DRC-2019-012783 - 0901a06880b42a23

Y FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Div of Waste Management
October 14, 2019 and Radiation Control
Sent VIA E-MAIL AND EXPEDITED DELIVERY
OCT 1 7 2019
Mr. Ty L. Howard
Ptz-c-20/9-o1a7e5
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Transmittal of Revised Spill Prevention, Control and Countermeasures Pan ("SPCC") and
Revised Stonnwater Best Management Practices Plan ("SWBMPP") for White Mesa Uranium
Mill
Dear Mr. Howard:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRI' s") proposed revisions to the White Mesa
Mill SPCC and SWBMPP. These revisions include changes made to:
1. Update personnel and contact information.
2. Correct typographical errors.
3. Update drainage information for Cell 2.
For ease of review we have provided both redline/strikeout (text only) and clean versions (text and all tables
and figures) of each document.
If you should have any questions regarding these plans please contact me.
Yours very truly,
twty WILA4
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Paul Goranson
Terry Slade
Logan Shumway Garrin Palmer
Scott Bakken
CLEAN
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
October 14, 2019
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
E ERGY FUELS
Contents
1.0 OBJECTIVE 1
1.1 Plan Organization 1
2.0 RESPONSIBILITIES 2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS 2
4.0 DESCRIPTION OF BASINS 2
4.1 Basin Al 2
4.2 Basin A2 2
4.3 Basin B1 2
4.4 Basin B2 3
4.5 Basin B3 3
4.6 Basin C 3
4.7 Basin D 3
4.8 Basin E 3
4.9 Basin F 3
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT 3
5.1 Reagent Tanks (Tank list included in Table 2.0) 4
5.2 Ammonia 4
5.3 Ammonium Meta-Vanadate 4
5.4 Caustic Storage (Sodium Hydroxide) 4
5.5 Sodium Carbonate (Soda Ash) 4
5.6 Sodium Chlorate 4
5.7 Sulfuric Acid 5
5.8 Vanadium Pentoxide 5
5.9 Kerosene (Organic) 5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT 5
6.1 Petroleum Tanks 6

6.1.1 Diesel 6
6.2 Aboveground Fuel Pump Tanks 6

6.2.1 Diesel 6

6.2.2 Unleaded Gasoline 6

6.2.3 Pump Station 6
6.3 Used/Waste Oil 6
6. 4 Truck Unloading 7
7.0 SPILL DISCOVERY AND REMEDIAL ACTION 7
8.0 SPILL INCIDENT NOTIFICATION 8
8.1 External Notification 8
8.2 Internal Notification 8
9.0 RECORDS AND REPORTS 9
10.0 SPILL REPORTING REQUIREMENTS 10
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES 10
11.1 Training Records 10
11.2 Monitoring Reports 10
12.0 REVISION 10
13.0 MILL MANAGER APPROVAL 11
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER 11
15.0 SUMMARY 12
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN FOR
CHEMICALS AND PETROLEUM PRODUCTS
1.0 OBJECTIVE
The objective of the Spill Prevention, Control, and Countermeasures (SPCC) Plan is to serve
as a site-specific guideline for the prevention of and response to chemical and petroleum
spills. The plan outlines spill potentials, containment areas, and drainage characteristics of
the White Mesa Mill site. The plan addresses chemical spill prevention, spill potentials, spill
discovery, and spill notification procedures. Spills are reportable if the spill leaves the site.
Ammonia is the only chemical (as vapor) that has the potential to leave the site. In addition,
chemical and petroleum spills will be reported in accordance with applicable laws and
regulations.
1.1 Plan Organization
This SPCC is organized as follows:
Section 1.0 Objective
Section 2.0 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4.0 Description of Basins
Section 5.0 Potential Chemical Spill Sources and Spill Containment
Section 6.0 Potential Petroleum Spill Sources and Containment
Section 7.0 Spill Discovery and Remedial Action
Section 8.0 Spill Incident Notification
Section 9.0 Records and Reports
Section 10.0 Spill Reporting Requirements
Section 11.0 Personnel Training and Spill Prevention Procedures
Section 12.0 Revision
Section 13.0 Mill Manager Approval
Section 14.0 Certification by Registered Professional Engineer
Section 15.0 Summary
Tables:
Table 1.0 is the Energy Fuels Resources (USA) Inc. (EFRI) personnel responsible for
implementing this SPCC.
Table 2.0 lists the reagent tanks and their respective capacities.
Table 3.0 lists the laboratory chemicals, their typical quantities in stock, and their reportable
quantities.
Table 4.0 lists the reagent yard and bulk chemical list.
Table 5.0 lists the petroleum products and solvents on site.
1
Figures:
Figure 1 shows the Mill Site Layout, shows the mill site including the locations of the
chemical tanks on-site.
Figure 2 shows the basins and drainage ditch areas for the Mill Site.
Figure 3 shows the organization chart for Mill Operations.
2.0 RESPONSIBILITIES
Personnel responsible for spill prevention and follow-up spill reporting are included on Table
1, which is included in the Tables Tab of this SPCC.
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS
The main drainage pathways are illustrated in Figure 2. The map shows drainage basin
boundaries, flow paths, constructed diversion ditches, tailing cells, the spillway between Cell
3 and 4A, dikes, berms, and other relevant features. The White Mesa Mill is a "zero"
discharge facility for process liquid wastes. The mill area has been designed to ensure that
all spills or leaks from tanks will drain toward the lined tailing management system.
The management system, in turn, is operated with sufficient freeboard (minimum freeboard
as required by the Groundwater Discharge Permit [GWDP]) to withstand 100% of the PMP
(Probable Maximum Precipitation). This allows for a maximum of 10 inches of rain at any
given time.
Precipitation and unexpected spills from the mill site are contained within their prospective
drainage basins. Overflow ultimately drains into the tailings management system.
4.0 DESCRIPTION OF BASINS
4.1 Basin Al
Basin A 1 is north of Cell 1 and Diversion Ditch No. 1. The basin contains 23 tributary acres,
all of which drain into Westwater Creek.
4.2 Basin A2
Basin A2 contains all of Cell 1 including an area south of the Diversion Ditch No. 1 and a
portion of Cell 2. The basin covers 104.3 acres. Any overflow from this basin would be
contained within Cell 1.
4.3 Basin B1
Basin B 1 is north of the mill area. The basin contains 45.4 tributary acres.
Overflow from this basin drains into a flood retention area by flowing through Diversion
Ditch No. 2. Diversion Ditch No. 2 drains into Westwater Creek.
2
4.4 Basin B2
Basin B2 is northeast of the mill area and contains only 2.6 tributary acres. Overflow from
this basin would drain into Diversion Ditch No. 3. Diversion Ditch No. 3 ultimately drains
into Diversion Ditch No. 2.
4.5 Basin B3
Basin B3 contains most of the mill area, buildings, ore stockpiles, process storage tanks,
retention ponds, spill containment structures, pipelines, and roadways. The normal direction
of flow in this basin is from the northwest to the southwest. Any overflow from this basin
would drain into Cell 1. The basin contains 64 acres. This basin has sufficient freeboard to
withstand 1 00% of the PMP (Probable Maximum Precipitation). This allows 10 inches of
rain for any given storm event.
4.6 Basin C
Basin C contains a portion of Cell 2. The basin consists of 60.4 acres. Areas in this basin
also include earth stockpiles and the heavy equipment shop. The direction of flow in this
basin is to the south-southwest. All overflows in this basin is channeled along the southern
edge of the basin. Overflow then flows into Cell 3 along the length of the boundary between
Cell 2 and Cell 3.
