DRC-2024-005862

June 6, 2024
VIA EXPRESS DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www .e nero vfue ls.c o111
Div of Waste Management
and Radiation Control
JUN 1 0 2024
Re: Response to Request for Infonnation Ahead of Implementing Phase 2 of the Rare Earth Circuit,
Radioactive Materials License Number UT 19004 79
Dear Mr. Hansen:
Pursuant to the Division of Waste Management and Radiation Control's ("DWMRC's") letter dated
April 25, 2024, Energy Fuels Resources (USA) Inc. ("EFRI") is providing responses to the request for
infonnation.
For ease of review, this letter provides the DWMRC comments verbatim, in italics, below, followed by
EFRI's response.
One copy of the enclosed Attachments is unredacted and complete for internal DWMRC review and use
(see Attachments 4 through 6). One copy has been redacted in accordance with Utah Code 63G-2-101 et
seq. as noted below (see Attachments I through 3).
EFRJ is requesting that certain information enclosed with this letter be withheld from public disclosure
because it is considered confidential business information ("CBI") pursuant to the provisions of the Utah
Government Records Access and Management Act ("GRAMA"), Utah Code 630-2-101 et seq. The
information sought to be withheld is that information in Attachments 1 through 3 that has been redacted or
"blacked out" on each page of the redacted transmittals. The redacted information is also indicated by an
electronic marking "Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated
in the redacted text below." All redactions were based on CBI/Proprietary Information.
Pursuant to Section 63G-2-309(l)(a)(i) of GRAMA, EFRI hereby designates the redacted infonnation
identified above as CBI. The documents and information qualify as CBI because they are not publicly
available, and disclosure of the information therein likely would cause substantial harm to EFRI's
competitive position. The documents and information have been provided for the exclusive use of the
DWMRC on the express understanding that the information therein will be treated as confidential.
Accordingly, the redacted information should be treated as confidential by DWMRC.
Pursuant to Section 630-2-305 of GRAMA, the DWMRC should maintain the enclosed documents and
information as protected and confidential, and exempt them from public records or disclosure laws,
including but not limited to any subsequent requests under GRAMA or under the Freedom of Information
Act ("FOIA"). If a request is made for public review of the documents or information, DWMRC must
DRC-2024-005862
Letter to Doug Hansen
June 6, 2024
Page 2
notify EFRI and provide the company with a reasonable time in which to object to their disclosure or seek
an injunction preventing disclosure .
Pursuant to Section 63G-2-107 of GRAMA, Energy Fuels also invokes relevant U .S . Nuclear Regulatory
Commission regulations and guidance that protect the redactions, including but not limited to the
withholding of proprietary, personally identifiable and security-related information under 10 CFR 2.390.
DWMRC Comment Number 1:
1. SOPs Related to the Uranium Bearing Rare Earth Procedures
License condition 9.6 requires EFRI to submit up-to-date copies of all operational and non-operational
Standard Operating Procedures (SOP) to the Director of the Division (Director) by December 31 of each
year. EFRI submits a list ofSOPs annually, most recently on December 19, 2022 (DRC-2022 -024175) and
on December 14, 2023 (DRC-2023-078612). However, in both submissions, the SOPs included in "Book
15 -Uranium B earing Rare Earth Procedures " have been omitted with a brief statement that the SOPs are
proprietary and contain confidential business information (CBI).
The Division is not in receipt of a valid CBI claim relating to these SOPs. Under GRAMA , Utah Code
Section 63G-2-309(1)(a)(i), a person w ho wants to claim that a record provided to the Division is protected
from disclosure to a member of the public because it is CBI shall provide with the record i) a written claim
of business confidentiality; and ii) a concise statement of reasons supporting the claim.
Utah Code Section 63G-2-305(1) (trade secrets) and (2) (commercial information) describes the standards
and requirements that apply to the kinds of information that may be subject to a CBI claim. A request for
CBI treatment mus t be specific as to the rationale for the CBI claim and which records, or portions of
records, are covered by th e CBI claim. Please also refer to Utah Code§ 63G-2-309(l)(a)(i). Without this
information, the Division is unable to determine whether the CBI claim is valid.
As such, the Division is requesting EFRI submit all SOPs contained in Book 15 and any other SOPs related
to rare earth processing, along w ith a valid claim for treatment as CBI, if appropriate, as outlined in the
preceding paragraphs. The Division recommends that EFRI submits both a complete and redacted version
of each SOP. When performing redactions, please ensure that it is clear what has been redacted and why.
To better protect any potential CBI, please submit the SOPs and CBI claim as hard copies through the mail
and not electronically through dw111rcsub111it @ utah.gov.
EFRI Response:
As requested, the SOPs for rare earth bearing uranium , ("RE U") ore processing are included in Attachments
I (redacted) and 4 (unredacted). EFRJ hereby claims for treatment of the redacted information contained in
Attachment I as CBI as set out abov e in thi s letter.
DWMRC Comment Numb er 2 :
2. Documentation Supporting Evaluations Conducted for the 2022 Annual SERP Report
License condition 9.4 outlines the procedures EFRI must follow when evaluating whether i) a change to
the facility, ii) a change to procedures , or iii) conducting an experiment would require a license amendment.
Part B of condition 9.4 outlines the criterium a potential change must meet to not require a license
amendment. A Safety and Environmental Review Panel (SERP), therefore, evaluates each potential change
Letter to Doug Hansen
June 6, 2024
Page3
against the criteria set forth in Part B to determine if the change requires a license amendment. Actions
taken by the SERP must follow the most up-to-date version of SOP "PBL-1-SERP Procedure" and are
required to be reported to the Director by March 31 of the following calendar year per license condition
9.4 part D.
EFRI has annually submitted a report summarizing actions taken by the SERP, most recently on March 31,
2022 (DRC-2022-005502), March 30, 2023 (DRC-2023-002850), and March 26, 2024 (DRC-2024-
005046).
Section 4.0 of SOP PBL-1, "SERP Procedure", requires the SERP to document its review of whether a
potential change meets the criteria described in license condition 9.4 part B:
Section 4. 0 SERP Review Procedure
In their documented {emphasis added] review of whether a potential change, test, or experiment
(hereinafter called "the change'') is allowed under the License or P BLC, without a License amendment, the
SERP shall consider the following:
(]) Current License Requirements: ...
(2) Impacts on regulations: ...
(3) Environmental Assessment: ...
The documentation associated with the SERP review is typically not submitted as part of the annual
summary of SERP actions. The Division requests that EFRJ submit all documentation supporting both
decisions summarized in the 2022 Safety and Environmental Review Panel (SERP) Annual Report dated
March 30, 2023 (DRC-2023-002850). Jf EFRI believes that this documentation contains CBI, please submit
a claim/or treatment as CBI as outlined above, and the Division will assess this claim upon receipt.
EFRI Response:
As noted above, EFRI completed two SERP analyses in 2022. The resulting SERP Reports and associated
documentation contain CBI as noted above and both redacted and unredacted copies have been provided.
The redacted versions are included in Attachments 2 and 3 and the unredacted versions are included in
Attachments 5 and 6. EFRI hereby claims for treatment of the redacted information contained in
Attachments 2 and 3 as CBI as set out above in this letter.
DWMRC Comment Number 3:
3. Documentation Supporting Forthcoming SERP Evaluations Related to Rare Earth Elements
As mentioned above, during the February 5, 2024 meeting, EFRI indicated that moving forward with
expansions to the rare earth circuit was a priority for the 2024 calendar year. Further expansions to the
rare earth circuit would require, at a minimum, a SERP evaluation. As described above, this evaluation
will require an analysis as to whether the expansion of the rare earth circuit would(]) conflict with license
conditions or regulations, (2) degrade essential safety or environmental commitments, or (3) fall outside of
the actions analyzed in the most recent Environmental Assessment.
As discussed during the February 5, 2024 meeting, the Division requests that EFRI submit any preliminary
documentation it has which would support 2024 SERP analyses and decisions concerning the rare earth
Letter to Doug Hansen
June 6, 2024
Page4
circuit. Any information EFRI currently has and can submit to the Division concerning 2024 expansions to
the rare earth circuit could help expedite the Division's review of such decisions.
EFRI Response:
As discussed on February 5, 2024, the Mill is contemplating expanding its existing REU circuit by adding
its Phase 2 REU separation circuit, which will include the addition of a calciner that is dedicated to REU
calcining.
EFRI is currently in the engineering and design process for this expanded circuit EFRI will continue to
evaluate this expanded circuit relative to the Mill's licensed environmental envelope, Mill License,
Groundwater Discharge Permit and Air Approval Order conditions and applicable laws and regulations to
determine what parts of the expanded circuit can be approved via SERP and what, if any, License,
Groundwater Discharge Permit or Air Approval Order Amendments may be required.
Once the engineering has been advanced to a sufficient level of certainty and detail, EFRI will submit a
detailed analysis to DWMRC explaining what matters EFRI believes can be approved via SERP and what
matters, if any, may require License, Permit or Air Approval Order Amendment.
Upon DWMRC concurrence with EFRI's analyses, EFRI will then proceed with the preparation of any
amendment applications that may be required and perform all SERP actions that wiJI be required.
DWMRC Comment Number 4:
4. Documentation Characterizing Monazite Sands from Alternative Sources
On June 25, 2020, EFRI submitted a letter advising the Division of its plan to receive and process natural
uranium ores in the form of monazite sands from The Chemours Company's (Chemours) Mineral Sand
Separation Plant in Offerman, Georgia (DRC-2020-011981). The Division requested additional
information concerning the Chemours monazite sands on July 21, 2020 (DRC-2020-012682), and EFRI
responded to this request on September 9, 2020 (DRC-2020-015241). In a letter dated September 11, 2020
(DRC-2020-015094), the Division concurred that the Chemours monazite sands discussed in the above-
mentioned correspondences is naturally occurring ore and that no additional licensing actions would be
required for the mill to accept the material.
During the February 5, 2024 meeting, EFRI indicated that they were pursuing monazite sands from sources
other than Chemours. Please be advised that the aforementioned September 11, 2020 letter from the
Division only considers monazite sands from Chemours June 25, 2020 and September 9, 2020 letters from
EFRI. Similar monazite sand from any other source would have to be similarly evaluated to determine if
the sand was natural ore and not an alternate feed This evaluation would also have to be documented.
During the February 5, 2024 meeting, the Division indicated that it would need to review this natural ore
determination as well as all supporting documentation on a case-by-case basis for each source of monazite.
Therefore, the Division requests that EFRI submit any documentation it has pertaining to monazite sands
from sources other than the Chemours Company's Mineral Sand Separation Plant in Offerman, Georgia,
including but not limited to: the composition of the sand; methods used to extract, generate, or produce the
sand; and any cleaning, sieving, or processing of the sand prior to potential receipt at White Mesa Again,
providing this information well ahead of any planned receipts allows the Division time to review EFRI's
determinations and helps mitigate any potential delays.
Letter to Doug Hansen
June 6, 2024
Page 5
EFRJ Response:
EFRJ will submit documentation that demonstrates to DWMRC that any monazite sands from sources
other than Chemours is natural ore and not an alternate feed, well ahead of any planned receipts of any
such monazite sands.
If you have any questions regarding this letter, please contact the undersigned at [phone] or Mr.
Scott Bakken at [phone].
Yours very truly,
{tial(Jfr~
ENERGY FuELS RESOURCES {USA) INC.
Kathy Weinel
Director, Regulatory Compliance
cc David Frydenlund
Garrin Palmer
Logan Shumway
Scott Balcken
Jo Ann T ischler (Tischler Consulting)
June 6, 2024
VIA EXPRESS DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
Re: Response to Request for Information Ahead of Implementing Phase 2 of the Rare Earth Circuit,
Radioactive Materials License Number UT 19004 79
Dear Mr. Hansen:
Pursuant to the Division of Waste Management and Radiation Control's ("DWMRC's") letter dated
April 25, 2024, Energy Fuels Resources (USA) Inc. ("EFRI") is providing responses to the request for
information.
For ease ofreview, this letter provides the DWMRC comments verbatim, in italics, below, followed by
EFRI's response.
One copy of the enclosed Attachments is unredacted and complete for internal DWMRC review and use
(see Attachments 4 through 6). One copy has been redacted in accordance with Utah Code 63G-2-101 et
seq. as noted below (see Attachments 1 through 3).
EFRI is requesting that certain information enclosed with this letter be withheld from public disclosure
because it is considered confidential business information ("CBI") pursuant to the provisions of the Utah
Government Records Access and Management Act ("GRAMA"), Utah Code 63G-2-101 et seq. The
information sought to be withheld is that information in Attachments 1 through 3 that has been redacted or
"blacked out" on each page of the redacted transmittals. The redacted information is also indicated by an
electronic marking "Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated
in the redacted text below." All redactions were based on CBI/Proprietary Information.
Pursuant to Section 63G-2-309(1)(a)(i) of GRAMA, EFRI hereby designates the redacted information
identified above as CBI. The documents and information qualify as CBI because they are not publicly
available, and disclosure of the information therein likely would cause substantial harm to EFRI's
competitive position. The documents and information have been provided for the exclusive use of the
DWMRC on the express understanding that the information therein will be treated as confidential.
Accordingly, the redacted information should be treated as confidential by DWMRC.
Pursuant to Section 63G-2-305 of GRAMA, the DWMRC should maintain the enclosed documents and
information as protected and confidential, and exempt them from public records or disclosure laws,
including but not limited to any subsequent requests under GRAMA or under the Freedom of Information
Act ("FOIA"). If a request is made for public review of the documents or information, DWMRC must
Letter to Doug Hansen
June 6, 2024
Page 2
notify EFRI and provide the company with a reasonable time in which to object to their disclosure or seek
an injunction preventing disclosure.
Pursuant to Section 63G-2-107 of GRAMA, Energy Fuels also invokes relevant U.S. Nuclear Regulatory
Commission regulations and guidance that protect the redactions, including but not limited to the
withholding of proprietary, personally identifiable and security-related information under 10 CFR 2.390.
DWMRC Comment Number 1:
1. SOPs Related to the Uranium Bearing Rare Earth Procedures
License condition 9. 6 requires EFRI to submit up-to-date copies of all operational and non-operational
Standard Operating Procedures (SOP) to the Director of the Division (Director) by December 31 of each
year. EFRI submits a list ofSOPs annually, most recently on December 19, 2022 (DRC-2022-024175) and
on December 14, 2023 (DRC-2023-078612). However, in both submissions, the SOPs included in "Book
15 -Uranium Bearing Rare Earth Procedures" have been omitted with a brief statement that the SOPs are
proprietary and contain confidential business information (CBI).
The Division is not in receipt of a valid CBI claim relating to these SOPs. Under GRAMA., Utah Code
Section 63G-2-309(l)(a)(i), a person who wants to claim that a record provided to the Division is protected
from disclosure to a member of the public because it is CBI shall provide with the record i) a written claim
of business confidentiality; and ii) a concise statement of reasons supporting the claim.
Utah Code Section 63G-2-305(1) (trade secrets) and (2) (commercial information) describes the standards
and requirements that apply to the kinds of information that may be subject to a CBI claim. A request for
CBI treatment must be specific as to the rationale for the CBI claim and which records, or portions of
records, are covered by the CBI claim. Please also refer to Utah Code§ 63G-2-309(l)(a)(i). Without this
information, the Division is unable to determine whether the CBI claim is valid.
As such, the Division is requesting EFRI submit all SOPs contained in Book 15 and any other SOPs related
to rare earth processing, along with a valid claim for treatment as CBI, if appropriate, as outlined in the
preceding paragraphs. The Division recommends that EFRI submits both a complete and redacted version
of each SOP. When performing redactions, please ensure that it is clear what has been redacted and why.
To better protect any potential CBI, please submit the SOPs and CBI claim as hard copies through the mail
and not electronically through [e-mail].
EFRI Response:
As requested, the SOPs for rare earth bearing uranium, ("REU") ore processing are included in Attachments
1 (redacted) and 4 (unredacted). EFRI hereby claims for treatment of the redacted information contained in
Attachment 1 as CBI as set out above in this letter.
DWMRC Comment Number 2:
2. Documentation Supporting Evaluations Conducted for the 2022 Annual SERP Report
License condition 9.4 outlines the procedures EFRI must follow when evaluating whether i) a change to
the facility, ii) a change to procedures, or iii) conducting an experiment would require a license amendment.
