DRC-2021-016769 - 0901a06880f877a2

Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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Inspection Year: 2021 Inspection Date: October 20, 2021
Module Reviewer Name: Phil Goble, Manager
Module Prepared by/Date Prepared:
Tom Rushing, P.G./October 26, 2021 DWMRC Staff Present: Tom Rushing (Inspector)
Phil Goble (Management Inspection Accompaniment)
Energy Fuels Resources Staff Present: Garrin Palmer Energy Fuels Resources Staff Interviewed: Garrin Palmer
Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements Inspected: Part I.D.10 – Requires management of contact and non-contact storm water and control of
contaminant spills in accordance with the currently approved Storm Water Best Management
Practices Plan (SWBMPP), Spill Prevention Control and Countermeasures Plan (SPCC), and applicable sections of the Utah Administrative Code. Part I.D.11 – Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Area, including requirements for container integrity, storage on an engineered
impervious surface, and controls for storm water run-on and run-off. Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm Water Best Management Practices Plan (SWBMPP) for the White Mesa Uranium Mill:

Date: May 3, 2021 (Approved by DWMRC on May 5, 2021) Section I – Document Review
SWBMPP (Documentation Requirements):
SWBMPP Part 4.1.4. -- Diversion ditches, drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair, such as excessive vegetative growth channel erosion or
pooling of surface water runoff, will be reported to appropriate departments and all follow up actions are to be documented.
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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Findings:
The Utah Division of Waste Management and Radiation Control (“DWMRC”) conducted an
inspection of upland diversion ditches 1, 2 and 3 and associated diversion berms. Per the inspection, the ditches and berms appeared to be well maintained. No excessive debris or erosion was noted in the ditches. It was noted that ditches 1 and 3 had been cleared
of vegetation and had no flow obstacles, ditch 3 had not been cleared of vegetation, however
it appeared that flow was unobstructed by the vegetation (grasses) in the ditch. Onsite EFRI representatives reported that ditch 3 was not cleared of vegetation since the vegetation provides bank stability and the growth was not excessive and did not inhibit water flow.
EFR inspects the diversion ditches and berms monthly and inspection “findings” fields are
included on the monthly inspection data form. DWMRC reviewed the September 30, 2021 monthly form and noted that the EFR Inspector (Tanner Holliday) noted that the Diversion Ditches showed no signs of sloughing, erosion, undesirable vegetation, or obstructions of flow. Additionally the form notes that diversion berms show no stability issues or signs of
distress. The form notes that “all ditches are in good condition.”
SWBMPP Appendix 1 – Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation Requirements):
1.6.1. – Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DWMRC August 8, 2012 Request for Information which stated as follows: “The EFR Spill Prevention, Control, and Countermeasures Plan, Part 1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include
the inspection findings with the daily inspection form used for storm water inspection
documentation within 30 days from your receipt of this letter,” EFR has removed the daily inspection requirement on the basis that the propane is a gas at ambient conditions and would be immediately vaporized under all foreseeable leakage conditions at the Mill. DWMRC concurred with this action and this item is no longer inspected as part of the documentation
review or included on the site walkthrough.
1.9.1. – External Notification of “reportable quantity” spills. Findings: No reportable quantity spills were reported by EFR during the period reviewed,
DWMRC has no additional comments.
1.9.2. Internal Notification of incidents, spills, and significant spills. The White Mesa Mill employees are using a formatted card to report the small quantity
spills; the card is titled “Non-Reportable Reportable Spillage.” The card provides the
following information: Name, Date of Discovery, Approximate Amount Spilled, Time of Discovery, Location of Incident, Description of Material Spilled, Cleanup Activities Taken
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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and Signature. The reports additionally include photographs of the spill and follow up actions in most cases.