4.7 Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including a portion of the
slopes of the topsoil stockpile and random stockpile. The basin contains all flows, including
those caused by the PMP.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4A.
4.9 Basin F
Basin F contains Cell 4B, and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4B.
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT
Routine monitoring is conducted of the reagent tanks and storage areas. Daily visual
monitoring of the reagent tanks and storage areas are conducted during the twice-daily shift
inspections. Weekly visual monitoring of the tank supports and foundations are conducted
by the Radiation Safety Officer ("RSO") or designee. The scope of the daily and weekly
visual monitoring includes an inspection for leaks or visual structural abnormalities. Any
issues identified during the routine visual monitoring would be noted as such on the
3
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
5.1 Reagent Tanks (Tank list included in Table 2.0)
5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of 31,409 gallons each. The
tanks are located southeast of the Mill building.
Integrity inspections will be conducted to minimize the hazard associated with ammonia.
The reportable quantity for an ammonia spill is 7 gallons.
Ammonia spills should be treated as gaseous. Ammonia vapors will be monitored closely to
minimize the hazard associated with inhalation. If vapors are detected, efforts will be made
to stop or repair the leak expeditiously. Ammonia is the only chemical (as vapor) that has the
potential to leave the site.
5.3 Ammonium Meta-Vanadate
Amrnonium meta-vanadate is present in the vanadium precipitation area of the Mill building
as the process solutions move through the circuit to produce the vanadium end product.
Spills would be contained in the process sump within the vanadium precipitation area. The
reportable spill quantity for ammonium meta-vanadate is 1,000 pounds.
5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner of the SX
building. The tank has a capacity of 19,904 gallons. The tank supports are mounted on a
concrete curbed catchment pad which directs spills into the sand filter sump in the northwest
corner of the SX building. The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located outside the
northeast corner of the SX building. Spills from the soda ash solution tank are contained in
the North SX impound and run to Cell 1. The smaller soda ash shift tank has a capacity of
8,530 gallons and is located in the SX building. Spills will be diverted into the boiler area,
and would ultimately drain into Cell 1. There is no reportable spill quantity associated with
sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of three fiberglass tanks located within a dike east of the SX
building. Tank maximum volumes of the three tanks are 16,075, 21,057 and 28,788 gallons.
Integrity inspections will be conducted to minimize the hazard associated with sodium
chlorate.
4
Sodium chlorate that has dried and solidified becomes even more of a safety hazard due to its
extremely flammable nature. The reportable spill quantity for sodium chlorate is 400
gallons.
5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of 1,600,000
gallons and one smaller tank with a capacity of 11,000 gallons.
The large tank is located in the northwest comer of mill area basin B3 and is primarily used
for acid storage and unloading. The tank support for the large tank is on a mound above a
depression which would contain a significant spill. All flows resulting would be channeled
to Cell 1. The tank is equipped with a high level audible alarm which sounds prior to tank
overflows. A concrete spill catchment with a sump in the back provides added containment
around the base of the tank. However, the catchment basin would not be able to handle a
major tank failure such as a tank rupture. The resulting overflow would flow towards Cell 1.
The smaller storage tank is located on the north side of the SX building. The tank is
equipped with a high level audible alarm.
The reportable spill quantity for sulfuric acid is 65 gallons.
5.8 Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the drying and fusing
circuits and is not present in the vanadium circuit until after the deammoniator. Efforts will
be made to minimize leaks or line breaks that may occur in processes in the circuit that
contain vanadium pentoxide. Special care will be taken in the transportation of this chemical.
The reportable spill quantity for vanadium pentoxide is 1000 pounds.
5.9 Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a combined capacity of
10,152 gallons in three tanks. Any overflow from these three tanks would flow around the
south side of the SX building and then into Cell 1. These tanks have drain valves which
remain locked unless personnel are supervising draining operations. The reportable spill
quantity for kerosene is 100 gallons.
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
Routine inspections are conducted of the petroleum containment, tanks, and storage areas.
Daily visual monitoring of the petroleum containment, tanks, and storage areas are conducted
during the twice-daily shift inspections. Weekly visual monitoring of the tank supports and
foundations are conducted by the RSO. The scope of the daily and weekly visual monitoring
includes an inspection for leaks or visual structural abnormalities. Any issues identified
during the routine visual monitoring would be noted as such on the associated
documentation. If no issues are noted, the system, tanks or storage area condition was
considered acceptable.
5
Annual visual inspections of the used/waste oil and fuels tanks will be completed as
discussed in the Discharge Minimization and Technology Monitoring Plan, Revision 12.4,
Section 4.3.
6.1 Petroleum Tanks
6.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The tanks have
capacities of 250 gallons each. One of the diesel tanks is for the emergency generator.
The other tank is located in the pumphouse on an elevated stand. Spillage from either
tank would ultimately flow into Cell 1. The reportable spill quantity for diesel is 100
gallons. The spill is also reportable if the spill has the potential for reaching any nearby
surface waters or ground waters.
6.2 Aboveground Fuel Pump Tanks
6.2.1 Diesel
The diesel tank is located on the east boundary of Basin B3 and has a capacity of 6,000
gallons. The tank is contained within a concrete catchment pad. The reportable spill
quantity for diesel is 100 gallons. A diesel spill is also reportable if the spill has the
potential for reaching any surface waters or ground waters.
6.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded gasoline tank
has a capacity of 3,000 gallons and is contained within the same containment system as
the diesel tank. Spills having the potential for reaching any surface waters or ground
waters will need to be reported. The reportable spill quantity for unleaded gasoline is 100
gallons.
6.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling company
vehicles used around the mill site. The pump station is equipped with an emergency
shut-off device in case of overflow during fueling. In addition, the station is also
equipped with a piston leak detector and emergency vent. Check valves are present along
with a tank monitor console with a leak detection system. The catchment is able to
handle a complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a temporary berm
would need to be constructed. Absorbent diapers or floor sweep would be used in an
effort to limit and contain the spill. The soil would have to be cleaned up and placed in
the Cell currently used for the disposal of solid Mill wastes.
6.3 Used/Waste Oil
Used/ Waste oil is located north of the maintenance shop in a tank and has a capacity of
5,000 gallons. The tank is contained within a concrete containment system. Used oil will be
disposed of on site or sent to an EPA permitted recycling facility. Any oil escaping the
6
concrete containment system will be cleaned up. Soil contaminated with used oil will be
excavated and disposed of in the Cell currently used for the disposal of solid Mill wastes.
6. 4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill area, proper
reporting and containment procedures will be followed when warranted, such as when oil or
diesel fuel is spilled. Proper clean-up procedures will be followed to minimize or limit the
spill. The spill may be temporarily bermed or localized with absorbent compounds. Any
soils contaminated with diesel fuel or oil will be cleaned up and placed in the Cell currently
used for the disposal of solid Mill wastes.
7.0 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take measures to
limit additional spillage and contain the spill that has already occurred. Chemical or
petroleum spills will be handled as follows:
• The Shift Foreman will direct efforts to shut down systems, if possible, to limit
further release.
• The Shift Foreman will also secure help if operators are requiring additional
assistance to contain the spill.
• The Shift Foreman is also obligated to initiate reporting procedures.
• Once control measures have begun and personal danger is minimized, the Shift
Foreman will notify the Production Superintendent, Maintenance Superintendent,
or Mill Manager.
• The Production or Maintenance Superintendent will notify the Mill Manager, who
in turn will notify the RSO and the Environmental Coordinator.
