DRC-2023-076848 - 0901a068812c03ff

DRC-2023-076848 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. 711
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 November 29, 2023 Kathy Weinel, Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 Lakewood, CO 80228 RE: Closeout Letter Regarding the November 8, 2023, Groundwater Module 65,
Storm Water Inspection at the White Mesa Uranium Mill Utah Groundwater Discharge Permit No. UGW370004 Radioactive Material License Number UT 1900479
Dear Ms. Weinel: The Division of Waste Management and Radiation Control (DWMRC) conducted a storm water inspection at the Energy Fuels Resources (USA) Inc. (EFRI) White Mesa Uranium Mill (Mill) on November 8, 2023.
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 DWMRC’s 2023 Ground Water Module 65, which
summarizes findings during the inspection, is attached for your information. Note that a closeout conference with EFRI representatives Garrin Palmer, Tanner Holliday, Logan Shumway, and Terry Slade was conducted after the inspection. Based on the inspection, the 2023
Storm Water Inspection (Ground Water Module 65) is hereby closed out. If you have any questions, please call Chris Leahy at 385-602-5505.
Sincerely, Phil Goble, Uranium Mills and Radioactive Materials Manager Division of Waste Management and Radiation Control (Over)

PRG/CL/jk Enclosure: Ground Water Module 65, DWMRC Annual Storm Water Inspection (DRC-2023-076878)
c: Grant Sunada, Health Director, San Juan Public Health Department Ronnie Nieves, Environmental Health Director, San Juan Public Health Department Russell Seeley, District Engineer, UDEQ Logan Shumway, Manager, White Mesa Mill Plant Manager (Email)

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: 2023
Inspection Date: November 8, 2023
Module Reviewer Name:
Phil Goble, Manager
Module Prepared by/Date Prepared:
Chris Leahy, P.G./November 22, 2023
DWMRC Staff Present: Chris Leahy
Phil Goble
Energy Fuels Resources Staff Present: Garrin Palmer
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 for the White Mesa Uranium Mill:
SPCC: September 8, 2023 (Approved by DWMRC on October 16, 2023).
SWBMPP: April 14, 2022 (Approved by DWMRC on May 5, 2022).
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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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.

Findings:

The Utah Division of Waste Management and 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 and excessive vegetation growth was not present.

EFR inspects the diversion ditches and berms monthly and are
included on the monthly inspection data form. DWMRC reviewed the July 2023 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, 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, howev
other areas and tanks (2023 Logs were inspected no comments regarding disrepair or
inaccessibility of the tanks was 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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1.9.1.

Findings: No reportable quantity spills were reported by EFR during the period reviewed.

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
and Signature. The reports additionally include photographs of the spill and follow up
actions for all reported spills during 2023.

Small quantity spill reports were reviewed between 1/1/2023 and 11/7/2023. 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 all cases, photos of the spill and clean-up are included.

During 2023, EFR implemented the storm water training program with the annual SPCC
refresher in four sessions (2/28/23, 3/2/23; 3/8/23, 3/10/23, 3/20/23, and 3/31/23). A total of
64 employees were trained during 2023 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: 7/1/2023 through 7/31/2023
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: July 2023 (31 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.
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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4. Physical inspection of the slurry lines.
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 actions
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)

DWMRC randomly selected and reviewed the Appendix A-1 daily forms
for the month of July 2023 (daily forms). 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.

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, and 4B,
as well as slimes drain liquid levels for Cell 2. 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 July 2023 weekly forms. All forms were filled out and identified the
individuals completing the inspections. Per the 2023 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
July 31, 2023. The monthly inspection reports include sections related to the slurry pipelines
and also diversion ditches which stated that no issues occurred during the month. 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
July 31, 2023. Regarding the embankment inspection it was noted that all embankments
were in good condition. There are no additional comments regarding the forms.

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 to soil potential measurements:

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.

Findings: Per DWMRC inspection of the tank foundations during the 2023 inspection, no
issues regarding the concrete foundations were noted.

Tank and pipeline thickness tests:

Findings: During the inspection period, as noted on the EFR monthly inspection form, and
Monthly Tailings Inspection - Pipeline Thickness
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 SPCC training
regarding the small quantity internal spill notification process.

