DRC-2014-006264 - 0901a068804ab561

--1 * 0Ai Department of
Environmental Quality
Amanda Smith
Executive Director
FILE
SF
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
DRC-2014-006264
October 20, 2014
CERTIFIED MAIL
(Return Receipt Requested)
Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd.
Suite 600
Lakewood, CO 80228
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Kathy Weinel
Energy Fuels Resources (USA) Inc
225 Union Blvd
msiaie:™ Lakewood co 80228
PS Form 3800, June 2002 See Reverse for Instructions
Subject: Transmittal of Findings of the Utah Division of Radiation Control September 23, 2014
Storm Water Inspection at the White Mesa Uranium Mill: DRC Request for
Information
Dear Ms. Weinel:
Representatives of the Utah Division of Radiation Control ("DRC") conducted a storm water
inspection at the White Mesa Uranium Mill on September 23, 2014. A copy ofthe DRC Review
Memo (DRC Groundwater Module 65) is attached for your information.
Per the inspection findings, DRC has the following requests for information:
Request for Information:
1. DRC noted that large erosion rills were present on the east side of the fueling island (north
of the new decontamination pad) where it was apparent that storm water had flowed east
from of the pad area. The erosion was observed continuing into the vegetated areas
beyond the chain-link fence which delineates the ore pad. This has been an ongoing area
of concern per previous DRC inspections. DRC notes that there is no berm along the
margins of the ore storage pad in this area and the pad is graded to discharge water in a
south easterly direction along the eastern pad margin. Additionally, since there is an
existing berm on areas north of the area of concern, a significant amount of storm water
runoff is channeled along the berm (southward) towards the non bermed area and there is
potential for considerable run off out of the fenced area at that spot. Based on the
observed erosion rills, it appears that this was the case previous to the inspection.
Per DRC Staff discussion with onsite EFR representatives, it was noted that the area needs
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^1097 • T.D.D. [phone]
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Printed on 100% recycled paper
Kathy Weinel
Page 2
additional erosion and/or sediment controls to ensure that contaminated soil from the ore
pad does not wash out ofthe restricted area (The restricted area was reported by EFR
Representatives to be bounded by a wire fence about 100 feet east of the chain-link fence).
Per discussion during the inspection close-out meeting it was discussed that DRC would
likely issue a request for information regarding this issue and that EFR would need to
provide a proposal for sediment and/or erosion controls at this ore pad location.
Please provide a response to DRC within 30 calendar days of your receipt of this letter
with proposed sediment and/or erosion controls to be installed at this area of the ore pad
(e.g. continuation of the perimeter berm). Also, please provide a proposed timeline for
installation of the controls.
2. DRC noted during the inspection that the Roberts Pond Liner had been removed and that
contaminated soils had been removed in anticipation of re-grading the area. The Roberts
Pond excavation (pit) was observed during the inspection. DRC notes that storm water
drainage (and other drainage) from areas of the Mill are directed to discharge where
Roberts Pond was in use. Within 30 days of your receipt of this letter, please provide
information regarding how these discharges will be directed and discharged in the future.
If you have questions or concerns regarding this letter please contact Tom Rushing at (801) 536-
Rusty Lundberg
Director
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Attachments: DRC 2014 Module 65
U AMON_WAST\Trushing\Energy Fuels\Storm Water Management\2014 SW InspectiorAWhite Mesa Mill 2014 SW Inspection DRC RFI docx
0080.
Sincerely,
Utah Division of Radiation Control (DRC)
Ground Water Module 65, DRC Annual Storm Water Inspection
Denison Mines, White Mesa Uranium Mill, Ground Water Permit UGW370004
Inspection Year: 2014
Inspection Date: September 23, 2014
Module Reviewer Name/Initials:
Phil Goble, Compliance Section Manager pu IO/'/M
Module Prepared by/Date Prepared:
Tom Rushing, P.G./October 16, 2014 -Jt fid*"
DRC Staff Present: Tom Rushing
Denison Mines Staff Present: David Turk
Tanner Holliday
Garrin Palmer
Denison Mines Staff Interviewed: David Turk
Tanner Holliday
Garrin Palmer
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the
White Mesa Uranium Mill:
Date: September, 2012
Revision No. 1.5
Section I - Document Review
SWBMPP (Documentation Requirements):
Part 4.1.4. — Diversion ditches, drainage channels and surface water control structures
in and around the Mill area will be inspected at least weekly. Areas requiring
maintenance or repair, such as excessive vegetative growth channel erosion or pooling
of surface water runoff, will be reported to appropriate departments and all follow up
actions are to be documented.
