DRC-2016-012001 - 0901a06880692e8f

V
*9
ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
December 12, 2016 Div of Waste Management
and Radiation Control
Sent VIA OVERNIGHT DELIVERY DEC 1 \ 201
Mr. Scott Anderson
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
0|Z/>01
Re: Transmittal of Revised Spill Prevention, Control and Countermeasures Plan (“SPCC”) and
Discharge Minimization Technology Monitoring Plan (“DMT”) for White Mesa Uranium Mill
Dear Mr. Anderson:
This letter transmits Energy Fuels Resources (USA) Inc.’s (“EFRFs”) proposed revisions to the White Mesa
Mill SPCC and DMT Plans for review and approval. These revisions include changes made to:
1. Incorporate changes requested by the Division of Waste Management and Radiation Control
(“DWMRC”) personnel during the annual Storm Water Inspection conducted in September 2016.
2. Correct typographical errors.
For ease of review we have provided both redline/strikeout (text only) and clean versions (text and figures) of
each document. Upon receipt of DWMRC approval EFRI will finalize the finalize the documents and have
them stamped and signed as appropriate.
The DWMRC letter transmitting the Storm Water inspection noted two items requiring an Energy Fuels
Resources (USA) Inc. (“EFRI”) response. The two items are noted in italics text below, followed by EFRFs
response.
DWMRC COMMENT:
Based upon the findings of the inspection and a telephone conference between Energy Fuels representatives
and Division representatives on October 11, 2016, it was agreed that the following actions would be completed
on or before the stated timelines:
1. It was noted during the inspection that the White Mesa Mill Spill Prevention, Control, and
Countermeasures (SPCC) Plan includes a requirement for an annual bulk oil and fuel tank visual
inspection. During the annual storm water inspection, it was noted that this annual inspection had not
been conducted. It was also noted that the SPCC Plan does not provide an explanation of the scope of
activities performed during the inspections.
Letter to Scott Anderson
December 12, 2016
Page 2 of 2
During the telephone conference. Energy Fuels Resources agreed to provide an updated SPCC Plan
which better reflects types, frequencies and scope of storm water inspections performed at the White
Mesa Mill, for the Director's review and approval, within 60 calendar days of the date of this letter.
EFRI RESPONSE:
Included in Attachment A to this letter are clean and redline revisions to both the SPCC and the DMT Plans.
The revised plans incorporate changes to address Storm Water inspections conducted at White Mesa Mill.
Specifically, the annual inspections of the used/waste oil and fuel tanks are incorporated into the DMT Plan.
In addition, all shift personnel at the Mill have been trained on daily monitoring of the reagent and petroleum
and fuel tanks and storage areas. Training was conducted on November 30, 2016 and December 2, 2016.
DWMRC COMMENT:
2. It was noted during the inspection that the storm water containment located at the southwest corner of the
ore storage pad was filled with sediment up to the discharge pipe and needed to be cleaned out. During the
telephone conference, Energy Fuels Resources agreed to clean out this storm water containment within seven
calendar days of the date of this letter.
EFRI RESPONSE:
The aforementioned DWMRC letter was dated October 13, 2016 and EFRI received the letter October 17,
2016. EFRI completed clean out activities on October 18, 2016. Photos of the containment area are included
in Attachment B.
In addition, a weekly inspection of the containment will be completed and will be documented on the Ore
Storage/Sample Plant Weekly Inspection Report. The revised weekly form is included in the DMT Plan
included in Attachment A. It is important to note that future inspections will initiate a cleanout of the
containment when 3 inches of sediment have built up. Three inches of sediment is well below outlet of the
containment and will prevent future issues as noted by DWMRC.
If you should have any questions regarding these responses or plans please contact me.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Harold R. Roberts
David E. Turk
Logan Shumway
Scott Bakken
ATTACHMENT A
REDLINE
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 12.34
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
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WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. INTRODUCTION..........................................................................................................3
1.1. Background.............................................................................................................3
2. DAILY TAILINGS INSPECTIONS................................................................................4
2.1. Daily Inspection.......................................................................................................4
3. WEEKLY TAILINGS AND DMT INSPECTION............................................................5
3.1. Weekly Tailings Inspections.....................................................................................5
Northing........................................................................................................................9
Easting...........................................................................................................................9
3.2. Weekly Feedstock Storage Area Inspections.............................................................12
4. ANNUAL EVALUATIONS..........................................................................................12
4.1. Annual Leak Detection Fluid Samples......................................................................12
4.2. Annual Inspection of the Decontamination Pads.......................................................12
4.4 Annual Inspection of Waste Oil and Fuel Tanks.......................................................13
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA.................................13
6. OTHER INSPECTIONS................................................................................................14
7. REPORTING REQUIREMENTS..................................................................................14
7.1. DMT Reports..............................................................................................................14
Attachment A
Attachment B
Attachment C
ATTACHMENTS
Forms
Feedstock Storage Area
Tables
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1. INTRODUCTION
This DMT Monitoring Plan (“DMT Plan”) sets out the procedures to demonstrate compliance with
Discharge Minimization Technology (“DMT”) as specified throughout Parts ID, I.E and I.F of the
White Mesa Mill’s (the “Mill’s”) Groundwater Discharge Permit (“GWDP”) Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT1900479 (the “RML”) are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the Mill’s Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of the feedstock storage areas at the Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill’s Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill’s
Environmental Protection Manual, under the Mill’s NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill’s Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill’s Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e.. Chapter 3.1 of the Mill’s Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill’s Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
This division of the requirements was discussed with DRC on October 26,2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1,2, and 3 Leak Detection Systems (“LDSs”) has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1,2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1,2, 3,4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-l to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2.1q).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
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elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell’s EDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1,2, and 3 the EDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-l of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill’s environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
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For Cells 1,2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3C of the
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table 1A and IB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered-bv platform fillclosed and Phase 1 cover activities
have commenced. Each cell has a slimes drain system which aids in dewatering the
slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in 2011 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the 20U_re­
grading of the interim cover and the placement of an additional 62,000 cubic yards of
fill material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe rs-was 6.97 feet in length; and therefore the new-measuring point is
was 37.97 feet from the bottom of the slimes drain. This value was used in all
calculations from 4'h quarter 2011 through the 3,rd quarter 2016. In April 2016. Phase . - -( Formatted: Superscript
1 cover placement and construction commenced. The Pahse 1 cover activities Formatted: Superscript
include the placement and compaction of aooroximatelv 4.5 feet of soil materials.
