DRC-2022-021642 - 0901a068810f89c2

DRC-2022-021642 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
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

October 7, 2022

Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228

RE: Close out Letter Regarding the October 3, 2022, Utah Division of Waste Management and
Radiation Control, Ground Water Module 65, Storm Water Inspection at the White Mesa
Uranium Mill
Utah Groundwater Discharge Permit No. UGW370004.
Radioactive Material License Number UT1900479

Dear Ms. Weinel:

The Utah Division of Waste Management and Radiation Control (Division) conducted a storm water
inspection at the Energy Fuels Resources (USA) Inc. (EFRI) White Mesa Uranium Mill (Mill) on
October 4, 2022.

Based on review of onsite storm water related documents and forms and a site walk-through inspection
of storm water management at the Mill, it appears that all requirements of the Mill Groundwater
Discharge Permit (including the currently approved EFRI Spill Prevention, Control and
Countermeasures Plan, and Storm Water Best Management Practices Plan) are being adequately
addressed. No violations were identified during the inspection. A copy of the Division 2022 Module
65, which summarizes findings during the inspection, is attached for your information.

Note that a close out conference with EFRI representatives Garrin Palmer and Tanner Holliday was
conducted after the inspection. Based on the inspection, the 2022 Storm Water Inspection (Groundwater
Inspection Module 65) is hereby closed out.

(Over)

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

Sincerely,

Phil Goble, Uranium Mills and Radioactive Materials Manager
Division of Waste Management and Radiation Control

PRG/TR/wa

c: Grant Sunada, Health Director, San Juan Public Health Department
Ronnie Nieves, Environmental Health Director, San Juan Public Health Department
Russell Seeley, UDEQ District Engineer
Logan Shumway, White Mesa Mill Plant Manager
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Inspection Year: 2022 Inspection Date: October 4, 2022
Module Reviewer Name:
Phil Goble, Manager 10/06/2022
Module Prepared by/Date Prepared:
Tom Rushing, P.G./October 6, 2022
DWMRC Staff Present: Tom Rushing
Phil Goble
Energy Fuels Resources Staff Present: Garrin Palmer
10/06/2022
Energy Fuels Resources Staff Interviewed: Garrin Palmer
Utah Ground Water Quality Discharge Permit No. UGW370004 Requirements Inspected:
Part I.D.10 – Requires management of contact and non-contact storm water and control of
contaminant spills in accordance with the currently approved Storm Water Best Management
Practices Plan (SWBMPP), Spill Prevention Control and Countermeasures Plan (SPCC), and applicable sections of the Utah Administrative Code.
Part I.D.11 – Requirements for Feedstock Material Stored Outside of the Mill Feedstock
Storage Area, including requirements for container integrity, storage on an engineered
impervious surface, and controls for storm water run-on and run-off.
Currently Approved Spill Prevention, Control, and Countermeasures Plan and Storm Water Best Management Practices Plan (SWBMPP) for the White Mesa Uranium Mill:
Date: April 14, 2022 (Approved by DWMRC on May 5, 2022).
Section I – Document Review
SWBMPP (Documentation Requirements):
SWBMPP Part 4.1.4. -- Diversion ditches, drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair, such as excessive vegetative growth channel erosion or pooling of surface water runoff, will be reported to appropriate departments and all follow up actions are to be documented.
DRC-2022-021622
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Findings:
The Utah Division of Waste Management and Radiation Control (“DWMRC”) conducted an
inspection of upland diversion ditches 1, 2 and 3 and associated diversion berms. Per the inspection, the ditches and berms appeared to be well maintained. No excessive debris or erosion was noted in the ditches. It was noted that ditches 1 and 3 had been cleared
of vegetation and had no flow obstacles, ditch 2 had not been cleared of vegetation, however
it appeared that flow was unobstructed by the vegetation (grasses) in the ditch. EFR inspects the diversion ditches and berms monthly and inspection “findings” fields are included on the monthly inspection data form. DWMRC reviewed the September 2022
monthly form, the EFR Inspector noted that the Diversion Ditches showed no signs of
sloughing, erosion, undesirable vegetation, or obstructions of flow.