The Utah Division of Radiation Control ("DRC") conducted an inspection of upland
Diversion Ditches 1 and 2; and Diversion Berms 1 and 2 as shown on the Energy Fuels
Resources ("EFR") Storm Water Best Management Practices Plan, Figure 2. DRC also
Findings:
1
inspected the outfall locations for Diversion Ditch 1 and 2 to verify the directions of upland
drainage (ensure that drainage is directed to areas distant from the Mill Facility).
DRC found Ditch 1 and berms to be adequately maintained, it was noted that in some areas
there was standing water present, indicating that the ditch was not correctly graded. Photos
of Ditch 1 and the outfall location, taken during the day of the inspection are included the
Memo Appendix 1. DRC notes that storm water entering Ditch 1 is draining toward the
west, fans out onto areas of Dakota/Burro Canyon Fm. Outcrop, and ultimately into the
Westwater Creek Drainage.
DRC found Ditch 2 and berms to be well maintained (Photos included in Appendix 1).
Drainage is towards the north and drained water is diverted to a vegetated area. It was noted
that the Mill property berms are at a higher elevation than the Ditch 2 outfall and water is not
expected to run onto the Mill confines.
EFR inspects the diversion ditches and berms monthly and inspection "findings" fields are
included on the monthly inspection data form. DRC reviewed the March 31, 2014 monthly
form and noted that the EFR Inspector (Garrin Palmer) noted that the Diversion Ditches 1, 2
and 3 showed no sloughing, erosion, undesirable vegetation or obstructions of flow with the
exception of erosion at Diversion Ditch 1. The form notes that "diversion ditches are still in
good working condition. Waiting for plan from Ryan Ellis to make repairs on erosion
channels." Per discussion with David Turk it was noted that an engineering plan was created
by Ryan Ellis to improve drainage from Diversion Ditch 1 due to EFR observations that the
ditch was retaining water in some spots. It was noted that the ditch had been re-graded per
the engineering plan but was still detaining water at some spots. EFR reported that more
work would be done to the ditch to eliminate standing water.
Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DRC August 8, 2012 request for information which
stated as follows: "The EFR Spill Prevention, Control, and Countermeasures Plan, Part
1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include
the inspection findings with the daily inspection form used for storm water inspection
documentation within 30 days from your receipt of this letter" EFR has removed the daily
inspection requirement on the basis that the propane is a gas at ambient conditions and would
be immediately vaporized under all foreseeable leakage conditions at the Mill. DRC
concurred with this action and this item has been removed from the storm water inspection at
the mill.
1.9.1. - External Notification of "reportable quantity" spills.
Findings: No reportable quantity spills occurred during the period reviewed, DRC has no
additional comments.
2
1.9.2. Internal Notification of incidents, spills, and significant spills.
Performance Standards (list):
In response to a DRC Request for Information item by letter dated September 1,2011,
regarding the findings of the DRC 2010 storm water inspection, EFR provided a change to
the small quantity spills protocols in the October 17, 2011 response letter, as follows:
"EFR has implanted an internal notification process for small quantity spills (less than
reportable quantities), with the following steps:
1) Mill environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size. The form will be amended to add spaces for this item.
2) In addition, all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day, and these will also be noted in the daily
inspection form.
3) Ifthe spill is of a reportable quantity, environmental personnel will follow the procedures
in the Mill's SWBMPP plan.
4) For spills smaller than reportable quantities, the environmental inspector will record
information regarding the spill, and the nature and type of cleanup, on the form.
5) The information on the inspection form will be added to a database maintained at the Mill.
The database will be updated and maintained on site indefinitely. Cards are maintained for
no longer than one year."
The White Mesa Mill employees are using an orange card to report the small quantity spills;
the card is titled "Non-Reportable Reportable Spillage". The card provides the following
information: Name, Date of Discovery, Approximate Amount Spilled, Time of Discovery,
Location of Incident, Description of Material Spilled, Cleanup Activities Taken and
Signature. Per the orange cards, the following spills were recorded from June 4, 2013 (Date
of the last DRC Stormwater Inspection) until the date of the inspection (October 16, 2014).
