DRC-2019-006002 - 0901a06880a8f9ca

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June 10, 2019
Sent VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Ty L. Howard
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Div of Waste Management
and Radiation Control
JUN 2 6 2019
TJf2C-20/CJ-C()bClJ Z-
Re: Follow-up to Response to Utah Division of Waste Management and Radiation Control
("DWMRC") September 25, 2018, Groundwater Module 65, Storm Water Inspection at the White
Mesa Mill, Request for Information ("RFI"), Groundwater Discharge Permit UGW370004
Dear Mr. Howard:
This letter is a follow-up and revision to Energy Fuels Resources (USA) Inc.'s. ("EFRI's") response to
the Utah Division of Waste Management and Radiation Control ("DWMRC") September 25, 2018, Storm
Water Inspection conducted at the White Mesa Mill (the "Mill"). EFRI submitted the Request for
Information ("RFI") responses by letter dated November 14, 2018.
Request for lnformationfrom the DWMRC Letter dated October 15, 2018
DRCComment
2. The storm water detention tank at the south side of the ore storage pad needs to be cleaned out. It was
noted that the detention tank was being used for operational purposes other than storm water management
and that water and sediment were being pumped to the tank. In cases where storm water management
controls are being used for purposes other than storm water management, the control should be maintained
and returned for storm water management as soon as possible. Please provide confirmation that the
detention tank has been cleaned out.
EFRI Response from the November 14. 2018 Letter:
The storm water detention tank at the south side of the OSP has been cleaned out. Photographic
documentation is included as Attachment C [of the November I4, 20I8 letter].
The Quality Assurance Manager ("QAM") conducted refresher training via e-mail with personnel who
routinely conduct the weekly OSP inspections. The retraining focused on having inspection personnel
complete work orders or send e-mails to the maintenance department when the storm water detention tank
needs attention. The training also noted that during subsequent inspections a follow up to verify issues
have been addressed should be completed. If issues have not been addressed the inspector should follow
up with appropriate personnel. A copy of the e-mail documenting training is included in Attachment D [ of
the November I4, 20I8 letter].
• ,,,,
Letter to Ty L. Howard
June 10, 2019
Page 2 of 2
The Mill Manager has addressed the use of the storm water detention tank for uses other than storm water
management. Other alternatives will be used and the storm water detention tank will not be used for non-
storm water management except in extreme circumstances.
EFRI is proposing to address the design issues with the storm water detention tank that lead to sediment in
the bottom of the tank. Currently, the tank' s concrete pipe outlet is several inches above the concrete floor
of the tank. This design allows for sediment to "fall out" of the storm water that enters the tank. The
sediment does not affect the tank performance, but builds up and results in the tank needing frequent
cleanout. To address this issue EFRI is planning on putting a layer of concrete in the floor of the tank to
build up the floor so that it is at the same level as the bottom of the outlet pipe. The concrete will be sloped
towards the outlet pipe to increase flow of the tank contents into the outlet pipe. Due to weather and
temperatures, EFRI expects this modification will be complete by the end of April 2019 when conditions
are more suitable for concrete curing.
EFRI Revision:
EFRI has completed the actions and implemented the changes noted in the first three paragraphs of our
November 14, 2018 responses. During the design phase for the addition of concrete to the detention tank,
EFRI reviewed the original design features of the detention tank, including slopes and outlet pipe grades.
As a result, EFRI noted that the addition of concrete to the detention tank would result in significant
sediment flow into the outlet pipe, which would result in a blockage in a short period of time. The outlet
pipe was not designed to handle sediment and based on the design review, EFRI believes it would be
counterproductive to add concrete.
In lieu of the additional concrete, EFRI has increased the inspections (as noted above) and EFRI has added
management oversight to the inspections. The results of the weekly inspections are provided to the Mill
Manager when necessary to assure timely response to requests for maintenance.
Please contact me if you have any questions or require any further information.
Yours very truty,
ENERG4 FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Dave Frydenlund
Terry Slade
Logan Shumway
Scott Bakken
Paul Goranson
Steve Snyder
Justin Perkins
Garrin Palmer