DRC-2021-015342 - 0901a06880f75d8d

DRC-2021-015342 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov
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State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director October 15, 2021
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd, Suite 600 Lakewood, CO 80228 RE: Construction Plans for Hydrochloric Acid Tank Secondary Containment: Conditional Approval Ground Water Discharge Permit (GWDP) UGW370004
Dear Ms. Weinel: On September 30, 2021, the Division received construction plans for the secondary containment
structure to serve the hydrochloric acid storage tanks you anticipate adding soon. Several telephone
calls and email messages have been exchanged since receipt of the plans, culminating in a conference call earlier today. Based upon the agreement reached in the conference call and the requirements of 40 CFR 112.9(c)(2), and to facilitate construction before winter weather conditions set in, the plans are approved, subject to the following conditions:
1. Either: a. A standpipe will be provided which terminates near the rim of the containment structure and ties into the storm drain system. This standpipe will be capable of conveying
quantities of fluid exceeding the containment volume to the storm water management
system, and ultimately to Impoundment 1. (The containment volume provided is roughly the working volume of one of the two tanks you plan to install), or b. Calculations will be provided to document the sizing of the secondary containment to hold the volume of the largest vessel (one of the two identical vessels) and the 25-year-
24-hour storm event volume generated within the containment structure footprint. If this option is chosen, include the calculation set with the as-built plans requested in the next item.
(Over)

2. An as-built plan set will be provided following completion of construction. That plan set should
contain sufficient elevation data to demonstrate the hydraulics of the system.
3. The Division will be afforded an opportunity to inspect the work in progress. Recognizing the tight construction window before poor weather prevents construction, an email message two business days prior to pouring the concrete will suffice. For record purposes, follow the email with a letter.
4. Several documents and procedures will need to be updated because of this project. Those should be submitted prior to the Division closing out this project. The affected documents include:
a. The Spill Prevention, Control and Countermeasures Plan,
b. The Storm Water Pollution Prevention Plan, c. The Surety (submit with your routine update in 2022 since the material volumes and cost associated with this project is small),
d. The Discharge Minimization Technology Plan (to be reflected in the quarterly DMT/BAT Reports)
If you have any questions, please call Russ Topham at [phone].
Sincerely,
Phil Goble, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control PRG/RJT/as

c: Mike Moulton, Interim Health Officer, San Juan County Public Health Department Ronnie Nieves, Environmental Health Director, San Juan County Public Health Department Russell Seeley, UDEQ District Engineer Logan Shumway, Plant Manager, White Mesa Mill