT1900479 (the "RML") are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the Mill' s Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of the feedstock storage areas at the Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill' s Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill' s
Environmental Protection Manual, under the Mill' s NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill' s Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill' s Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill' s Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill' s Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 4 of 26
This division of the requirements was discussed with DRC on October 26, 2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1, 2, and 3 Leak Detection Systems ("LDSs") has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1, 2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1, 2, 3, 4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer ("RSO") or his designee is responsible for performing these daily
tailings inspections. The RSO may designate other individuals with training, as described in Section
2.4 below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-1 to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2.1q).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 5 of 26
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the GWDP must be adhered to when the
solution level trigger for Cell 4A or 4B has been exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3. 1 . Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell' s LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1 , 2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1 .0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest O. 10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1 , 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A- 1 of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill's environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
For Cells 1 , 2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3. 1 a) shall be implemented.
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 6 of 26
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C of the
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table lA and 1B (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 closed and Phase
1 cover activities have commenced. Each cell has a slimes drain system which aids
in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in 2011 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the 2011 re-
grading of the interim cover and the placement of an additional 62,000 cubic yards of
fill material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe was 6.97 feet in length and the measuring point was 37.97 feet from
the bottom of the slimes drain. This value was used in all calculations from 4th
quarter 2011 through the 3rd quarter 2016. In April 2016, Phase 1 cover placement
and construction commenced. The Phase 1 cover activities include the placement
and compaction of approximately 4.5 feet of soil materials. During the 3rd quarter
2016, the slimes drain access pipe was extended 5.44 feet as a result of the Phase 1
cover activities. The measuring point on the extension pipe was surveyed by a Utah-
Certified Land Surveyor. The measuring point elevation is now 5624.17 fmsl. For the
quarterly recovery test described in section vi below, this extension has no effect on
the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
43.41 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe. . This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 44.31 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 7 of 26
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv)All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5624. 17 fmsl), and made to the nearest 0.0 I foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5624. 17 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 1 1 , 20 1 1 , on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one ( 1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi)No process liquids shall be allowed to be discharged into Cell 2;
(vii)In accordance with GWDP Part I.F. 1 1 an Annual Slimes Drain Recovery Head
Report will be submitted with the annual DMT report for fourth quarter. The Annual
Slimes Drain Recovery Head Report will be submitted on or before of March 1 of
each year. The report will conform to Part I.D.3, I.E.7 and II.G of the GWDP;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1 , 4A, and 4B are to be taken by survey on a weekly
basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a
monthly basis when beaches are first observed, as follows:
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 8 of 26
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee (the
"Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.0 1 feet, such as a Sokkai No. B2 1, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.0 1 foot increments;
(iii)The Reference Points for Cells 1 , Cell 4A, and 4B, are known points established by
professional survey. For Cell 1 , the Reference Point is a wooden stake with a metal
disk on it located on the southeast corner of Cell 1 . The elevation of the metal disk
(the "Reference Point Elevation") for Cell 1 is at 5,623. 1 4 feet above mean sea level
("FMSL"). For Cell 4A and 4B, the Reference Point is a piece of stamped metal
monument located next to the transformer on the south side of Cell 4A and 4B. The
elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A
and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a
location where both the applicable Reference Point and pond surface are visible.
(iv)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and
4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by
gently rocking the rod back and forth until the Surveyor has established a level
reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1 , Cell 4A, or Cell 4B, or
the area of the beach in Cell 4B with the highest elevation, as the case may be. These
designated locations, and the methods to be used by the Assistant to consistently use
the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
I. Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
White Mesa Mill — Discharge Minimization Technology Monitoring Plan 01/22 Revision: EFRI 13.0
Page 9 of 26
II. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
Ill. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are:
Northing Easting
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
B. Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
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represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
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F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest corner of the
Mill' s maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
3.2. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
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water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 1 5 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4. 1 . Annual Leak Detection Fluid Samples
Pursuant to Part I.E. 10(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad' s exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
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4.3. Annual Inspection of Waste Oil and Fuel Tanks
During the second quarter of each year, the used/waste oil tank and fuel tanks will be inspected to
ensure the integrity of the tanks and support structures. The tanks and any associated piping will be
visually inspected for signs of corrosion or leaking. Any concrete structures, containments and
supports will be inspected to ensure the integrity of the exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the surface, repairs will be made within 7 days. All
inspection findings and any repairs required shall be documented on the Annual Inspection form.