Small quantity spill reports were reviewed (Inspection range 12/20/2020 through 9/23/2021) for the period prior to the inspection. A total of 8 small quantity spills and follow up actions were reported during that time frame. Per DWMRC review it appears that the spills are being adequately reported and follow up actions are described, and in many cases photos of
the spill and clean-up are included.
During 2021, EFR implemented the storm water training program with the annual radiological refresher in four sessions (March 21, 2021; February 26, 2021; March 8, 2021, and February 8, 2021). A total of 64 employees were trained during 2021 as of the date of
the inspection.
The spill reporting provides records of identification and follow-up procedures thereby making the chemical management at the mill transparent and supports employee involvement in spill identification, reporting, and follow-up.
1.10 Records and Reports. Period of Records Examined During Inspection:
Begin/Ending: 9/1/2021 through 9/30/2021
No. of On-site Records Required: Daily, Weekly, and Monthly Forms No. of On-site Records Found: All Stormwater Related Records/Reports Onsite No of Records Examined: September 2021 (30 days) How Selected: DWMRC Inspected a random month of daily, weekly, and monthly
forms completed since the last annual DWMRC Storm Water Inspection. Daily Tailings Inspection Data: Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-1 of the
Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport
system (Slurry pipeline, pipeline joints and supports, valves and point of discharge); 2. Operational systems (interior cell walls, water level, beach, liner and cover); 3. Dikes and embankments (slopes and crest) to check for erosion and seepage; 4. Physical inspection of the slurry lines, and; 5. Dust control and leak detection, are conducted daily and documented
on a daily inspection form. The forms additionally include fields for observations of
potential concerns and action required. Spills and clean up actions are noted in the text boxes for these fields. Additionally, EFR inspects tank integrity daily (including fuel tanks) and reports comments (e.g. odors or leaks) on the “Operating Foreman’s Daily Inspection” log.
DWMRC randomly selected and reviewed the Appendix A-1daily forms and foreman’s log
for the month of September 2021 (daily forms) and 9/30/2021 (foreman’s log). The forms
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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and log appeared to be appropriate and inspections were conducted on all days. There are no additional comments regarding the forms or log.
Weekly Tailings Inspections and Survey: Findings: Weekly tailings inspections were done and documented on weekly tailings inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection
Manual Section 3.1.). The forms include sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, 4B and Roberts Pond, as well as slimes drain liquid levels in Cell 2, Existing Decontamination Pad and general tailing area. The form also includes information regarding the leak detection systems for Cells 1, 2, 3, 4A and 4B as well as the potential blowing of tailings, and
condition of concrete at the decontamination pad.
DWMRC inspected the September 2021 weekly forms. All forms were filled out and identified the individuals completing the inspections. Per the 2021 DWMRC storm water inspection, the inspection forms reviewed appeared to be completed appropriately. There are
no additional comments regarding the forms.
Monthly Tailings Inspection, Pipeline Thickness: Findings: Monthly inspection data is documented on Appendix A-3 of the Environmental
Protection Manual, Section 3. DWMRC reviewed the EFR monthly inspection report dated
September 30, 2021. Note that the monthly inspection reports include comments related to the slurry pipelines that “Pipelines are in good condition.” There are no additional comments regarding the forms.
Quarterly Tailings Inspection, Embankments:
Findings: Quarterly inspection data is documented on Appendix A-4 of the Environmental Protection Manual, Section 3. DWMRC reviewed the EFR quarterly inspection report dated September 30, 2021. Regarding the embankment inspection it was noted “all embankments
are in good condition.” There are no additional comments regarding the forms.
Tank to soil potential measurements: Findings: This item was included as part of a September 1, 2011 DWMRC Request for
Information (“RFI”), RFI # 2. DWMRC had concerns regarding on-grade tanks (tanks where
the bottom is in contact with soil). Per DWMRC communication with EFR it was clarified that tanks which sit on the ground must have cathodic protection or sit on a concrete foundation.
Per DWMRC inspection of the tank foundations during the 2021 inspection, no issues
regarding the concrete foundations were noted.
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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Tank and pipeline thickness tests:

Findings: During the inspection period, as noted on the EFR monthly inspection form, the slurry pipelines were noted to be in good condition by EFR. Spill Incident Reports:

Findings: This item is discussed above in the section related to reportable and small quantity spills. DWMRC notes that an effective spill reporting and tracking system has been implemented at the Mill.
1.11 Personnel training and Spill Prevention Procedures (records of training required to be maintained in the general safety training files): Personnel training for spill prevention are discussed in the internal notification of spills section of this module above. Per DWMRC findings the personnel training has been
implemented and appears to be effective. Mill staff attends annual training regarding the
small quantity internal spill notification process. It was noted and discussed during the October 20, 2021, inspection that the agenda for the stormwater training should be expanded on the printed agenda. Follow up regarding the agenda will be done during the 2022 stormwater inspection.