• The Mill Manager will assess the spill and related damage and direct remedial
actions. The corrective actions may include repairs, clean-up, disposal, and
company notifications. Government notifications may be necessary in some
cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
7
8.0 SPILL INCIDENT NOTIFICATION
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
1. EPA National Response Center 1-800-424-8802
2. US Nuclear Regulatory Commission 301-816-5100
3. State of Utah 801-538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301-816-5100
2. State of Utah, Natural Resources 801-538-7200
8.2 Internal Notification
Internal reporting requirements for incidents, spills, and significant spills are as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits operations or assesses
penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-product
8
In the event of a spill requiring reporting, the Mill Manager is required to call the RSO,
Quality Assurance Manager, the Chief Operating Officer, and/or the President and Chief
Executive Officer. The spill will first be reported to the Shift Foreman. The Shift Foreman
will then report the spill to the Mill Superintendent, Maintenance Superintendent, or Mill
Manager.
The Mill or Maintenance Superintendent will report to the Mill Manager. The RSO and the
Quality Assurance Manager will be contacted by the Mill Manager.
Name
Mill Personnel:
Logan S humw ay
Terry Slade
Garrin Palmer
Thayne Holt
Wade Hancock
Lakewood Personnel:
Mark Chalmers
Paul Goranson
Scott Bakken
Kathy Weinel
Title
Mill Manager
RS 0
Assistant RSO/Mill Environmental
Compliance
Coordinator
Production Superintendent
Maintenance Superintendent
President and Chief Executive
Officer
Chief Operating Officer
Sr. Director, Regulatory Affairs
Quality Assurance Manager
Home Phone
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
In the event the next person in the chain-of-command cannot be reached, then proceed up the
chain-of-command to the next level. Figure 3.0 shows the organizational chart for the mill
site.
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the Environmental
or Maintenance Department for inspection and review for a minimum of five years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection
d. Quarterly Tailings Inspection
e. Daily Operating Foreman and weekly RSO inspection reports
9
2. Annual used/waste oil and fuel tank visual inspections
3. Tank thickness tests
4. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
5. Tank supports and foundation inspections
6. Spill Incident reports
7. Latest revision of SPCC plan
10.0 SPILL REPORTING REQUIREMENTS
1. Report to applicable government agency as required by laws and regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of spill
impacts
4. Report release of 5,000 pounds or more of any process material or waste product
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES
All new employees are instructed on spills at the time they are employed and trained. They
are briefed on chemical and petroleum spill prevention and control. They are informed that
leaks in piping, valves, and sudden discharges from tanks should be reported immediately.
Abnormal flows from ditches or impoundments are of immediate concern. In addition, a
safety meeting is presented annually by the Environmental Coordinator to review the SPCC
plan.
11.1 Training Records
Employee training records on chemical and petroleum spill prevention are maintained in the
general safety training files.
11.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
12.0 REVISION
This procedure is to be reviewed by the mill staff and a registered professional engineer at
least once every three years, and updated when circumstances warrant a revision.
10
13.0 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with the Standard
Operating Procedures currently in effect.
,-/ A----'----25----
Ls !an Shumway
Mill Manager
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with good
engineering practices.
Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
11
15.0 SUMMARY
Chemical and petroleum spills will be reported in accordance with applicable laws and
regulations. Spills that leave the property need to be reported immediately. Each spill
will be assessed and reported as required by the applicable regulations. Reportable
quantities are shown in the attached tables.
12
TABLES
TABLE 1.0
RESPONSIBILITIES
r Person in charge of facility rewonsible for spill prevention: 1
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
Terry Slade
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
1 • QUANTITY REAGENT CAPACITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 WEST SALT 17,635
1 SALT DILUTION 9,451
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
1 SODA ASH SILO 22,841
1 SODIUM CHLORATE 16,075
1 SODIUM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
Chemical in Lab RQ2
=c
Ty pical Quantity In Stock
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 L or 571 gal.) 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20 kg
Ammonium carbonate 5,000 lb (2,270 kg) 2 kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4 L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5 L
Ferric chloride 1,000 lb (454 kg) 2 kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) 1 L
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate 0.1N 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6 kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 kg) 1 kg
Chemical in Volatiles and
Flammables Lockers (A,B,C)
3 R Typical Quantity in Stock
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2 L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) 1 L
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) 1 L
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2 L
Toluene 1,000 lb (454 kg) (approx. 523 L) 12 L
Chemical in Outside Acid
Conex
2,3 Typical Quantity in Stock
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 L or 501 gal.) 22 L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20 L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 L
1. This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
The lab also stores small quantities of other materials that are not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE 4.0
REAGENT YARD AND BULK CHEMICALS LIST1
Reagent RQ2 Typical Quantity In '
Stock
Sulfuric acid 93 to 98% 1, 000 lb (454 kg)
(approx. 247 L) 4,000,000 lb
Ammonia — East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia — West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 60, lb 000
in 50% solution
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
1. This list identifies the bulk chemicals and the chemicals in the reagent yard whether
or not they are regulated as hazardous substances under the Federal Water Pollution
Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of
the Clean Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the
Reagent Yard itself, but are present in closed containers in the Mill Building and/or Mill
Yard.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or
Utah regulations. These values are used by the Mill for conservatism as Best
Management Practices.
TABLE 5.0
PETROLEUM PRODUCTS AND SOLVENTS USTI r Reagent , R — 4 Typical Quantity In Stock
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg)
(approx. 13.9 gal) 50 gallons
Acetone 5,000 lb (2,270 kg)
(approx. 759 gal) 55 gallons (362 lbs)
Methyl Ethyl Ketone 5,000 lb (2,270 kg)
(approx. 745 gal) 55 gallons (369 lbs)
Toluene 1000 lbs (454 kg)
(approx. 138 gal) 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates) 100 gal* 0 gallons
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
100 50 0 100 200 REAGENT YARD ,K
Drafted By: Scale: 1...200' Date: May 12, 2000
SX
BUILDING FUEL
ISLANDE
o 0000
1000 000
ALTERNATE
FEED
CIRCUIT
00
ou
SODIUM
CHLORATE
DRY REAGENT
STORAGE
ACID
TANK
SUBST 10
ORE PAc
OLD
DECONTAMINATION
PAD
AMMONIUM
SULFATE
BOILERS
SCALE IN FEET
TRUCK SHOP
Mill Site Layout 4.28.16.dwg Rgure 11
REVISIONS WHITE MESA MILL
Date By County. San Juan State: Utah
10-11 GM Location:
5-14 DLS Figure 1
MILL SITE LAYOUT 4-16 RE
Energy Fuels
Energy Fuels Resources (USA) Inc 225 Union Blvd. Suite 600 Lakewood, CO 80228
I—OFFICE
SC4L
HOU E
DRAINAGE
_ (5ASlN "Al"
23 AC.
BERM 1
BERM 2
DRAINAGE BASIN "BS
64 AC.
o
\
O
8
DR4 AGE
BASIN
104.27 AC.
DRAINAGE BASIN "D"
78.3 AC.
SPILLWAY
CELL 4B
DRAINAGE BASIN "F"
44.67 AC.
DRAINAGE BASIN "E"
42.14 AC.
CF ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
Lakewood, CO 80228
REVISIONS Project: White Mesa Mill
State: UT County: San Juan Date
10/24/07 Location: i
5/16/08 BM
6/11/08 BM
12/9/08 DLS
1/7/09 BM
MILL SITE
DRAINAGE BASINS
FIGURE 2
By
BM
Sufrace Water Flow
Drainage Basins
immommil Diversion Ditches
Diversion Berm
1000 1000 2000
Environmental
Technician(s)
Chief Operating
Officer
CFO, General
Counsd, Corp
Secretary
Min Operations
Personnel
Mill Manager Senior Dir.
