DRC-2022-017441 - 0901a068810ae01d

DRC-2022-017441,,! ~
~-, '.•
1896
State of Utah
GARY R. HERBERT
Governor
SPENCER l COX
Lieutenant Governor
Department of
Environmental Quality
L. Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Tyl. Howard
Director
MEMORANDUM
TO: Project File C-2022-32
THROUGH: Phil Goble, Uranium Mill Section Manager
FROM: Russell J. Topham, PE
DATE: June 2, 2022
SUBJECT: 2022 Engineering Module 73, Inspection of disposal of 11 e.(2) decommissioning debris
from in situ recovery facilities File Audit, May 10, 2022
Authority
Radioactive Materials License #UTJ900479, Condition 10.5: "In accordance with the Licensee's
submittal to the NRC dated May 20, 1993, the Licensee is hereby authorized to dispose of byproduct
material generated at licensed in situ leach (ISL) [aka in situ recovery (ISR) facilities, subject to [ ... ]
conditions." (Conditions are cited below as Requirements.)
R313-12-3 (quoting JO CFR 40.4): "Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes." 1
10 CFR Part 40 Appendix A, Criterion 2: "To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such off site disposal
1 This definition amends the language given in Section 11 e.(2) of the Atomic Energy Act as amended in 1954 to include in
situ recovery (or in situ leach) facilities on the same footing as conventional uranium mills. This is done by referencing
"solution extraction" in the definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980,
Volume l, No. 10.
DRC-20 195 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 l 00% recycled paper
2022 ISR Decommissioning Debris Disposal File Inspection Report
June 2, 2022
Page2
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations."
Requirements
1. Radioactive Materials License #UTJ900479, Condition 10.5A: "1 le.(2) byproduct material
[disposal] is limited to 10,000 cubic yards total in aggregate annually generated at any source outside
the State of Utah." The Division considers a source to be a discrete facility defined by its
geographic boundaries.2 Additionally, "1 le.(2) byproduct material is unlimited in quantity from any
in-situ recovery source outside the State of Utah owned by the holder of this license or its affiliates."
And, disposal of 11 e.(2) byproduct material is unlimited in quantity from any source located within
the State of Utah."
2. Radioactive Materials License #UT1900479, Condition 10.5B: "All ISL contaminated equipment
shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other
than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels
containing soil or sludges shall be verified by the Licensee to be full prior to disposal. Barrels not
completely full shall be filled with tailings or soil prior to disposal."
3. Radioactive Materials License #UT1900479, Condition 10.5C: "All ISL waste shall be buried in
Cell No. 3 unless prior written approval is obtained from the Director for alternate burial locations."
4. Radioactive Materials License #UT1900479, Condition 10.5D: "All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include descriptions of
the ISL waste and the disposal locations, as well as all actions required by this License condition."
5. Radioactive Materials License #UTJ900479, Condition 10.5E: "The Licensee shall also submit for
Director approval a revised written Standard Operating Procedure (SOP) for ISL disposal on or
before December 1, 2010. The revised SOP shall describe the documentation required for ISL
disposal, which shall include but is not limited to the following:"
(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an
area of the cell that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material will be segregated from any mill material and equipment disposed
of in the cells pursuant to License Condition 10.4, and the ISL byproduct material from each in
situ leach source will be segregated from the byproduct material from all other in situ leach
sources;
2 A "source" in this context is a geographically discrete facility. See Letter from Rusty Lundberg to Jo Ann Tischler dated
November 7, 2013 (DRC-2013-005682)
2022 ISR Decommissioning Debris Disposal File Inspection Report
June 2, 2022
Page 3
(4) Absence of void space inside barrels disposed, including physical verification before disposal;
and
(5) Detailed engineering drawings which demonstrate:
a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the
tailings cell.
6. Radioactive Materials License #UT1900479, Condition 10.5F: The Licensee shall notify the
Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any
byproduct material generated at ISL facilities in the tailings cells.