During the 3rd quarter 2016, the slimes drain access pipe was extended 5.44 feet as a - j Formatted: Superscript i
result of the Phase 1 cover activities. The measuring point on the extension pipe was
surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is now
5618.735624.17 fmsl. For the quarterly recovery test described in section vi below,
this extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.9743.41 feet below a water level measuring point which is a notch on the side of
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the Cell 2 slimes drain access pipe.. This means that the bottom of the slimes drain
pool and the location of the pump are one foot above the lowest point of the FML in
| Cell 2, which, based on construction reports, is at a depth of 3^79744.31 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) All head measurements must be made from the same measuring point (the notch at
| the north side of the access pipe 5618.735624.17 fmsl), and made to the nearest 0.01
foot. The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
| 564-8t-735624. 17 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11,2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) success! ve readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi) No process liquids shall be allowed to be discharged into Cell 2;
(vii) If at any time the most recent average annual head in the Cell 2 slimes drain is found
to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Partl.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
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c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1,4A, and 4B are to be taken by survey on a weekly
basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a
monthly basis when beaches are first observed, as follows:
(i) The survey will be performed by the Mill’s Radiation Safety Officer or designee (the
“Surveyor”) with the assistance of another Mill worker (the “Assistant”);
(ii) The survey will be performed using a survey instrument (the “Survey Instrument”)
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the “Survey Rod”) having a visible scale in 0.01 foot increments;
(iii) The Reference Points for Cells 1, Cell 4A, and 4B, are known points established by
professional survey. For Cell 1, the Reference Point is a wooden stake with a metal
disk on it located on the southeast corner of Cell 1. The elevation of the metal disk
(the “Reference Point Elevation”) for Cell 1 is at 5,623.14 feet above mean sea level
(“FMSL”). For Cell 4A and 4B, the Reference Point is a piece of stamped metal
monument located next to the transformer on the south side of Cell 4A and 4B. The
elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A
and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a
location where both the applicable Reference Point and pond surface are visible.
(iv) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and
4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by
gently rocking the rod back and forth until the Surveyor has established a level
reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the “Reference Point Reading”), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1, Cell 4A, or Cell 4B, or
the area of the beach in Cell 4B with the highest elevation, as the case may be. These
designated locations, and the methods to be used by the Assistant to consistently use
the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25’ or 45’).
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A. Pond Surface Measurements
l. Cell 4A
The Assistant will walk down the slope in the northeast comer of Cell 4A and
place the Survey Rod at the liquid level.
H. Cell 4B
The Assistant will walk down the slope in the southeast comer of Cell 4B and
place the Survey Rod at the liquid level.
m. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are;
Northine Easting
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
B. Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
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has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the “Pond Surface Reading”), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast comer of the ore
pad, near the Mill’s scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
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form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill’s maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
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the Tailings Management System and as Attachment A to this DMT Plan.
3.2. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Annual Leak Detection Fluid Samples
Pursuant to Part I.E. 10(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad’s exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
4.4 Annual Inspection of Waste Oil and Fuel Tanks
During the second quarter of each year, the used/waste oil tank and fuel tanks will be inspected to
ensure the integrity of the tanks and support structures. The tanks and any associated piping will be
visually inspected for signs of corrosion or leaking. Any concrete structures, containments and
supports will be inspected to ensure the integrity of the exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the surface, repairs will be made within 7 days. All
inspection findings and any repairs required shall be documented on the Annual Inspection form.
The documentation of the inspection findings, any repairs required and repairs completed will be
maintained at the Mill.
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Page 13 of 25
Ammonium AMMONIUM Strifete-SULFATE
€evef-COVER AfeaAREA
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1/8 inch separation (width) or any significant deterioration or damage of the concrete
pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
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Page 14 of 25
6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7.1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3.1(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3.1(d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
including any repairs required, and repairs completed]);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
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Page 15 of 25
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
e) With respect to the annual inspection (after the completion of 8 quarterly
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
0 An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report.
| White Mesa Mill-Discharge Minimization Technology Monitoring Plan
ATTACHMENT A
FORMS
4/T5I2/I6 Revision: EFRI 12.34
Page 16 of 25
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 4/4412/16 Revision: EFRI 12.34
Page 17 of 25
ATTACHMENT A-l
DAILY INSPECTION DATA
Inspector:______
Date:__________
Accompanied by:.
Time:__________
Any Item not “OK” must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked Checked
Wet Drv Wet Drv Wet Drv Wet Drv Wet Drv
Initial level Initial level Initial level Initial level Initial level
Final
level
Final
level
Final
level
Final
level
Final
level
Gal. pumoed Gal. pumned Gal. pumoed Gal. pumoed Gal. pumoed
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tailings Management
System (Appendix A-I)
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Page 18 of 25
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date:__________________ Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation ____________
elevations (msl, ft)
(b) FML Bottom Elevation ______5597_
(c) Depth of Water above FML ((a)-(b))___________
Cell 4A: (a)Pond Solution Elevation ___________
(b) FML Bottom Elevation ______5555.14_
(c) Depth of Water above FML ((a)-(b))__________
Cell 4B: (a)Pond Solution Elevation ___________
(b) FML Bottom Elevation ______5557.50
(c) Depth of Water above FML ((a)-(b))__________
(d) Elevation of Beach Area with Highest Elevation
(monthly) ___________
2. Leak Detection Systems
Observation:
New Decon Pad. Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
wet drv wet drv wet drv
If wet, Record liquid
level:
Ft to Liquid Ft to Liquid Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? _____no ______yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
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Page 19 of 25
ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week ofthroughDate of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes:no:
comments:____________________________________________________________
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes:no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes:No:
If “No”, how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes:______No:
Comments:_____________________________________________________
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Page 20 of 25
Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes:______No:
Comments:_____________
Is there any evidence of breakage, spillage or leakage?