Regulatory Affairs
Mill RSO
Safety Coordinator Radiation Safety
Technician(s)
President & CEO
Figure 3
Energy Fuels Resources (USA) Inc.
Mill Management Organization Chart
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
October 14, 2019
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
Best Management Practices Plan
Revision 1.6: October 2019
TABLE OF CONTENTS
1.0 1NTRODUCTION/PURPOSE 2
2.0 SCOPE 3
3.0 RESPONSIBILITY 4
4.0 BEST MANAGEMENT PRACTICES 5

4.1 General Management Practices Applicable to All Areas 5
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: 5
4.1.2 Keep Potential Pollutants from Contact with Precipitation 5
4.1.3 Keep Paved Areas from Becoming Pollutant Sources 5
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels
within the Process and Reagent Storage Area 5
4.1.5 Recycle Fluids Whenever Possible: 5

4.2 Management Practices for Process and Laboratory Areas 6
4.2.1 Clean Up Spills Properly 6
4.2.2 Protect Materials Stored Outdoors 6
4.2.3 Management 6
4.2.4 Materials Management 6

4.3 Management Practices for Maintenance Activities 7
4.3.1 Keep a Clean Dry Shop 7
4.3.2 Manage Vehicle Fluids 7
4.3.3 Use Controls During Paint Removal 7
4.3.4 Use Controls During Paint Application and Cleanup 7

4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment 7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas 7
4.4.2 Manage Stockpiles to Prevent Windborne Contamination 8
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources 8
Figures
Figure 1: White Mesa Mill Site Layout
Figure 2: White Mesa Mill Site Drainage Basins
Figure 3: Energy Fuels Resources (USA) Inc.- White Mesa Mill Management Organization Chart
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP
TABLE 2.0: REAGENT YARD LIST
TABLE 3.0: LABORATORY CHEMICAL INVENTORY L1ST
TABLE 4.0: REAGENT YARD AND BULK CHEMICALS LIST
TABLE 5.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Page 1
Best Management Practices Plan
Revision 1.6: October 2019
1.0 INTRODUCTION/PURPOSE
Energy Fuels Resources (USA) Inc. ("EFRP') operates the White Mesa Uranium Mill (the "Mill")
in Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect
to water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to EFRI on March 8,
2005. As a part of compliance with the Permit, EFRI is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Director of the Division of Waste Management and
Radiation Control ("DWMRC"), Utah Department of Environmental Quality. This BMPP
presents operational and management practices to minimize or prevent spills of chemicals or
hazardous materials, which could result in contaminated surface water effluents potentially
impacting surface waters or ground waters through runoff or discharge connections to stormwater
or surface water drainage routes. Although the Mill, by design, cannot directly impact
stormwater, surface water, or groundwater, the Mill implements these practices in a good faith
effort to minimize all sources of pollution at the site.
Page 2
Best Management Practices Plan
Revision 1.6: October 2019
2.0 SCOPE
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings management impoundments in accordance with the
Mill's Radioactive Materials License ("RML") #UT1900479 conditions. All of the process and
laboratory building sinks, sumps, and floor drains are tied to the transfer lines to the tailings
impoundments. A site map of the Mill is provided in Figure 1 . A sketch of the site drainage
basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by RML to manage some spills via draining or wash down
to the process sewers, and ultimately the tailings management system. However, as good
environmental management practice, the Mill attempts to minimize.
1 . the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of stormwater, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
EFRI White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP"), and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs").
Page 3
Best Management Practices Plan
Revision 1.6: October 2019
3.0 RESPONSIBILITY
All Mill personnel are responsible for implementation of the practices in this BMPP. EFRI White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The EFRI Corporate Management and Mill Management Organization is presented in Figure 3.
An updated spill prevention and control notification list is provided in Table 1.
Page 4
Best Management Practices Plan Revision 1.6: October 2019
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
the RML. Areas requiring maintenance or repair, such as excessive vegetative growth,
channel erosion or pooling of surface water runoff, will be reported to site management
and maintenance departments for necessary action to repair damage or perform
reconstruction in order for the control feature to perform as intended. Status of
maintenance or repairs will be documented during follow up inspections and additional
action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings management system for disposal.
Page 5
Best Management Practices Plan
Revision 1.6: October 2019
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
9 (Groundwater Discharge Permit No. UGW370004, Section I.D.10.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE") near the areas where they may be needed for spill response.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 6
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings management system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings management system.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
Page 7
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and decontamination pads).
• At the decontamination pads, make sure the water collection and recycling system is working
before turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep surfaces moist but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
Page 8
TABLES
TABLE 1.0
RESPONSIBILITIES
Person in charge of facility responsible for spill prevention:
Logan Shumway
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
Terry Slade
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
QI T \ NTITY REAGENT CAPACITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USED/WASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 WEST SALT 17,635
1 SALT DILUTION 9,451
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
1 SODA ASH SILO 22,841
1 SODIUM CHLORATE 16,075
1 SODIUM CHLORATE 21,057
1 SODIUM CHLORATE 28,788
1 SULFURIC ACID 1,600,000
1 SULFURIC ACID 11,000
TABLE 3.0
LABORATORY CHEMICAL INVENTORY USTI
Chemical in Lab RQ2 Typical Quantity In Stock
Acetic Acid, Glacial 5,000 lbs (2,270 kg) (approx. 2,160 L or 571 gal.) 10 L
Aluminum nitrate 5,000 lb (2,270 kg) 20 kg
Ammonium carbonate 5,000 lb (2,270 kg) 2 kg
Ammonium bifluoride 100 lb (45.4 kg) 10 lbs
Ammonium chloride 5,000 (2,270 kg) 6 kg
Ammonium hydroxide 1,000 lb (454 kg) (approx. 510 L) 57.5 L
Ammonium oxalate 5,000 (2,270 kg) 12 kg
Ammonium thiocyanate 5,000 (2,270 kg) 15 kg
Antimony potassium tartrate 100 lb (45.4 kg) 0.500 kg
Ammonium, hydroxide 1,000 lb (454 kg) (approx. 510 L) 5L
n-Butyl acetate 5,000 lb (2,270 kg) (approx. 2594 L) 4 L
Calcium acetate None 1 kg
Cyclohexane 1,000 lb (454 kg) (approx. 583 L) 5 L
Ferric chloride 1,000 lb (454 kg) 2 kg
Ferric nitrate 1,000 lb (454 kg) 0.500 kg
Ferrous ammonium sulfate 1,000 lb (454 kg) 10 kg
Ferrous sulfate heptahydrate 1,000 lb (454 kg) 6 kg
Hydrofluoric Acid 100 lb (45.4 kg) (approx. 39 L) 1 L
Lead nitrate 10 lb (4.54 kg) 1 kg
Potassium chromate 10 lb (4.54 kg) 1 lb
Potassium Permanganate 0.1N 100 lb (45.4 kg) (32 gal) 5 kg (11 lbs)
Silver Nitrate 1 lb (0.454 kg) 2.6 kg
Sodium hydrosulfide 5,000 lb (2,270 kg) 2.5 kg
Sodium nitrite 100 lb (45.4 kg) 10 kg
Sodium phosphate tribasic 5,000 lb (2,270 kg) 3 lbs
Zinc acetate 1,000 lb (454 kg) 1 kg
Chemical in Volatiles and
Flammables Lockers (A,B,C)
2RQ ,3 Typical uantity in Stock
Acetone 5,000 lb (2,270 kg) (approx. 759 gal) 2 L
Chloroform 10 lb (4.54 kg) ( approx. 3.1 L) 1 L
Formaldehyde 100 lb (45.4 kg) (approx. 41.7 L) 1 L
Nitrobenzene 1,000 lb (454 kg) (approx. 377 L) 12 L
Trichloroethylene 100 lb (45.4 kg) (approx. 31.1 L) 2 L
Toluene 1,000 lb (454 kg) (approx. 523 L) 12 L
Chemical in Outside Acid
Conex
21 R Typical uantity in Stock
Hydrochloric acid 5,000 lbs (2,270 kg) (approx. 1,894 L or 501 gal.) 22 L
Nitric acid 1,000 lb (454 kg) (approx. 322 L) 25 L
Phosphoric acid 5,000 lb (2,270 kg) (approx. 1,350 L) 20 L
Sulfuric acid 1,000 lb (454 kg) (approx. 247 L) 45 L
1. This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
The lab also stores small quantities of other materials that are not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
3. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration, unless otherwise specified.