Part B of condition 9.4 outlines the criterium a potential change must meet to not require a license
amendment. A Safety and Environmental Review Panel (SERP), therefore, evaluates each potential change
Letter to Doug Hansen
June 6, 2024
Page 3
against the criteria set forth in Part B to determine if the change requires a license amendment. Actions
taken by the SERP must follow the most up-to-date version of SOP "P BL-1 -SERP Procedure" and are
required to be reported to the Director by March 31 of the following calendar year per license condition
9.4 part D.
EFRI has annually submitted a report summarizing actions taken by the SERP, most recently on March 31,
2022 (DRC-2022-005502), March 30, 2023 (DRC-2023-002850), and March 26, 2024 (DRC-2024-
005046).
Section 4.0 of SOP PBL-1, "SERP Procedure", requires the SERP to document its review of whether a
potential change meets the criteria described in license condition 9.4 part B:
Section 4. 0 SERP Review Procedure
In their documented [emphasis added] review of whether a potential change, test, or experiment
(hereinafter called "the change'') is allowed under the License or P BLC, without a License amendment, the
SERP shall consider the following:
(1) Current License Requirements : ...
(2) Impacts on regulations: ...
(3) Environmental Assessment: ...
The documentation associated with the SERP review is typically not submitted as part of the annual
summary of SERP actions. The Division requests that EFRI submit all documentation supporting both
decisions summarized in the 2022 Safety and Environmental Review Panel (SERP) Annual Report dated
March 30, 2023 (DRC-2023-002850). If EFRI believes that this documentation contains CBL please submit
a claim for treatment as CBI as outlined above, and the Division will assess this claim upon receipt.
EFRI Response:
As noted above, EFRI completed two SERP analyses in 2022. The resulting SERP Reports and associated
documentation contain CBI as noted above and both redacted and unredacted copies have been provided.
The redacted versions are included in Attachments 2 and 3 and the unredacted versions are included in
Attachments 5 and 6. EFRI hereby claims for treatment of the redacted information contained in
Attachments 2 and 3 as CBI as set out above in this letter.
DWMRC Comment Number 3:
3. Documentation Supporting Forthcoming SERP Evaluations Related to Rare Earth Elements
As mentioned above, during the February 5, 2024 meeting, EFRI indicated that moving forward with
expansions to the rare earth circuit was a priority for the 2024 calendar year. Further expansions to the
rare earth circuit would require, at a minimum, a SERP evaluation. As described above, this evaluation
will require an analysis as to whether the expansion of the rare earth circuit would (1) conflict with license
conditions or regulations, (2) degrade essential safety or environmental commitments, or (3) fall outside of
the actions analyzed in the most recent Environmental Assessment.
As discussed during the February 5, 2024 meeting, the Division requests that EFRI submit any preliminary
documentation it has which would support 2024 SERP analyses and decisions concerning the rare earth
Letter to Doug Hansen
June 6, 2024
Page4
circuit. Any information EFRI currently has and can submit to the Division concerning 2024 expansions to
the rare earth circuit could help expedite the Division 's review of such decisions.
EFRI Response:
As discussed on February 5, 2024, the Mill is contemplating expanding its existing REU circuit by adding
its Phase 2 REU separation circuit, which will include the addition of a calciner that is dedicated to REU
calcining.
EFRI is currently in the engineering and design process for this expanded circuit. EFRI will continue to
evaluate this expanded circuit relative to the Mill's licensed environmental envelope, Mill License ,
Groundwater Discharge Permit and Air Approval Order conditions and applicable laws and regulations to
determine what parts of the expanded circuit can be approved via SERP and what, if any, License,
Groundwater Discharge Permit or Air Approval Order Amendments may be required.
Once the engineering has been advanced to a sufficient level of certainty and detail, EFRI will submit a
detailed analysis to DWMRC explaining what matters EFRI believes can be approved via SERP and what
matters, if any, may require License, Pennit or Air Approval Order Amendment.
Upon DWMRC concurrence with EFRI's analyses, EFRI will then proceed with the preparation of any
amendment applications that may be required and perform all SERP actions that will be required.
DWMRC Comment Number 4:
4. Documentation Characterizing Monazite Sands from Alternative Sources
On June 25, 2020, EFRI submitted a letter advising the Division of its plan to receive and process natural
uranium ores in the form of monazite sands from The Chemours Company's (Chemours) Mineral Sand
Separation Plant in Offerman, Georgia (DRC-2020-011981). The Division requested additional
i,iformation concerning the Chemours monazite sands on July 21, 2020 (DRC-2020-012682), and EFRJ
responded to this request on September 9, 2020 (DRC-2020-015241). In a letter dated September 11, 2020
(DRC-2020-015094), the Division concurred that the Chemours monazite sands discussed in the above-
mentioned correspondences is naturally occurring ore and that no additional licensing actions would be
required for the mill to accept the material.
During the February 5, 2024 meeting, EFRJ indicated that they were pursuing monazite sands.from sources
other than Chemours. Please be advised that the ciforementioned September 11, 2020 letter from the
Division only considers monazite sands from Chemours June 25, 2020 and September 9, 2020 letters from
EFRI. Similar monazite sand from any other source would have to be similarly evaluated to determine if
the sand was natural ore and not an alternate feed. This evaluation would also have to be documented.
During the February 5, 2024 meeting, the Division indicated that it would need to review this natural ore
determination as well as all supporting documentation on a case-by-case basis for each source of monazite.
Therefore, the Division requests that EFRJ submit any documentation it has pertaining to monazite sands
from sources other than the Chemours Company's Mineral Sand Separation Plant in Offerman, Georgia,
including but not limited to: the composition of the sand; methods used to extract, generate, or produce the
sand; and any cleaning, sieving, or processing of the sand prior to potential receipt at White Mesa. Again,
providing this information well ahead of any planned receipts allows the Division time to review EFRJ 's
determinations and helps mitigate any potential delays.
Letter to Doug Hansen
June 6, 2024
Page 5
EFRJ Response:
EFRJ will submit documentation that demonstrates to DWMRC that any monazite sands from sources
other than Chemours is natural ore and not an alternate feed, well ahead of any planned receipts of any
such monazite sands.
If you have any questions regarding this letter, please contact the undersigned at [phone] or Mr.
Scott Bakken at [phone].
Yours very truly,
(M1Jr~
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Director, Regulatory Compliance
cc David Frydenlund
Garrin Palmer
Logan Shumway
Scott Bakken
Jo Ann Tischler (Tischler Consulting)
REDACTED ATTACHMENTS
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below
Pursuant to Utah Code 63G-2-101 et seq. each page in this attachment that contains information
sought to be withheld from public disclosure is indicated based on Confidential Business
Information (CBI) or Proprietary Information.
ATTACHMENT I
REU SOPs -REDACTED
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 -Introduction
INTRODUCTION
Mill Process
Date: 03-21 Revision: EFR-1
Page 1 of 1
The rare earth bearing uranium, ("REU"), ore process begins with receipt, weighing, and sampling of the
REU ore. The REU ore is fed into a
The solid tailings from the rare earth acid leach are subsequently processed like typical uranium ore to
recover uranium, which will be recovered using existing ore processing procedures.
Process Controls
Process control computers are located in the central control room, solvent extraction control room,
vanadium control room, grind circuit below the derrick screens, and in the upper level of the counter-current
decantation ("CCD") circuit.
Radiation Protection
Energy Fuels Resources (USA) Inc. ("EFRI") has outlined and implements a personnel radiation protection
program to ensure that operations at the plant are conducted in a safe and efficient manner and in accordance
with approved procedures.
This radiation protection program is documented and administered in accordance with the State of Utah
Division of Waste Management and Radiation Control ("DWMRC") applicable regulations detailed in the
Code of Federal Regulations ("CFR") Title 10 Energy and the State of Utah regulations.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Rare Earth Bearing Uranium Ore Operating
Procedures
Book 15 Section I -Receiving
RECEIVING
Preface
Date: 03-21 Revision: EFR-1
Page 1 of 4
The following procedure applies to the acceptance, handling, and storage of rare earth bearing uranium
("REU") ore at the White Mesa Mill. It is important that all shipments are received at the mill in a safe and
efficient manner while complying with required regulations during the receiving process.
Prior to Shipment
All radioactive shipments must conform to Titles 10 and 49 of the U.S. Code of Federal Regulations
("CPR"). Each load must have all required placards and labels affixed to the trailer and a copy of the
completed shipping manifest will accompany each shipment. Energy Fuels Resources (USA) Inc. ("EFRI")
must be notified when shipments are scheduled to depart and when they are expected to arrive at the White
Mesa Mill for offloading.
Designated Storage Area
REU ores will be stored at a designated location on the ore storage pad. The material will be stored in super
sacks and will be kept on pallets while waiting to be processed in the mill. No other alternate feed materials
or uranium ore will be stored in the same location on the ore storage pad as the REU ores while they are in
storage. If material is on the ore pad longer than one year from the date of receipt storage procedures will
be modified.
The dose rate around the designated storage area of the REU ores will be monitored. If the dose rate exceeds
5 mrem/hr, the storage location area will be posted as a radiation area. UT Admin Code R313-12-13 and
R313-l 5-902
Material Receiving
1. Before a shipment of REU ore enters the restricted area, a qualified individual will inspect the
shipment and its contents. This inspection is to verify that the material has not leaked during
transport, the truck is properly placarded, and to record the beta/gamma readings of the shipment.
If material has leaked out of the super sacks the spill must be documented on the Feed Material
Receipt inspection form and cleaned. Leaking bags will be handled in a manner to avoid dispersing
the REU ore.
2. When each truck driver enters the restricted area for the first time, the scale house operator will
provide a hazard awareness training for the driver as described in EFRI Standard Operating
Procedure ("SOP") in Bookl, Section 2.
3 . The onsite transportation expert will inspect all copies of the Shipping Manifest and the
transporter's Bill of Lading to ensure that the shipment is destined for the Mill, to verify the
contents of the shipment, and to ensure all of the required paper work is provided. If there are any
discrepancies in the shipping manifest, the scale house operator will notify their supervisor and
wait for guidance before off-loading.
4. The scale house operator will create a scale ticket for each shipment. The following information
will be recorded on the scale ticket:
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Rare Earth Bearing Uranium Ore Operating
Procedures
Book 15 Section I -Receiving
a. Date and time
b. Truck and trailer number
c. Gross, tare, net weights
d. Bill of lading or shipment number
e. Shipper ID
Date: 03-21 Revision: EFR-1
Page 2 of 4
5. Prior to transporting the material to the offloading area, a member of the utility crew will be
notified by the scale house operator and the driver will then be allowed to proceed to the off-
loading location on the ore pad.
Material Unloading
1. The scale house operator will direct the driver to the offloading location on the ore pad.
2. The driver will back his truck and trailer to the portable off-loading ramp on the ore pad.
3. Before using the portable offloading ramp, the safety chains will be attached to the trailer.
4. The load will then be visually inspected again for any potential damage and then the cribbing and
strapping will be removed from the trailer.
5. When offloading the super sacks, the fork lift operator should take caution not to damage the super
sacks or pallets and have a spotter present to assist when needed.
6. After all material is unloaded, disconnect the ramp from the trailer and guide empty truck back to
the scale house followed by decon pad.
7. Before leaving the property, all placards and labels will be removed from the trailer. Additional
placards or labels may be applied if the trailer is leaving as an unrestricted load.
Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Any trailers that
are to be released for restricted use will be decontaminated according to the requirements contained in
Department of Transportation ("DOT") Part 49 CFR 173.428 or 173.443.
Any trailers that are to be released for unrestricted use will be decontaminated according to the requirements
found in Table 2 of the Nuclear Regulatory Commission's Regulatory Guide 8.30 Rev. 1 "Health Physics
Surveys in Uranium Recovery Facilities" or NRC document "Guidelines for Decontamination of Facilities
and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or
Special Nuclear Material" issued April 1993.
For the appropriate decontamination procedures 1 refer to the procedures in Book 9, Radiation Protection
Manual, Section 6.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Rare Earth Bearing Uranium Ore Operating
Procedures
Book 15 Section I -Receiving
Documentation
Documentation of Shipments:
Date: 03-21 Revision: EFR-1
Page 3 of 4
For each shipment the following records will be maintained at the mill for at least 5 years.
• Shipper's Manifest and Bill of Lading.
• Completed scale ticket.
• Survey release forms.
Hazard Identification and Safety
Personal P1·otective Equipment ("PPE ) and Clothing
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
1. Industrial Hazards and Safety
a) Use caution when the trailers are backing to the unloading area.
b) Drivers must use caution during the unloading process and be aware of any overhead hazards.
c) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do not
jump off the equipment.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Rare Earth Bearing Uranium Ore Operating
Procedures
Book 15 Section 1 -Receiving
Date: 03-21 Revision: EFR-1
Page 4 of 4
d) Always use a ladder when entering and/or exiting the interior of a trailer.
2. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment .
b) All mobile equipment will be inspected by the operator and any safety defects corrected before the
equipment is used . If safe to do so , the equipment may be driven to the shop for repairs . Otherwise,
the equipment must be towed or repaired at the location.
c) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
d) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards are
not allowed .
e) Report all accidents to your supervisor regardless of how minor they are . If property damage or
personal injury is involved, do not move the equipment until your supervisor has released it.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Date: 03-21 Revision: EFR-1
Page 1 of 4
Book 15 Section 2 -Ore and -
REU ORE AND -FEED
Preface
The purpose of this Standard Operating Procedure ("SOP") is to describe the procedures used to feed the
REU ore to the mill and to begin processing. Additionally,
The circuit consists of a bag dumping unit and an agitated feed tank. The mill building
overhead crane will be used to lift bags from the null floor to the bag dumping unit.
are also fed into the tank.
The operators' responsibility is to add URE ore and -at the correct speed and in the right proportions.
To help accomplish this, operators will take samples of the feed tank slurry and analyze it for -
Communication:
To be successful as an operator in achieving the desired results in your circuit good communication
between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do not
understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be written
on White Boards. Information such as circuit parameters, required changes in circuit operations, or
special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the responsibility
to pass along information about your circuit to the person relieving you. You will be given verbal
instructions from your supervisor or metallurgical department which you need to be sure you
understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Health and Safety
Care must be taken in all aspects of the dumping procedure to ensure the continued health and safety of
null employees. The super sacks must be lifted from the null floor to the bag dumping system, presenting
a suspended load risk near the feed tank at all times. Additionally, REU ores (just like standard uranium
ore) are radioactive. Instructions from the Radiation Safety Department regarding procedure, Personal
Protective Equipment (" PPE"), etc. must be followed at all times to reduce physical and physiological
risks.
Hazards:
• Over head loads
• Radioactive solids
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 2 -Ore and -
• Pinch points
• Moving equipment
•
+
Date: 03-21 Revision: EFR-1
Page 2 of 4
• Hose Pumps can fail if either the intake or discharge lines are restricted, which may spray
solutions.
• Pumps that require gland seal water will fail if the gland seal water is not turned on.
Additionally, if the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Personal Protective Equipment and Clothing
1. Minimum PPB requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots . Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
Monazite Dumping
The REU ore feed will be weighed and sampled before dumping. The REU ore super sacks will be dumped
using a bag dumping system into a mixing tank. The mixing tank will contain REU ore, I . Dusting and fumes will be contained using the existing leach demister
system. The rate at which bags are dumped will be determined by the metallurgical and operations
departments to achieve a target feed rate .
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 2 -Ore and -
Bag Dumping Operating Procedures
Date: 03-21 Revision: EFR-1
Page 3 of 4
1. Operators will wear complete PPE as directed by supervisors and the Radiation Safety Department.
2. The bag lifting area under the crane should be closed to access and appropriately posted.
3. The demister system should be running at all times during dumping operations.
4. Bags will be fed to the circuit on a schedule to be set by the metallurgical department (e.g. one bag of
REU or Additional bags of REU ore and
5. Inspect the super sack to be dumped for any defects, leaks, etc.
6. Secure the bag to the overhead crane.
7. Vacate the area under the crane.
8. Lift and load the super sack into the bag dumping system. Be sure the bag is emptied as completely as
possible into the system.
9. Empty super sacks will be collected and disposed of in tailings. Bags should be rolled or folded up from
the bottom and placed in a container to avoid spillage on the ground when leaving the mill building.
10. After the addition of the super sacks, the operator will analyze a sample of the feed tank for -
The sample should be taken from the sample port near the feed tank
outlet. Targets will be set by a supervisor to determine acceptable ranges for these analyses.
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 2 -Ore and -
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Date : 03-21 Revision : EFR-1
Page 4 of 4
12. The feed tank level should be maintained at a level dictated by a supervisor. The level should be
controlled by the peristaltic pump feeding the crack tank.
Dumping System Start-up Procedure
1. Inform other personnel that URE ore and
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7. Inform the downstream circuits that they can begin operating.
