DRC-2023-004322 - 0901a068811f77a8

DRC-2023-004322 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

M E M O R A N D U M

TO: Project File C-2023-37

THROUGH: Phil Goble, Uranium Mill Section Manager

FROM: Heather Mickelson, PE, PG
DATE: May 16, 2023

SUBJECT: 2023 BAT/DMT Field Inspection; Radioactive Materials License Number UT1900479,
Amendment # 10 and Ground Water Discharge Permit UG37004, dated March 8, 2021;
Energy Fuels Resources White Mesa Mill, Blanding, Utah

Authority

UAC R317-6-4 Issuance of a Discharge Permit
“A. The Director may issue a ground water discharge permit for a new facility if the Director
determines, after reviewing the information provided under R317-6-6.3, that:...3. the applicant is using
best available technology to minimize the discharge of any pollutant; ...”

UAC R313-15-406(2) Minimization of Contamination
“Licensees shall, to the extent practical, conduct operations to minimize the introduction of residual
radioactivity into the site, including the subsurface, in accordance with the existing radiation protection
requirements in Section R313-15-101 and radiological criteria for license termination in Sections R313-
15-1401 through R313-15-1406.”

Permit and License Conditions

The data collected during the BAT/DMT inspections is used to generate reports for the quarterly DMT
Performance Standards Monitoring Report and Cell 4A BAT Performance Standards Monitoring Report
and Annual Technical Evaluation Report of the White Mesa Tailings Management System. These
reports are used to show compliance with the following conditions in the Radioactive Materials License
and the Ground Water Discharge Permit.

May 16, 2023
05/16/2023
2023 BAT/DMT Field Inspection
May 16, 2023
Page 2

Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.3
“The licensee shall implement a monitoring program of the leak detection systems for disposal Cells 4A
and 4B in accordance with requirements of the Permit. The licensee shall implement an operation,
maintenance, and monitoring program of the leak detection systems for disposal Cells 1, 2, and 3…”

Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.7
“Settlement Monitoring Standard Operating Procedure - the licensee shall perform settlement monitoring for
vertical settlement in the tailings management cell area in accordance with the currently Director approved
Settlement Monitoring Standard Operating Procedure (SOP) The Licensee shall document settlement
monitoring data and compare such data to previous data to track potential settlement. All data collected by
the Licensee for these purposes shall be included in an annual report to be submitted to the Director, pursuant
to License Condition 12.2. …”

Radioactive Materials License #UT1900479, Amendment # 05, Condition 11.8
“Movement (Displacement) Monitoring Standard Operating Procedure - the Licensee shall perform
monitoring for potential vertical and horizontal movements in the constructed dike portions of the tailings
management cells in accordance with the currently Director approved Movement Monitoring Standard
Operating Procedure (SOP). The Licensee shall document displacement monitoring data and compare such
data to previous data to track potential movement (displacement). …”

Ground Water Discharge Permit #UGW370004, Part I.E.7
“DMT Performance Standards Monitoring - the Permittee shall perform technology performance
monitoring in accordance with the currently approved DMT Monitoring Plan to determine if DMT is
effective in minimizing and controlling the release of contaminants…”

Ground Water Discharge Permit #UGW370004, Part I.E.8
“Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the currently
approved Cell 4A BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall immediately
implement all monitoring and recordkeeping requirements therein….”

Ground Water Discharge Permit #UGW370004, Part I.E.12
“Cell 4B BAT Performance Standards Monitoring and Maintenance - immediately following Director
approval of the Cell 4B BAT, Monitoring, Operations and Maintenance Plan, the Permittee shall
immediately implement all monitoring and recordkeeping requirements therein….”

Observations

Heather Mickelson, PE, PG, of the Utah Division of Waste Management and Radiation Control (the
Division), inspected the White Mesa Uranium Mill during data collection activities on May 5, 2023.
The mill is owned and operated by Energy Fuels Resources (the Licensee).