TABLE 4.0
REAGENT YARD AND BULK CHEMICALS LIST'
Reagent RQ2 Typical Quantity In
Stock
Sulfuric acid 93 to 98% 1, 000 lb (454 kg)
(approx. 247 L) 4,000,000 lb
Ammonia — East Tank 100 lb (45.4 kg) 50,000 lb
Ammonia — West Tank 100 lb (45.4 kg) 50,000 lb
Kerosene 100 gal* 5,000 gal
Salt (Bags) None 40,000 lb
Soda Ash Bulk None 80,000 lb
Soda Ash Dense (Bag) None 40,000 lb
Hydrogen Peroxide None 20,000 lb
Diesel 100 gal* 3,000 gal
Gasoline 100 gal* 1,500 gal
Tertiary Amine None 30,000 lb
Salt (Bulk solids) None 50,000 lb
Caustic Soda 1,000 lb (454 kg) 60,000 lb
in 50% solution
Ammonium Sulfate None 120,000 lb
Sodium Chlorate None 70,000 lb
in 50% solution
Alamine 335 Bulk None 0 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lb (454 kg) 50,000 lb
Yellowcake3 None 200,000 lb
Liquid Natural Gas 10,000 lbs (4,540 kg) 60,000 lb
Tri-decyl alcohol None 20,000 lb
Flocculant 655 None 40,000 lb
Flocculant 314 None 4,000 lb
Propane None 16,000 lb
Solid-A-Sorb None 44,000 lb
Perlite None 25,000 lb
Diatomaceous Earth Filter Aid None 30,000 lb
DEHPA None 2,000 lb
1. This list identifies the bulk chemicals and the chemicals in the reagent yard whether
or not they are regulated as hazardous substances under the Federal Water Pollution
Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of
the Clean Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the
Reagent Yard itself, but are present in closed containers in the Mill Building and/or Mill
Yard.
* These materials do not have an RQ under 40 CFR. 110, 40 CFR 117, 40 CFR 302 or
Utah regulations. These values are used by the Mill for conservatism as Best
Management Practices.
TABLE 5.0
PETROLEUM PRODUCTS AND SOLVENTS LIST'
Reaoent R _'3,4 Typical Quantity In Stock
Lubricating Oils in 55 gallon drums 100 gal* 1,000 gallons
Transmission Oils 100 gal* 250 gallons
Dielectric fluids None 5 gallons
Antifreeze (Ethylene glycol) 5,000 lb 100 gallons
Greases None 500 lbs
Water Soluble Oils 100 gal* 30 gallons
Xylene (mixed isomers) 100 lbs (45.4 kg)
(approx. 13.9 gal) 50 gallons
Acetone 5,000 lb (2,270 kg)
(approx. 759 gal) 55 gallons (362 lbs)
Methyl Ethyl Ketone 5,000 lb (2,270 kg)
(approx. 745 gal) 55 gallons (369 lbs)
Toluene 1000 lbs (454 kg)
(approx. 138 gal) 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates) 100 gal* 0 gallons
Resin None 25 gallons
Epoxy Paints None 50 gallons
Epoxy Catalyst None 20 gallons
Oil Base paints None 25 gallons
Paint thinners None 40 gallons
Other paints None 20 gallons
1. This list includes all solvents and petroleum-based products in the Mill warehouse
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the
Clean Water Act."
3. If a spill occurs of a product that is a mixture of chemicals, Mill personnel will contact
EFRI Corporate Environmental Department.
4. Estimation of Reportable Quantities in L assumes pure compound (100%) concentration.
* These materials do not have an RQ under 40 CFR 110, 40 CFR 117, 40 CFR 302 or Utah
FIGURES
SUBSTÍ 10
SAMPLE PLANT cAu IC
BOILERS ITL 0E1
00
SODIUM
CHLORATE
OFFICE
TOPSOIL'
\GRIZZLY
OLD DECONTAMINATION
Q AMMONIUM u SULFATE
MILL °
BUILDING
SX
BUILDING o 0000
ob o°o CI
FUEL
ISLANDE
ALTERNATE
FEED CIRCUIT
DRY REAGENT
STORAGE
PVl DECONTA [NATION SCAL
HOUSE
c=1
REAGENT YARD 100 50 100 200
SCALE IN FEET
Energy Fuels
Energy Fuels Resources (USA) Inc 225 Union Blvd. Suite 600
Lakewood, CO 80228
TRUCK
SHOP REVISIONS WHITE MESA MILL
Date By County: San Juan State: Utah
10-11 GM Location:
5-14 DLS Figure 1
MILL SITE LAYOUT 4-16 RE
Scale: r=200' Date: May 12, 2000 Drafted By: D.Slec
Mill Site Layout 4.28.16.dwg Figure 11
RStON
BERM I
DRAINAGE BASIN "BS r 64 AC.
DRAI' AGE
BASIN
104.27 AC.
DRAINAGE BASIN "C"
BASIN "C"
60.43 AC. CELL 2-\
DRAINAGE BASIN "D"
78.3 AC.
SPILLWAY
CELL 4B
DRAINAGE BASIN "F"
44.67 AC.
CELL 4A
PMF CONTAINED
WITHIN BASIN DRAINAGE BASI
42.14 A.
1000 0
Sufrace Water Flow
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Ste 600
Lakewood, CO 80228
REVISIONS Project: White Mesa Mill
Drainage Basins Date By County: State: UT San Juan
10/24/07 BM Location:
Diversion Ditches 5/16/08 BM MILL SITE 6/11/08 BM Diversion Berm 12/9/08 DLS DRAINAGE BASINS
1000 2000 1/7/09 BM FIGURE 2
Environmental
Technician(s)
Chief Operating
Officer
CFO, General
Counsel, Corp
Secretary
Mill Operations
Personnel
Mill !Manager Senior Dir.
Regulatory Affairs
Mill RSO
Safety Coordinator Radiation Safety
Technician(s)
President & CEO
Figure 3
Energy Fuels Resources (USA) Inc.