Dumping System Shut-down Procedure
1. Inform downstream circuits that the dumping circuit is shutting down.
2. Ensure that the overhead crane and any bags are safely parked and free of any stored energy .
3. -
Emergency Shut Down
• Take remote to the Crane and shut power off to the Crane. Be sure to follow zero energy
practices, if the Crane has a load suspended lower the load to the floor before turning the
Crane off.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Date: 03-21 Revision: EFR-1
Page 1 of 4
Book 15 Section 3 --
Preface -
Communication:
To be successful as an operator in achieving the desired results in your circuit good communication
between you, the metallurgical depa1tment, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do not
understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be written
on White Boards. Information such as circuit parameters, required changes in circuit operations, or
special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the responsibility
to pass along information about your circuit to the person relieving you. You will be given verbal
instructions from your supervisor or metallurgical department which you need to be sure you
understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Hazards:
•
• Radioactive solids
• Steam
• Hose Pumps will fail if either intake or discharge lines are restricted. Which may spray
solution.
• Pumps that require gland seal water will fail if the gland seal water is not turned on.
Additionally, if the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 3 --
Personal Protective Equipment and Clothing
Date: 03-21 Revision: EFR-1
Page 2 of 4
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
will be released from the steam coils through steam traps. Steam traps make the steam coils more energy
efficient by regulating the discharge of the steam coils and only allowing condensate to exit the system.
The steam traps are probably not functioning correctly if there isn't any condensate leaving the condensate
line or if steam is leaving the condensate line.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 3--
Date: 03-21 Revision: EFR-1
Page 3 of 4
ear appropriate PPE at
all times. Care must also be taken to ensure that the sample is representative of the slurry. This includes
purging lines before collecting samples and not leaving solids behind in the sample cup.
Operating lnstructi.ons
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: Crack temperature, feed flow rate, feed density, tank
level, -concentration of the crack solution.
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Sta..t-up Procedures
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 3 --
Shut-down Procedures
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Emergency Shut-down Procedures
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Date: 03-21 Revision : EFR-1
Page 4 of 4
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating Date: 03-21 Revision: EFR-1
Page 1 of 4 Procedures
Book 15 Section 4 -
Preface
Communication:
To be successful as an operator in achieving the desired results in your circuit good communication
between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do not
understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be written
on White Boards. Information such as circuit parameters, required changes in circuit operations, or
special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the responsibility
to pass along information about your circuit to the person relieving you. You will be given verbal
instructions from your supervisor or metallurgical department which you need to be sure you
understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Health and Safety
The slurry exiting the crack tank will be very hot and contains high concentrations of -Care needs
to be taken to avoid exposure to this slurry. Additionally, the washing procedures will make use of
centrifuges to separate the solids from the solution . Proper guarding must be in place and procedures
followed to ensure the safety of personnel operating this equipment.
Hazards:
•
• Moving equipment
• Pinch points
• Radioactive solids
•
• Hose Pumps will fail if either intake or discharge lines are restricted. Which may spray
solution.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 4 -g
Date: 03-21 Revision: EFR-1
Page 2 of 4
• Pumps that require gland seal water will fail if the gland seal water is not turned on.
Additionally, if the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Personal Protective Equipment and Clothing
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots . Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly . Personnel will be fully trained prior to
using respirators.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 4 -
I. Perform a pre-shift inspection with the operator(s) coming off shift. Review flow rates, temperatures,
concentrations, operational challenges, etc. Visually inspect lines, tanks, and equipment for any
irregularities.
2. Appropriate PPE, dictated by the Radiation Safety Department is required while working in this circuit.
3. Follow schedules set by the maintenance depattment for greasing and cleaning the centrifuges .
4. Maintain wash water flow rates as determined by a supervisor.
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I. Perform periodic service based on manufactures recommendation on the centrifuges as outlined by a
supervisor.
2. Inform the upstream and downstream circuits that the solids washing circuit is starting up.
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 4 -
6.
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Date: 03-21 Revision: EFR-1
Page 4 of4
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Date: 03-21 Revision: EFR-1
Page 1 of3
Book 15 Section 5 --
Preface
-
Communication:
To be successful as an operator in achieving the desired results in your circuit good communication
between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do not
understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be written
on White Boards. Information such as circuit parameters, required changes in circuit operations, or
special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the responsibility
to pass along information about your circuit to the person relieving you. You will be given verbal
instructions from your supervisor or metallurgical department which you need to be sure you
understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Health and Safety
Hazards:
•
• Heat, steam
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 5 --
• Radioactive Solids
Date: 03-21 Revision: EFR -1
Page 2 of3
• Tyvek, respirators, and chemical resistant gloves worn when handing.
• Hose Pumps will fail if either intake or discharge lines are restricted. Which may spray
solution.
• Pumps that require gland seal water will fail if the gland seal water is not turned on.
Additionally, if the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Personal Protective Equipment and Clothing
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators. -
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 5 --
If a bag is broken, wash the area down immediately and thoroughly.
Date: 03-21 Revision: EFR-1
Page 3 of 3
When dumping bags be aware of traffic in the area . People without PPE should not be in the area.
1. Operators will wear complete PPE as directed by supervisors and the Radiation Safety Department.
2 . Perform a pre-shift inspection with the operator(s) coming off shift. Review flow rates,
temperatures, concentrations, operational challenges, etc. Visually inspect lines, tanks, and
equipment for any irregularities.
3. Ensure that the demister system is operating at all times .
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 6 --
Preface
Communication:
Date: 03-21 Revision: EFR-1
Page 1 of 4
To be successful as an operator in achieving the desired results in your circuit good communication
between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do not
understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be written
on White Boards. Information such as circuit parameters, required changes in circuit operations, or
special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the responsibility
to pass along information about your circuit to the person relieving you. You will be given verbal
instructions from your supervisor or metallurgical department which you need to be sure you
understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Health and Safety
-Therefore, solids handling must be conducted carefully to limit exposure to radioactivity. Proper
Personal Protective Equipment ("PPE") must be worn, and solids should be wetted at all times to prevent
dusting. Any solids spills should be washed down before they dry.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 6 --
Hazards:
•
• Radioactive Solids
• Slow moving rakes in CCD
• Heat
•
•
Date: 03-21 Revision: EFR-1
Page 2 of 4
• Hose Pumps will fail if either intake or discharge lines are restricted. Which may spray
solutions
• Pumps that require gland seal water will fail if the gland seal water is not turned on.
Additionally, if the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Personal Protective Equipment and Clothing
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
2 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
3 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
4 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
5 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 6 --
Date : 03-21 Revision : EFR-1
Page 3 of 4
1. Operators will wear complete PPE as directed by supervisors and the radiation and safety departments.
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Start-up Procedures
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 6--
·-·-Shut Down Procedures
Emergency Slmt Down
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Date: 03-21 Revision: EFR-1
Page 4 of 4
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Op erating
Procedures
Book 15 Section 7 --Removal
Preface
• • • • to separate t
. .
Communication
Date: 01-22 Revision: EFR-1
Page I of 4
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board . In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safety
The solution that is fed to the -removal circuit is
rare earth metals. This solution should not be ingested. The
-also contains heavy metals and should not be ingested. The organic solution is flammable. No
Hot Work will be done in the solvent extraction building without a Hot Work permit. Any possible ignition
source must be avoided. The solution used to strip or remove the rare earths from the organic solution is
and should be handled appropriately and only when using appropriate Personal Protective
Equipment (PPE). generates vapors that should be avoided. These vapors can cause
extreme irritation and injury.
Hazards:
•
•
• Stairs and elevated work areas
• Pressurized solutions pumping throughout the circuit
•
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7 -
Personal Protective Equipment (PPE)
Date: 01-22 Revision : EFR-1
Page 2 of 4
I . Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs . If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
Equipment and Important Information
■
■
-
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7
Raffinate pH
One of the most critical aspects of this circuit is
I
Sampling
Date : 01-22 Revision : EFR-1
Page 3 of 4
Sampling of the various solutions in this circuit is required on a regular basis. It is important to ensure that
any sample taken is representative of the tank's contents. This means that tanks should be well mixed,
sampling equipment should be clean, and any sample ports purged before collecting the sample.
Operating Instructions
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: flow rates, tank levels, solution concentrations.
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7 -
Start-up Procedures
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Shutdown Procedures
Emergency Shutdown Procedures
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Date : 01-22 Revision: EFR-1
Page 4 of 4
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating Date: 04-221 Revision: EFR-2
Page 1 of 4 Procedures
Book 15 Section 8 -
Preface
As always, wearing
appropriate Personal Protective Equipment ("PPE") and following all safety procedures must be done at all
times.
Communication:
To be successful as an operator in achieving the desired results in your circuit good communication
between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do not
understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be written
on White Boards. Information such as circuit parameters, required changes in circuit operations, or
special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the responsibility
to pass along information about your circuit to the person relieving you. You will be given verbal
instructions from your supervisor or metallurgical department which you need to be sure you
understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Hazards:
•
• Elevated work areas
• Pressurized process lines
• Hose pumps will fail if either intake or discharge lines are restricted. Which may spray
solutions.
• Pumps that require gland seal water will fail if the gland seal water is not turned on.
Additionally, if the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 8 -
Personal Protective Equipment and Clothing
Date : 04-22 l Revision: EFR-2
Page 2 of 4
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to : ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
-
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures •
Book 15 Section 8 -
Date : 04-221 Revision : EFR-2
Page 3 of 4
IMPORTANT : This pump is a hose (peristaltic)
pump . This type of pump builds high pressures. The feed and discharge line and valves must be open
before the pump is turned on or the discharge line or pump will fail.
-
Sampling
Sampling of the is required on a regular basi s. It is important to ensure that
any samples taken are representative of the tank's contents. This means using clean sampling equipment
and purge sample ports before sampling.
Operating ln tructions
1. Conduct a proper Shift Change with the person you are relieving . Get information about all circuit
parameters, including, but not limited to : temperature, feed flow rate, and tank levels.
2. Perform a pre-work exam of the precipitation circuit. Look at all lines (feed and over flow lines,
steam lines, etc.) for any leaks. Check all walkways and travel s areas for general cleanliness.
Ensure all process control s , readouts and safety showers are functioning properly.
3. Check the process parameters targets. Remember that process parameters may have changed since
the previous shift.
4. Check and record all flow rates and tank levels.
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book I 5 Section 8 -
I
Start-up Procedures
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Shutdown Procedures
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Emergency Shut-down Procedures
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Date: 04-221 Revision: EFR-2
Page 4 of 4
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Date : 04-22 Revision: EFR-2
Pagel of 4
Book 15 Section 9 --
Preface
Communication:
To be successful as an operator in achieving the desired results in your circuit good
communication between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do
not understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be
written on White Boards. Information such as circuit parameters, required changes in circuit
operations, or special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the
responsibility to pass along information about your circuit to the person relieving you. You will
be given verbal instructions from your supervisor or metallurgical department which you need to
be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Hazards:
• Pinch points
• Moving equipment
• High pressure lines
• Pumps, if hose pumps are restricted on either the intake or discharge the hose will fail
spraying solution.
• Pumps, pumps requiring gland seal water if the gland seal water is not turned on the
pump will fail. If the pump is off and the gland seal water is left on it will dilute process
solutions and cause problems in the process.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 9 --
Personal Protective Equipment and CJothing
Date : 04-22 Revision: EFR-2
Page 2 of 4
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet
suits, welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are
required in designated areas and/or while performing certain jobs. If in doubt, contact your
supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work
Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in
the mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
Equipment
1. Pumps-
a. The feed pump is a centrifugal slurry pump. The feed pump transfers slurry from the
precip aging tank to the
2. Piping-
a. Process piping is HOPE
b. Plant Air is steel
c. Plant water is HOPE.
3. Valves -
a . Isolation valves are manual butterfly type. Isolation valves are for flow direction control
as well as isolation for maintenance.
b. The feed control valve is for flow control to the -
4 . Instrumentation -
I
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 9 --
I
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Operating Instructions (Automatic):
Date: 04-22 Revision: EFR-2
Page 3 of 4
1. Conduct a proper shift change with the person you are relieving. Gather information on the status
and operation of the equipment as well as batches processed.
2. Prior to operating the equipment conduct a pre shift inspection.
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Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 9--
ShutDown
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Date: 04-22 Revision: EFR-2
Page4 of 4
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 10 -Packaging
Packagin&
Preface
Date: 04-22 Revision: EFR-2
Page 1 of2
The purpose of the bulk bag filling system is to prepare and package the finished product for shipping.
Prior to packaging, ensure there are bulk bags available. Prior to operating the packaging circuit, make
sure the packaging unit has been serviced and cleaned and that the scale has been zeroed out. Ensure the
480 volt power has been turned on and a clean, dry air supply is available to the packaging unit.
Communication:
To be successful as an operator in achieving the desired results in your circuit good
communication between you, the metallurgical department, and your supervisor should exist.
Information is given the operator verbally, written, and by test results. As an operator if you do
not understand any information given you have the responsibility to ask questions until you do
understand.
White board. In a few locations in the mill critical information about mill operations will be
written on White Boards. Information such as circuit parameters, required changes in circuit
operations, or special instructions about maintenance.
Circuit sheets. Circuit sheets will have operating parameters on them along with sampling times
for the circuit. They will also have a place for you to pass along written information about your
circuit.
Verbal. One of the most important times of your shift is at shift change. You have the
responsibility to pass along information about your circuit to the person relieving you. You will
be given verbal instructions from your supervisor or metallurgical department which you need to
be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above if you do not
understand any instruction ask your supervisor.
Hazards:
• Pinch points
• Moving equipment
• Heavy product bags
Personal Protective Equipment and Clothine
1. Minimum Personal Protective Equipment ("PPE") requirements at White Mesa Mill while in the
restricted area is hard hats, safety glasses, and steel toed shoes. No ragged or lose fitting clothing
is allowed. Body jewelry, rings, wrist watches, etc. are required to be removed while working.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 10 -Packaging
Date: 04-22 Revision: EFR-2
Page 2 of2
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet
suits, welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are
required in designated areas and/or while performing certain jobs. If in doubt, contact your
supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work
Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in
the mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained prior to
using respirators.
Procedure
From here the bag liner is sealed up and the fill spout is tied closed. This bag is now moved to the
shipping prep area to be loaded on containers and shipped out.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 11 -
Rare Earth
Preface
Communication
Date : 03-23 Revision: EFR-1
Page 1 of3
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safetv
Hazards:
•
• Elevated temperatures
• Elevated work areas
• Pressurized process lines
• Pumps, if hose pumps are restricted on either the intake or discharge the hose will fail
spraying solution.
• Pumps, pumps requiring gland seal water if the gland seal water is not turned on the pump
will fail. If the pump is off and the gland seal water is left on it will dilute process solutions
and cause problems in the process.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 11
Personal Protective Equipment (PPE)
Date: 03-23 Revision: EFR-1
Page 2 of3
l . Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2. Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3. Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing --a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5. The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6. It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
Equipment and Important Information
IMPORT ANT : This pump is a hose (peristaltic) pump. This type of pump builds high pressures . The feed
and discharge line and valves must be open before the pump is turned on or the discharge line or pump will
fail.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 1 S Section I I
-It is important
to ensure that any samples taken are representative of the tank's contents. This means using clean sampling
equipment and purging sample ports before sampling.
Operating Instructions
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: temperature, feed flow rate, and tank levels.
Start-up Procedures
I
I
I I
Shutdown Procedures
I
I
Emergency Shut-down Procedures
I
I
I
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 -
Preface
Communication
Date: 03-23 Revision: EFR-1
Page 1 of 4
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safetv
Hazards:
•
•
• Stairs and elevated work areas
•
•
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 -
Personal Protective Equipment (PPE)
Date: 03-23 Revision: EFR-1
Page 2 of4
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2. Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3. Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work
Permit
5. The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6. It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
Equipment and Important Information
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 --
I
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-Sampling
Sampling of the various solutions in this circuit is required on a regular basis. It is important to ensure that
any sample taken is representative of the tank's contents. This means that tanks should be well mixed,
sampling equipment should be clean, and any sample ports purged before collecting the sample.
Operating Instructions
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: flow rates, tank levels, solution concentrations.
2. Perform a pre-work exam of the Inspect all lines and tanks for any leaks.
Check all walkways and travel areas for general cleanliness. Ensure all process controls, readouts
and safety showers are functioning properly .
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 -
Date: 03-23 Revision: EFR-1
Page 4 of4
3. Check the process parameter targets. Remember that process parameters may have changed since
the previous shift.