An annual summary of the amounts of waste disposed of from off-site ISL generators shall be sent to
the Director on or before November 1 of each calendar year.
Observations
Russell J. Topham, PE of the Utah Division of Waste Management and Radiation Control (the
Division), inspected the records of disposal activities for 2021 and the portion of 2022 from January 1
through May 10. The inspection focused on completeness of the records required under SOP PBL-10,
adherence to the quantity limitations specified in License Condition IO.SA, and fulfillment of the
notification requirement in License Condition IO.SF. Note that SOP PBL-10 was submitted to fulfill the
requirements of License Conditions 10.5 D (record keeping) and E (submittal of the SOP to the
Director). Also note that adherence to SOP PBL-10 insures compliance with License Condition IO.SF
regarding burial location.
2021 Paperwork Audit
• The file for 2021 contained eighteen packets of paperwork: All packets met the requirements of
SOP PBL-10 for content.
• The documentation contained a notice from the generator that a shipment was prepared,
including the generators description of the material and a certification indicating absence of
RCRA waste in the load. Each data packet included such a notice.
• The information in the shipper's notice compared with the description that EFRI's agents entered
on the PBL-10 form included in each packet. This confirmed that the mill staff were checking to
see that the material received was consistent with what the generator's notice described. Mill
staff consistently entered a description of the material received on the form, and each description
correlated well with the generator's documentation.
• Each packet contained a notice to the Director dated at least seven days prior to the documented
burial date.
• Each packet included measurements made upon receipt of the material upon receipt for
radiological exposure at the container surface and photoionization detector (PID) readings to
screen for presence of volatile organic compounds (an indicator of the presence ofRCRA waste).
All radiological measurements were within expectations for 1 le.(2) byproduct material, and
2022 ISR Decommissioning Debris Disposal File Inspection Report
June 2, 2022
Page4
indicated no need for special handling to meet the mill's ALARA goals. All PID readings were
zero.
• Physical survey data in the packets indicated that all material was buried laterally and vertically
distant from the impoundment liner, and below the liner crest elevation.
• Received byproduct material quantities did not exceed the limits established in License
Condition 10.5A. The quantities reported in the Annual technical Evaluation Report were
checked against the total represented in the data packets contained in the 2021 file. See Tables 1
and 2 at the end of this report.
2022 Paperwork Audit
· • The file for 2022 contained six packets of paperwork: All packets met the requirements of SOP
PBL-10 for content.
• The documentation contained a notice from the generator that a shipment was prepared,
including the generators description of the material and a certification indicating absence of
RCRA waste in the load. Each data packet included such a notice.
• The information in the shipper's notice compared with the description that EFRI's agents entered
on the PBL-10 form included in each packet. This confirmed that the mill staff were checking to
see that the material received was consistent with what the generator's notice described. Mill
staff consistently entered a description of the material received on the form, and each description
correlated well with the generator's documentation.
• Each packet contained a notice to the Director dated at least seven days prior to the documented
burial date. Note that three of the loads had not been buried but were staged at the burial site.
The burial would have been observed as part of this inspection effort, but mill staff were
unavailable to do the burial at that time due to other work responsibilities.
• Each packet included measurements made upon receipt of the material upon receipt for
radiological exposure at the container surface and photoionization detector (PID) readings to
screen for presence of volatile organic compounds (an indicator of the presence ofRCRA waste).
All radiological measurements were within expectations for 11 e.(2) byproduct material, and
indicated no need for special handling to meet the mill's ALARA goals. All PID readings were
zero.
• Physical survey data in the packets representing the three buried loads indicated that all material
was buried laterally and vertically distant from the impoundment liner, and below the liner crest
elevation.
• Received byproduct material quantitie~ did not exceed the limits established in License
Condition 10.5A. See Table 2 at the end of this report.