Mill Management Organization Chart
REDLINE
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
Deeembef-12T20-160ctober 14, 2019
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
FENE RGY FUELS
_
I ,
Contents
1.0 OBJECTIVE 11-
1.1 Plan Organization 11-
2.0 RESPONSIBILITIES 2
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS 2
4.0 DESCRIPTION OF BASINS 2
4.1 Basin Al 2
4.2 Basin A2 2
4.3 Basin B1 2
4.4 Basin B2 33
4.5 Basin B3 33
4.6 Basin C 33
4.7 Basin D 33
4.8 Basin E 33
4.9 Basin F 33
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT 33
5.1 Reagent Tanks (Tank list included in Table 2.0) 44
5.2 Ammonia 44
5.3 Ammonium Meta-Vanadate 44
5.4 Caustic Storage (Sodium Hydroxide) 44
5.5 Sodium Carbonate (Soda Ash) 44
5.6 Sodium Chlorate 44
5.7 Sulfuric Acid 55
5.8 Vanadium Pentoxide 55
5.9 Kerosene (Organic) 55
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT 56
6.1 Petroleum Tanks 66

6.1.1 Diesel 66
6.2 Aboveground Fuel Pump Tanks 66

6.2.1 Diesel 66

6.2.2 Unleaded Gasoline 66

6.2.3 Pump Station 66
6.3 Used/Waste Oil 77
6. 4 Truck Unloading 77
7.0 SPILL DISCOVERY AND REMEDIAL ACTION 77
8.0 SPILL INCIDENT NOTIFICATION 88
8.1 External Notification 88
8.2 Internal Notification 88
9.0 RECORDS AND REPORTS 99
10.0 SPILL REPORTING REQUIREMENTS 1014
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES 104-0
11.1 Training Records 1044
11.2 Monitoring Reports 104-0
12.0 REVISION 104-0
13.0 MILL MANAGER APPROVAL 1144
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER 111-1-
15.0 SUMMARY 124-2
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN FOR
CHEMICALS AND PETROLEUM PRODUCTS
1.0 OBJECTIVE
The objective of the Spill Prevention, Control, and Countermeasures (SPCC) Plan is to serve
as a site-specific guideline for the prevention of and response to chemical and petroleum
spills. The plan outlines spill potentials, containment areas, and drainage characteristics of
the White Mesa Mill site. The plan addresses chemical spill prevention, spill potentials, spill
discovery, and spill notification procedures. Spills are reportable if the spill leaves the site.
Ammonia is the only chemical (as vapor) that has the potential to leave the site. In addition,
chemical and petroleum spills will be reported in accordance with applicable laws and
regulations.
1.1 Plan Organization
This SPCC is organized as follows:
Section 1.0 Objective
Section 2.0 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4.0 Description of Basins
Section 5.0 Potential Chemical Spill Sources and Spill Containment
Section 6.0 Potential Petroleum Spill Sources and Containment
Section 7.0 Spill Discovery and Remedial Action
Section 8.0 Spill Incident Notification
Section 9.0 Records and Reports
Section 10.0 Spill Reporting Requirements
Section 11.0 Personnel Training and Spill Prevention Procedures
Section 12.0 Revision
Section 13.0 Mill Manager Approval
Section 14.0 Certification by Registered Professional Engineer
Section 15.0 Summary
Tables:
Table 1.0 is the Energy Fuels Resources (USA) Inc. (EFRI) personnel
implementing this SPCC.
Table 2.0 lists the reagent tanks and their respective capacities.
Table 3.0 lists the laboratory chemicals, their typical ameufitsquantities in
reportable quantities.
Table 4.0 lists the reagent yardismall-quentity-ehemiealsand bulk chemical lis
Table 5.0 lists the chemicals in the reagent yard, their amounts, and
quantkieth,
Table 56.0 lists the petroleum products and solvents on site.
responsible for
stock, and their
t.
their reportable
1
Figures:
Figure 1 shows the Mill Site Layout, shows the mill site including the locations of the
chemical tanks on-site.
Figure 2 shows the basins and drainage ditch areas for the Mill Site.
Figure 3 shows the organization chart for Mill Operations.
2.0 RESPONSIBILITIES
Personnel responsible for spill prevention and follow-up spill reporting are included on Table
1 which is included in the Tables Tab of this SPCC.
3.0 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS
The main drainage pathways are illustrated in Figure 2. The map shows drainage basin
boundaries, flow paths, constructed diversion ditches, tailing cells, the spillway between Cell
2-3 and 34A, dikes, berms, and other relevant features. The White Mesa Mill is a "zero"
discharge facility for process liquid wastes. The mill area has been designed to ensure that
all spills or leaks from tanks will drain toward the lined tailing management system.
The management system, in turn, is operated with sufficient freeboard (minimum-et-three
feet freeboard as required by the Groundwater Discharge Permit [GWDP1) to withstand
100% of the PMP (Probable Maximum Precipitation). This allows for a maximum of 10
inches of rain at any given time.
Precipitation and unexpected spills from the mill site are contained within their prospective
drainage basins. Overflow ultimately drains into the tailings management system.
4.0 DESCRIPTION OF BASINS
4.1 Basin Al
Basin A1 is north of Cell 1 and Diversion Ditch No. 1. The basin contains 23 tributary acres,
all of which drain into Westwater Creek.
4.2 Basin A2
Basin A2 contains all of Cell 1 including an area south of the Diversion Ditch No. 1 and a
portion of Cell 2. The basin covers 84104.3 acres. Any overflow from this basin would be
contained within Cell 1.
4.3 Basin B1
Basin B1 is north of the mill area. The basin contains 45.4 tributary acres.
Overflow from this basin drains into a flood retention area by flowing through Diversion
Ditch No. 2. Diversion Ditch No. 2 drains into Westwater Creek.
4.4 Basin B2
Basin B2 is northeast of the mill area and contains only 2.6 tributary acres. Overflow from
this basin would drain into Diversion Ditch No. 3. Diversion Ditch No. 3 ultimately drains
into Diversion Ditch No. 2.
4.5 Basin B3
Basin B3 contains most of the mill area, buildings, ore stockpiles, process storage tanks,
retention ponds, spill containment structures, pipelines, and roadways. The normal direction
of flow in this basin is from the northwest to the southwest. Any overflow from this basin
would drain into Cell 1 . The basin contains 64 acres. This basin has sufficient freeboard to
withstand 100% of the PMP (Probable Maximum Precipitation). This allows 10 inches of
rain for any given storm event.
4.6 Basin C
Basin C contains a portion 11 of Cell 2. The basin consists of 80,760.4 acres. Areas in this
basin also include earth stockpiles and the heavy equipment shop. The direction of flow in
this basin is to the south-southwest. All overflows in this basin is channeled along the
southern edge of the basin. Overflow then flows into Cell 3 via-the-spillway-frem-along the
length of the boundary between Cell 2 te-and Cell 3.
4.7 Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including a portion of the
slopes of the topsoil stockpile and random stockpile. The basin contains all flows, including
those caused by the PMP.
4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4A.
4.9 Basin F
Basin F contains Cell 4B, and consists of 40 acres. All anticipated flows including those
caused by the PMP will be contained within the basin and will flow directly into Cell 4B.
5.0 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT
Routine monitoring is conducted of the reagent tanks and storage areas. Daily visual
monitoring of the reagent tanks and storage areas are conducted during the twice-daily shift
inspections. Weekly visual monitoring of the tank supports and foundations are conducted
3
by the Radiation Safety Officer ("RSO") or designee. The scope of the daily and weekly
visual monitoring includes an inspection for leaks or visual structural abnormalities. Any
issues identified during the routine visual monitoring would be noted as such on the
associated documentation. If no issues are noted, the system, tanks or storage area condition
was considered acceptable.
5.1 Reagent Tanks (Tank list included in Table 2.0)
5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of 31,409 gallons each. The
tanks are located southeast of the Mill building.
Integrity inspections will be conducted to minimize the hazard associated with ammonia.
The reportable quantity for an ammonia spill is 7 gallons.
Ammonia spills should be treated as gaseous. Ammonia vapors will be monitored closely to
minimize the hazard associated with inhalation. If vapors are detected, efforts will be made
to stop or repair the leak expeditiously. Ammonia is the only chemical (as vapor) that has the
potential to leave the site.
5.3 Ammonium Meta-Vanadate
Ammonium meta-vanadate is present in the vanadium precipitation area of the Mill building
as the process solutions move through the circuit to produce the vanadium end product.