Yes:No:
Comments:_____________________________________
Other comments:
Ore Pad Southwest Stormwater Containment (Kiva):
Is there sediment or debris in the bottom of the Kiva?
Yes:Ncn
Comments:
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Ktva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes:No:
Comments:
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Page 21 of 25
ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector.
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the pad surface?____Yes____No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank?____Yes____No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September
1 of each calendar year.
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Page 22 of 25
ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection:
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the pad surface?____Yes____No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the asphalt surface?____Yes____No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
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Page 23 of 25
ATTACHMENT A-6
ANNUAL USEDAVASTE OIL AND FUEL TANK INSPECTION
Date of Inspection:
Are there any anomalies on tanks including dents or rusty areas?
Yes No
Comments:_______________________________________________________________________
Inspect the following as appropnate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:+
Valves:
Pointfs) of Discharge:
Are there any cracks on the concrete surfaces (If present! greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
Yes No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):
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Page 24 of 25
ATTACHMENT B
FEEDSTOCK STORAGE AREA
DATE:
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ATTACHMENT C
TABLES
Table 1A
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( gallons / acre / day)
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
(gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
May-2December_12,2016
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
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 A1.......................................................................................................................................2
4.2 Basin A2...................................................................................................................................... 2
4.3 Basin B1......................................................................................................................................2
4.4 Basin B2....................................................................................................................................32
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)................................................................43
5.2 Ammonia...................................................................................................................................43
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...............................................................................................................................54
5.8 Vanadium Pentoxide..................................................................................................................5
5.9 Kerosene (Organic)....................................................................................................................5
5.10 Used/Waste Oil............................................................................................................................5
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT..................................................5
6.1 Petroleum Tanks......................................................................................................................65
6.1.1 Diesel.................................................................................................................................65
6.2 Aboveground Fuel Pump Tanks............................................................................................65
6.2.1 Diesel.................................................................................................................................65
6.2.2 Unleaded Gasoline............................................................................................................6
6.2.3 Pump Station.......................................................................................................................6
6.2.4 Truck Unloading................................................................................................................75
7.0 SPILL DISCOVERY AND REMEDIAL ACTION..........................................................................76
8.0 SPILL INCIDENT NOTIFICATION.................................................................................................87
8.1 External Notification......................................................................................................................87
8.2 Internal Notification........................................................................................................................87
9.0 RECORDS AND REPORTS.............................................................................................................9
10.0 SPILL REPORTING REQUIREMENTS.....................................................................................109
11.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES..............................109
11.1 Training Records...................................................................................................................109
11.2 Monitoring Reports.................................................................................................................109
12.0 REVISION......................................................................................................................................109
13.0 MILL MANAGER APPROVAL..................................................................................................1J49
14.0 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER.................................1149
15.0 SUMMARY...................................................................................................................................1244
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 2d3 Responsibilities
Section 3.0 Drainage Basins, Pathways, and Diversions
Section 4X) 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 amounts, and their reportable quantities.
Table 4.0 lists the reagent yard/small quantity chemicals.
Table 5.0 lists the chemicals in the reagent yard, their amounts, and their reportable
quantities.
Table 6.0 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
2 and 3, 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 of three
feet) 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 A1
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. The
basin covers 84 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.
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 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 all of Cell 2. The basin consists of 80.7 acres. Areas in this basin include
earth stockpiles and the heavy equipment shop. The direction of flow in this basin is to the
southwest. All overflows in this basin is channeled along the southern edge of the basin.
Overflow then flows into Cell 3 via the spillway from Cell 2 to 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 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.
3
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.
Daily monitoring of-t-he-tanks-fer leaks and routine ilntegrity 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.
Daily monitoring of the tanks for leaks and ilntegrity 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 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.
5.10 Used/Wastc OH
Used/ Waste oil for parts washing 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. 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.
6.0 POTENTIAL PETROLEUM SOURCES AND CONTAINMENT
5
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.
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
6
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. 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. 2=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/or 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.
7
4. Plan further clean-up and decontamination measures.
8.0 SPILL INCIDENT NOTIFICATION
8.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies should be
notified:
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
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
1-800-424-8802
301-816-5100
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
5. Release exceeding 5,000 pounds of process material, waste, or by-product
In the event of a spill requiring reporting, the Mill Manager is required to call the Quality
Assurance Manager, the Executive Vice President and Chief Operating OfficerConventional
Operations, 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
Manager and the Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Logan Shumway Mill Manager [phone]
David Turk EH&S Manager [phone]
Garrin Palmer Mill Environmental Compliance
Coordinator
[phone]
Thayne Holt Production Superintendent [phone]
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Stephen P. Antony President and Chief Executive
Officer [phone]
Harold R. Roberts Executive Vice President
Conventional Operations [phone]
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 thickness
d. Quarterly Tailings Inspection
e. Daily Operating Foreman and weekly RSO inspection reports
2. Tank to soil potential measurements
3. Annual buHeused/waste oil and fuel tank visual inspections
4. Tank and pipeline thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
6. Tank supports and foundation inspections
7. Spill Incident reports
8. 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.