This inspection was specific to the Licensee’s Standard Operating Procedures, Discharge Minimization
Plan (DMP), dated December 2016, and Tailings Management System (TMS), dated March 2017, for
the time period since the previous inspection last performed by Russ Topham on March 18, 2022. The
Licensee provided copies of the current revision of the field report forms used to perform the daily,
weekly, and annual inspections for the DMP and the daily, weekly, monthly, and quarterly inspections
for the TMS.
2023 BAT/DMT Field Inspection
May 16, 2023
Page 3

Mr. Tanner Holiday, and Mr. Deen Lyman conducted the daily and weekly inspections of the DMP and
the TMS. The monthly inspection for the TMS was also executed. As the quarterly inspection for the
TMS is a summary of the quarter’s activities and overall status of the tailings cells, this inspection was
not performed during this visit. The annual inspection for the decontamination pad and the ammonium
sulfate cover area for the DMP is pending for the 2nd Quarter of 2023.

All individual inspections components of the inspection are not reviewed in this narrative. During the
collection of the data, I agreed with the data collected and the staff’s evaluation of the status of the
Mill’s components. The Licensee’s staff demonstrated an appropriate understanding the data collected
and its further use. Specific components of the onsite inspection are discussed further.

 Pictures showing the methods used by Mill staff to measure the liquid elevation in Cells 1, 4A,
AB are shown in Photos 1- 3.
 The leak detection system for the Old Decon Pad and New Decon Pad were checked for leaks
(Photo 4.)
 The fuel tank and pump area was in good condition with no obvious signs of leakage and cracks
on the concrete were filled (Photos 5 and 6).
 Diversion ditches were free of debris to allow for water movement away from the site during a
significant storm event.
 A records review of the data collected since the last inspection was performed following the site
inspection. I specifically reviewed the daily, weekly, monthly, and quarterly reports for June
2022, October 2022, December 2022, and February 2023. The records show similar conditions
for the previous months.
 In addition to appropriate data collection techniques and site evaluation, the records review
demonstrated ongoing maintenance to protect human health and the environment. For instance,
when rodent burrows are noted near or on the cells, the rodents are removed. They are also make
note of road maintenance issues caused by precipitation.

A close out meeting to discuss observations from the inspection included with Heather Mickelson, Terry
Slade, Tanner Holiday, and Deen Lyman.

Conclusions and Recommendations

The Licensee appears fully compliant with applicable laws, standards, requirements with respect to
DMT/BAT data collection and evaluation. The Licensee’s personnel appear to understand the
significance of the data being collected and provide accurate and comprehensive records. In addition,
the correct forms are being used to record the data.

No new recommendations were identified during this inspection.

Attachments: 2023 Annual BAT/DMT Inspection Photolog

Photo 1. Liquid level measurement in Cell 1. Photo was taken on May 5, 2023 and is
looking west.
Photo 2. Liquid level measurement in Cell 4A. Photo was taken on May 5, 2023 and
is looking north.
Photo 3. Liquid level in Cell 4B. Currently, the EFR is filling with fresh water from
Recapture Reservoir. Photo was taken on May 5, 2023 and is looking west.
Photo 4. Checking for leaks in the leak detection system on the New Decon Pad.
Photo was taken on May 5, 2023.
Photo 5. Diesel and gasoline tanks. Tanks appear to be in good condition and cracks
under them have been filled. Photo was taken on May 5, 2023.
Photo 6. Diesel and gasoline tanks and pumps. All appear in good condition and
there is no staining on the concrete or nearby soil. Photo was taken on May 5, 2023.
Photo 7. Diversion ditch 1 looking east toward the northern end of the mill. Water
flows north from the middle of the picture to the right lower corner of the photo.
Photo was taken on May 5, 2023.
Photo 8. Diversion Ditch 2 where recent vegetation was removed. Water flows north
from the middle of the picture to the right lower corner of the photo. Photo was taken
on May 5, 2023 and looks north toward the mill.