4. Check and record all flow rates and tanks levels on the Operator Sheet.
5. Ensure that the bench pH probe is calibrated and functional.
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8. Adjust the recycle valves to achieve the specified organic to aqueous ratio in the mixers.
9. Sample the circuit as directed by the Metallurgical Department.
Start-up Procedures
Shutdown Procedures
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Emergency Shutdown Procedures
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White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 -
Preface
Communication
Date: 03-23 Revision: EFR-1
Page I of 4
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safetv
Hazards:
•
•
• Stairs and elevated work areas
•
•
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 -
Personal Protective Equipment (PPE)
Date: 03-23 Revision: EFR-1
Page 2 of4
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2. Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3. Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work
Permit
5. The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6. It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
Equipment and Important Information
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 --
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-Sampling
Sampling of the various solutions in this circuit is required on a regular basis. It is important to ensure that
any sample taken is representative of the tank's contents. This means that tanks should be well mixed,
sampling equipment should be clean, and any sample ports purged before collecting the sample.
Operating Instructions
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: flow rates, tank levels, solution concentrations .
2. Perform a pre-work exam of the Inspect all lines and tanks for any leaks.
Check all walkways and travel areas for general cleanliness. Ensure all process controls, readouts
and safety showers are functioning properly.
Withold from Public Disclosure Under Utah Code 63G-2-101 et seq. and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 -
Date: 03-23 Revision: EFR-1
Page 4 of4
3. Check the process parameter targets. Remember that process parameters may have changed since
the previous shift.
4. Check and record all flow rates and tanks levels on the Operator Sheet.
5. Ensure that the bench pH probe is calibrated and functional.
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9. Sample the circuit as directed by the Metallurgical Department.
Start-up Procedures
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Shutdown Procedures
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Emergency Shutdown Procedures
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ATTACHMENT 2
SERP 2022-01 -REDACTED
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
REPORT
ENERGY FUELS RESOURCES (USA) INC.
WHITE MESA URANIUM MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL
MEETING OF JANUARY 27, 2022
SOPs fo~ Removal During Uranium Rare Earth Ore
Recovery
SERP No. 2022-01
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
ENERGY FUELS RESOURCES (USA) INC.
WHITE l\ffiSA URANIUM MILL
SAFETY AND ENVIRONl\ffiNTAL REVIEW PANEL
MEETING OF JANUARY 27, 2022
SERP NO. 2022-01
1. PURPOSE
The Energy Fuels Resources (USA) Inc. ("EFRI") Safety and Environmental Review
Panel ("SERP") for the White Mesa Uranium Mill (the "Mill") met by telephone
conference on January 27, 2022 in accordance with SERP procedures in While Mesa Mill
Standard Operating Procedure PBL-1, Rev. No. R-6 (the "SERP SOP"), to consider
SERP No. 2022-01, regarding the following (the "Change"):
Review and approve a proposed extractant and Standard Operating
Procedure ("SOP") for removal of -from Rare Earth -
product ("RE-') using existing Mill equipment.
The SERP followed the SERP SOP as it performed this SERP evaluation, to ensure that
the change is consistent with the following three criteria (the "SERP Approval Criteria"):
(a)The change, test or experiment did not conflict with any requirement
specifically stated in the Mill license, and did not impair EFRI's ability to
meet all applicable regulations;
(b)There would be no degradation in the essential safety or environmental
commitments in the license applicalion, or provided by the approved
reclamation plan; and
(c)The change, lest or experiment was consistent with lhe conclusions of actions
analyzed and selected in the most recent Environmental Assessment (EA)
conducted by the Division of Waste Management and Radiation Control
("DWMRC") from the last license renewal and/or major license amendment.
2. OVERVIEW AND BACKGROUND
EFRI plans to reuse existing circuit equipment to remove -from rare earth
("RE") ~roducts. The Mill produces R~ by proces ing rare earth
bearing uranium ("REU") ores. The propo ed Change, i.e., U1e removal o _,
will allow the Mill to test the capability to and will also reduce
the radionuclide content of RE products by reducing the levels o which will
followth~
The proposed proces involves the use of an extractant from one or more of the classes
of referred to as
Page 2
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
as extractants in its solvent extraction ("SX"). The classes of
to be used in connection with this Change are
comparable to those previously used in the Mill.
The proposed proces will also use an additional quantity of
one of the fiberglass tanks in the vanadium SX area, which has been converted for use in
-removal.
In addition to the proposed materials, the SERP evaluated the SOP, which addressed the
operation described above. The proposed process is referred to in this report as the
process, or the "Change." The SERP evaluated the process with
respect to the requirements of condition 9.4 of the Mill's RML, worker safety, process
safety, and environmental protection.
3. SERP MEMBERSHIP AND QUALIFICATIONS
This SERP consisted of the following members :
Resoonsibilitv Name/Position
Corporate Radiation Safety Officer or Garrin Palmer
equivalent; Mill Radiation Safety Officer (Member)
Assuring Tests conform to radiation safety
and environmental requirements
Management Expertise; David Frydenlund
Responsibility for managerial and financial Chief Financial Officer, General Counsel
approvals and Corporate Secretary (Member)
Operations and/or Construction Logan Shumway
Management; Mill Manager (Member)
Responsibility for implementing
operational procedures
Responsibility for regulatory compliance at Kathy W einel
WMM Director, Regulatory Compliance
Corporate responsibility for regulatory Scott Bakken
compliance Vice President, Re_gulatory Affairs
Independent Safety/Environmental Jo Ann Tischler
Evaluation Independent Chemical Engineering
Consultant
Page 3
3
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and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
In addition, the following Mill or Corporate Personnel attended the SERP :
Reason for Attendance Name/Position
Regulatory and Legal Support to General Julia Hoffmeier
Counsel Corporate Counsel
Corporate Secretary
4. SERP REVIEW OF PROPOSED CHANGE AND SOP
and Assistant
The SERP reviewed specific details relating to the process, including the SOP and the
independent consultant's Technical Memorandum.
A copy of the SOP and the Technical Memorandum are provided in Attachments to this
report. Specific points discussed are summarized below.
The SERP reviewed all processing steps, and identified those procedures that did not
need to be included in the processing SOP, or materials, specifically,., that did not
need to be re-addressed because they have been approved separately.
The SERP also reviewed the Document Control SOP, in place since 2000, which requires
that any new SOP, or any significant change to an existing SOP, requires a SERP review.
5. REVIEW OF SERP APPROVAL CRITERIA
5.1. Review of the Criteria
In order for a change in the facility or process, as presented in the license application, to
be eligible for approval by the SERP, the three SERP Approval Criteria, detailed in
Section 1 above, must be satisfied. The three SERP Approval Criteria, as detailed in the
five steps of the SERP procedure, were reviewed and discussed, as folJows:
5. I .1. Does the change conflict with any requirement specifically stated in the license?
The SOPs will not require any types of process operations not currently performed at the
Mill. Processes such as solvent extraction and product stripping, have been regularly
performed at the Mill. The SOPs will not require any new equipment. Existing
equipment in the vanadium circuit will be converted (re-used) periodically for the
-removal step in RE -recovery as needed, and returned to other
service when needed.
Storage of chemicals will not require constriction of new tanks or storage areas. The
Change will not require use of electricity, fuel, or water resources beyond levels
anticipated in the license for full Mill production.
Use of the -and extractants will not require any worker protections beyond those
currently in use in other Mill operations.
Page4
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and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Based on the above, the SERP determined that the Change does not conflict with any
requirement stated in the license or any license requirement contained in any license tie-
down letters. Therefore, this criterion is met.
The purified and concentrated yellowcake that will be produced will not cause the Mill to
exceed the yellowcake production limit under the License.
5.1.2. Does the change impair EFRI's ability to meet all applicable regulations?
No. The SERP identified that there are no RCRA CERCLA, or TSCA requirements
applicable to the REU ore or proposed process chemicals.
The chemicals and proposed process as described in the SOPs will not generate any new
air emissions or require revision to the Air Approval Order ("AO").
Approval Order DAQE-ANl 12050020-19 on December 23, 2021.
Utah DWMRC identified in the 2004 Statement of Basis for the Mill's Groundwater
Discharge Permit that the Mill bas previously u. e and did
not require that compounds or degradation products be monitored in
groundwater or Mill tailings.
Existing spill management procedures will be sufficient for the proposed process
chemicals. The SERP noted that there are no EPCRA reporting quantities for any of the
extractants in the classes considered. The Spill Prevention Control and Countermeasures
("SPCC") plan tables will be updated as appropriate for these materials.
5.1.3. ls the change consistent with the conclusions of actions analyzed in the most
current EA?
The original 1980 Environmental Assessment, subsequent environmental reports, and the
DWMRC Technical and Environmental Report for the Mill contemplated that the Mill
would recover secondary metals, in addition to uranium. The original EA contemplated
recovery of copper and/or vanadium. The Mill has also previously been approved to
recover, and has modified the process to recover, tantalum and niobium.
The process will not generate any new tailings constituents not already monitored or
addressed by other indicator parameters in the groundwater discharge permit ("GWDP").
The process will produce no new or increased air emissions. The tailings to be generated
will be comparable to, and contain comparable non-radiological constituents, as the
tailings previously generated and managed in the tailings management system.
The Change will not introduce any new radionuclides. The process will involve levels of
radiological constituents, comparable to other feed materials previously processed.
Page 5
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Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
The Mill has previou sly used compounds as extractants in the SX .
The classes of extractants approved in this Change are comparable to
those previously used in the Mill.
5.1.4. Does the change require any adjustment to the financial surety arrangement or
approved amount?
The SERP determined that there would be no change to any criterion that would affect
the Mill's surety. There would be no change to the footprint of the Mill. There would be
no increased volume of equipment to be disposed in the tailings management system at
reclamation.
The Change will not measurably increase the quantity of materials discharged to the
tailings system, relative to the RE process.
There will be no new equipment required. The volume of the equipment to be used for
the process were anticipated within the licensed tailings capacity.
The composition of tailings from the proposed process will not require any change to the
cover design as noted in the September 9, 2020 letter to DWMRC. The quantity of
removed and discharged -will be minimal and will not require any special
management or changes to the tailings reclamation plan.
5.1.5. Does the change create any degradation in the essential safety or environmental
commitments in the license application, or provided by the approved reclamation plan?
The SERP assessed that there would be no change in the safety or environmental
commitments in the license application or reclamation plan .
Processing according to the SOP is not expected to produce any environmental impacts
beyond those assessed in any EA, and is consistent with the conclusions regarding actions
analyzed in the EAs. As a result, this criterion is also satisfied.
Processing according to the SOP will:
• Not produce any increased levels of radionuclides in processes or wastes beyond
those anticipated in the EAs or previously managed under approved SOPs,
• Not introduce any constituents to the tailings system that arc detrimental to the
tailings solutions or tailings Jiner,
• Not produce any new emissions or pathways for exposure to workers or the
public,
• Not require any changes to spill control or storm water management plans or
drainage designs,
• Not require additional tailings capacity or changes to tailings management plans,
and
• Not introduce any new pathways of contamination to the environment.
Page 6
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Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Processing according to the SOP is within the envelope of conditions evaluated in the
Mill's MILDOS model for dose to off-site receptors.
Processing according to the SOP will have no effect on the commitments or quantities
addressed in the Reclamation Plan.
6. CONCLUSIONS
The SERP concluded that the proposed Change and SOP meet the criteria set forth in the
SERP SOP for approval, and approved the SOP and extractants.
The SERP authorized immediate implementation of the SOP .
7. ATTACHMENTS
• Attachment 1 -Technical Memorandum of J. Tischler January 27, 2022
• Attachment 2-SOP fo-Removal
Page 7
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and as indi t d • e seq .
All redactions wer~b:s~~ the ~edacted !ext below. on Bl/Proprietary Information
SIGNATURES
Report reviewed by:
~~
Scott Bakken
Dute:~.,x_-:z_ _______ _
LVS}mmway c::::_:y=
GamnPalmer
Page 8
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Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
ATTACHMENT l
Technical Memorandum of Jo Ann Tischler
January 27, 2022
01.27.2022
To:
S . Bakken,
D Frydenlund,
L. Shumway,
K. Weinel
From:
Jo Ann Tischle r
Cc:
Re:
Technical Review of
Propo~ed Rare Earth
-Process
SOPs -for SERP
Evaluation
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq .
and as indicated in the redacted text below .
All redactions were based on CBI/Proprietary Information
Technical Memorandum
Introduction
This Technical Memorandum (the "Memorandum") describes the results of the evaluation
of a proposed Change and associated Standard Operating Procedures ("SOPs") al the White
Mesa Mill (the "Mill") for reuse of existing equipment to re mo v from rare earth
("RE") -products . The Mill produces RE by processing rare earth
bearing uranium ("REU") ores. The proposed Change, i.e., th e removal of -will
allow the Mill to test the capability to separate individual RE ·, and will also reduce the
radionuclide content of RE products by reducing the levels of
T his evaluation will consider both classes o f compound,, since th e
compounds in both classes have very similar properties, and since the Mill may test one or
more compounds from either class to id e nLi fy the optimum extraclant. The initial co mp o un d
lo be used will be
The Mill has previously used
solvent extraction ("SX") circuits. cxtractants to
be used in connection with this Change are comparabJe to those previously used in
the Mill. The proposed process will also use an additional quantity of
, which is used in current RE recovery process.
This Memorandum assesses whether the process may pose any worker safety or
environmental hazards, or be inconsistent with conditions and assumptions in the Mill's
current State of Utah Radioactive Materials License No . UTI900479 (the ;'RML" or the
"license") or other regulations. This evaluation was performed as part of a SERP evaluation
of this potential Change or test under the RML and the Mill SOPs. The proposed_
removal process and materials will be referred to in this memo, for the purposes of SERP
evaluation, as the "proposed process" or "Change."
In order for a Change or test in the facility or process, as presented in the license application,
10 be eligible for approval by the SERP, three SERP Approval Criteria must be satisfied.
This memorandum provides information needed to answer the three SERP criteria as follows:
I. Does the Change conflict with any requirement specifically stated in the license, or
impair Energy Fuels Resourct!s (USA) Inc.'s ("EFRI's") ability lo meet all
applicable regulations?
2 . Does the Change create any degradation in the essential safety or environmental
commitments in the license application, or provided by the approved reclamation
plan?
ischler Consulting Services , LLC J)fc
Tel [phone]
8015 South Krameria Way
Centennial, CO 80112 [e-mail]
01.27.2022
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.02
3. The change, test or experiment was consistent with the conclusions of actions
analyzed and selected in the most recent Environmental Assessment (EA)
conducted by the Division of Waste Management and Radiation Control ("DWMRC")
from the last license renewal and/or major license amendment
The following report provides an evaluation of potential safety and environmental hazards,
of consistency with the RML, and provides information for comparison to the SERP criteria.
To perform this evaluation, we have considered the following questions:
1. What, if any, new chemicals or reagents will be required for the proposed process?
2. Are there any new or different environmental or safety issues associated with the
storage, use, handling, or disposal of the new chemicals or reagents?
3. Would use or new chemicals or reagents create any additional requirements for spill
or emergency response equipment or training?
4. Would the use of new chemicals or reagents create any additional environmental
emissions?
5. Are the existing and the proposed SOPs appropriate and sufficient for the reagents
to be used?
6. ls the implementation of the proposed process and SOPs consistent with the Mill's
RML, RML application, other permits, and plans?
7. Does the implementation of the proposed process and SOPs conflict with any EFRI
environmental or safely commitment made in any other plan or document?
8. Do any of the following requirements apply to the materials proposed to be used or
produced in this Change:
• Resource Conservation and Recovery Act ("RCRA"),
• Toxic Substances Control Act ( "TSCA"), or
• Comprehensive Environmental Response, Compensation and Liability
Act/Superfund Amendment and Reauthorization Act ("CERCLNSARA")
• Clean Air Act ("CAA") and regulations in Utah Administrative Code R307-
401
01.27.2022
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and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technica l Memorandum
1.0 Basis and Limitations of this Evaluation
The evaluation in Lhis report is based on the following documents:
• Schematic process flow information provided by Mill personnel.
Pg.03
• Safety Data Sheets ("SDSs") for the proposed matc1ials, provided by Mill personnel,
and internet access
• Communications with Mill personnel during January and February 2022.
• Additional technical references listed at the end of this memorandum.
2.0 Description of Proposed Change and SOPs
A potential flow configuration for the proposed Change is depicted in the schematic flow
diagram in the attached Figure I.
The proposed Change would involve reuse of existing equipment within the existing
buildings/footprint of the Mill for the removal of -from the RE -with no
significant changes at this time.