Spills would be contained in the process sump within the vanadium precipitation area. The
reportable spill quantity for ammonium meta-vanadate is 1,000 pounds.
5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner of the SX
building. The tank has a capacity of 19,904 gallons. The tank supports are mounted on a
concrete curbed catchment pad which directs spills into the sand filter sump in the northwest
corner of the SX building. The reportable spill quantity for sodium hydroxide is 85 gallons.
5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located outside the
northeast corner of the SX building. Spills from the soda ash solution tank are contained in
the North SX impound and run to Cell 1. The smaller soda ash shift tank has a capacity of
8,530 gallons and is located in the SX building. Spills will be diverted into the boiler area,
and would ultimately drain into Cell 1. There is no reportable spill quantity associated with
sodium carbonate.
5.6 Sodium Chlorate
Sodium chlorate tanks consist of three fiberglass tanks located within a dike east of the SX
building. Tank maximum volumes of the three tanks are 16,075, 21,057 and 28,788 gallons.
4
Integrity inspections will be conducted to minimize the hazard associated with sodium
chlorate.
Sodium chlorate that has dried and solidified becomes even more of a safety hazard due to its
extremely flammable nature. The reportable spill quantity for sodium chlorate is 400
gallons.
5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of 1,600,000
gallons and one smaller tank with a capacity of 11,000 gallons.
The large tank is located in the northwest corner of mill area basin B3 and is primarily used
for acid storage and unloading. The tank support for the large tank is on a mound above a
depression which would contain a significant spill. All flows resulting would be channeled
to Cell 1. The tank is equipped with a high level audible alarm which sounds prior to tank
overflows. A concrete spill catchment with a sump in the back provides added containment
around the base of the tank. However, the catchment basin would not be able to handle a
major tank failure such as a tank rupture. The resulting overflow would flow towards Cell 1.
The smaller storage tank is located on the north side of the SX building. The tank is
equipped with a high level audible alarm.
The reportable spill quantity for sulfuric acid is 65 gallons.
5.8 Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the drying and fusing
circuits and is not present in the vanadium circuit until after the deammoniator. Efforts will
be made to minimize leaks or line breaks that may occur in processes in the circuit that
contain vanadium pentoxide. Special care will be taken in the transportation of this chemical.
The reportable spill quantity for vanadium pentoxide is 1000 pounds.
5.9 Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a combined capacity of
10,152 gallons in three tanks. Any overflow from these three tanks would flow around the
south side of the SX building and then into Cell 1. These tanks have drain valves which
remain locked unless personnel are supervising draining operations. The reportable spill
quantity for kerosene is 100 gallons.
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
Routine inspections are conducted of the petroleum containment, tanks, and storage areas.
Daily visual monitoring of the petroleum containment, tanks, and storage areas are conducted
during the twice-daily shift inspections. Weekly visual monitoring of the tank supports and
foundations are conducted by the RSO. The scope of the daily and weekly visual monitoring
includes an inspection for leaks or visual structural abnormalities. Any issues identified
5
during the routine visual monitoring would be noted as such on the associated
documentation. If no issues are noted, the system, tanks or storage area condition was
considered acceptable.
Annual visual inspections of the used/waste oil and fuels tanks will be completed as
discussed in the Discharge Minimization and Technology Monitoring Plan, Revision 12.4,
Section 4.3.
6.1 Petroleum Tanks
6.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The tanks have
capacities of 250 gallons each. One of the diesel tanks is for the emergency generator.
The other tank is located in the pumphouse on an elevated stand. Spillage from either
tank would ultimately flow into Cell 1. The reportable spill quantity for diesel is 100
gallons. The spill is also reportable if the spill has the potential for reaching any nearby
surface waters or ground waters.
6.2 Aboveground Fuel Pump Tanks
6.2.1 Diesel
The diesel tank is located on the east boundary of Basin B3 and has a capacity of 6,000
gallons. The tank is contained within a concrete catchment pad. The reportable spill
quantity for diesel is 100 gallons. A diesel spill is also reportable if the spill has the
potential for reaching any surface waters or ground waters.
6.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded gasoline tank
has a capacity of 3,000 gallons and is contained within the same containment system as
the diesel tank. Spills having the potential for reaching any surface waters or ground
waters will need to be reported. The reportable spill quantity for unleaded gasoline is 100
gallons.
6.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling company
vehicles used around the mill site. The pump station is equipped with an emergency
shut-off device in case of overflow during fueling. In addition, the station is also
equipped with a piston leak detector and emergency vent. Check valves are present along
with a tank monitor console with a leak detection system. The catchment is able to
handle a complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a temporary berm
would need to be constructed. Absorbent diapers or floor sweep would be used in an
effort to limit and contain the spill. The soil would have to be cleaned up and placed in
the Cell currently used for the disposal of solid Mill wastes.
6
6.3 Used/Waste Oil
Used/ Waste oil is located north of the maintenance shop in a tank and has a capacity of
5,000 gallons. The tank is contained within a concrete containment system. Used oil will be
disposed of on site or sent to an EPA permitted recycling facility. Any oil escaping the
concrete containment system will be cleaned up. Soil contaminated with used oil will be
excavated and disposed of in the Cell currently used for the disposal of solid Mill wastes.
6. 4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill area, proper
reporting and containment procedures will be followed when warranted, such as when oil or
diesel fuel is spilled. Proper clean-up procedures will be followed to minimize or limit the
spill. The spill may be temporarily bermed or localized with absorbent compounds. Any
soils contaminated with diesel fuel or oil will be cleaned up and placed in the Cell currently
used for the disposal of solid Mill wastes.
7.0 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take measures to
limit additional spillage and contain the spill that has already occurred. Chemical or
petroleum spills will be handled as follows:
• The Shift Foreman will direct efforts to shut down systems, if possible, to limit
further release.
• The Shift Foreman will also secure help if operators are requiring additional
assistance to contain the spill.
• The Shift Foreman is also obligated to initiate reporting procedures.
• Once control measures have begun and personal danger is minimized, the Shift
Foreman will notify the Production Superintendent, Maintenance Superintendent,
or Mill Manager.
• The Production or Maintenance Superintendent will notify the Mill Manager, who
in turn will notify the EH&S Manager and/orRSO and —the Environmental
Coordinator.
• The Mill Manager will assess the spill and related damage and direct remedial
actions. The corrective actions may include repairs, clean-up, disposal, and
company notifications. Government notifications may be necessary in some
cases.
If a major spill continues uncontrolled, these alternatives will be considered:
I. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
7
8.0 SPILL INCIDENT NOTIFICATION
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
1. EPA National Response Center 1-800-424-8802
2. US Nuclear Regulatory Commission 301-816-5100
3. State of Utah 801-538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301-816-5100
2. State of Utah, Natural Resources 801-538-7200
8.2 Internal Notification
Internal reporting requirements for incidents, spills, and significant spills are as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits operations or assesses
penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-product
8
In the event of a spill requiring reporting, the Mill Manager is required to call the RSO,
Quality Assurance Manager, the Executive Vice President Conventional OperationsChief
Operating Officer, and/or the President and Chief Executive Officer. The spill will first be
reported to the Shift Foreman. The Shift Foreman will then report the spill to the Mill
Superintendent, Maintenance Superintendent, or Mill Manager.
The Mill or Maintenance Superintendent will report to the Mill Manager. The EH&S
ManagerRSO and the Quality Assurance Manager will be contacted by the Mill Manager.
