DRC-2020-018632 - 0901a06880d85c7c

DRC-2020-018632 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 Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor
Department of Environmental Quality
L. Scott Baird Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director

November 19, 2020

Kathy Weinel, Quality Assurance Manager Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd, Suite 6500
Lakewood, CO 80228 RE: Engineering Module 73 Inspection of Disposal of Bulk Byproduct Material
Radioactive Material License Number UT 1900479
Dear Ms. Weinel: On November 10, 2020, Russ Topham, representing the Division of Waste Management and Radiation
Control (Division), conducted an inspection of mill-site records for disposal of 11e.(2) byproduct
material at the White Mesa Uranium Mill. Results of the inspection were discussed with plant management at the conclusion of the inspection. The inspection focused on application of Procedure PBL-10, governing receipt and disposal of 11e.(2)
byproduct material. Based on the findings documented during the inspection, the items reviewed were
found to be in compliance with the Utah Radiation Control Rules and requirements for this license, and in conformance with the referenced procedure. One recommendation was made. The recommendation was not driven by Rule or License condition, but
represented an opportunity to implement a best practice. Currently the driver delivering 11e.(2)
byproduct material to the mill for disposal is required to carry and present to mill receiving staff a Certificate of Compliance with the requirement that no RCRA-listed substances are included in the delivered material. Retaining this information with the load records may help the mill defend itself against allegations of receipt and disposal of hazardous materials. The Certificate appeared in all but
one of the data packets examined during the inspection. The missing certificate was located and added
prior to conclusion of the inspection. (Over)

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: Kirk Benge, Health Officer, San Juan County Health Department
Ronnie Nieves, Acting Environmental Health Director, San Juan County Health Department
Russell Seeley, P.E., UDEQ District Engineer