Following the inspection, I reported his findings to Mr. Logan Shumway, Mill Manager.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 11 e.(2) byproduct material generated as decommissioning debris
from in situ uranium recovery facilities during the time period January 1, 2021 through May 10, 2022.
The inspection should be closed out.
2022 ISR Decommissioning Debris Disposal File Inspection Report
J~ne 2, 2022
Page 5
Energy Fuels Resources (USA) Inc. l le.(2) Receipts for November 1, 2020-December 31, 2021.
G enerator
Crow Butte
Resources
IEC
Mestena Uranium,
L.L.C -Alta Mesa
ISL Project
Cameco-Highland
Cameco -North
Butte
Cameco -SAT 2
Cameco -SAT 3
Cameco -Smith
Ranch Property
Cameco-CPP
Strata Energy
UEC -South Texas
Mining
UEC-Goliad
UEC -La Palangana
Uranerz -Nichols
Ranch
Uranium One
URI. Inc. -Rosita
URI, Inc. -Kingsville
Dome ISR Project
URI, Inc. -Vasquez
ISR Project
USX-Texas
Uranium operations
Weston Solutions
Totals
Received
Cubic
Received Yards
T 2021 2021 ons
85.40 240.00
0.00 0.00
6.10 19.20
17.80 74.70
7.90 24.70
5.20 42.29
0.00 0.00
0.00 0.00
5.40 24.70
18.60 94.00
1.50 1.10
0.00 0.00
19.30 28.10
4.10 20.00
0.00 0.00
6.50 25.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
177.80 593.79
Cubic
Tons Yards
Received Received
from from
nceot,on ncept1on C omments
688.04 1945.00 Active
4826.37 4920.00 Closed
3322.91 3566.25 Active
1388.40 3129.38 Active
23.50 74.40 Active
37.30 204.09 Active
13.20 43.90 Active
1554.89 3635.06 Active
68.80 257.40 Active
98.60 498.00 Active
5008.40 4046.00 Active
0.00 0.00 Active
397.70 480.70 Active
46.70 290.00 Active
29.20 198.10 Active
664.47 928.79 Active
2676.66 4992.26 Active
172.23 424.70 Active
5099.99 4636.35 Closed
0.60 0.50 Active
Table 1: Reproduction of final page of 2021 Annual Technical Evaluation Report (DRC-2022-004426)
showing 1 le.(2) receipts at the White Mesa Uranium Mill for the fourteen month period November 1,
2020 through December 31, 2021. The odd time period co~ered in the table reflects a change in
reporting due date for the Annual Technical Evaluation Report and a change in reporting period to
coincide with the calendar year: The final two months of 2020 were included in the 2021 report at the
direction of the Director in lieu of preparing a separate report for those two months.
2022 ISR Decommissioning Debris Disposal File Inspection Report
June 2, 2022
Page 6
Data from Forms PBL-10 Weigh Ticket Data Bill of Lading Data
Rad RCRA
Date Generator Shipper ID Notice mr/hr PIO Date Weight Volume Certification
27-Jan-22 URI Kinl!SYille l)ome 22KVD-001 28-Jan-22 0.3 0 27-Jan-22 14940 25 Yes
3-Mar-22 URI Kingsville Dome 22KVD-002 3-Mar-22 0.1 0 3-Mar-22 9880 25 Yes .......
1-Mar-22 URI Kingsvillel)orne 22KVD-003 1-Apr-22 0.2 0 31-Mar-22 17860 25 Yes
3-May-22 Strata. Energy 22-039 6-May-22 1.5 0 3~May-22 13360 33 Yes
6-May-22 UEC Hobson HOB-145 6-May-22 0.05 0 6-May-22 34240 17 Yes
6-May-22 UEC Hobson HOB-146 6-May-22 0.5 0 6-May-22 30920 7 Yes
18-0ct-21 Crow Butte W-04-21 CBR-1 12-0ct-21 0.02 0 18-0ct-21 20640 30 Yes
11-0ct-21 Crow Butte W-03-21 CBR-2 4-0ct-21 0.3 0 11-0ct-21 23340 30 Yes
7-Jun-21 Crow Butte W-01-21 CBR-1 7-Jun-21 0.3 0 7-Jun-21 20620 30 Yes
30-Jun-21 Crow Butte W-02-21 24-Jun-21 2 0 3-Jun-22 24240 30 Yes ....