Name Title
Mill Personnel:
Logan Shumway Mill Manager
David TurkTerry Slade EH&S ManagerRSO
97863545
Home Phone
[phone]
(435) 459-

Garrin Palmer Assiatant RSO/Mill Environmental Compliance (435)
459-9463
Coordinator
Thayne Holt Production Superintendent [phone]
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Stephen P. AntonyMark Chalmers President and Chief Executive
Officer (303) 974 2142389-
4155
Harold R. RobertsPaul Goranson Executive Vice President
Conventional OperationsChief Operating Officer (303) 389-41680
Scott Bakken Sr. Director, Regulatory Affairs [phone]
Kathy Weinel Quality Assurance Manager [phone]
In the event the next person in the chain-of-command cannot be reached, then proceed up the
chain-of-command to the next level. Figure 3.0 shows the organizational chart for the mill
site.
9.0 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the Environmental
or Maintenance Department for inspection and review for a minimum of five years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
9
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thicknesa
d. Quarterly Tailings Inspection
e. Daily Operating Foreman and weekly RSO inspection reports
2. Tank-t-e-seil-petential-measucements
32. Annual used/waste oil and fuel tank visual inspections
43. Tank thickness tests
54. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
65. Tank supports and foundation inspections
76. Spill Incident reports
87. Latest revision of SPCC plan
10.0 SPILL REPORTING REQUIREMENTS
1. Report to applicable government agency as required by laws and regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of spill
impacts
4. Report release of 5,000 pounds or more of any process material or waste product
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES
All new employees are instructed on spills at the time they are employed and trained. They
are briefed on chemical and petroleum spill prevention and control. They are informed that
leaks in piping, valves, and sudden discharges from tanks should be reported immediately.
Abnormal flows from ditches or impoundments are of immediate concern. In addition, a
safety meeting is presented annually by the Environmental Coordinator to review the SPCC
plan.
11.1 Training Records
Employee training records on chemical and petroleum spill prevention are maintained in the
general safety training files.
11.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
12.0 REVISION
This procedure is to be reviewed by the mill staff and a registered professional engineer at
least once every three years, and updated when circumstances warrant a revision.
1 0
13.0 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with the Standard
Operating Procedures currently in effect.
Logan S humw ay
Mill Manager
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum product SPCC
plan, that I am familiar with the Energy Fuels Resources (USA) Inc. White Mesa Mill
facilities, and attest that this SPCC plan has been prepared in accordance with good
engineering practices.
Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
11
15.0 SUMMARY
Chemical and petroleum spills will be reported in accordance with applicable laws and
regulations. Spills that leave the property need to be reported immediately. Each spill
will be assessed and reported as required by the applicable regulations. Reportable
quantities are shown in the attached tables.
12
TABLES
FIGURES
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
May4October 14, 20196
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
Best Management Practices Plan
Revision 1.56: 114a0ctober 20162019
TABLE OF CONTENTS
1.0 INTRODUCTION/PURPOSE 24
2.0 SCOPE 33
3.0 RESPONSIBILITY 44
4.0 BEST MANAGEMENT PRACTICES 5S
4.1 General Management Practices Applicable to All Areas 5S
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: 5S
4.1.2 Keep Potential Pollutants from Contact with Precipitation 5S
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels
4.2
within the Process and Reagent Storage Area
4.1.5 Recycle Fluids Whenever Possible.
Management Practices for Process and Laboratory Areas
5S
5S
66
4.2.1 Clean Up Spills Properly 66
4.2.2 Protect Materials Stored Outdoors 66
4.2.3 Management 66
4.2.4 Materials Management 66
4.3 Management Practices for Maintenance Activities 77
4.3.1 Keep a Clean Dry Shop 77
4.3.2 Manage Vehicle Fluids 77
4.3.3 Use Controls During Paint Removal 77
4.3.4 Use Controls During Paint Application and Cleanup 77
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment 77
4.4.1 Wash Down Vehicles and Equipment in Proper Areas 87
4.4.2 Manage Stockpiles to Prevent Windborne Contamination 88
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources 88
Figures
Figure 1: White Mesa Mill Site Layout
Figure 2: White Mesa Mill Site Drainage Basins
Figure 3: Energy Fuels Resources (USA) Inc.- White Mesa Mill Management Organization Chart
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP
TABLE 2.0: REAGENT YARD LIST
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST
TABLE/1.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST
TABLE 45.0: REAGENT YARD/ AND BULK CHEMICALS LIST
TABLE 56.0: PETROLEUM PRODUCTS AND SOLVENTS LIST
Page 1
Best Management Practices Plan
Revision 1.56: MrpfrOctober 20162019
1.0 INTRODUCTION/PURPOSE
Energy Fuels Resources (USA) Inc. CEFRI") operates the White Mesa Uranium Mill (the "Mill")
in Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect
to water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to EFRI on March 8,
2005. As a part of compliance with the Permit, EFRI is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Director of the Division of Waste Management and
Radiation Control ("DWMRC"), Utah Department of Environmental Quality. This BMPP
presents operational and management practices to minimize or prevent spills of chemicals or
hazardous materials, which could result in contaminated surface water effluents potentially
impacting surface waters or ground waters through runoff or discharge connections to stormwater
or surface water drainage routes. Although the Mill, by design, cannot directly impact
stormwater, surface water, or groundwater, the Mill implements these practices in a good faith
effort to minimize all sources of pollution at the site.
Page 2
Best Management Practices Plan
Revision 1.56: May-October 204-62019
2.0 SCOPE
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings management impoundments in accordance with the
Mill's Radioactive Materials License ("RML") #UT1900479 conditions. All of the process and
laboratory building sinks, sumps, and floor drains are tied to the transfer lines to the tailings
impoundments. A site map of the Mill is provided in Figure 1 . A sketch of the site drainage
basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by RML to manage some spills via draining or wash down
to the process sewers, and ultimately the tailings management system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
This BMPP addresses the management of stormwater, and the prevention of spills of chemicals
and hazardous materials, at the Mill site. Detailed requirements and methods for management,
recordkeeping, and documentation of hazardous material spills are addressed separately in the
EFRI White Mesa Mill Spill Prevention, Control and Countermeasures ("SPCC") Plan, the
Emergency Response Plan ("ERP"), and the housekeeping procedures incorporated in the White
Mesa Mill Standard Operating Procedures ("SOPs").
Page 3
Best Management Practices Plan
Revision 1.56: May-October 20162019
3.0 RESPONSIBILITY
All Mill personnel are responsible for implementation of the practices in this BMPP. EFRI White
Mesa Mill management is responsible for providing the facilities or equipment necessary to
implement the practices in this BMPP.
The EFRI Corporate Management and Mill Management Organization is presented in Figure 3.
An updated spill prevention and control notification list is provided in Table 1.
Page 4
Best Management Practices Plan
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Revision 1.56: May-October 294-62019
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
9 Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
the RML. Areas requiring maintenance or repair, such as excessive vegetative growth,
channel erosion or pooling of surface water runoff, will be reported to site management
and maintenance departments for necessary action to repair damage or perform
reconstruction in order for the control feature to perform as intended. Status of
maintenance or repairs will be documented during follow up inspections and additional
action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings management system for disposal.
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Best Management Practices Plan
Revision 156: May-October 20162019
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D.10.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE") near the areas where they may be needed for spill response.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
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Best Management Practices Plan
Revision 1.56: May-October 204-62019
4.3 Managernent Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings management system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings management system.
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
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4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only in areas designated for this purpose
(such as wash down pad areas and decontamination pads).
• At the decontamination pads, make sure the water collection and recycling system is working
before turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water. Keep surfaces moist but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary.
• Seed or plant temporary vegetation for erosion control on slopes.
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TABLES
FIGURES