SWBMPP Appendix 1 – Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation Requirements):

1.6.1. – Daily monitoring of propane tanks required.
Findings: Per an EFR response to a DWMRC August 8, 2012 Request for Information which stated as follows: “The EFR Spill Prevention, Control, and Countermeasures Plan, Part
1.6.1 requires the documentation of a daily inspection of the propane tanks. Please include
the inspection findings with the daily inspection form used for storm water inspection
documentation within 30 days from your receipt of this letter,” EFR has removed the daily inspection requirement on the basis that the propane is a gas at ambient conditions and would be immediately vaporized under all foreseeable leakage conditions at the Mill. DWMRC concurred with this action and this item is no longer inspected as part of the documentation
review or included on the site walkthrough. It is noted, however, that the “Propane and LNG” area is included on the Mill Operating Foreman’s Daily Inspection Log, along with other areas and tanks (2022 Logs were inspected no comments regarding disrepair or inaccessibility of the tanks was noted). 1.9.1. – External Notification of “reportable quantity” spills.
Findings: No reportable quantity spills were reported by EFR during the period reviewed, DWMRC has no additional comments. 1.9.2. Internal Notification of incidents, spills, and significant spills.
The White Mesa Mill employees are using a formatted card to report the small quantity spills; the card is titled “Non-Reportable Reportable Spillage.” The card provides the following information: Name, Date of Discovery, Approximate Amount Spilled, Time of
Discovery, Location of Incident, Description of Material Spilled, Cleanup Activities Taken
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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and Signature. The reports additionally include photographs of the spill and follow up actions for all reported spills during 2022.

Small quantity spill reports were reviewed (Inspection range 1/1/2022 through 10/4/2022) for the annual period prior to the inspection. A total of 5 small quantity spills and follow up actions were reported during that time frame. Per DWMRC review it appears that the spills are being adequately reported and follow up actions are described, and in many cases photos
of the spill and clean-up are included.
During 2022, EFR implemented the storm water training program with the annual radiological refresher in four sessions (2/18/22; 2/21/22; 2/22/22, and 2/25/22). A total of 61 employees were trained during 2022 as of the date of the inspection.

The spill reporting provides records of identification and follow-up procedures thereby making the chemical management at the mill transparent and supports employee involvement in spill identification, reporting, and follow-up. 1.10 Records and Reports.

