DRC-2014-001528 - 0901a068803ff74f

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DAQC-117-14 Site ID 11205(B1) MEMORANDUM
TO: FILE – ENERGY FUELS – WHITE MESA MILL
THROUGH: Jay Morris, Minor Source Compliance Section Manager
FROM: Sarah Malluche, Environmental Scientist DATE: January 27, 2014 SUBJECT: PCE, Minor, San Juan County, AIRS #037-00017
REVIEW DATE: January 27, 2014
SOURCE LOCATION: White Mesa Mill, San Juan County, Utah SOURCE CONTACT(S): Jo Ann Tischler, Manager, Compliance and Licensing 303-389-4132 OPERATING STATUS: Operating
PROCESS DESCRIPTION: Underground Uranium mine APPLICABLE REGULATIONS: AO dated 3/2/11 (DAQE-AN0112050018-11), NESHAP Part 61, Subpart W SOURCE INSPECTION EVALUATION: NESHAP Part 61 Subpart W Annual Report, December 2013
Monthly Monitoring 61.252 Standard
(a) Radon-222 emissions to the ambient air from an existing uranium mill tailings pile shall not exceed 20 pCi m2 –s of radon-222. Status: In violation. The annual report indicated that Cell #2 exceeded the 20 pCi m2 –s of radon-222. If
an exceedance is included in the annual report, monthly monitoring and reporting is required until the source can meet the standard. The facility is conducting monthly monitoring and reporting. The first required monthly report was submitted by May 30, 2013, with the April 2013, data.
61.254 Annual Reporting Requirements (a)(1-3) owners or operators of operating existing mill impoundments shall report the results of the
compliance calculations in Section 61.253 and the input parameters used in making the calculations. This report shall be sent to EPA by March 31 of the following year.
Status: In compliance. The report was received on April 1, 2013. The annual calculations and the results of the report are listed in Attachment 1 (Large Area Activated Charcoal Canisters were utilized). Refer to (a) (3). The December report was received on January 17, 2014.

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(a)(1-3) Each reports shall contain the following information: (1) name and location of mill.
Status: In compliance. White Mesa Mill is located 6 miles south of Blanding, in San Juan County, Utah. (2) persons responsible for operations, and report preparation.
Status: In compliance. Jaime Massey, Regulatory Compliance Specialist from Energy Fuels Resources, Inc, is the responsible person for operations and Tellco Environmental, DL Cooper, technician, from Grand Junction, Colorado was responsible for the prepared the report.
(3) results of testing conducted, including the results of each measurement.
Status: In compliance. The reported December 2013 result for the radon-222 flux monitoring for the tailing cell #2 was 10.0 pCi m2 -s. Cell 2 indicates that it is within the required limit (< 20 pCi m2 -s). (4) each report shall be signed and dated by a corporate officer…
Status: In compliance. David Frydenlund signed the report and dated the report on January 15, 2014.
(b)(1 &2) if the facility is not in compliance with the emission limits of 61.252 in the calendar year covered by the report, then the facility must commence reporting to the Administrator on a monthly basis the information listed in 61.254 (a)(1-4) for the preceding month.
In addition to 61.254(a)(1-4) monthly report shall include: (1) all controls or other changes in operation of the facility that will be or are being installed to bring the facility into compliance; and (2) if the facility is under a judicial or administrative enforcement decree,….
Status: In compliance. Refer above for 61.254 (a) (1-4). On page 6 of the report, Energy Fuels Resources discusses the construction and monitoring of interim cover test area, and the application of the additional random fill. The facility is currently constructing a test area with additional fill. The test area
consists of 12 areas of 100 feet by 120 feet area of one foot random fill at 90% compaction; this was constructed on August 2, 2013. Monitoring the radon flux is scheduled prior, during, and after the fill is placed on the cell. If the radon flux monitoring shows that the fill has contributed to compliance, then similar fill will be placed on the remaining cell 2 area. The facility stated that prior to September 2013 sampling, wetting and soil compaction of the test area was conducted. The effectiveness of the facility’s actions will be monitored over the next several months. The facility has addressed some areas identified as elevated radon flux located in cell 2 area. A five foot berm has been constructed between cell area 2
and 3, to prevent entrance of windblown tailings to cell 2 area. The facility stated in the report that any contaminated material near the surface has been reburied and additional cover material was placed on the identified areas in cell 2. Also, the facility is not under a judicial or administrative enforcement decree. (c) first report will cover the emission of calendar year 1990. Status: Not applicable. Facility did not operate the mine during the calendar year of 1990.
EMISSION INVENTORY: 2012 inventory submitted the following information in tons/year: CO: 10.71 Formaldehyde: 0.00745
NOX: 13.89 PM10: 0.98 PM2.5: 0.98 SOX: 0.7 VOC: 1.55

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PREVIOUS ENFORCEMENT ACTIONS: Warning issued on February 10, 2012 DAQC-157-12 for failing to include the certification statement on annual reports for 2008-2010. Denison Mines submitted the certification statement for
the years 2008-2010 on February 14, 2012. Warning issued on March 19, 2012 DAQC-282-12 for failing to
meet emission standards from November 26, 2011 through December 12, 2011. The operator work procedures that caused the violation were addressed in correspondence on December 27, 2011.
CAN issued on October 17, 2013, DAQC-1126-13 for an opacity exceedance. Energy Fuels submitted a breakdown report for the exceedance stating the opacity was due to operator error. A signed Early Settlement Agreement (DAQC-1376-13, dated
11/25/13) was received from Energy Fuels on December 3, 2013 which included a penalty of $942.00.
COMPLIANCE STATUS & RECOMMENDATIONS: The facility is in compliance with the monthly reporting
requirements. Monthly reporting is required due to Cell 2’s radon flux exceedance. Monthly monitoring will be conducted until Cell 2 is within the NESHAP limit of 20 pCi m2 –s. The December 2013 monitoring results show that the cell is within the required
limits. Subpart W requires monthly monitoring to occur until the facility can show compliance with the emission limit. ATTACHMENTS: January 17, 2013 received, White Mesa Mill December Report