Logan 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
FIGURES
CLEAN
WHITE MESA MILL DISCHARGE
MINIMIZATIONTECHNOLOGY (DMT) MONITORING PLAN
Revision 12.4
December 2016
Prepared by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
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Page 2 of 25
WHITE MESA MILL
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
1. INTRODUCTION..............................................................................................................................3
1.1. Background.................................................................................................................................3
2. DAILY TAILINGS INSPECTIONS...............................................................................................4
2.1. Daily Inspection.......................................................................................................................... 4
3. WEEKLY TAILINGS AND DMT INSPECTION.......................................................................5
3.1. Weekly Tailings Inspections.....................................................................................................5
Northing..............................................................................................................................................9
Easting.................................................................................................................................................9
3.2. Weekly Feedstock Storage Area Inspections........................................................................12
4. ANNUAL EVALUATIONS...........................................................................................................12
4.1. Annual Leak Detection Fluid Samples..................................................................................12
4.2. Annual Inspection of the Decontamination Pads.................................................................12
4.4 Annual Inspection of Waste Oil and Fuel Tanks......................................................................13
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA.......................................13
6. OTHER INSPECTIONS.................................................................................................................14
7. REPORTING REQUIREMENTS.................................................................................................14
7.1. DMT Reports..................................................................................................................................14
ATTACHMENTS
Attachment A Forms
Attachment B Feedstock Storage Area
Attachment C Tables
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1. INTRODUCTION
This DMT Monitoring Plan (“DMT Plan”) sets out the procedures to demonstrate compliance with
Discharge Minimization Technology (“DMT”) as specified throughout Parts ID, I.E and I.F of the
White Mesa Mill’s (the “Mill’s”) Groundwater Discharge Permit (“GWDP”) Number 370004.
Additional procedures for monitoring the tailings cell systems as required under State of Utah
Radioactive Materials License No. UT1900479 (the “RML”) are set out in the Tailings Management
System procedure for the Mill, which comprises Chapter 3.1 of the Mill’s Environmental Protection
Manual.
This DMT Plan and the Tailings Management System procedure when implemented in concert are
designed as a comprehensive systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of the feedstock storage areas at the Mill.
This DMT Plan is issued as a stand-alone document, while the Tailings Management System
procedure is published and maintained in the Mill’s Environmental Protection Manual.
1.1. Background
The Tailings Management System procedure was originally developed as Chapter 3.1 of the Mill’s
Environmental Protection Manual, under the Mill’s NRC Source Material License, and constituted a
comprehensive systematic program for constant surveillance and documentation of the integrity of
the tailings impoundment system. Upon the State of Utah becoming an Agreement State for uranium
mills in 2004, the Mill’s Source Material License was replaced by the State of Utah RML and the
State of Utah GWDP. The GWDP required that EFRI develop the initial DMT Plan in response to
GWDP requirements. In developing the initial DMT Plan, EFRI combined the existing Tailings
Management System procedure set out as Chapter 3.1 of the Mill’s Environmental Protection
Manual with a number of new DMT requirements from the GWDP to form the initial DMT Plan.
The initial DMT Plan and subsequent revisions (through revision 11.5) maintained the requirements
from the RML (i.e., Chapter 3.1 of the Mill’s Environmental Protection Manual) and the DMT
requirements of the GWDP in a single document.
However, after several years of implementing the DMT Plan, EFRI concluded that it is preferable to
separate the RML portions of the DMT Plan from the GWDP portions of the DMT Plan, into two
separate documents. This DMT Plan continues to be a stand-alone plan that contains the DMT
requirements from the GWDP except for the daily recording of the Cells 1, 2, and 3 LDS
measurements as noted below. However, the portions of the initial DMT Plan that flowed from the
RML and not from the GWDP have been separated from the DMT Plan and have been returned to
their original status as the Tailings Management System procedure, which comprises Chapter 3.1 of
the Mill’s Environmental Protection Manual. This allows the DMT Plan to be managed, inspected
and enforced under the requirements of the GWDP and this Tailings Management System procedure
to be managed, inspected and enforced under the requirements of the RML.
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This division of the requirements was discussed with DRC on October 26,2011. DRC agreed with
the division of the requirements into two distinct documents as noted in their correspondence dated
December 20, 2011. Pursuant to a written request from DRC, dated May 30, 2012, the RML
requirements for the inspections of the Cells 1,2, and 3 Leak Detection Systems (“LDSs”) has been
included in this DMT Plan. The inclusion of this RML requirement into this DMT Plan is to address
the DRC request for uniformity in monitoring and reporting requirements for Cells 1,2, and 3 and to
address anticipated GWDP modifications regarding the LDS monitoring in Cells 1, 2, and 3.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Inspection
On a daily basis, including weekends, the Cells 1, 2, 3,4A, and 4B leak detection systems must be
inspected either under the DMT Plan or the Tailings Management System procedure.
The Radiation Safety Officer (RSO) or his designee is responsible for performing these daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform these inspections.
Observations made by the inspector will be recorded on Attachment A to this DMT Plan. The
inspector will place a check by all inspection items that appear to be operating properly. Those items
where conditions of potential concern are observed should be marked with an "X". A note should
accompany the "X" specifying what the concern is and what corrective measures will resolve the
problem. This observation of concern should be noted on the form until the problem has been
remedied. The date that corrective action was taken should be noted as well. See the Tailings
Management System procedure for additional daily inspection requirements.
a) Daily measurements in the leak detection system sumps of Cells 1, 2, 3, (as
required by the RML) and Cells 4A, and 4B (as required by the GWDP) are
recorded. For simplicity, the leak detection system measurements for all cells
have been combined on the Daily Inspection Data Form included as Attachment
A-l to this DMT Plan regardless of the origin of the requirement.
The triggers for further action and the associated actions when evaluating Cells 1,
2, and 3, leak detection systems are discussed in the Tailings Management
System procedure, Section 2.1q).
The solution level in Cell 4A or 4B leak detection system is not allowed to be
more than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell 4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
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elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the RSO or his designee and include the
following:
a) Leak Detection Systems
Each tailings cell’s LDS shall be checked weekly (as well as daily) to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cells 1, 2, and 3 the LDS is measured by use of a dual probe system
that senses the presence of solutions in the LDS (comparable to the systems in
Cell 4A and Cell 4B) and indicates the presence of solution with a warning light.
The Cell 4A and 4B leak detection systems are monitored on a continuous basis
by use of a pressure transducer that feeds water level information to an electronic
data collector. The pressure transducer is calibrated for fluid with a specific
gravity of 1.0. The water levels are measured every hour and the information is
stored for later retrieval. The water levels are measured to the nearest 0.10 inch.