The Mill has processed REU to produce mixed RE _since the second quarter of
2021 . The REV process was described and evaluated in SERP 2021-0 I. Since its inception,
the REV process included steps for the removal of the following radionuclides:
• uranium and thorium, which are advanced to the uranium circuit for uranium
recovery, and
• radium, which is currently transferred to the TMS.
The proposed change involves adding a comparable step following the radium removal, lo
re move on e r::i re earth -fr om 1h e mi xe d rar eanh -prod uc t.
To operate the -removal step, the following reagents will be used:
•
I•
-will be prepared at amb ie nt tem pera ture in one of the rubber-lined steel leach tanks
by dilution of th e as purc ha. ed form the supplier. The -will be
transfen-ed to one of the fiberglass tanks in the vanadium SX area, which has been converted
for use in -removal.
Calculations discussed in this evaluation are based on an assumed case of pr oc s. in g
tons per year of REU ore. On this basis, up to -pet year of
the trace levels o-would be removed and transferred to tailings. Regardless of the
01.27.2022
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Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.04
ore source, the proposed throughput will not cause the Mill to exceed the RML limit of 4,380
tons of yellowcake production per year.
As a result of the proposed process:
• There will be no change to the uranium drying or packaging areas,
• Existing equipment in the vanadium circuit will be converted (re-used) periodically
fo r the -re moval . te p in RE -re cove ry as nee ded , a nd return ed to
other service when needed,
•
approved by Air Approval Order DAQE-AN 11 20 002 0-19 on Dece mb e r 23,
2021.
• Vanadium recovery cannot be conducted in the same time period as rare earth
-recovery.
• There will be no change to the vanadium drying or packaging areas. These areas
will not be used for R~ recovery.
3.0 Properties of Proposed Chemicals and Reagents
As mentioned above, the proposed
either of two classes of compounds:
These two classes differ as follows:
Parameter
2
2
type -formula -
In the table above, "R" represents an
3
2
--
As can be seen from the table, the two classes differ in the number of oxygen atoms associated
with the central -atom, and can differ in the size ofth (number
01.27.2022
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Under Utah Code 638-2-101 et seq .
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.05
of As a result, they have very simi Jar chemical prope,ties and can be
considered collectively .
The physical state of the potential extractants is discussed in Section 4.0 below. Hazardous
properties are discussed in Sections 4.0 and 5.0, below.
Each of the remaining additives is discussed in the TechnicaJ and Regulatory Review in
Attachment 1. All other chemicals will be those historically used in ore processing, with no
other changes.
4.0 Proposed Storage and Use of Chemicals and Reagents
The storage location, and the storage and use quantities of additives for the proposed process
are detailed in the Technical and Regulatory Review in Attachment I. For ease of reference,
storage locations of proposed additives are summarized below.
New Additive
or Product Form Storage & Use
Location Incompatibilities
-
approved under the
most recent Air Approval Order. The tanks have been constructed near the pre-leach
thickener northwest of the counter-cun-ent decantation ("CCD") area of the main Mill
building, and will be loaded by periodic deliveries from bulk tank trucks.
closed area within the particular circuit or building where it will
be used near the location where it will be introduced into the circuil, or possibly in the
additional covered outdoor storage area referred to as the "manger," or both. The extractant
01.27.2022
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Under Utah Code 63G-2-101 et seq .
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.06
will be received in plastic drums or plastic totes, and will be charged via plastic pumps and
piping in to the fiberglass SX equipment. Any remaining extractant not charged into the
system will be stored in the drums or totes in which it was received. Up to -
may remain stored in drums or totes .
Regardless of how the additive is introduced into the process, each additive will leave the
system only when discharged periodically to the tailings management system (''TMS"), or
when vessels are emptied for transition back to other uses.
4.1 Compatibility of-Removal Chemicals with Mill Process and
Equipment
are not corrosive to metals, as identified in their SDSs . The Mill plans corrosion
monitoring as indicated below .
• --routine monitoring -similar to tanks in sulfuric acid service.
• --no additional corrosion monitoring required.
id
Tncom atibilities
Combustion Products
Reactivit
Stability rocess conditions rocess conditions
Volatility (flash point)
5.0 Health and Safety in Mill Process
The hazard properties of the proposed reagents are discussed in the attached Technical and
Regulatory Review, the attached Table l. and summarized here.
01.27.2022
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Under Utah Code 63G-2-101 et seq .
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum
5.1 Extractants
Pg.07
The compound mono extractant is evaluated below as
representative of the two classes of compounds considered in this SERP. The remaining
compounds in these classes have similar properties as described in the attached Table 1,
which also com a re · the ro osed extractants to those pre iou:ly u •
in the Mill.
The representative extractant has a tlash point of It is anticipated that it will
be added to the process at ambie.nt temperature condition, or possibly at conditions up to
11111111 Therefore, it is not expected that the extractant will be volatilized at process conditions.
The extractants in both classes considered have no published occupational exposure limits,
that is, in normal conditions, no respiratory protection requirements are identified. Because
the compounds in these classes are irritating to membranes of the eye, skin, mouth,
respiratory tract and digestive tract, prevention of dermal and eye contact, breathing and
ingestion is required, both during introduction/charging of product into the system and during
operation of the -removal process. The cun-ent procedures for splash protection
from other solutions in the vanadium SX area will be sufficient for worker protection from
contact with the extractant, and they do not need to be modified regardless of the quantity of
extractant to he used. The operation with the highest potential for worker contact with the
cxtractant will be during introduction/charging of pure product into the system.
In fires or hi gh tern era ture conditions, the extractant decomposes to produce -
The Occupational Sa fety and Health Administration
( 'O HA ") Permissible Exposure Lim it 'PE L") fo r
The level f -con ·id e red imminently dangerous to life and
The Emergency Response Plan ("ERP") has previously been
reviewed during the 2020 SERP for use of -• to confirm that it addresses the
re. piratory protection for fire response in the potential presence of minor quantities of
. during the period that -is in use . Any increases in extractant to be
stored, or used in the system. will not change the respiratory protection requirements for fire
responders .
Mill personnel are experienced with addition and use of
compounds. The Mill has pre viou . ly used llllllin solvent extraction, and more recently, in
2019 and 2020, used for chloride pond return extraction. Both are comparable, but
more aggressive, than the ones currently proposed .
01.27.2022
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.OB
The operations under the Change will be conducted in the same building that houses the
vanadium SX area. The fire protection system in place for an organic (kerosene) fire is more
than sufficient for the quantities of extractant to be used in the proposed Change.
The SOS for whichever extractant is selected from the above classes should be added to the
records available on site.
5.2
Mill personnel have experience with the use of strong mineral acids, based on the extensive
presence of sulfuric acid throughout the Mill's leach area and TMS. Mill personnel are also
. pec if ically experienced with use o f . in the ongo ing REU process in g fo r reco ve ry of RE
-The anticipated additi o na l q ua nti ty f -~ cd [o r -re moval
will be minimal compared to the ongoing us e fo r ~-proces ·in g. Rcq uireme,nl s
for use of-in the process have been evaluated in SERP 2021-01, and will not be re-
addressed here.
5.3 General/Other
The REU process may operate at temperatures up to -The process will generate
regular hazards of hot steam lines. heated equipment, and hot condensate lines. Mill
personnel are experienced with operation of processes at these temperatures from the ongoing
REU processing.
None of the extractants or the removed -residual solutions are volatile or
flammable. None of the extractants or product have been repmted to be carcinogenic or
teratogenic.
SDSs for the extractant , or other extractants, would need to be added to the
records available on site. The respiratory protection progra m should be modified to address
the required protection for the combustion products of based extractants,
that is phosphine ga , in the event of a fire.
Derived Air Concentrations ("DACs") may need to be developed for activities in connection
with the concentrated residuals removed and transferred to
tailings.
6.0 Environmental Considerations
Environmental and other regulatory considerations are described in Attachment 1 and
discussed below.
01.27.2022
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum
6.1 Air Emissions
Pg.09
There will be no new emissions other than potential minor vaporization of . evolved
during dilution in the
As discussed in Section 5.1, above, it is not expected that the proposed solvents would evolve
vapors requiring air pollution control equipment.
There will be no new stacks and no new air pollution control devices required. -
is water soluble and will be absorbed in the existing demislers in the
leach area.
The removed -will be will be in the form of aqueous solutions or slurries that will
not generate dust.
6.2 Tailings Management System
The Mill proposes to discharge process solutions from the proposed process to Cell I, Cell 3
and/or to Cell 4A,. For conservatism, the discussion below af:sumes the entire mass of
chemical residual from the process is discharged to one cell, either Cell 1, Cell 3 or Cell 4A.
The chemical constituent, will be transferred to the Mill's TMS in
res idu a ls d isc ha rge d peri od ica ll y fr o m the process. Based on an anticipated -use rate of
-during processi ng, and ass umin g a full ye ar of pr oc ·ing, the annual addition of
to th e T M S -be a pproxim ate ly
--Th e qu a ntily is comp ara ble to antily of d e
from th which are u ·ed in t he ongoing RE
process .
The will be recycled and reused lo the extent possible. It will
be d isc harged to the TMS when the. equipment in the vanadium area is to be converted to
reuse from REs to vanadium proces . ing. For th e foll owing di c u. ion, it has been a-;sumed
that the entire quantity of up k , 0 1 . in th e process could be
discharged to the TMS at one time. Based on current estimates of total mass in each cell:
Cell I Cell 3 Cell 4A
Current Total Mass in Cell 556,450 2,700,000 911.700 (tons)
Current Total Mass in 1,112,888,000 5,400,000,000 1,823,400.000 Cell (lbs)
01.27.2022
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq .
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum
Concentration of
if total mass is
di ·pos e d (mg/kg or ppm)
■ I
Pg.10
■
Note : The mass in Cell I was approximated assuming solutions have :.i dl!nsity of 8.33 lbJgal. Due to the high
metal and anion content, the densily is likely higher, am! the coneentration shown is conservative.
In all cases, the residuals will be transferred initially to Cell 1, Cell 3, or to Cell 4A, and
potentially re-circulated through the TMS.,
Cells I and 3 were each constructed with a polyvinyl chloride ("PVC'') membrane liner. Cell
4A and Cell 4B have high-density polyethylene ("HOPE") liners.
A number of studies evaluated both PVC and HOPE in conditions similar lo or more
aggressive than those anti ip ate d in the Mill 's TMS. The tests included cati o ns acidic anions
(s uch as
-th an th e Mill's k rose ne .
Haxo, el. al. (EPA 1985) and Battelle Laboratories (Farnsworth and Hymas, 1989) and EPA
(EPA, I 988) evaluated the performance of PVC and other vinyl and polyethylene liner
materials in leachate solutions containing metals, salts and volatile hydrocarbons in field tests
in some cases up to 18 years exposure. Battelle's studies included the -
Polyelhylenc was unaffected; PVC had good retention of properties .
Performance data on HDPE and PVC liners in service since the 1970's was tabulated for
leachate mixtures in the presence of oxy organics (phenols) up to 29,000 mg/L; sulfates up
to 950 mg/L; and BTEX and naphthalene up to 2,500 mg/L. Both showed good performance
over the lifetime in service. (Haxo. 1991)
As mentioned above, compounds have previously been introduced to the
Mill and disposed in the Mill's TMS, with no apparent adverse effects. The estimated
concentrations calculated above should not be considered as a threshold or allowable limit
for concentrations in Lai lings. The TMS is expected to be able to handle
substantially higher levels as explained below .
01.27.2022
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.11
Other studies including laboratory tests up to l 9 months and field service up to IO years
including hydrocarbons up to O.Dl mg/L (Artieres et. al, no date) showed no degradation of
PVC or HDPE.
It can be concluded that both the PVC and HOPE liners will have suitable resistivity to the
concentrations of any of the chemicals to be discharged to the TMS as a result of the proposed
process.
6.3 Worst Case Spill Results and CERCLA/SARA Title II Section 302 Reportable
Quantities (RQs)
The worst-case spill estimates and CERCLA reportable quantities ("RQs"), where
applicable, for each additive or product are summarized below.
As mentioned above, extractant will be received in either 55-gallon plastic drums or 250-
gallon plastic totes. The worst-case spill of solvent would potentially consist of the loss of
either a pallet of 4 drums (220 gallons) or a full tote (250 gallons) before it was introduced
into the process. For conservatism, this evaluation assumes the worst-case spill is 250 gallons
or 1,980 pounds. Spills of solvent from the storage area, or leaks or spills of extractant from
the vessels used in the vanadium SX area, would be managed consistent with the Mill's Spill
Prevention, Control, and Countermeasures Plan ("SPCC") plan. Residual material would
flow to the Mill's TMS. None of the compounds in the two solvent categories evaluated
have any reportable quantity ("RQ") under SARA Section 302.
As discussed above, the tailings cell liners have suitable resistivity to
to receive many times the worst-case pill of one tote or one pallet, as
well as the discharge of the full quantity of
extractant in the circuit at any one time.
A worst-case spill of -has been addressed previously in SERP 2021-01 and is not re-
visited in this document. SERP 2021-01 addressed the spill of a full 5,000-gallon truck.
Whether -is delivered in a truck of 5,000 gallons or larger, the spill response consistent
with the Mill's SPCC would be the same. The on-site -storage tanks are in a secondary
containment structure and any spill would be returned to the tanks or transfen-ed to the Mill's
TMS
01.27.2022
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technica l Memorandum
Additive or
Product
extractant
Worst Case Spill
1111
6.4 Reclamation and Surety Considerations
CERCLA RQ or Other
Reporting Requirement
NoCERCLARQ
Pg.12
The proposed Change will utilize existing equipment within existing Mill buildings on site.
The Change requires no construction and no change to the Mill footprint. The Change will
not require new equipment that would increase the reclamation tailings volume beyond the
current estimate for full Mill production. The Change will not require any additional
procedures or special provisions or monitoring beyond those proposed in the approved
Reclamation Plan.
The Change will therefore not require any change to the reclamation plan or adjustment to
the financial surety amount.
6.5 Drainage and Surface Water
Spills of solvent would occur within its storage area or the vanadium area within the Mill
buildings, and will drain to the Mill's TMS.
Spills of -would be contained in the storage tank diked area and would be returned to the
tanks or transferred to the Mill's TMS. Drainage maps in the Mill's SPCC and Storm Water
Best Management Practices Plan ("SWBMPP") will need to be updated to indicate the location
of thellllllstorage tanks and the storage areas for the extractant.
01.27.2022
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq .
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Techn ica l Memorandum
7.0 Consistency with License, Permits, Plans and SOPs.
7.1 Groundwater Discharge Permit ("GWDP")
The reagents and additives for the proposed process are phosphonic or
Pg.13
has been addressed in Lhe 2020-01 SERP for REU processing. the
ion is currently monitored in the TMS and groundwater. and will not be further revisited here.
The extractant classes are comparable to other organic compounds previously or currently used
in the Mill and historically present in the TMS.
The 1997 EA for the Mill anticipated the use of similar
compounds in the lab, which would be discharged to the TMS . None were required as analytes
in tailings solution monitoring or groundwater monitoring.
Utah DWMRC's 2004 GWDP Statement of Basis ("SOB") identified that the more aggressive
had previously been used with kerosene in the Mill's uranium solvent
extraction step. The SOB included tailings data showing that following the historic use of-
the TMS ·a mples indic ated up to , and immeasurably small levels of
-in tailings soluti o n . DWMRC determined, based on this SOB, that even following
use and introduction of inl'o the TMS, it would not be necessary to include monitoring of
compounds, in groundwater or in tailings solutions .
All of the compounds in the two -extractant classes considered in this SERP
are less aggressive and less mobile than the -addressed by DWMRC in the 2004 SOB.
Hence, no modification of the GWDP should be required to address these chemicals.
7.2 Air Approval Order ("AO")
As discussed in Section 6.1, there will be no new air emissions and no new air pollution co11trol
devices required. No amendment to the Mill's AO will be required.
7.3 Other Permits, Plans and SOPs
Based on the discussion above, the following documents may require amendments or
revisions to address the proposed process:
• SPCC tables,
• SWBMPP,
01.27.2022
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum
• SOP books,
• ERP to address the -storage tanks,
• SDS books throughout the Mill.
Pg.14
The SOPs describing the proposed Change evaluated in this memorandum are provided in
Attachment 3. All needed items are listed in detail in the Action Item list in Section I 0.0 of this
memorandum.
8.0 Compliance with Other Regulations
8.1 Resource Conservation and Recovery Act (RCRA)
RCRA regulates the treatment, storage and disposal of hazardous wastes. None of the proposed
chemicals are associated with any RCRA waste listings.