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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Section II -- Site Walk-through Inspection

Areas and Observations:

Ore Storage:

No areas of storm water ponding were noted on the ore pad. The storm water detention tank
(kiva) was free of water and sediment buildup was minimal. The ore storage area
surrounding the kiva was recently graded to prepare for additional ore storage per EFR
representative. No areas of storm water ponding were noted on the ore pad.

Photo 1: Storm water detention tank (kiva)

Photo 2: Typical condition around the ore storage pad. No standing water observed.

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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Reagent Yard:

Per DWMRC observations, no issues were noted regarding reagent storage.

Shop/Vehicle Maintenance Area:

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 secondary
containment. The secondary containments were generally free of standing water.

Photo 3: Secondary containments under oil and hydraulic fluid drums

Mill Processing Areas:

Alternate Feed Circuit South of the SX Building:

The tanks and concrete containment appeared in good condition. No additional comments
were noted.

Photo 4: Alternate feed circuit tanks and secondary containment

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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Storage Area West of the SX Building:

All drums/containers of alternate feed were stored on the concrete impervious surface areas
and the concrete staging pads also appeared to be in good condition. No additional
comments were noted during the 2023 inspection.

Old Decontamination Pad:

According to the EFR representative, the old decontamination pad is still being used
sparingly. No evidence of a discharge outside of the pad area was noted and no additional
comments were noted during the 2023 inspection.

Photo 5: Old decontamination pad

New Decontamination Pad:

Per DWMRC inspection findings, no evidence of a discharge outside of the pad area was
noted and no additional comments were noted during the 2023 inspection.

Reagent Tanks:

Sodium Chloride Tanks Per observations, no comments were noted during the 2023
inspection.
Photo 6: Sodium chloride tanks and secondary containment
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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Kerosene Tanks (West of Shop) 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 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. The kerosene tanks and concrete platforms appeared in good condition.

Ammonia Tanks Secondary containment is earthen per the same agreement as the
kerosene tanks. Per observations, no comments were noted.

Photo 7: Ammonia tanks

Ammonium Sulfate Crystal Tanks The secondary containment and the surrounding
impervious pad for the nitrate corrective action plan were in good condition. Only minimal
concrete spalling was observed.

Photo 8: Ammonium sulfate crystal tank secondary containment

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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Kerosene Tank (shop) The shop kerosene tank sits in the same secondary containment as
the used oil tank. No comments were noted.

Photo 9: Kerosene and used oil tanks and associated containment.

Fuel Tanks No comments were noted. The tanks and concrete containment appeared in
good condition.

Photo 10: Fuel tank area

Uranium Liquor Tanks No comments were noted.

Vanadium Pregnant Liquor (VPL) Tanks No comments were noted.

Clean Water Tank The tank appeared in good condition. No comments 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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Sulfuric Acid Tank The tank and concrete platform appeared in adequate condition. The
berm around the tank was in good condition. No other comments were noted.

Photo 11: Sulfuric Acid Tank, berm around tank and tank in good condition.

Caustic Soda Tank Spalling was observed in the secondary containment. No other
comments were noted.

Photo 12: Caustic soda tank containment

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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Soda Ash Tanks Spalling was observed in the secondary containment for the soda ash. No
other comments were noted.

Photo 13: Spalling of concrete under soda ash tanks

HCL Tanks Spalling was observed on the surface of the concrete in the secondary
containment. No other comments were noted.

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 2023 inspection and the embankments were in good condition.

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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Summary of Onsite Closeout Meeting:

Date/Time: November 8, 2023/08:00 A.M.

EFR Representatives Present Garrin Palmer (RSO)
Tanner Holliday
Logan Shumway
Terry Slade

DWMRC Representatives Present Chris Leahy
Dean Henderson
Phil Goble

An onsite close-out meeting took place to discuss findings of the storm water. Specifically,
the following items 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 spalling on the concrete surface under the soda ash
tanks, caustic soda tanks, and HCL tanks was discussed. The concrete will be monitored to
ensure that it is providing an impervious barrier and if necessary, a concrete slurry will
additionally be added on top.

Conclusions

A close-out letter will be sent to EFR regarding the 2023 storm water inspection at the White
Mesa Uranium Mill.