The documentation of the inspection findings, any repairs required and repairs completed will be
maintained at the Mill.
4.4. Annual Inspection of Hydrochloric Acid ("HC1") Secondary Containment Concrete
During the second quarter of each year, the HC1 secondary containment concrete will be inspected.
Any associated piping will be visually inspected for signs of corrosion or leaking. Any concrete
structures, containments and supports will be inspected to ensure the integrity of the exposed
concrete surface. If any abnormalities are identified, i.e. cracks in the concrete with greater than 1/8
inch separation (width) or any significant deterioration or damage of the surface, repairs will be made
within 7 days. All inspection findings and any repairs required shall be documented on the Annual
Inspection form included as Attachment A-7. The documentation of the inspection findings, any
repairs required and repairs completed will be maintained at the Mill.
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1 /8 inch separation (width) or any significant deterioration or damage of the concrete
pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
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6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7.1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3.1(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3.1(d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
including any repairs required, and repairs completedp;
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
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e) With respect to the annual inspection (after the completion of 8 quarterly
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
0 An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report.
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ATTACHMENT A
FORMS
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ATTACHMENT A-1
DAILY INSPECTION DATA
Inspector:
Date:
Accompanied by:
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked Checked
Wet Dry Wet Dry Wet Dry Wet Dry Wet Dry
Initial level Initial level Initial level Initial level Initial level
Final
level
Final
level
Final
level
Final
level
Final
level
Gal. pumped Gal. pumped Gal. pumped Gal. pumped Gal. pumped
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included inte Tailings Managemen
System (Appendix A-1)
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ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date: Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation
elevations (msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b))
(d)Elevation of Beach Area with Highest Elevation
(monthly)
2. Leak Detection Systems
Observation:
New Decon Pad, Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
wet dry wet dry wet dry
If wet, Record liquid
level:
Ft to Liquid Ft to Liquid Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
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ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no:
comments:
Are there any alternate feed materials stored outside the ore storage pad?
yes: no:
If yes, are the alternate feedstock materials located outside the ore storage pad maintained within water-
tight containers:
yes: no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No:
Comments:
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Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes: No:
Comments:
Is there any evidence of breakage, spillage or leakage?
Yes: No:
Comments:
Other comments:
Ore Pad Southwest Stormwater Containment (Kiva):
Is there sediment or debris in the bottom of the Kiva?
Yes: No:
Comments:
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes: No:
Comments:
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ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? Yes No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September
1 of each calendar year.
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ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection:
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
_Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
_Yes No
Is there any significant deterioration or damage of the asphalt surface? Yes No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
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ATTACHMENT A-6
ANNUAL USED/WASTE OIL AND FUEL TANK INSPECTION
Date of Inspection:
Are there any anomalies on tanks including dents or rusty areas?
Yes No
Comments:
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:
Valves:
Point(s) of Discharge:
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
_Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
Yes No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):
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ATTACHMENT A-7
ANNUAL HC1 SECONDARY CONTAINMENT CONCRETE INSPECTION
Date of Inspection:
Are there any anomalies on tanks?
Yes No
Comments:
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:
Valves:
Point(s) of Discharge:
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
Yes No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):
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ATTACHMENT B
White Mesa Miff Discharge Minimization Technology Plan
1 'LE:
Page Te of 26

ENERGY FUELS RESOURCES (USA), INC.
WHITE MESA MILL
San Juan County, Utah
Feedstock Storage Area Map
Feedstock Storage Area
Date: January 2022
Source: Energy Fuels, 2022
UTAH o 50 100 200
Feet
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FEEDSTOCK STORAGE AREA
ATTACHMENT C
TABLES
Table 1 A
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table 1B
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20