The data collector is currently programmed to store 7 days of water level
information. The number of days of stored data can be increased beyond 7 days
if needed. For Cells 1, 2, and 3, the water level data is recorded on the Daily
Tailings Inspection Form included as Attachment A-l of this DMT Plan . For
Cells 4A and 4B, the water level data is downloaded to a laptop computer
periodically and incorporated into the Mill’s environmental monitoring data
storage. The data are reviewed during the weekly inspections of the tailings cell
leak detection systems.
If an LDS monitoring system becomes inoperable, alternate methods for LDS
fluid measurements may be employed with Executive Secretary approval.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
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For Cells 1,2, and 3, if fluid is pumped from an LDS, the procedures specified in
the Tailings Management System procedure Section 3.1 a) shall be implemented.
For Cells 1, 2, and 3, upon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11,3C of the
RML as described in the Tailings Management System procedure.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow Rates
in the Cell 4A and 4B leak detection systems, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell 4B. The
maximum daily LDS flow volume will be compared against the measured cell
solution levels detailed on Table 1A and IB (for Cells 4A and 4B, respectively)
in Attachment C, to determine the maximum daily allowable LDS flow volume
for varying head conditions in Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 closed and Phase
1 cover activities have commenced. Each cell has a slimes drain system which aids
in dewatering the slimes and sands placed in the cell;
(ii) EFRI re-graded the interim fill on Cell 2 in 2011 in order to reduce the potential for
the accumulation of storm water on the surface of Cell 2. As a result of the 2011 re­
grading of the interim cover and the placement of an additional 62,000 cubic yards of
fill material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe was 6.97 feet in length and the measuring point was 37.97 feet from
the bottom of the slimes drain. This value was used in all calculations from 4th
quarter 2011 through the 3rd quarter 2016. In April 2016, Phase 1 cover placement
and construction commenced. The Pahse 1 cover activities include the placement
and compaction of approximately 4.5 feet of soil materials. During the 3rd quarter
2016, the slimes drain access pipe was extended 5.44 feet as a result of the Phase 1
cover activities. The measuring point on the extension pipe was surveyed by a Utah-
Certified Land Surveyor. The measuring point elevation is now 5624.17 fmsl. For the
quarterly recovery test described in section vi below, this extension has no effect on
the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
43.41 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe.. This means that the bottom of the slimes drain pool
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and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 44.31 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at three feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic surface of
tailings Cell 2, about 27 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the average
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5624.17 fmsl), and made to the nearest 0.01 foot.
The equation specified in the GWDP will be used to calculate the slimes drain
recovery elevation (SDRE). To calculate the SDRE contemplated by the GWDP, the
depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will be subtracted
from the surveyed elevation of the measuring point. The calculation is as follows:
5624.17 - Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
(v) Effective July 11,2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vi) No process liquids shall be allowed to be discharged into Cell 2;
(vii) If at any time the most recent average annual head in the Cell 2 slimes drain is found
to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(viii) Because Cell 3, Cell 4A, and 4B are currently active, no pumping from the Cell 3,
Cell 4A, or 4B slimes drain is authorized. Prior to initiation of tailings dewatering
operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure will be developed for
ensuring that average head elevations in the Cell 3, Cell 4A, and 4B slimes drains are
kept as low as reasonably achievable, and that the Cell 3, Cell 4A, and Cell 4B slimes
drains are inspected and the results reported in accordance with the requirements of
the permit.
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c) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1,4A, and 4B are to be taken by survey on a weekly
basis. The beach area in Cell 4B with the maximum elevation is to be taken by survey on a
monthly basis when beaches are first observed, as follows:
(i) The survey will be performed by the Mill’s Radiation Safety Officer or designee (the
“Surveyor”) with the assistance of another Mill worker (the “Assistant”);
(ii) The survey will be performed using a survey instrument (the “Survey Instrument”)
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the “Survey Rod”) having a visible scale in 0.01 foot increments;
(iii) The Reference Points for Cells 1, Cell 4A, and 4B, are known points established by
professional survey. For Cell 1, the Reference Point is a wooden stake with a metal
disk on it located on the southeast corner of Cell 1. The elevation of the metal disk
(the “Reference Point Elevation”) for Cell 1 is at 5,623.14 feet above mean sea level
(“FMSL”). For Cell 4A and 4B, the Reference Point is a piece of stamped metal
monument located next to the transformer on the south side of Cell 4A and 4B. The
elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A
and 4B) is 5600.49 fmsl. The Surveyor will set up the Survey Instrument in a
location where both the applicable Reference Point and pond surface are visible.
(iv) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1 Reference Point on the top of the rebar on the Cell 4A and
4B Reference Point. The Assistant will ensure that the Survey Rod is vertical by
gently rocking the rod back and forth until the Surveyor has established a level
reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the
Survey Rod, and record the number (the “Reference Point Reading”), which
represents the number of feet the Survey Instrument is reading above the Reference
Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the Cell 1, Cell 4A, or Cell 4B, or
the area of the beach in Cell 4B with the highest elevation, as the case may be. These
designated locations, and the methods to be used by the Assistant to consistently use
the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25’ or 45’).
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A. Pond Surface Measurements
l. Cell 4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
H. Cell 4B
The Assistant will walk down the slope in the southeast corner of Cell 4B and
place the Survey Rod at the liquid level.
m. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for the Cells are:
Northing Easting
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
B. Cell 4B Beach Elevation
Beach elevations in Cell 4B will commence when beaches are first observed. The
Assistant will place the Survey Rod at the point on the beach area of Cell 4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
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(i) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(ii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the “Pond Surface Reading”), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell, as the case may be, to the Reference Point Elevation
for the Cell and subtracting the Pond Surface Reading for the Cell, and will record the
number accurate to 0.01 feet.
d) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast comer of the ore
pad, near the Mill’s scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 11 of 25
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the RSO.