5-0ct-21 Cameco Smith Ranch 2021-CPP-15 29-Sep~21 2 0 5-0ct-21 10880 24.7 Yes
1-0ct-22 Cameco Smith Ranch 2021-SAT2-14 22-Sep-21 0.07 0 1-0ct-21 4500 17.3 Yes
21-May-21 Cameco Smith Ranch 2021-CPP-04 2-Jun-21 2 0 21-May-21 13580 24.7 Yes ' ' 26:May-21 Cameco Smith Ranch 2021-SRl-07 26-May-21 2 0 26-May-21 4380 24.7 Yes ..
13-0ct-21 URI Rosita 21ROS-030 7-0ct-21 0.2 0 13-0ct-22 13040 25 Yes ..
28-May-21 Cameco Smith Ranch 2021-SAT2-08 26-Feb-21 2 0 28-May-21 5920 24.7 Yes
3-Nov-21 SVata Energy 21-038-1 4-Nov-21 0.2 0 3-Nov-21 22100 41 Yes ...
17-Mar-21 Strata Enei:.gy .21-037-1 17-Mar-21 3 0 17-Mar-21 15020 9 Yes
17-Mar-21 Strata Energy 21-037-2 17-Mar-21 3 0 17-Mar-21 15020 32 Yes
20-Apr-21 Nichols Ranch NR-017-CPP 22-Apr-21 0.3 0 20-Apr-21 8240 20 Yes ...
13-Jan-21 UEC Hobson HOB-144 14-Jan-21 3 0 13-Jan-21 3000 1.11 Yes ..
13-Jan-21 La Palngana LP-029 14-Jan-21 3 0 13-Jan-21 10240 11.11 Yes
24-Jun-21 La Palngana LP-030 24-Jun-21 2 0 24-Jun-21 28300 11.11 Yes
3-May-21 Mestena -Alta Mesa 'i76 3-May-21 0.2 0 3-May-21 12260 19.2 Yes
Elevation Data from Survey Status
Top of Bottom
Liner at Burial of Burial
Perimeter Envelope Envelope
5,608.50 5,605.90 5,601.84 Buried
5,608.50 5,606.01 5,602.19 Buried
5,608.50 5,605.79 5,601.84 Buried
Staged
'
Staged
Staged
5,608.50 5,605.40 5,600.20 Buried
5,608.50 5,601.56 5,597.64 Buried
5,608.50 5;607.34 5,602.80 Buried
5,608.50 5,607.34 5,602.80 Buried
5,608.50 5,600.96 5,597.68 Buried
5,608.50 5,600.96 5,597.68 Buried
5,608.50 5,606.60 5,603.60 Buried
5,608.50 5,606.60 5,603.60 Buried
5,608.50 5,601.66 5,597.65 Buried
5,608.50 5,606.60 5,603.60 Buried
5,608.50 5,605.40 5,600.20 Buried
5,608.50 5,604.74 5,599.70 Buried
5,608.50 5,604.74 5,599.70 Buried
5,608.50 5,606.38 5,600.60 Buried
5,608.50 5,605.17 5,602.02 Buried
5,608.50 5,605.56 5,602.50 Buried
5,608.50 5,606.12 5,603.40 Buried
5,608.50 5,607.28 5,601.80 Buried
Table 2: Data collected during the paperwork audit of in situ recovery-generated l le.(2) burial records
at the White Mesa Uranium Mill for 2021 and 2022 through May 10, 2022.