As described above, compounds will be transferred to the TMS,
which already has received these or comparable compounds from sources in the Mill and
alternate feed materials.
8.2 Toxic Substances Control Act (TSCA)
All chemicals identified for the proposed process have active status on the TSCA Chemical
Substances Inventory, that is, they are approved for sale, use and transport.
8.3 Emergency Preparedness and Community Right-to-Know (EPCRA) Section 313
Toxic Release Inventory (TRI) Reporting
lndustries under SIC Code I 094, which include uranium, thorium and radium extraction and
recovery, are exempt from reporting under EPCRA Section 313.
8.4 OSHA Hazard Communication Standards ("HCS'')
The OSHA HCS in 29 CFR 1910.1200, as accepted by MSHA, require that the Mill update all
copies of the SDS binders to include the proposed new extractants.
9.0 Sustainability
EFRJ evaluates each new project to determine whether there is any alternative that will have
measurably lower environmental impacts. This step confirms that the chosen alternative is as
sustainable as is reasonably possible ("ASARA"). The following considerations have been
considered.
01.27.2022
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum Pg.15
• Removal of the , REs wil I reduce the quantity to be shipped, with
an associated reduction in transportation, specifically
o Fewer supersacks
o Fewer truck trips and less fuel consumption
• The removal of , will improve the
quality and salability of the product, reducing the quanlity that must be reprocessed or
disposed.
• The proposed change is the first step in allowing eventual separation of RE _
Producing REs in the US will greatly reduce the
environmental impacts of transporting RE metal products from foreign producers such
as China.
10.0 Conclusions and Recommendations
Based on the foregoing information, it can be concluded that:
I . The proposed change will not produce any environmental impacts outside the
envelope of those already addressed in the approved ERs for the Mill. No license
amendment is required for the proposed change.
2. SOPs have addressed appropriate Personal Protective Equipment ("PPE") for the
additional respiratory hazards from phosphoric oxides in a fire.
3. The proposed Change generates no additional environmental emissions.
4. All chemicals or material to he discharged to the TMS under the proposed
change. are already monitored, or well represented by other analytes already
monitored in the tailings solutions and under the GWDP. The proposed change
will not require any modification of the Mill's GWDP.
5. No RCRA requirements apply to the proposed change.
6. All proposed materials arc acceptable under TSCA.
7. As listed above, revisions will be required to certain documentation referred to
in lhe RML application as itemized in Section 10.0, below.
01.27.2022
Withold from Public Disclosure
Under Utah Code 63G-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum
11.0 Action Items
Based on the above evaluation, the following action items need to be implemented.
• Update the SPCC tables.
• Update the SWBMPP.
• Update the SOPs books to include appropriate additional SOPs.
• Confirm the SOPs have been reviewed for proper PPE.
• Update the ERP to address
• Add SDSs for the new extractant(s).
Pg.16
01.27.2022
Withold from Public Disclosure
Under Utah Code 638-2-101 et seq.
and as indicated in the redacted text below.
All redactions were based on CBI/Proprietary Information
Technical Memorandum
11.0 References
Pg.17
Artieres, 0., F. Gousse and E. Prigent laboratory Ageing of GeomembraneJ· in Municipal
l..andjill Leachares no date
Centers for Disease Control ("CDC") National Instilute for Occupational Safety and Health
("NIOSH ") accessed at hu ~://v W \ .c dc .crov/ni os h/n w n gd0492 .hLml January 2022
Dames & Moore Environmental Rep011 White Mesa Uranium Mill San Juan County, Utah
January 30, 1978
Farnsworth, R.K. and C.R. Hymas, August 1989 The Compatibility of Various Polymeric li1ter
and Pipe Materials wirh Simulated Double-Shell Slurry Feed at 9(J'C. Pacific Northwest
Laboratory, US. Department of Energy, Battelle Memorial Institute
Haxo, Henry E., Jr. Compatibility of Flexible Membrane Liners and Municipal Solid Waste
Leachates US EPA Risk Reduction Engineering Laboratory August I 991
Haxo. H.E., Jr., Robe11 S. Haxo, Maney A. Nelson, Paul 0. Haxo, Richard M. White, and Suren
Dakess ian Liner Materials Exposed to Hazardous and Toxic Wastes US EPA Hazardous Waste
Engineering Research Laboratory EPA-600/S2-94-I 69 January 1985
National Institute of Occupational Safety and Health Online NIOSH Pocket Guide to Chemical
Hazards hllpl:.:ll ww ,v.cd c.gov/n i . h/npg/sca rc h .html accessed January 2022
OSHA Hazard Communication Standards as stated in 29 CFR 1900.] 200
US EPA list of lists Consolidated list of Chemicals Sub jeer to EPCRA, CERCLA and CAA 550-
B-19-03 June 2019
US EPA, 1988. Risk Reduction Engineering Laboratory . lining of Waste Containment a11d
Other Impoundmenr Facilities EPN600/2-88/052 September 1988
US EPA Toxic Substances Control Act Chemical Inventory Chemical Substance Invento1)•
February 20 I 9
US Nuclear Regulatory Commission Environmental Assessment for Renewal of Source
Material License SUA-1358 Energy Fuels Nuclear. Inc . White Mesa Uranium Mill March 14,
1997
01.27.2022 Technica l Memorandum Pg.18
ACGIH
AO
BaCb
CAA
CCD
CDC
CERCLA
EFRI
EPCRA
ER
GWDP • HCS
HOPE
NTOSH
OSHA
PPE
PVC
RCRA
REE
REU
RML
RQ
SARA
SDS
SERP
SOP
LIST OF ACRONYMS
American Conference. of Government Industrial Hygienists
Air Approval Order
Barium Chloride Di hydrate
Clean Air Act
Counter Current Decantation
Centers for Disease Control
Comprehensive Environmental Restoration, Compensation and Liability Act
("Supcrfund'')
Energy Fuels Resources (USA) Inc.
Emergency Preparedness and Community Right-to-Know Act
Environmental Report
Groundwater Discharge Permit
Hazard Communication Standard
High density polyethylene
National Institute for Occupational Safety and Health
Occupational Safely and Health Administration
Personnel Protective Equipment
Polyvinyl Chloride
Resource Conservation and Recovery Act
Rare Earth Elements
Rare Earth Bearing Uranium Ore
Radioactive Material License
Reportable Quantity
Superfund Amendments and Reauthorization Act
Safety Data Sheet
Safety Environmental Review Panel
Standard Operating Procedure
01.27.2022 Technical Memorandum
SPCC
SWBMPP
sx
TMS
TRI
TSCA
Attachments
• Figure 1
Spill Prevention, Control, and Countermeasure Plan
Storm Water Best Management Practices Plan
Solvent Extraction
Tailings Management System
Toxic Release Inventory
Toxic Substances Control Act
Schematic Flow Diagram for
• Table l Comparison of Extractants
• Attachment I Technical and Regulatory Review
• Attachment 2 Safety Data Sheets
Pg.19
Removal
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(ti
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ATTACHMENT I
TECHNICAL AND REGULATORY REVIEW
Redact entire page
Chemical and Regulatory Summary
-
ATTACHMENT 2
SAFETY DATA SHEETS
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SAFETY DAT A SHEET
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SAFETY DATA SHEET
-available
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SAFETY DATA SHEET
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c loth ing/equipment in Section B, wear a two p iece PVC suit with hood or PVC overalls
w ith hood .
■
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--
SAFETY DATA SHEET
--..
--
-.... _c__c__c__c__c__c__c__c__----------=--------=--------=--------=--------=--------=--------=--------=----=-
--
-================-=:::,
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SAFETY DATA SHEET
--
--
Chronic toxicity to daphnia and
•
--
10/ 13
Organophosphorus ester
12.6 Other adverse effects
Ecotoxicity assessment
Short-term (acute) aquatic hazard
SAFETY DATA SHEET
-'--------------~
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TCIAMERICA
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No data available
~o data available
o data available
No data available
No data available
No data available
No data available
No data available
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Preparation Date 2/24/2015
Latest Revision Date (If Revised) 3/6/2018
I -----..
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WHMIS Symbols (Canada)
~~
...
Eye/Face Protection
Safety goggles or face shield . All equipment should have been tested and approved under appropriate standards, such
as NIOSH (US), CSA (Canada), or EN 166 (EU).
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ATTACHMENT 2
-Removal SOP
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7 ■■■■Removal
Preface
• • • • ate t
Comm uni cation
Date: 01-22 Revision: EFR-1
Page I of 4
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safety
The solution that is fed to the -removal circuit is -and has high concentrations of
rare eruth metals. This solution should not be ingested. The
~!so contains heavy metals and should not be ingested. The organic solution is flammable. No
Hot Work will be done in the solvent extraction building without a Hot Work permit. Any possible ignition
source must be avoided. The solution used to strip or remove the rare earths from the organic solution is
and should be handled appropriately and only when using appropriate Personal Protective
Equipment (PPE). generates vapors that should be avoided. These vapors can cause
extreme irritation and injury.
Hazards:
•
I
• Stairs and elevated work areas
• Pressurized solutions pumping throughout the circuit
•
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7 -Removal
Per onal Protective Equipment (PPE)
Date: 01-22 Revision: EFR-1
Page 2 of 4
1. Minimum PPB requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2 Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3 Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4 The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that pa1ticular job listed on the Safe Work Permit
5 The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6 It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
While Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7 ■■■■I Removal -One of the most critical aspects of this circuit is
I
I
Sampling
Date: 01-22 Revision: EFR-1
Page 3 of 4
Sampling of the various solutions in this circuit is required on a regular basis. It is important to ensure that
any sample taken is representative of the tank's contents. This means that tanks should be well mixed,
sampling equipment should be clean, and any sample ports purged before collecting the sample.
Operating ln tructions
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
2.
I
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I
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parameters, including, but not limited to: flow rates, tank levels, solution concentrations.
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 7 ■■■■1 Removal
tart-up Procedures
Shutdown Procedures
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Emergency Shutdown Procedures
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Date: 01-22 Rl!vision: EFR-1
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ATTACHMENT 3
SERP 2022-02 -REDACTED
REPORT
ENERGY FUELS RESOURCES (USA) INC.
WHITE MESA URANIUM MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL
MEETING OF DECE:MBER 14, 2022
SOPs for Separation
During Uranium Rare Earth Ore Recovery
SERP No. 2022-02
ENERGY FUELS RESOURCES (USA) INC.
WHITE MESA URANIUM MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL
MEETING OF DECEMBER 14, 2022
SERP NO. 2022-02
1. PURPOSE
The Energy Fuels Resources (USA) Inc. ("EFRI") Safety and Environmental Review
Panel ("SERP") for the White Mesa Uranium Mill (the "Mill") met by telephone
conference on December 14, 2022 in accordance with SERP procedures in White Mesa
Mill Standard Operating Procedure PBL-:1, Rev. No. R-6 (the "SERP SOP"), to consider
SERP No. 2022-01, regarding the following (the "Change"):
Review and approve a proposed
Procedure ("SOP") for separation of
the currently-produced mixed rare earth intermediate stream ("the
Change").
The SERP followed the SERP SOP as it performed this SERP evaluation, to ensure that
the change is consistent with the following three criteria (the "SERP Approval Criteria"):
(a)The change, test or experiment did not conflict with any requirement
specifically stated in the Mill license, and did not impair EFRI' s ability to
meet all applicable regulations;
(b)There would be no degradation in the essential safety or environmental
commitments in the license application, or provided by the approved
reclamation plan; and
( c) The change, test or experiment was consistent with the conclusions of actions
analyzed and selected in the most recent Environmental Assessment (EA)
conducted by the Division of Waste Management and Radiation Control
("DWMRC") from the last license renewal and/or major license amendment.
2. OVERVIEW AND BACKGROUND
The Mill intends to modify its existing solvent extraction ("SX") facility by removing
an existing rare earth ("RE") SX circuit and some redundant vanadium SX tanks and
replace them with an expanded RE SX circuit to be used to purify the currently-
produced mixed rare ea intermediate stream. The mixed rare earth
solution will be separated into
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-similar to what is currently produced from the existing RE circuit that will be
removed and replaced by the expanded RE SX circuit. The will be
calcined to produce
The Mill is evaluating and this SERP assumes packaging and selling an interim 111111
-_pro~quirements and equipment related to oxidation are finalized.
~tep and associated equipment will be evaluated in a separate
SERP process and, if required, air approval order ("AAO") revision process. The SERP
evaluated the remainder of the proposed process described above.
In addition to the proposed process and chemicals, the SERP evaluated the SOPs, which
addressed the operation described above. The proposed process is referred to in this
report as the 111111 process, or the "Change." The SERP evaluated the process with
respect to the requirements of condition 9.4 of the Mill's RML, worker safety, process
safety, and environmental protection.
3. SERP MEMBERSIDP AND QUALIFICATIONS
This SERP consisted of the following members:
Resoonsibilitv Name/Position
Corporate Radiation Safety Officer or Garrin Palmer
equivalent; Mill Radiation Safety Officer (Member)
Assuring Tests conform to radiation safety
and environmental requirements
Management Expertise; David Frydenlund
Responsibility for managerial and financial Executive Vice President, Chief Legal
approvals Officer and Corp Secretary (Member)
Operations and/or Construction Logan Shumway
Management; Mill Manager (Member)
Responsibility for implementing
operational procedures
Responsibility for regulatory compliance at Kathy Weinel
WMM Director, Regulatory Compliance
Corporate responsibility for regulatory • Scott Bakken
compliance Vice President Environmental Affairs
Independent Safety /Environmental Jo Ann Tischler
Evaluation Independent Chemical Engineering
Consultant
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In addition, the following Mill or Corporate Personnel attended the SERP :
Reason for Attendance Name/Position
Technical Expertise on proposed process Timo Groves
Chief Metallundst, PE
Worker Safety Expertise Dax Jacobsen
4. SERP iu:VIEW OF PROPOSED CHANGE AND SOP
The SERP reviewed specific details relating to the process, including the SOPs and the
independent consultant's Technical Memorandum.
A copy of the SOPs and the Technical Memorandum are provided in attachments to this
report. Specific points discussed are summarized below.
The SERP reviewed all processing steps, and identified those procedures that did not
need to be included in the processing SOP, or materials, specifically,
_, that did not need to be re-addressed because they have been approved
separately.
The SERP also reviewed the Document Control SOP, in place since 2000, which requires
that any new SOP, or any significant change to an existing SOP, requires a SERP review.
5. REVIEW OF SERP APPROVAL CRITERIA
5.1. Review of the Criteria
In order for a change in the facility or process, as presented in the license application, to
be eligible for approval by the SERP, the three SERP Approval Criteria, detailed in
Section 1 above, must be satisfied. The three SERP Approval Criteria, as detailed in the
five steps of the SERP procedure, were reviewed and discussed, as follows:
5.1.1. Does the change conflict with any requirement specifically stated in the license?
The SOPs will not require any types of process operations not currently performed at the
Mill. Processes such as solvent extraction and product stripping, have been regularly
performed at the Mill. The Change will involve an additional stage of RE product
separation using the same types of solvent extraction equipment, such as feed tanks and
as currently and historically used. The Change will require the relocation
of some existing installation of addit ional SX equipment of the same
type as currently used, which will be installed within existing buildings.
Storage of chemicals will not require construction of new tanks or storage areas. The
Change will not require use of electricity, fuel, or water resources beyond levels
anticipated in the license for full Mill production.
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There are no reported incompatibilities for -and it can be stored near other
products or reagents.
Use of the will not require any worker protections beyond those
currently in use in other Mill operations.
The Mill's License anticipates the recovery of secondary metals, such as vanadium, from
uranium ores, via additional SX circuits.
Based on the above, the SERP determined that the Change does not conflict with any
requirement stated in the license or any license requirement contained in any license tie-
down letters. Therefore, this criterion is met.
The purified and concentrated yellowcake that will be produced from the ore 1111 to the
RE recovery step will not cause the Mill to exceed the yellowcake production limit under
the License.
5.1.2. Does the change impair EFRI's ability to meet all applicable regulations?
No. The SERP identified that there are no Resource Conservation Recovery Act
("RCRA") Comprehensive Environmental Response, Compensation and Liability
Act ("CERCLA"), or Toxic Substances Control Act ("TSCA") requirements applicable to
the ore, -or proposed process chemicals,
The chemicals and proposed Change and SOPs will not generate any new air emissions
or r uire revision to the AA O.