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill’s maintenance shop and the ore feeding grizzly. Weekly inspection
requirements for the Existing Decontamination Pad are discussed in the Tailings
Management System Procedure.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A to
the Tailings Management System and as Attachment A to this DMT Plan.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 12 of 25
3.2. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Attachment B;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Attachment A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
4.1. Annual Leak Detection Fluid Samples
Pursuant to Part I.E. 10(c) of the GWDP, a sample will be collected from the Cells 4A and 4B leak
detection systems annually as part of the Tailings Cell Wastewater Quality Monitoring. Sampling
procedures are described in the Tailings Sampling and Analysis Plan.
4.2. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad’s exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 13 of 25
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be visually
inspected for any areas of damage, cracks, or bubbling indicating corrosion that may have occurred
since the last inspection. If any abnormalities are identified, defects or damage will be reported to
Mill management and repairs will be made prior to resuming the use of the facility. All inspection
findings and any repairs required shall be documented on the Annual Decontamination Pad
Inspection form. A record of the repairs will be maintained as a part of the Annual Inspection
records at the Mill site. The inspection findings, any repairs required and repairs completed shall be
summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each calendar year.
4.4 Annual Inspection of Waste Oil and Fuel Tanks
During the second quarter of each year, the used/waste oil tank and fuel tanks will be inspected to
ensure the integrity of the tanks and support structures. The tanks and any associated piping will be
visually inspected for signs of corrosion or leaking. Any concrete structures, containments and
supports will be inspected to ensure the integrity of the exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the surface, repairs will be made within 7 days. All
inspection findings and any repairs required shall be documented on the Annual Inspection form.
The documentation of the inspection findings, any repairs required and repairs completed will be
maintained at the Mill.
5. INSPECTION OF THE AMMONIUM SULFATE COVER AREA
After installation and approval of the As-Built plans by DRC, the Ammonium Sulfate Cover Area
will be inspected quarterly for eight (8) quarters and annually thereafter. The annual inspections will
be conducted during the second quarter of each year. The results of quarterly and annual inspections
will be reported in the quarterly DMT Reports. Quarterly and annual inspections will be completed
as described below and will be documented on the inspection form included as Attachment A-5.
The Ammonium Sulfate Cover Area will be inspected to ensure the integrity of the exposed concrete
and asphalt surfaces. If any abnormalities are identified, i.e. cracks in the concrete or asphalt with
greater than 1/8 inch separation (width) or any significant deterioration or damage of the concrete
pad or asphalt surfaces, repairs will be made within 7 calendar days of the inspection. All inspection
findings and any repairs required shall be documented on the Decontamination Pad/Ammonium
Sulfate Cover Area Inspection form. The inspection findings, any repairs required and repairs
completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1 of each
calendar year. The first inspection of the Ammonium Sulfate Cover Area will be conducted during
the second quarter in the year following installation/completion of the pad.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 14 of 25
6. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in this DMT Plan. See also the Tailings Management System procedure included in the
EPM for additional inspection requirements. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
7. REPORTING REQUIREMENTS
In addition to the forms included in this DMT Plan, the following additional reports shall also be
prepared:
7.1. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1 .F.2 of the GWDP
relating to the inspections described in Section 3.1 (a) (Leak Detection Systems
Monitoring), Section 3.1(b) (Slimes Drain Water Level Monitoring), 3.1 (c)
(Tailings Wastewater Pool Elevation Monitoring), 3.1(d) (Tailings Wastewater
Pool and Beach Area Elevation Monitoring), 3.2(Weekly Feedstock Storage Area
Inspections) 5.0 (Inspection of the Ammonium Sulfate Cover Area [for 8 quarters
including any repairs required, and repairs completed]);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 4.3(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 4.3(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year;
e) With respect to the annual inspection (after the completion of 8 quarterly
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 15 of 25
inspections) of the Ammonium Sulfate Cover Area described in Section 5.0, the
inspection findings, any repairs required, and repairs completed shall be
summarized in the 2nd Quarter report, due September 1 of each calendar year; and
f) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report.
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Page 16 of 25
ATTACHMENT A
FORMS
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ATTACHMENT A-l
DAILY INSPECTION DATA
Inspector:______
Date:__________
Accompanied by:
Time:_________
Any Item not “OK” must be documented. A check mark = OK, X = Action Required
VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked Checked
Wet Drv Wet Drv Wet Drv Wet Drv Wet Drv
Initial level Initial level Initial level Initial level Initial level
Final
level
Final
level
Final
level
Final
level
Final
level
Gal. pumoed Gal. pumoed Gal. pumoed Gal. pumoed Gal. pumoed
Record Observations of Potential Concern and Actions Required on the Daily Inspection Form included in the Tai ings Management
System (Appendix A-l)
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Page 18 of 25
ATTACHMENT A-2
WEEKLY TAILINGS INSPECTION
Date:_________________ Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation ___________
elevations (msl, ft)
(b) FML Bottom Elevation 5597_
(c) Depth of Water above FML ((a)-(b))__________
Cell 4A: (a)Pond Solution Elevation __________
(b) FML Bottom Elevation 5555.14.
(c) Depth of Water above FML ((a)-(b))_________
Cell 4B: (a)Pond Solution Elevation __________
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))_________
(d) Elevation of Beach Area with Highest Elevation
(monthly) __________
2. Leak Detection Systems
Observation:
New Decon Pad, Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3
Is LDS (Portal) wet or
dry?
wet drv wet drv wet drv
If wet. Record liquid
level:
Ft to Liquid Ft to Liquid Ft to Liquid
If wet, Report to RSO
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? _____no _____yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
3. New Decontamination Pad (concrete):
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 19 of 25
ATTACHMENT A-3
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week ofthroughDate of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes:no:
comments:__________________________________________________________
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes:no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes:No:
If “No”, how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes:______No:
Comments:___________________________________________________
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 20 of 25
Ore Pad Stormwater Transfer Line:
Is the transfer line visible?
Yes:______No:
Comments:____________
Is there any evidence of breakage, spillage or leakage?
Yes:______No:
Comments:__________________________________
Other comments:
Ore Pad Southwest Stormwater Containment (Koval:
Is there sediment or debris in the bottom of the Kiva?
