DRC-2020-017848 - 0901a06880d6f7c8

DRC-2020-017848 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 4, 2020
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228 RE: Close out Letter Regarding the October 20, 2020 Division of Waste Management and Radiation Control, Ground Water Module 65, Storm Water Inspection at the White Mesa Uranium Mill
Utah Groundwater Discharge Permit No. UGW370004 Radioactive Material License Number UT 1900479 Dear Ms. Weinel:

The Division of Waste Management and Radiation Control (DWMRC) conducted a storm water inspection at the Energy Fuels Resources (EFR) White Mesa Uranium Mill (Mill) on October 20, 2020. Based on review of onsite storm water related documents and forms and a site walk-through inspection of storm water management at the Mill, it appears that all requirements of the Mill Groundwater
Discharge Permit (including the currently approved EFR Spill Prevention, Control and Countermeasures Plan, and Storm Water Best Management Practices Plan) are being adequately addressed. No violations were identified during the inspection.
As noted, and discussed during the inspection, and as reported during the close-out conference with
Logan Shumway and Garrin Palmer, three findings were identified during the inspection which need follow-up actions by EFR. These items are currently regarded as advisories only, and are summarized below: 1. It was noted that areas of the secondary containment concrete for the caustic soda tank were
cracked (without repair) and spalling. The disrepair was noted on areas of the concrete where the caustic soda was spilling into the containment. The concrete needs to be inspected and repaired where needed. (Over)

2. Areas of the nitrate contamination investigation concrete cover, east of the mill building, were
removed to repair a burst portion of the Mill fire suppression water line. As discussed onsite
during the inspection and at the inspection close-out meeting, these areas of the concrete need to be repaired as soon as possible to maintain the effectiveness of the concrete impervious cover as a corrective action for the nitrate groundwater contamination. This is specified in the corrective action plan consent order.
3. Several large cracks and open gaps were noted in the alternate feed circuit concrete staging areas. Additionally, curbing around the staging areas was cracked and worn. The staging area concrete needs to be inspected and repaired. Specific areas were noted and discussed during the inspection.

As noted above, these items are not immediately identified as violations but are included in this report as advisory areas needing attention and follow-up. The areas will be inspected during future inspections to determine if the maintenance/repair has been completed. Based on the inspection, the 2020 DWMRC Storm Water Inspection (Groundwater Inspection Module
65) is hereby closed out. If you have any questions, please call Tom Rushing at [phone].
Sincerely,
Phil Goble, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control
PRG/TR/as c: Kirk Benge, Health Officer, San Juan Public Health Department
Rick Meyer, Environmental Health Director, San Juan Public Health Department
Russell Seeley., UDEQ District Engineer Logan Shumway, White Mesa Mill Plant Manager