Date of
Discovery
Material Spilled Quantity Spilled
6/5/2013 Oil and Antifreeze 3 gallons
6/6/2013 Hydraulic Fluid 0.5 gallon
6/29/2013 Oil 55 gallons
7/8/2013 Descaler 55 gallons
7/9/2013 Oil 4 gallons
7/10/2013 Sulfuric Acid 10 gallons
7/24/2013 Hydraulic Fluid 10 gallons
7/29/2013 Process Solution 30 gallons
8/20/2013 Pond Return Solution 50 gallons
8/20/2013 CCD Process Solutions 850 gallons
8/21/2013 Salt Crystals 1 gallon
8/27/2013 Sulfuric Acid 55 gallons
8/30/2013 Soda Ash 1,800 lbs
3
Date of
Discovery
Material Spilled Quantity Spilled
9/13/2013 Soda Ash 3 gallons
9/24/2013 Diesel 1 gallon
10/1/2013 Tailings Solution 200 gallons
10/8/2013 UF4 Acid Solutions 2 gallons
10/14/2013 Unknown Solution 1 gallon
10/17/2013 Pica Lite (filter aid) 200 lbs.
10/29/2013 Liquid UF4 550 gallons
10/30/2013 Pond Return Solutions 500 gallons
11/12/2013 Raffinate 1500 gallons
11/19/2013 Raffinate 0.5 gallon
12/17/2013 Used Oil 1 quart
1/3/2014 Process Solution 50 gallons
1/20/2014 Pond Return Solution 200 gallons
2/5/2014 Hydrogen Peroxide 60 gallons
3/14/2014 Pond Return Solution 50 gallons
3/25/2014 Raffinate 175 gallons
4/10/2014 Caustic Soda 10 gallons
5/4/2014 Sulfuric Acid 4 gallons
6/29/2014 Sulfuric Acid 20 gallons
6/29/2014 Soda Ash 40 lbs.
8/12/2014 Sulfuric Acid 15 gallons
8/20/2014 Slurry/Pond Return 500 gallons
9/19/2014 Soda Ash 10 gallons
DRC sees the new spill reporting process as very effective. EFR has additionally started
attaching photographs ofthe spill and clean-up activities to the orange card when deemed
appropriate and is tracking the spills and follow-up actions on a spread sheet (White Mesa
Spill Log).
DRC notes that the spill reporting training program required under the requirements of the
Spill Prevention, Control, and Countermeasures Plan for Chemicals and Petroleum Product,
Section 1.11., and also outlined in the EFR response as a corrective action, continues to be
improved.
EFR has implemented the training program in two parts, training is required for the
environmental personnel at the mill and is required of all employees at the mill. Per the
attendance logs, all environmental personnel (3 people) attended the training on 1/2/2014 and
all other mill employees received the training, as part of a safety meeting, as follows:
4/30/2014 - 20 employees
5/2/2014 - 13 employees
5/6/2014-40 employees
5/12/2014-20 employees
5/13/2014-1 employee
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Total employees trained - 94
The employee training is very effective. The spill reporting provides records of identification
and follow-up procedures thereby making the chemical management at the mill transparent
and supports employee involvement in spill identification, reporting and follow-up.
1.10 Records and Reports.
Period of Records Examined During Inspection:
Begin/Ending: 3/1/2014 through 3/31/2014
No. of On-site Records Required: Daily, Weekly and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: 10% (Percent of Total)
How Selected: DRC Inspected a month of daily, weekly and monthly forms
completed since the last annual DRC Storm Water Inspection.
Daily Tailings Inspection Data:
Findings:
EFR inspection of: 1. Tailings slurry transport system (Slurry pipeline, pipeline joints and
supports, valves and point of discharge); 2. Operational systems (water level, beach, liner
and cover); 3. Dikes and embankments (slopes and crest) to check for erosion and seepage; 4.
Physical inspection of the slurry lines, and; 5. Dust control and leak detection, are conducted
daily and documented on a daily inspection form. The forms additionally include fields for
observations of potential concerns and action required. Spills and clean up actions are noted
in the text boxes for these fields.
DRC randomly selected and reviewed all of the daily forms for the months of March 2014.