Yes:______No:
Comments:_________________________________
Is the sediment or debris level below the bottom of the outlet line? If the sediment/debris is greater than 3
inches deep, complete a work order to have the Kiva cleaned out. If there is significant debris (tumble
weeds or trash present, complete a work order to have the Kiva cleaned out.
Yes:______No:
Comments:
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Page 21 of 25
ATTACHMENT A-4
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the pad surface?____Yes____No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank?____Yes____No
Findings:
Repair Work Required:
Note: For the annual inspection of the Existing and New Decontamination, the annual inspection
findings, any repairs required, and repairs completed, along with a summary of the weekly
inspections of the Decontamination Pads, shall be discussed in the 2nd Quarter report, due September
1 of each calendar year.
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Page 22 of 25
ATTACHMENT A-5
AMMONIUM SULFATE COVER AREA INSPECTION
Date of Inspection:
Ammonium Sulfate Concrete Pad:
Are there any cracks on the concrete pad surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the pad surface?____Yes____No
Findings:
Repair Work Required:
Ammonium Sulfate Asphalt Cover:
Are there any cracks on asphalt surface greater than 1/8 inch of separation?
__Yes___No
Is there any significant deterioration or damage of the asphalt surface?____Yes____No
Findings:
Repair Work Required:
Note: For the quarterly inspection of the Ammonium Sulfate Cover Area, the quarterly inspection findings,
any repairs required, and repairs completed, shall be discussed in the associated quarterly DMT Report. For
the annual inspection of the Ammonium Sulfate Cover Area, the annual inspection findings, any repairs
required, and repairs completed, along with a summary of the weekly inspections of the Decontamination Pads,
shall be discussed in the 2nd Quarter report, due September 1 of each calendar year.
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 23 of 25
ATTACHMENT A-6
ANNUAL USEDAVASTE OIL AND FUEL TANK INSPECTION
Date of Inspection:
Are there any anomalies on tanks including dents or rusty areas?
__Yes___No
Comments:_________________________________________________________________
Inspect the following as appropriate. Note any leakage, seepage, breakage or unusual conditions.
Pipeline Joints:
Pipeline Supports:+
Valves:
Point(s) of Discharge:
Are there any cracks on the concrete surfaces (if present) greater than 1/8 inch of separation?
Yes No
Is there any significant deterioration or damage of the concrete surfaces (if present)?
____Yes____No
Findings:
Repair Work Required:
Date Repair Work Completed (if applicable):
l

i
if>
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Page 24 of 25
ATTACHMENT B
FEEDSTOCK STORAGE AREA
DATE:
N
ponison Mines (USPj Ccwp.
Prcgcd "WHITE MESA ftlju:
ns*-
Foodstodk EtnrEsaAmo Map
■RWh/a
TOBt-rr yAn
White Mesa Mill - Discharge Minimization Technology Monitoring Plan 12/16 Revision: EFRI 12.4
Page 25 of 25
ATTACHMENT C
TABLES
Table 1A
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White Mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
December 12,2016
Energy Fuels Resources (USA) Inc.
WHITE MESA MILL
6425 S. HWY 191
BLANDING, UT 84511
r-j,
ENERGY 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 A1......................................................................................................................................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
5.10 Used/Waste Oil.....................................................................Error! Bookmark not defined.
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
6.2.4 Truck Unloading.................................................................................................................7
7.0 SPILL DISCOVERY AND REMEDIAL ACTION............................................................................7
8.0 SPILL INCIDENT NOTIFICATION...................................................................................................7
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 amounts, and their reportable quantities.
Table 4.0 lists the reagent yard/small quantity chemicals.
Table 5.0 lists the chemicals in the reagent yard, their amounts, and their reportable
quantities.
Table 6.0 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
2 and 3, 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 of three
feet) 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 A1
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. The
basin covers 84 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.
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 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 all of Cell 2. The basin consists of 80.7 acres. Areas in this basin include
earth stockpiles and the heavy equipment shop. The direction of flow in this basin is to the
southwest. All overflows in this basin is channeled along the southern edge of the basin.
Overflow then flows into Cell 3 via the spillway from Cell 2 to 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 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.
3
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 comer 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 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
during the routine visual monitoring would be noted as such on the associated
5
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.
6.3 UsedAVaste Oil
6
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. 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/or 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.
8.0 SPILL INCIDENT NOTIFICATION
7
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 Quality
Assurance Manager, the Executive Vice President Conventional Operations, 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
Manager and the Quality Assurance Manager will be contacted by the Mill Manager.
Name Title Home Phone
Mill Personnel:
Logan Shumway Mill Manager [phone]
David Turk EH&S Manager [phone]
Garrin Palmer Mill Environmental Compliance
Coordinator
[phone]
Thayne Holt Production Superintendent [phone]
Wade Hancock Maintenance Superintendent [phone]
Lakewood Personnel:
Stephen P. Antony President and Chief Executive
Officer [phone]
Harold R. Roberts Executive Vice President
Conventional Operations [phone]
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
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thickness
d. Quarterly Tailings Inspection
9
e. Daily Operating Foreman and weekly RSO inspection reports
2. Tank to soil potential measurements
3. Annual used/waste oil and fuel tank visual inspections
4. Tank thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer contains PCBs)
6. Tank supports and foundation inspections
7. Spill Incident reports
8. 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.