Section II -- Site Walk-through Inspection Areas and Observations:
Ore Storage:
Berms and storm water detention tank (kiva) was well maintained. Minor ponding of water was noted by the fuel tanks, as discussed onsite, the area cannot be completely pumped out due to the location of the tanks and room constraints. Per discussion is important to maintain
ore pad apron berm in this area and minor ponding in this area is a relatively smaller concern.
Reagent Yard: Per DWMRC observations no issues were noted regarding reagent storage.
Shop/Vehicle Maintenance Area: DWMRC notes that areas inside of the vehicle maintenance shop and surrounding area drain through the pipeline to Cell 1. DWMRC noted that hydraulic fluid and oil drums were stored
on pallets with secondary containment. The secondary containments looked dry and the
pallets appeared to be in good condition.
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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Mill Processing Areas:
SX Building Roof Drainage:
It was noted that the area around the SX building had been stabilized with rock riprap and that the drainage channel had been improved. No comments during the 2021 inspection.
Alternate Feed Circuit South of the SX Building:
Observations: Concrete staging pads had been repaired per DWMRC comments during the previous inspection. DWMRC had noted several large cracks/seams which were open and had not been repaired and noted that the curbing was cracked to ground level in several
locations. All items had been repaired per the 2021 inspection findings.
Old Decontamination Pad: Observations: No observations noted during the 2021 inspection.
New Decontamination Pad: Observations: Pump now located at the top of the decontamination pad. Any leaks from the pump will re-enter the water circuit. This was in response to comments documented during
the 2018 inspection. Per DWMRC inspection findings no evidence of a discharge outside of
the restricted area was noted and no additional comments were noted during the 2021 inspection. Reagent Tanks:
Sodium Chloride Tanks – Per past agreements between DWMRC and EFR (Agreements made in 2005) the secondary containment for these tanks is earthen. Per the agreement, all reagent tanks that pre-existed the Ground Water Permit (3/05) would be acceptable as is – and that as upgrades or replacements were installed, EFR would work to meet BAT
requirements. More detail regarding this agreement is in the December 2004 Statement of
Basis for the site Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit. No issues were noted during the 2021 inspection. Kerosene Tanks (West of Shop) – The kerosene tanks and concrete platforms appeared in
good condition.
Ammonia Tanks – Secondary containment is earthen per the same agreement as the sodium chloride tanks. Per observations no comments were noted.
Ammonium Sulfate Crystal Tanks – It was noted per the previous year stormwater
inspection that the Mill fire suppression water line had burst, and a portion of the nitrate CAP concrete pad had been removed in the area of the ammonium sulfate crystal tanks to inspect
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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and repair the water line. It was discussed during the inspection and inspection close out that the pad areas need to be repaired as soon as possible to maintain the integrity of the pad as a
nitrate corrective action. Per observation during the 2021 inspection all repairs had been
made. No additional comments regarding the crystal tanks or pad. Kerosene Tank (shop) – The shop kerosene tank sits in the same secondary containment as the used oil tank. DWMRC did not note any problems regarding taps and valves on the tank.
No additional comments. Fuel Tanks – Above ground tanks and containment appeared maintained, no additional comments.
Uranium Liquor Tanks – No comments were noted.
Vanadium Pregnant Liquor (VPL) Tanks – No comments were noted. Clean Water Tank – No standing water was noted around the tank. The tank appeared in
good condition. No comments were noted.
Sulfuric Acid Tank – The tank, concrete platform appeared in adequate condition. The berm around the tank was in good condition. No comments noted.
Caustic Soda Tank – Per the previous inspection, cracks and spalling were noted in the
secondary containment for the caustic soda tank and it was noted that the concrete needs to be inspected and repaired. Per the 2021 inspection follow up, all repairs had been made and there were no additional comments.
Soda Ash Tanks – No comments regarding the soda ash tanks was noted.
Tailings Cells Areas (Note that upland drainage was included in comments above) – DWMRC toured the tailings cell areas (Cells 4A and 4B) and observed the condition of the
outer toe areas of the dikes to ensure that excessive erosion or damage (e.g. burrowing
animal intrusion or rooting damage) was not present. No areas of excess erosion were noted during the 2021 inspection. Summary of Onsite Closeout Meeting:

Date/Time: October 20, 2021/10:20 A.M. EFR Representatives Present – Garrin Palmer (RSO) Tanner Holliday

DWMRC Representatives Present – Tom Rushing Phil Goble
Utah Division of Waste Management and Radiation Control (DWMRC) Ground Water Module 65, DWMRC Annual Storm Water Inspection
Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004

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An onsite close-out meeting took place to discuss findings of the storm water. Specifically,
the following issues were discussed by DWMRC:

Documentation: DWMRC discussed that the documentation review appeared to be fully filled out and to address the requirements of the permit. No specific issues were identified.
Site Walkthrough: DWMRC discussed that during the site walkthrough no specific
violations were noted. It was discussed that areas which were noted during the previous year’s inspection to need repair had been repaired as noted during the 2021 inspection. No additional items were noted during the close-out.
Conclusions
A close-out letter will be sent to EFR regarding the 2021 storm water inspection at the White Mesa Uranium Mill.