The forms appeared to be appropriate and inspections were conducted on all days. There are
no additional comments regarding the forms.
Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings
inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection
Manual Section 3.1.). The forms include sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, 4B and
Roberts Pond, as well as slimes drain liquid levels in Cell 2, Existing decontamination Pad
and general tailing area. The form also includes information regarding the leak detection
systems for Cells 1, 2, 3, 4 A and 4B as well as the potential blowing of tailings, and
condition of concrete at the new decontamination pad.
Per the 2014 DRC storm water inspection, the inspection forms reviewed appeared to be
completed appropriately. There are no additional comments regarding the forms.
5
Monthly Tailings Inspection, Pipeline Thickness:
Findings:
The monthly inspection report includes; 1. A summary of the slurry pipeline condition and
measurement of pipe thickness (applicable only when the Mill is operational); 2. Inspection
protocols and observations related to the diversion ditches, berms, sedimentation pond, dust
control, settlement monitors, and slimes drain static head measurements for Cells 2 and 3.
DRC reviewed the EFR monthly inspection report dated March 31, 2014. Note that the
monthly inspection reports include comments related to the upland diversion ditches which
noted erosion at Diversion Ditch 1 and that, "ditches are still in working condition." The
form also noted a leak in the slurry pipeline (pond return line), and a tear in the liner of the
sedimentation pond. The form also notes that digging had taken place on the Ivans property
north of the mill to upgrade ponds for potential mill use, and that sampling of Cottonwood
Creek had taken place. The monthly report also noted that NESHAP sampling for cells 2 and
3 had been completed. It was noted that the Mill was not actively processing ore or alternate
feed at the time of the inspection.
There are no additional DRC comments regarding the monthly forms.
Tank to soil potential measurements:
Findings:
This item was included as part of a September 1, 2011 DRC Request for Information
("RFI"), RFI # 2. DRC had concerns regarding on-grade tanks (tanks where the bottom is in
contact with soil. Per DRC communication with EFR it was clarified that tanks which sit on
the ground must have cathodic protection or sit on a concrete foundation.
Per DRC inspection of the tank foundations during the 2014 inspection, all concrete
foundations inspected appeared in good condition.
Annual bulk oil and fuel tank visual inspections:
Findings:
In response to a DRC request for information, EFR reviewed the White Mesa Mill Spill
Prevention Countermeasure and Control ("SPCC") Plan for the Mill to ensure that all
inspection processes and oil containers are in conformance with those Federal (40CFR112)
regulations. In response (EFR September 7,2012 letter), EFR removed the SPCC Plan as an
appendix to the SWBMPP. EFR additionally removed the Emergency Response Plan as an
appendix to the SWBMPP. The removal of these documents was done in order to maintain
each plan as a stand-alone document. EFR states in the September 7, 2012 letter that "the
requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are not part of the SWBMPP and are addressed separately in other
documents, specifically, the Spill Prevention control and Countermeasures Plan, the
6
Emergency Response Plan, and the housekeeping procedures within Mill SOP's." Per
comments related to inspection of the propane tanks and applicability of those requirements
in the SPCC Plan, a revised copy was submitted with the September 7,2012 letter (SPCC
Plan dated September, 2012).
DRC has no additional comments regarding the SPCC Plan, DRC storm water inspections
focus on insuring that the SWBMPP adequately addresses all requirements of the Permit,
including spill reporting requirements in Part I.D. 10, which specifically requires actions for
identification and cleanup of reagent and chemical spills for non-reportable quantities and
procedures for reportable quantity spills in conformance with Utah Administrative Code 19-
5-114.
Tank and pipeline thickness tests:
Findings: During the inspection period the slurry pipelines were noted to be in good
condition by EFR. DRC has no additional comments related to the pipeline tests.
Quarterly and annual PCB transformer inspections (currently PCB only):
Findings: The Mill currently does not inspect the transformers based on all transformers
containing non-PCB based oil.
Spill Incident Reports:
Findings: This item is discussed above in the section related to reportable and small quantity
spills. DRC notes that an effective spill reporting and tracking system has been implemented
at the Mill.
Latest revision of SPCC plan (onsite and available?):
Findings: The SPCC plan was not requested during the inspection.
