DRC-2017-001887 - 0901a068806ce756

State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

March 21, 2017

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
RE: Energy Fuels Resources December 12, 2016 Transmittal of Revised Spill Prevention, Control
and Countermeasures Plan (“SPCC”) and Discharge Minimization Technology Monitoring Plan
(“DMT”) for the White Mesa Uranium Mill
Utah Groundwater Discharge Permit No. UGW370004
Dear Ms. Weinel:

The Division of Waste Management and Radiation Control (DWMRC) has completed its review of the
Energy Fuels Resources (EFR) December 12, 2016 Transmittal (EFR Transmittal) regarding response to a Division Request for Information Letter dated October 12, 2016 (DWMRC RFI). The DWMRC RFI
was based on findings documented during the 2016 Storm Water Inspection (Groundwater Module 65)
at the White Mesa Uranium Mill (Mill).

Two specific requests were included with the RFI, specifically:
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.

During the telephone conference (October 11, 2016 Telephone Conference between DWMRC and
EFR), 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.”, and;
(Over)
DRC-2017-001887 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
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.”
In response to the first DWMRC request above, the EFR Transmittal includes redline and clean copies
of a Revised (December 2016) Spill Prevention, Control and Countermeasure Plan (SPCC) and a
Revised (December 2016 Revision 12.4) Discharge Minimization Technology Monitoring Plan (DMT).
The EFR Transmittal additionally states that “all shift personnel at the Mill have been trained on daily monitoring of the reagent and petroleum and fuel tanks and storage area. Training was conducted on
November 30, 2016, and December 2, 2016.”

In response to the second DWMRC request above, the EFR Transmittal states that the storm water
containment was cleaned out on October 18, 2016. In addition, EFR included a specific item on the Ore Storage/Sample Plant Weekly Inspection Report to ensure that excessive sediment does not accumulate
in the containment in the future. The EFR inspection requirement is that the Mill Personnel will initiate
a clean out of the containment whenever three inches of sediment are observed during the weekly
inspection.
Based on review of the EFR Transmittal, including the revised SPCC and DMT Plans, it appears that
EFR has address all concerns listed in the DWMRC RFI. Therefore, the 2016 Storm Water Inspection
(Groundwater Module 65) is hereby closed out.

If you have any questions, please call Tom Rushing at [phone].
Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control

STA/TR/ka
c: Kirk Benge, Health Officer/Environmental Health Director, San Juan County Health Department
Rick Meyer, Environmental Health Director, San Juan County Health Department
Scott Hacking, P.E., DEQ District Engineer