Logan 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
ZT .Person in
Logan Shumway
le for spill prevention:
6425 South Highway 191
B landing, UT 84511
[phone] (work)
[phone] (home)
—Person in charge r-up spill reporting:
David Turk
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (cell)
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT CAPACITY (GAL)
2 AMMONIUM SULFATE 24,366
2 DIESEL 250
3 KEROSENE 10,152
1 USEDAVASTE OIL 5,000
1 DIESEL 6,000
1 UNLEADED 3,000
1 PROPANE 30,000
1 LNG 30,000
2 AMMONIA 31,409
1 SODIUM HYDROXIDE 19,904
1 SODA ASH SOLUTION 16,921
1 SODA ASH SHIFT 8,530
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 Quantity In Stock
Aluminum nitrate 2,270 kg 1.8 kg
Ammonium carbonate 2,270 kg 11.3 kg
Ammonium bifluoride 45.4 kg _______________2.27 kg
Ammonium chloride 2,270 kg 2-27 kg
Ammonium oxalate 2,270 kg 6.8 kg
Ammonium thiocyanate 2,270 kg 7.8 kg
Antimony potassium tartrate 45.4 kg 0.454 kg
n-Butyl acetate 2,270 kg 4 L
Calcium acetate 4.54 kg 0.454 kg
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.810 kg
Ferric nitrate 454 kg 0.454 kg
Ferrous ammonium sulfate 454 kg 0.57 kg
Ferrous sulfate 454 kg 0.454 kg
Lead nitrate 4.54 kg 2.7 kg
Potassium chromate 4.54 kg 0.114 kg
Sodium hydrosulfide 2,270 kg 1.0 kg
Sodium nitrite 45.4 kg 2-5 kg
Sodium phosphate tribasic 2,270 kg 1.4 kg
Zinc acetate 454 kg 0.91 kg
Chemical in Volatiles and
Flammables Lockers (A,B,C)
RQ2 Quantity In Stock
Chloroform 4.54 kg 1 L
Formaldehyde 45.4 kg <1L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ2 Quantity In Stock
Hydrochloric acid 2,270 kg 58 gal
Nitric acid 454 kg 5 L
Phosphoric acid 2,270 kg 10 L
Sulfuric acid 454 kg 25 L
Hydrofluoric Acid 45.4 kg 1 L
Ammonium hydroxide 454 kg 18 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.”
TABLE 4.0
REAGENT YARD/SMALL OUANTITIY CHEMICALS LIST
CHEMICAL
i
____Acetic Acid, Glacial
Ammonium Hydroxide
Ferrous Sulfate Heptahydrate
Hydrochloric Acid
Nitric Acid
Potassium Permanganate 0.1 N
Silver Nitrate
Trichloroethylene
1000 lbs
1000 lbs
1,000 lbs
5,000 lbs
1,000 lbs
32 gal
1 lb
1001b
QUANTITY IN
STORAGE
COMPOUND 4
4 gal
5L
5 kg (1 libs)
60 gal of 40% solution
10 L
5 kg (11 lbs)
2.6 kg
2 L
1. This list identifies chemicals which are regulated as hazardous substances under the Federal
Water Pollution Control Act 40 CFR Part 117. Materials in this list are stored in a locked
storage compound near the bulk storage tank area. The Mill 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.”
TABLE 5.0
REAGENT YARD AND BULK CHEMICALS LIST1
REAGENT RQ2 QUANTITY ON SITE
Sulfuric Acid 1,000 lbs 2,719,680 lbs
Floe #301 None 0 lbs
Hyperfloe 102 None 1,500 lbs
Ammonia - East Tank 100 lbs 113,600 lbs
Ammonia - West Tank 100 lbs 93,720 lbs
Kerosene 100 gal approx. 5,100 gal
Salt (Bags)None 19,600 lbs
Ammonium Hydrogendifluoride None 20,450 lbs
Soda Ash Dense (Bag)None 2,000 lbs
Phosphoric Acid 5,000 lbs 6,300 lbs
Hydrogen Peroxide None 3,600 gal
Polyox None 560 lbs
Millsperse None 1,410 lbs
Nalco TX760 None 9 barrels
Nalco 7200 None 1,590 lbs
Tributyl phosphate None 9,450 lbs
Distillates None 110 gal
Diesel 100 gal approx. 6,000 gal
Gasoline 100 gal approx. 3,000
Alamine 336 drums None 0 lbs
Floe 109 None 7,750 lbs
Floe 208 None 1,500 lbs
Floe 904 None 1,500 lbs
Hyperfloe 624 None 4,230 lbs
Salt (Bulk solids) None Total of 70,000 lbs
Salt (Bulk solutions)None on site in all forms
Caustic Soda 1,000 lbs 24,000 lbs in
40% solution
Ammonium Sulfate None 21,300 lbs
Sodium Chlorate None 66,000 gal
Alamine 335 Bulk None 310 lbs
Alamine 310 Bulk None 0 lbs
Isodecanol None 0 lbs
Vanadium Pentoxide3 1,000 lbs 500,000 lbs
Yellowcake3 None < 10,000 lbs
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.
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1,540 gallons
Transmission Oils 100 gal 0 gallons
Dielectric fluids 5 gallons
Antifreeze None 55 gallons
Greases 1,787 lbs
Water Soluble Oils 100 gal 30 gallons
Xylene (mixed isomers)100 lbs 0 gallons
Lacquer thinner 0 gallons
Acetone None 55 gallons
Methyl Ethyl Ketone None 55 gallons
Toluene 1000 lbs 0 gallons
Varsol Solvent (2% trimethyl
benzene in petroleum distillates)100 gal 0 gallons
Resin None 10 gallons
Epoxy Paints None 55 gallons
Epoxy Catalyst None 30 gallons
Oil Base paints None 15 gallons
Paint thinners None 0 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.”
FIGURES
N
SCALE IN FEET
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600^mWEnergy Fuels Lakewood, CO 80228
REVISIC)NS WHITE MESA MILL
Date By County: San Juan | State: utah
10-11 GM Location:
5-14 DLS Figure 11
MILL SITE LAYOUT4-16 RE
Scale: r=200' | Date: May 12, 2000 | Drafted By: D.SIedd
Mill Site Layout 4.28.16.dwg Figure 11
^ ArjS- •
r v
f S-JJ. / /
\V
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Berm
1000 2000
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
REVISIONS ■p?5iSS^ White Mesa Mill
Date -SL County: SanJuan | itere- UT
2/15/07 BM Location:
10/24/07 BM
MILL SITE
DRAINAGE BASINS
FIGURE 2
05/16/06 BM
06/11/08 BM
12/9/00 DLS
1/7/09 BM
11/15/11
Figure 3
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Organizational Structure
ATTACHMENT B