-will be supplied in It has previously been used at the
Mill in laboratory test quantities and transferred to tailings from the Mill laboratory. The
SERP reviewed the facts that:
• -is a natural, non-hazardous compound present in plant material with
minimal environmental lifetime and no hazardous effects if spilled or released to
the environment,
• it forms inert, stable, insoluble precipitates with many metals and will not be
reactive within the tailings solution environment,
• it is far less aggressive than the mineral acids currently present in the tailings
management system ("TMS''), and will not have any effect on the tailings cell
liners,
• it will be present only as , and will be
present at immeasurably small, non-detectable levels in the TMS and could not be
identified or measured in any way in groundwater.
Utah DWMRC identified in the 2004 Statement of Basis for the Mill's Groundwater
Discharge Permit specific organic compounds targeted for monitoring in the Mill's
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groundwater and justified why other organic compounds were not of significant concern
to be monitored.
Existing spill management procedures will be sufficient for the proposed process
chemicals. The SERP noted that there are no Emergency Planning and Community
Right-to-Know Act ("EPCRA") reporting quantities for
The Spill Prevention Control and Countermeasures ("SPCC") plan tables
will be updated as appropriate for-
5.1 . 3. Is the change consistent with the conclusions of actions analyzed in the most
current EA?
The original 1980 Environmental Assessment ("EA"), subsequent environmental reports,
and the DWMRC Technical and Environmental Report for the Mill contemplated that the
Mill would recover secondary metals, in addition to uranium. The original EA
contemplated recovery of copper and/or vanadium. The Mill has also previously been
approved to recover, and has modified the process to recover, tantalum and niobium.
The process will not generate any measurable new tailings constituents not already
monitored or addressed by other indicator parameters in the groundwater discharge
permit ("GWDP"). Precipitates of -are so insoluble and so immobile they
would not be measurable or detectable in tailings solutions or groundwater.
The process will produce no new or increased air emissions. The tailings to be generated
will be comparable to, and contain comparable non-radiological constituents, as the
tailings previously generated and managed in the tailings management system.
The Change will not introduce any new feed materials or new radionuclides. The process
will involve no change to the uranium recovery circuit or radionuclide levels in the
uramum recovery process.
5.1. 4. Does the change require any adjustment to the financial surety arrangement or
approved amount?
The SERP determined that there would be some required change to the Mill's surety.
There would be some increase to the Mill building footprint but no change to the
footprint of the Mill's disturbed area. There would be a minor increase to the volume of
equipment to be disposed in the tailings management system at reclamation. This will be
addressed in the next revision to the tailings volume capacity estimate and surety
estimate.
The Change will not measurably increase the quantity of materials discharged to the
tailings system, relative to the RE process.
The volume of any new equipment to be used for the process was anticipated within the
licensed tailings capacity.
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The composition of tailings from the proposed process will not require any change to the
cover design as noted in the September 9, 2020 letter to DWMRC. The composition and
quantity of tailings generated will not require any special management or changes to the
tailings reclamation plan.
5.1.5. Does the change create any degradation in the essential safety or environmental
commitments in the license application, or provided by the approved reclamation plan?
The SERP assessed that there would be no change in the safety or environmental
commitments in the license application or reclamation plan.
Processing according to the SOPs is not expected to produce any environmental impacts
beyond those assessed in any EA, and is consistent with the conclusions regarding actions
analyzed in the EAs. As a result, this criterion is also satisfied.
The proposed process will:
• Not produce any increased levels of radionuclides in processes or wastes beyond
those anticipated in the EAs or previously managed under approved SOPs,
• Not introduce any constituents to the TMS that are detrimental to the tailings
solutions or tailings liner,
• Not produce any new emissions or pathways for exposure to workers or the
public,
• Not introduce any new pathways of contamination to the environment,
• Not increase the disturbed area footprint,
• Require no changes to the Radiation Protection Manual ("RPM"),
• Require no changes to the Environmental Protection Manual ("EPM"),
• Require no changes to the Emergency Response Plan ("ERP"),
• Require no changes to the ALARA SOP,
• Require no change to the GWDP,
• Require no changes to the training program, and
• Not require additional tailings capacity or changes to tailings management plans,
The Change will Require an update of the SPCC and Stormwater Best Management
Practices Plan (' SWBMPP") to incorporate -All other chemicals have been
historically used at the Mill and have been evaluated in previous SERPs.
Processing according to the SOP is within the envelope of conditions evaluated in the
Mill's MILD OS model for dose to off-site receptors. All changes involve additional
aqueous and solvent extraction steps on non-radioactive metals. There will be no new
sources of radionuclide emissions.
The tailings capacity evaluation 2023 update will confirm that suitable tailings capacity
exists for equipment associated with the proposed Change.
The Mill sought to meet EFRI's sustainability goals by:
• optimizing the re-use of existing equipment
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• minimizing the footprint of new or relocated equipment to maintain and minimize
the footprint of the Mill's disturbed area, and
• selecting the least hazardous chemical suitable to perform the
precipitation.
6. CONCLUSIONS
The SERP concluded that the proposed Change and SOPs meet the criteria set forth in the
SERP SOP for approval, and approved the proposed process and SOPs.
7. ATTACHMENTS
• Attachment 1 -Technical Memorandum of J. Tischler December 14, 2022
• Attachment 2 -SOPs for separation
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SIGNATURES
Re )Ort reviewed bv :
~~-__ __ _ Date:J~1?---'---_
Scott Balcken
Date: ?' /f C/ / l-./
~,~'; ~Bl~-
(i.1 ,Tin Palmer
Date: __ L_t~/_l _._1 /--=2"---->-=-------
Date: __ ~___,__/ 3:.....0_,i--'-~-=-=,;__;;;;_3 ___ _
Ka~y Weinel
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Date: ---t/1/('Z',3 _ __.____.__ _______ _
~ ~~ ~ 1 Date: /11\or ~o rz..o Z.~
------------------I--------Timo Groves
PaPe 9
ATTACHMENT 1
Technical Memorandum of Jo Ann Tischler
December 14, 2022
12.14.2022
To:
S . Bakken,
D. Frydenlund,
T. Groves, P. Keller
L. Shumway,
K. Weinel
From:
Jo Ann Tischler
Cc:
Re:
Draft Technical
Review of Proposed
Rare Earth Separation
and Rare Earth _
Production
Technical Memorandum
Introduction
This Technical Memorandum (the "Memorandum") evaluates a proposed change at the White
Mesa Mill (the "Mill") to produce alllllllrare earth ("RE") product, along with uranium from
its uranium-bearing natural monazite ores. The Mill intends to modify its existing solvent
extraction ("SX") facility by removing an existing RE SX circuit and some redundant
vanadium SX tanks and replace them with an expanded RE SX circuit to be used to purify the
currently-produced mixed rare earth stream. The mixed rare earth
stream will be precipitated using
to produce --The
stream will be to produce -product, similar to
what is currently produced from the existing RE circuit that will be removed and replaced by
the expanded RE SX circuit. The -will be -to produce -• a
The step will be evaluated in a separate
SERP . Tbe Mill is evaluating packaging and selling an interim -product while
requirements and equipment related to are finalized, as discussed in Section
6.1.
This Memorandum assesses whether the Change may pose any worker safety or environmental
hazards, or be inconsistent with conditions and assumptions in the Mill's current State of Utah
Radioactive Materials License No. UT1900479 (the "RML'' or the "license") or other
regulations. This assessment was performed as part of a SERP evaluation of this potential
change or test under the RML and the Mill Standard Operating Procedures ("SOPs"). The
proposed RE recovery process expansion and SOPs will be referred to in this memo, for the
purposes of SERP evaluation, as the "proposed process" or "Change".
In order for a Change or test in the facility or process, as presented in the license application,
to be eligible for approval by the SERP, three SERP Approval Criteria must be satisfied. This
memorandum provides information needed to answer the three SERP criteria as follows:
la) Does the change conflict with any requirement specifically stated in the License?
1 b) Does the change impair EFRI's ability to meet all applicable regulations?
2) Does the change create any degradation in the essential safety or environmental
commitments in the license application or provided by the approved Reclamation Plan?
3) Is the change consistent with the conclusions and actions analyzed in the most recent
Environmental Assessment conducted by the Division from the last license ren~wal and/or
major license amendment?
Tischler Consulting Services, LLC J1JC Tel [phone]
8015 South Krameria Wa y
Centennial, CO 80112 japmst55@gmai l.com
12.14.2022 Technical Memorandum Pg.02
The following report provides an evaluation of potential safety and environmental hazards,
consistency with the RML, and provides information for comparison to the SERP criteria. To
perfonn this evaluation, we have considered the following questions:
1. Will the footprint of the disturbed area increase, e.g., for new buildings, storage pads,
tanks?
2. What, if any, new chemicals or reagents will be required for the proposed process?
3. Are there any new or different environmental or safety issues associated with the
storage, use, handling, or disposal of new chemicals or reagents?
4. Would use of new chemicals or reagents create any additional requirements for spill
or emergency response equipment or training?
5. Would the use of new chemicals or reagents create any additional environmental
emissions?
6. Are the existing and the proposed SOPs appropriate and sufficient for the reagents
to be used?
7. Is the implementation of the proposed process and SOPs consistent with the Mill's
RML, RML application, reclamation bond, other permits, and plans?
8. Does the implementation of the proposed process and SOPs conflict with any EFRI
environmental or safety commitment made in any other plan or document?
9. Do any of the following requirements apply to the materials proposed to be used or
produced in this Change:
• Resource Conservation and Recovery Act ("RCRA"),
• Toxic Substances Control Act ("TSCA"), or
• Comprehensive Environmental Response, Compensation and Liability
Act/Superfund Amendment and Reauthorization Act ("CERCLA/SARA")
• Clean Air Act ("CAA") and regulations in Utah Administrative Code R307-
401
12.14.2022 Technical Memorandum Pg.03
10. Is the proposed Change being implemented in a manner that satisfies the Mill's As
Sustainable as Reasonably Achievable ("ASARA") objective?
1.0 Basis and Limitations of this Evaluation
The evaluation in this report is based on the following documents:
• Schematic process flow infonnation provided by Mill personnel.
• Safety Data Sheet ("SOS'') for from
• Process schematic diagram for the proposed process provided by Mill personnel.
• Communications with Mill personnel from October through November 2022.
• Additional technical references listed at the end of this memorandum.
2.0 Description of Proposed Change
A potential flow configuration for the proposed Change is depicted in the schematic flow
diagram in the attached Figure 1.
The recovery of REs from Rare Earth-bearing Uranium ("REV") ores at the proposed scale
would use the same initial steps as the previous test scale process approved by the April 19,
2021 SERP. As evaluated previously, ores would be received , weighed , and sam led using
existing equipment. The REV ore will be dum ed into a
using existing uranium o
will be treated to remov
which is commonly used in the Mill, and the rare earth
12.14.2022 Technical Memorandum
in the Mill's tailings management system ("TMS").
The
for disposal in the TMS in a similar fashion
-elution will be precipitated with
Pg.04
will be disposed
generated as a byproduct of the precipitation step may be recycled to the process or disposed
ofin the TMS. Th
product.
The proposed Change would require the modifications listed below, to produce a modified RE
solvent extraction circuit for the above process.
• Some vanadium be moved to another location to accommodate
the new RE SX equipment. Other vanadium SX equipment would remain in place, but
would not be used for the RE SX.
• The mini SX equipment that was previously used for RE separations will be
removed. Additional units will be installed in the building extension that formerly
housed additional vanadium mixer-settlers.
Mill is evaluating This
equipment is discussed further in Section 6.1.
The SERP of April 19, 2021 evaluated all of the process steps and chemical use and disposal
required for processing of 15,000 tons per year ("TPY") ofREU ore for production of a mixed
RE -product. The SERP of January 22, 2022 evaluated the modification of the SX
facility to add RE SX equipment to se arate from the -product, which is
currently being done (the being sent to the tailings to allow for
production of a ). The current evaluation addresses
installing additional SX equipment (similar to equipment already installed) to allow for more
complete separation of the REs. The more complete separations would produce
report to tails similar to the current process.
The following chemicals have historically been used in the Mill's circuits and are not re-
evaluated here.
12.14.2022 Technical M emorandum
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Pg.05
The following chemicals and their use at rates to support processing of 15,000 TPY REU ores
have been evaluated and approved in the SERP of April 19, 2021 and are not re-evaluated here.
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The following chemical and its use at rates to support processing of 15,000 TPY REU ores has
been evaluated and approved in the SERP of January 22, 2022 and is not re-evaluated here.
·-
The use and discharge to tailings o-at levels required for the Change is discussed in
Section 6.2.
-will also be used, specifically in the precipitation step, to produce the-
tltrough the above-described process. -has historically been used in the Mill
laboratory, but has not been used for process operations in the Mill circuits. The current
technical memorandum and SERP will evaluate the effects of adding to the RE
circuit , a:n d producing and handling
-in addition to the wastewater and
Calculations discussed in this evaluation are based on an assumed case of processing
approximately 15,000 TPY of monazire ores to produce approximately 11111111 TPY ofllllll
-Regardless of the ore source, the proposed throughput will not cause the Mill to exceed
the RML limit of 4,380 tons of yellowcake production per year.
-acid is discussed under Section 4.1, 5.1 and 6.2, below, and in the Technical and
Regulatory Review in Attachment 1. As mentioned above, all other chemicals will be those
historically used in ore processing, and have been evaluated at use rates greater than the
proposed Change.
As a result of the proposed Change:
• There will be no change to the uranium leaching and recovery circuit or alternate feed
circuit.
• There will be no change to the uranium drying or packaging equipment.
12.14.2022 Technical Memorandum Pg.06
• The mini SX equipment will be removed, but the uranium circuit can operate without
this equipment
• Vanadium mixer-settlers will be removed, but the vanadium circuit can operate without
this equipment.
• A vanadium -which was approved in the Mill's Air Approval Order
("AAO"), was never constructed, but has remained as an approved portion of the Mill's
Potential to Emit in the AAO. The vanadium Ill will be removed from the AAO and
will be replaced by the (any required amendments to the AAO will be
obtained).
• Vanadium
the
operate with existing vanadium ~quipment and without
o be removed from the AAO.
• The Mill's TMS will not receive any new radiological wastes.
• There will be no increase to the footprint of the Mill's disturbed area.
2.1 Past History of Uranium Extraction from Ores with Secondary Metals
The Mill has extensive experience with the extraction and recovery of secondary metals from
natural uranium ores or alternate feed materials. The Mill has recovered, and continues to
recover, REs from uranium monazite ores, vanadium from vanadium-bearing uranium ores as
well as tantalum and niobium from alternate feed materials, as approved by the US NRC in
RML Amendment 5. The majority of the process steps for the Change are the same as those
currently used for ongoing RE recovery at the Mill. The additional steps, such as -
are similar to those used for of uranium, and of secondary metals
previously recovered at the Mill.
12.14.2022 Technical M emorandum Pg.07
3.0 Properties of Proposed Chemicals and Products
The properties of each of the proposed chemical additives are described in detail in the attached
Technical and Regulatory Review. The physical state is discussed in Section 4.0 below.
Hazardous properties are discussed in Sections 4.0 and 5.0, below.
4.0 Proposed Storage and Use of Chemicals and Reagents
Storage location, and storage and use quantities of additives for the proposed process are
detailed in the attached Technical and Regulatory Review. For ease of reference, storage
locations of proposed additives are summarized below.
New Additive
or Product
-
Form
Dry powder added
to solution
Dry powder
Storage & Use
Location
Stored in closed or
covered building.
Incompatibilities
Strong acids, strong
oxidizers , silver
compounds, strong
alkalis, chlorites. -
~ill not be in direct
contact with any of these
materials in the Mill.
Oxidizing agents.
will be
stored in sealed
product drums or
super sacks and will
not be in contact with
oxidizers.
The storage of all reagents, extractants and additives associated with RE recovery through the
-production have been addressed in the April 19 , 2021 and January 22, 2022 SERPs.
-will be stored in -in one of the Mill's buildings or storage areas.
The-storage drums/super sacks and product drums/super sacks will
also be stored in one of the Mill buildings or storage areas. There are no reported
incompatibilities for-and it can be stored near other products or reagents.
12.14.2022 Technical Memorandum Pg.08
product containers, and transport vehicles will undergo surface
radiological scanning before leaving the Mill. Either product may potentially undergo analysis
for uranium, thorium isotopes or other radiological constituent levels, if required by the
customer, as has been done for vanadium products.
4.1 Compatibility ofREU Processing Chemicals with Mill Process and Equipment -As mentioned above, -has been used historically in the Mill laboratory but has not
previously been introduced into the Mill's process circuits, so is evaluated here. Compatibility
of all other chemicals has been evaluated in the SERPs of April 2021 and January 2022.