Period of Records Examined During Inspection: Begin/Ending: 9/1/2022 through 9/30/2022
No. of On-site Records Required: Daily, Weekly, and Monthly Forms
No. of On-site Records Found: All Stormwater Related Records/Reports Onsite No of Records Examined: September 2022 (30 days) How Selected: DWMRC Inspected a random month of daily, weekly, and monthly forms completed since the last annual DWMRC Storm Water Inspection. Daily Tailings Inspection Data:
Findings: Daily Inspections are documented on Appendix A-1 and Attachment A-1 of the Environmental Protection Manual Section 3.1. EFR inspects: 1. Tailings slurry transport system (Slurry pipeline, pipeline joints and supports, valves and point of discharge); 2.
Operational systems (interior cell walls, water level, beach, liner and cover); 3. Dikes and
embankments (slopes and crest) to check for erosion and seepage; 4. Physical inspection of the slurry lines, and; 5. Dust control and leak detection, are conducted daily and documented on a daily inspection form. The forms additionally include fields for observations of potential concerns and action required. Spills and clean up actions are noted in the text boxes
for these fields. Additionally, EFR inspects tank integrity daily (including fuel tanks) and
reports comments (e.g. odors or leaks) on the “Operating Foreman’s Daily Inspection” log. DWMRC randomly selected and reviewed the Appendix A-1daily forms and foreman’s log for the month of September 2022 (daily forms) and 10/2/2022 (foreman’s log). The forms
and log appeared to be appropriate and inspections were conducted on all days. There are no
additional comments regarding the forms or log.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Weekly Tailings Inspections and Survey:
Findings: Weekly tailings inspections were done and documented on weekly tailings inspection forms (Appendix A-2 and Attachment A-2 of the Environmental Protection Manual Section 3.1.). The forms include sections to document pond elevations (solution elevation, FML bottom elevation, and depth of water above FML) for Cells 1, 3, 4A, 4B and
Roberts Pond, as well as slimes drain liquid levels in Cell 2, Existing Decontamination Pad
and general tailing area. The form also includes information regarding the leak detection systems for Cells 1, 2, 3, 4A and 4B as well as the potential blowing of tailings, and condition of concrete at the decontamination pad.
DWMRC inspected the September 2022 weekly forms. All forms were filled out and
identified the individuals completing the inspections. Per the 2022 DWMRC storm water inspection, the inspection forms reviewed appeared to be completed appropriately. There are no additional comments regarding the forms. Monthly Tailings Inspection, Pipeline Thickness:
Findings: Monthly inspection data is documented on Appendix A-3 of the Environmental Protection Manual, Section 3. DWMRC reviewed the EFR monthly inspection report dated September 30, 2022. Note that the monthly inspection reports include comments related to
the slurry pipelines that which stated that no issues occurred during the period. There are no
additional comments regarding the forms.
Quarterly Tailings Inspection, Embankments:
Findings: Quarterly inspection data is documented on Appendix A-4 of the Environmental
Protection Manual, Section 3. DWMRC reviewed the EFR quarterly inspection report dated
September 30, 2022. Regarding the embankment inspection it was noted that all embankments were in good condition. There are no additional comments regarding the forms. Tank to soil potential measurements:
Findings: This item was included as part of a September 1, 2011 DWMRC Request for Information (“RFI”), RFI # 2. DWMRC had concerns regarding on-grade tanks (tanks where the bottom is in contact with soil). Per DWMRC communication with EFR it was clarified
that tanks which sit on the ground must have cathodic protection or sit on a concrete
foundation. Per DWMRC inspection of the tank foundations during the 2022 inspection, no issues regarding the concrete foundations were noted.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Tank and pipeline thickness tests: Findings: During the inspection period, as noted on the EFR monthly inspection form, the
slurry pipelines were noted to be in good condition by EFR.
Spill Incident Reports: Findings: This item is discussed above in the section related to reportable and small quantity
spills. DWMRC notes that an effective spill reporting and tracking system has been implemented at the Mill. 1.11 Personnel training and Spill Prevention Procedures (records of training required to be maintained in the general safety training files): Personnel training for spill prevention are discussed in the internal notification of spills section of this module above. Per DWMRC findings the personnel training has been implemented and appears to be effective. Mill staff attend an annual training regarding the small quantity internal spill notification process.

Section II -- Site Walk-through Inspection
Areas and Observations: Ore Storage:
The storm water detention tank (kiva) was full of water and sediment due to a storm event on the previous day. Onsite EFR representatives noted that the tank would be pumped out and
sediment removed soon.
Areas of storm water ponding were noted on the ore pad. It was noted that this was due to the recent storm event(s). Onsite EFR representative noted that those areas would be pumped to remove standing water to the degree possible.

Storm water detention tank (kiva)
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Standing water (ponding) on ore storage pad

Standing water in area of the transformers and sulfuric acid tank
Reagent Yard:
Per DWMRC observations no issues were noted regarding reagent storage.

Shop/Vehicle Maintenance Area:
DWMRC notes that areas inside of the vehicle maintenance shop and surrounding area drain through the pipeline to Cell 1. DWMRC noted that hydraulic fluid and oil drums were stored
on pallets with secondary containment. The secondary containments contained water due to
the recent storm event(s). EFR representatives noted that the secondary containments would be pumped out to maintain the pallets for capture of potential leaks and spills. Water was noted in the secondary containment of the used oil and kerosene tanks from recent
storm event(s). EFR representatives noted that this water would be removed to maintain the
containment volume.
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Used oil tank containment, water will be removed
Mill Processing Areas:
SX Building Roof Drainage:

It was noted that the area around the SX building had been stabilized with rock riprap and that the drainage channel had been improved. There was no evidence of erosion or other impact from drainage. No additional comments during the 2022 inspection. Alternate Feed Circuit South of the SX Building: Observations: Concrete staging pads appeared to be in good condition. All drums/containers of alternate feed were stored on the concrete impervious surface areas. No additional comments during the 2022 inspection.
Old Decontamination Pad:
The old decontamination pad was being used minimally. It was noted that the pump was leaking slightly onto the impervious pad around the ammonium sulfate tanks but posed no
issues regarding ponding on permeable surfaces. No additional comments noted during the
2022 inspection.
New Decontamination Pad: Observations: Pump now located at the top of the decontamination pad. Any leaks from the
pump will re-enter the water circuit. This was in response to comments documented during the 2018 inspection. Per DWMRC inspection findings no evidence of a discharge outside of the pad area was noted and no additional comments were noted during the 2022 inspection. Reagent Tanks: Sodium Chloride Tanks – Per past agreements between DWMRC and EFR (Agreements made in 2005) the secondary containment for these tanks is earthen. Per the agreement, all reagent tanks that pre-existed the Ground Water Permit (3/05) would be acceptable as is – and that as upgrades or replacements were installed, EFR would work to meet BAT
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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requirements. More detail regarding this agreement is in the December 2004 Statement of Basis for the site Ground Water Quality Discharge Permit, and in Part I.D.3(g) of the Permit.
No issues were noted during the 2021 inspection.
Kerosene Tanks (West of Shop) – The kerosene tanks and concrete platforms appeared in good condition.
Ammonia Tanks – Secondary containment is earthen per the same agreement as the sodium
chloride tanks. Per observations no comments were noted. Ammonium Sulfate Crystal Tanks – Per the 2022 inspection the secondary containment for the ammonium sulfate crystal tanks and the surrounding impervious pad for the nitrate
corrective action plan were in good condition. No concrete spalling or cracks were noted.

Ammonium sulfate crystal tanks secondary containment
Kerosene Tank (shop) – The shop kerosene tank sits in the same secondary containment as the used oil tank. Per comments regarding the shop/maintenance areas above the secondary containment had some water accumulation from recent stormevents, and will be pumped to
maintain secondary containment volume.
Fuel Tanks – A significant amount of water was ponded around the fuel tanks due to the elevation and grading in this area. EFR representatives stated that the ponded water would be pumped and removed from this area.

Ponded water at fuel tank area
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Uranium Liquor Tanks – No comments were noted.
Vanadium Pregnant Liquor (VPL) Tanks – No comments were noted.
Clean Water Tank – No standing water was noted around the tank. The tank appeared in good condition. No comments were noted.
Sulfuric Acid Tank – The tank, concrete platform appeared in adequate condition. The
berm around the tank was in good condition. No comments noted.

Sulfuric Acid Tank, Berm around tank and tank in good condition.
Caustic Soda Tank – No comments regarding the caustic soda tanks was noted. Concrete in
secondary containment and tanks were in good condition. Soda Ash Tanks – Spalling was noted in the secondary containment for the soda ash. No cracks were noted, and it was discussed with EFR representatives that the concrete should be inspected to ensure that integrity of the concrete was not impacted by the surface
degradation. DWMRC had no additional comments.

Spalling of concrete under soda ash tanks
Utah Division of Waste Management and Radiation Control (DWMRC)
Ground Water Module 65, DWMRC Annual Storm Water Inspection Energy Fuels Resources, White Mesa Uranium Mill, Ground Water Permit UGW370004
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Tailings Cells Areas (Note that upland drainage was included in comments above) – DWMRC toured the tailings cell areas (Cells 4A and 4B) and observed the condition of the
outer toe areas of the dikes to ensure that excessive erosion or damage (e.g. burrowing animal intrusion or rooting damage) was not present. No areas of excess erosion were noted during the 2022 inspection and the embankments were in good condition.. Summary of Onsite Closeout Meeting: Date/Time: October 4, 2021/10:00 A.M. EFR Representatives Present – Garrin Palmer (RSO)
Tanner Holliday
DWMRC Representatives Present – Tom Rushing Phil Goble
An onsite close-out meeting took place to discuss findings of the storm water. Specifically,
the following issues were discussed by DWMRC: Documentation: DWMRC discussed that the documentation review appeared to be fully filled out and to address the requirements of the permit. No specific issues were identified.

Site Walkthrough: DWMRC discussed that during the site walkthrough no specific
violations were noted. The findings of standing water on the ore pad, in the used oil containment, and at the fuel tank and transformer areas was discussed. The issue of the concrete under the soda ash tanks was discussed. Per discussion the standing water was scheduled to be removed/pumped and was the result of recent precipitation. The concrete
will be monitored to ensure that it is providing an impervious barrier.
Conclusions

A close-out letter will be sent to EFR regarding the 2022 storm water inspection at the White
Mesa Uranium Mill.