1.11 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files):
Personnel training for spill prevention are discussed in the internal notification of spills
section of this module above. Per DRC findings the personnel training has been
implemented and appears to be effective. All Mill staff received training regarding the small
quantity spill notification process. DRC has no additional comments related to personnel
training.
Section II — Site Walk through Inspection
Areas and Observations:
Ore Storage:
7
Observations: DRC noted that large erosion rills were present on the east side of the fueling
island (north ofthe new decontamination pad) where storm water had apparently flowed
from the pad, through the chain link fence, and the erosion was observed to continue into the
vegetated areas. This has been an ongoing area of concern per previous years DRC
inspections. The area has been a concern since there is no berm along the margins of the ore
storage pad in this area and the pad is graded to discharge water in a south easterly direction
along most of the eastern pad margin. Additionally, since there is an existing berm on areas
north of the area of concern, a significant amount of storm water runoff is channeled along
the berm (southward) towards the non bermed area and there is potential for considerable run
off out of the fenced area at that spot. Based on the observed erosion rills, it appears that this
was the case previous to the inspection.
Per DRC Staff discussion with onsite EFR representatives, it was agreed that the area needs
additional erosion and/or sediment controls to ensure that contaminated soil from the ore pad
does not wash out of the restricted area. DRC is including a request for information for EFR
plans to reduce the potential for offsite drainage from the area of concern.
Reagent Yard:
No comments regarding the reagent yard.
Shop/Vehicle Maintenance Area:
DRC notes that areas inside of the vehicle maintenance shop and surrounding area were
designed to drain to Roberts Pond. Since the pond has been removed DRC will request
information regarding where these areas will drain in the future.
Mill Processing Areas:
SX Building Roof Drainage:
As discussed above, the north end of the SX building roof is designed to drain to pre-existing
Roberts Pond. Since the pond has been removed, DRC will request information regarding
the new discharge location for the drainage.
Alternate Feed Circuit South of SX Building:
Observations:
The Mill was not processing alternate feed at the time of the inspection. No drums were
stored on the staging areas and no active draining was occurring inside ofthe alternate feed
processing area. DRC has no additional comments/observations regarding the alternate feed
area.
Old Decontamination Pad:
DRC has no comments regarding the old decontamination pad.
8
New Decontamination Pad:
Observations:
The pump back system and east apron drainage appeared to be in good condition. DRC
noted that very little water was present in the storage/baffle boxes used by the
decontamination process. Per EFR representatives this was due to very few vehicles
requiring decontamination because of inactivity at the Mill. DRC staff had no additional
comments.
Reagent Tanks:
Sodium Chloride Tanks - Per past agreements between DRC and EFR (Agreements made
in 2005) the secondary containment for these tanks is earthen. Per the agreement, all reagent
tanks that pre-existed the Ground Water Permit (3/05) would be acceptable as is - and that as
upgrades or replacements were installed, EFR would work to meet BAT requirements. More
detail regarding this agreement is in the December 2004 Statement of Basis, and in Part
I.D.3(g). No issues were noted during the 2014 inspection.
Kerosene Tanks (West of Shop) - Keronsene tanks were not observed during the inspection.
Ammonia Tanks - Secondary containment is earthen per the same agreement as the sodium
chloride tanks. DRC had no comments regarding the ammonia tanks.
Used Oil Tank (shop) - Used oil tank was not observed during inspection.
Kerosene Tank (shop) - Kerosene tank was not observed during inspection.
Fuel Tanks - Above ground tanks and containment appeared maintained, no additional
comments.
Uranium Liquor Tanks - Secondary containment appeared to be in good condition. DRC
had no additional comments regarding tanks or secondary containment. Note - ore was not
being processed at time of inspection.
Vanadium Pregnant Liquor (VPL) Tanks - The VPL tank steam condensate containment
area, tanks and foundations appeared to be in good condition. Note - Ore was not being
processed at the time ofthe inspection.
Clean Water Tank - New chlorination facility is in use. Standing water was not observed
in the vicinity of the tank. No additional comments regarding the clean water tank.
Sulfuric Acid Tank - The tank and berm appeared in good condition. No additional
comments.
9
Caustic Soda Tank - Tank and secondary containment appeared to be in good condition.
No additional comments.
Soda Ash Tanks - The Soda Ash Tanks and Secondary Containment appeared to be
maintained. DRC has no comments regarding this area.
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC toured the tailings cell areas (Cells 4A and 4B and observed the condition of the outer
toe areas of the dikes to ensure that excessive erosion or damage (e.g. burrowing animal
intrusion or rooting damage) was not present. The dikes appeared to be in overall good
condition (minor rilling in some areas ~ see photos Appendix 1).
Summary of Onsite Closeout Meeting:
Date/Time: September 23, 2014/1330.
EFR Representatives Present ~ David Turk
Tanner Holiday
Garrin Palmer
DRC Representatives Present - Tom Rushing
An onsite close-out meeting took place amongst Tom Rushing (DRC), David Turk (EFR),
Tanner Holliday (EFR), and Garrin Palmer (EFR). During this meeting, DRC informed and
discussed inspection findings with the EFR representatives.
Conclusions
A request for information letter regarding the 2014 storm water inspection will be sent to
EFR. DRC notes that overall, the Mill facility storm water management and spill training and
reporting has significantly improved in recent years.
U:\MON_WAST\Trushing\Energy Fuels\Storm Water Management\2014 SW InspectionAWhite Mesa Mill 2014 SW Inspection Memo
Final docx
10
Ground Water Module 65, DRC 2014 Annual Storm Water Inspection
Appendix 1 - Photo Pages
11
DRC Storm Water Inspection
Energy Fuels Resources (USA) Inc.
White Mesa Uranium Mill, Bianding, UT
Inspection Date 9/23/2014
Photo Pages
Photo 1 - Roberts Pond Excavation, Pond area has been excavated to bedrock, EFR is waiting for
confirmation sample results prior to approval for backfill
Photo 2 - Southwest corner of Roberts Pond is the low area where storm water accumulates.
Accumulated storm water is pumped when observed.
Photo 3 - Photo of drainage on the south side ofthe Solvent Extraction Building. Photo is looking east
toward the main office building. Water in this area is drained toward cell 1, however, it appears that most
of the surface drainage in impounded right outside of the Facility fenceline.
DRC Storm Water Inspection
Energy Fuels Resources (USA) Inc.
White Mesa Uranium Mill, Bianding, UT
Inspection Date 9/23/2014
Photo Pages
Photo 4 - Alternate Feed Processing Area Drum Staging Area. No Alternate Feed or Uranium Ore being
processed at the time of the inspection.
Photo 5 - Storm Water Runon Ditch 1 north of Cell 1. Note Standing Water in Ditch.
Photo 6 - Discharge location of Runon Ditch 1, Discharge is to the west into the Cottonwood Creek
drainage.
DRC Storm Water Inspection
Energy Fuels Resources (USA) Inc.
White Mesa Uranium Mill, Bianding, UT
Inspection Date 9/23/2014
Photo Pages
Photo 7 - End of Runon Ditch 1 looking southeast
___________ _ _
Photo 8 - End of Runon Ditch 2 looking north.
Photo 9 - Ditch 2 looking south toward the mill, note uphill grade, water flows towards camera.
DRC Storm Water Inspection
Energy Fuels Resources (USA) Inc.
White Mesa Uranium Mill, Bianding, UT
Inspection Date 9/23/2014
Photo Pages
Photo 10 - Cell 4A Embankment, Erosion Channel
Photo 11 - Cell 4A/4B Embankment
Photo 12 - Boneyard. Note that grading and hill in background drain water north west towards the White
Mesa Tailings Cells.
DRC Storm Water Inspection
Energy Fuels Resources (USA) Inc.
White Mesa Uranium Mill, Bianding, UT
Inspection Date 9/23/2014
Photo Pages
Photo 13 - Another view of the boneyard. Drainage is north west toward the camera
Photo 14 - Roof drainage from the North West side of the SX building. Drainage formerly discharged to
Roberts Pond.
Photo 15 - Caustic Soda Tank Secondary Containment, Tank has been refurbished.
DRC Storm Water Inspection
Energy Fuels Resources (USA) Inc.
White Mesa Uranium Mill, Bianding, UT
Inspection Date 9/23/2014
Photo Pages
2s£
Photo 16 - Existing asphalt on the east side of the ore processing building. Asphalt will be retained
part of the ammonium sulfate crystal tank pad.
Photo 17 - Boneyard looking south east, drainage is toward the camera.
Photo 18 - Ammonium Sulfate Crystal Tanks, area designated for impervious cover.