, reacted with~
The precipitation reaction does not produce hazardous
off-gases or byproducts.
-has no recorded upper or lower explosive limit. -The only new product will be-. After it is produced in the~ide
product will be packaged and will not be in further contact with any Mill chemicals or
equipment.
5.0 Health and Safety in Mill Process
As mentioned above, the only new chemical to be introduced in the RE separation process is
-· Compatibility of all other chemicals with the Mill process have been evaluated in
the SERPs of April 2021 and January 2022.
The hazard properties of-and -are discussed in the attached Technical
and Regulatory Review and summarized here .
5.1 -
-in its -form is a nutrient present in edible plants such as parsley, chard,
spinach, buckwheat, most nuts and berries, beans, and tea leaves. It's important in plant tissues
12.14.2022 Technica l M emorandum Pg.09
for its ability to bind and store minerals. It's also present in humic components of soils as the
decay product of many other types of vegetation.
For -in its dry powdere~ form, manufacturer SOSs recommend sufficient
ventilation to keep occupational exposures lower than the limits below.
The NIOSH REL and OSHA Permissible Exposure Limit ("PEL") for
powder Threshold Limit Value ("TLV") Time Weighted Average ("TWA") is 1 mg/m3. The
Short-Term Exposure Limit ("STEL") is 2 mg/m 3 . If ventilation is sufficient to maintain
concentrations below these levels, no additional respiratory protection is required.
Mill employees are experienced in working with far more corrosive agents, such as sulfuric
acid (liquid), hydrochloric acid (liquid), and sodium hydroxide (powder and liquid solution).
No additional protections will be required beyond the Mill's current worker protection
measures for handling these types of materials.
5.2 -
, are both considered to be of low to moderate
toxicity. Neither has any published occupational exposure
limits. SOS information does not require any specific respiratory protection or other personal
protective equipment ("PPE") beyond common dust protection measures, such as gloves, safety
glasses, and possible dust mask. No additional protections will be required beyond the Mill's
current worker protection measures for powdered materials.
5.4 General/Other
Neither-nor~products have been reported to be carcinogenic or teratogenic.
An SOS for-should be added to the records available on site.
An SOS will need to be developed or adapted for-product. I~ is sold as an
-• an SOS needs to be developed.
The proposed process will require operation o
~efore storage. The Mill currently operates two
Mill personnel are trained in the use of this type of equipment.
12.14.2022 Technical Memorandum Pg.10
6.0 Environmental Considerations
6.1 Air Emissions
is water soluble, will be added to an aqueous solution, and will react with ..
solution. Any spills from bag handling would be immediately cleaned up. There will
be no opportunity for dust or fugitive emissions, once it is added to the system.
As discussed in previous SERPs, the RE-product will be a moist solid that will not
generate dust or fugitive emissions.
The-product will be packaged, sealed, and stored prior to sale and shipment off-
site. The drums/bags will be stored in one of the Mill's storage areas. Any product spills will
be cleaned up.
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Either selection will require modification of the Mill's Air Approval Order ("AAO"). Either
option may result in fewer air emissions th~ but not constructed,
vanadium~hich it would replace. The .............. result in low enough
air emissions that credit for an emissions offset, and reduced air permitting requirements and
schedule, may be possible.
The Mill will select an equipment type after design and price information is provided by the
manufacturers in early 2023.
The AAO and any required revisions are not part of, nor subject to, the Mill's RML. They
are discussed in this assessment for the sake of completeness, but will be addressed
separately.
Depending on the length of time to complete selection, permitting, and construction of the
-equipment, the Mill may package and ship .. as an -product until such
time as the facilities are competed to producei. as the JIii product.
12.14.2022 Technical Memorandum Pg.11
6.2 Tailings Management System
The April 19, 2021 SERP evaluated the addition of cations (such as Ba and Na), anions (such
as-• at levels resulting from 15,000 TPY REU ore processing. The potential effect of
the only additional additive, -is evaluated below. -As mentioned in Sectio~ was previously evaluated in the SERP of January 2022.
Haxo, et. al. (EPA 1985) and Battelle Laboratories (Farnsworth and Hymas, 1989) and EPA
(EPA, 1988) evaluated the performance of PVC and other vinyl and polyethylene liner
materials in leachate solutions containing metals, salts, volatile hydrocarbons, as well as
sulfuric and nitric acid environments in field tests in some cases up to 18 years exposure.
Battelle's studies included assessment of resistance to acidic mixtures containing the
which is the same functional group as in-including
0.05 molar phosphate, 0.05 molar sulfate, 0.1 molar chloride and in the presence of
radionuclides. PVC had good retention of properties; polyethylene was unaffected. These
conditions approximate or are more aggressive than the conditions in the Mill's tailings, and
represent phosphate levels substantially higher than could be produced by ~ischarge
from the Mill for the proposed Change evaluated in this memorandum. -As mentioned in Section 2.0, -will be added to react with the
to produce , which will be to yield and,
potentially,
The Mill proposes to discharge process solutions from the proposed
process to Cell 3 and/or Cell 4A, depending on conditions, capacities and recirculation.
At the acidic conditions of the Mill's tailings discharge and cell solutions, -
discharged to tailings from the small process excess would immediately react with dissolved
metals such as iron, uranium, vanadium, and residual REs in the tailings solution to form
would settle to the bottom of the
tailings cells. Historica ll y , the Mill has used other forms of
in the laboratory to
Hence the Mill has historically been introducing
At more aggressive acidic conditions, i.e., at higher sulfuric acid levels,
immediately degraded to form inert molecules of
presence of cations such as sodium or potassium, which are in the tailing solution, the CO2 will
12.14.2022 Technical Memorandum Pg.12
further be consumed in forming inert carbonates. That is, even in the most aggressive acidic
tailings environment,_ will not fonn hazardous byproducts in the TMS.
The EPA Risk Reduction Engineering Laboratory study cited above, (EPA, 1988) evaluated
data from a number of short and long-tenn test studies on liner material behavior in leachate
and waste solutions of
As discussed
above, PVC had good retention of properties; polyethylene was unaffected . It can be concluded
that -will not have harmful effects on either the PVC or HDPE liners in the Mill's
TMS.
The only other mechanism by which
a spill of
aqueous solution.
would reach the TMS would be by cleanup of
which would be washed to the TMS in
For conservatism, the introduction of a spill volume to the TMS has been estimated for each
cell in Section 6.3, below, assuming the entire mass of a spill has been discharged to one cell,
ether Cell 3 or Cell 4A. -Introduction of REs into the tailings system was evaluated in the SERPs of April 2021 and
January 2022 . The only additional means for introduction of additional REs into the TMS is
the cleanup of a spill of a product container of product.
Potential worst-case spills are quantified in Section 6.3, below. These metals are already
present in the TMS as residuals from 42 years of processing of conventional ores and alternate
feeds from which they were not recovered as a product, but disposed as a process residual
(tailings).
Numerous studies, including those cited in the SERPs of April 2021 and January 2022
(e.g.,Famsworth and Hymas, 1989), demonstrate that both polyethylene and PVC are resistant
to metal-metal carbonates, metal salts, and other inorganic compounds in all proportions
even in the presence of fluorides, phosphate ions, sulfuric acid and elevated temperatures.
It can be concluded that both the PVC and HDPE liners will have suitable resistivity to the
minute concentrations of RE compounds that might reach the TMS from cleanup of a spill.
Each of the chemicals or classes of chemicals proposed for use in the proposed process, which
could reach the TMS is already present in the tailings system from historic operations.
The following table summarizes the status of each chemical considered .
12.14.2022 Technical Memorandum Pg.13
Chemical Status --are already present in the tailings
from historic use in the laboratory.
Rare earths are already present in tailings from
previous REU processing. Uranium and heavy
RE residuals or spills metals, which are more mobile than any of the
rare earths based on their lower soil partition
coefficient KD values, are already monitored
in groundwater.
6.3 Worst Case Spill Results and CERCLA/SARA Title II Section 302 Reportable
Quantities (RQs) -If a full were spilled and washed to either Cell 3 or Cell 4A,
the resulting concentration o in either cell would be immeasurably small compared
to the mass of any tailing cell, approximately:
As discussed above, -would not exist in the tailings environment as unreacted
chemical. It would immediately react with and precipitate with metals in tailings and be present
only in insoluble, immobile, metal -forms.
Lithologic log s forthe Mill typically show that very shallow soils at the Mill react moderately
to strong ly with dilute .; and deeper soils that presumably represent mainly weathered
Mancos Shale, react strongly to very strongly with dilut •. If-were to be spilled
directly on Mill soil the reactivity of the soils to dilute suggests relatively large calcium
carbonate contents . -would react with calcium carbonate in soil to form insoluble
preci.pitate,just as it would form metal-precipitates in tailings.
Even if-were to be spilled directly on soil without calcium present, it would be
rapidly biodegraded in soil ultimately into CO2, H2 and H20, with an environmental lifetime
less than a few hours, even at full strength. It would have virtually no environmental effect
even it was not remediated.
12.14.2022 Technical Memorandum Pg.14
However, all spills are subject to the Mill's spill response and spill documentation procedures.
As mentioned in Section 7. I, below, -in soils is being evaluated for its potential to
actually retard the environmental mobility of heavy metals and other contaminants. -A product spill o-would likewise be immeasurably small compared to the mass of
any tailing cell. The published bulk density of a heavier
Assuming a spill of a full 55-gallon drum of dry powder
density with no beadspace would yiel . For conservatis m, this evaluation uses
1,000 lbs./drum, as follows.
Cell 3
Cell 4A
1,000 lbs. (0.5 tons) /2.6 million tons= 0.000019%
1,000 lbs. (0.5 tons) /700,000 tons= 0.000071 %
The above values are worst-case overestimates. As shown below, neither -nor the
-product have any CERCLA reportable quantities ("RQ's") for a spill.
Additive or
Product -
Worst Case Spill
6.4 Reclamation and Surety Considerations
CERCLA RQ or Other
Reporting Requirement --
The proposed Change will require new equipment and potentially an increase to the Mill
building footprint. However, any new buildings would be constructed on previously-disturbed
land . To the extent possible, at the termination of the RE program or at the end of Mill life,
equipment will either be decontaminated for transport for offsite sale or will be disposed in a
designated reclamation cell consistent with the Mill's approved Reclamation Plan. The
reclamation volume and surety estimate will be reviewed in Spring 2023 to confirm it
accommodates the volume of additional equipment associated with the RE process, and any
required adjustments to the surety will be made at that time.
12.14.2022 Technical Memorandum Pg.15
The Mill currently assumes that the -which will not be in contact with any radioactive
materials, will be decontaminated for sale and off-site transport. If for some reason it were to
be disposed in the TMS, the Reclamation Surety estimate would be modified to address its
volume and disposal cost.
6.5 Drainage and Surface Water
As mentioned above, spills of-or product materials wou ld drain or be washed to the
Mill's TMS . There are no RQs for off-site releases of-or
7.0 Consistency with License, Permits, Plans and SOPs.
7.1 Groundwater Discharge Permit ("GWDP")
The products from the proposed process are all inorganic compounds except -As
mentioned above, they could only reach the TMS via a spill. Each of the inorganic compounds
is represented by an indicator chemical or cation that is monitored under the GWDP as
discussed in the SERPS of April 2021 and January 2022.
Each of the reagents, diluents and other chemicals used in the process have previously been
evaluated in the SERPs of April 2021 and January 2022, except-.
·s the single new chemical proposed for use in the process. In nonnal operations,
would be consumed by reaction with the stream and would be
Unreacted would be
discharged to tailings, but would reci itate immediately in the tailings, fonning insoluble
As discussed above, i-reached the soil environment at the Mill it would react with
calcium carbonate in Mill soil to form insoluble calcium -• just as it would
fonn in tailings. Even if-were to be spilled or reach soils
without calcium present, it would be rapidly biodegraded in soil ultimately into CO2, H2 and
H2O, with an environmental lifetime less than a few hours, even at full strength. In either case,
it would not exist long enough in the soil environment to reach groundwater. As a result, soil
water partition coefficients, l<d, for-in alkaline or calciferous soils are not published.
12.14.2022 Technical Memorandum Pg.16
The Utah DWMRC December 1, 2004 Statement of Basis for the Mill's GWDP addressed
which volatile organic compounds should be considered as monitoring parameters under the
GWDP. After reviewing the historic data for chemical constituents known to be present in the
Mill's TMS based on tailings analytical and historic process information, DWMRC selected a
limited list of classes of volatile organic compounds ("VOCs") known to be present in tailings,
which would be required to be monitored in groundwater, specifically two ketones, chlorinated
VOCs, tetrahydrofuran, naphthalene, and BTEX compounds . DWMRC defended their
selection of this list in order to streamline the agency's monitoring by focusing on parameters
with known environmental persistence and very low Ki values in the literature, that is,
parameters that are expected to be more mobile than, and can be expected to be indicators for,
other species known to be present in the Mill's TMS. As discussed above, -has very
limited environmental lifetime, and soil reactivity high enough that K,i values have not been
published.
At the conclusion of RE operations or the end of Mill life, any unused-would either
be sold or potentially disposed in the TMS.
If afull
Cell 3
Cell 4A
solution was disposed in Cell 3 or Cell 4A, the resulting
in either cell would be immeasur ably sm a ll com pared to the mass
Based on the m aximum so lubil ity of-in water, appro ximately:
1,000 lbs. (0.5 ton) /2.6 million tons= 0.000039% or 0.39 mg/kg
1,000 lbs. (0.5 ton)/700,000 tons= 0.000071% or 0.71 mg/kg
In either case,just as with exce ss -d is charged from the process, any unused disposed
-would reac t and precipitate as in soluble metal -
No amendment of the GWDP will be required.
7.2 Air Approval Order ("AAO")
As discussed in Section 6.1, any required revisions to the AAO will be evaluated following
receipt of..ilJiesign information and selection of an appropriate equipment type, and are
not the subject of this assessment.
7 .3 Other Permits, Plans and SOPs
Based on the discussion above , the following documents may require amendments or revisions
to address the proposed process:
• Spill Prevention, Control and Countermeasures ("SPCC") Plan tables,
12.14.2022 Techn ical Memorandum
• Stonnwater Best Management Practices Plan ("SWBMPP"),
• SOPs,
• Emergency Response Plan ("ERP"),
• Tailings Capacity Evaluation,
• Surety Estimate,
• SOS books throughout the Mill.
All needed items are listed in detail in the Action Item list in Section 10.0 of this
memorandum.
8.0 Compliance with Other Regulations
8.1 Resource Conservation and Recovery Act (RCRA)
Pg.17
RCRA regulates the treatment, storage and disposal of hazardous materials. -is not
associated with any RCRA hazardous waste listings. are not associated with
any RCRA hazardous waste listings.
8.2 Toxic Substances Control Act (TSCA)
All chemicals identified for the proposed process have active status on the TSCA Chemical
Substances Inventory, that is, they are approved for sale, use and transport. Each chemical is
identified in the attached Technical and Regulatory Review.
8.3 Emergency Preparedness and Community Right-to-Know (EPCRA) Section 313
Toxic Release Inventory (TRI) Reporting
Industries under SIC Code I 094, which include uranium, thorium and radium extraction and
recovery, are exempt from reporting under EPCRA Section 313.
8.4 OSHA Hazard Communication Standards (HCS)
The Occupational Safety and Health Administration ("OSHA") hazard communication
standards ("HCS") in 29 CFR 1910 .1200, as accepted by MSHA, require that the Mill prepare
an SOS for the product, . The Mill will also need to update all
copies of the SDS binders to include
9.0 Sustainability Objectives
The proposed Change represents an inherently sustainable opportunity as detailed below .
12.14.2022 Technical Memorandum Pg.18
First, the ongoing recovery of valuable REs by the processes and equipment currently in place
at the Mill actually reduces the consumption of non-renewable resources. The Mill recovers
RE products, such as the currently produced mixed RE _, from natural uranium
monazite ore feeds, that are received at the Mill for the recovery of uranium product.
Recovering of secondary products, such as REs, from the same ore source at the Mill does not
require the excavation of new or expanded mining operations to provide the feedstock.
The alternative to the proposed Change, that is, continuing the current method
production, would require the Mill to continue producing REs as mixed RE
RE urrently must be acka ed and shipped internationally to the
The facility performs the additional processing steps to
the and ultimately produce -
-The must be repackaged for a second round of shipment to the customer
facilities in the US or elsewhere. The Change would allow the Mill to separate the REs at the
~itate an -product at the Mill, and ultimately, produce a marketable
11111111111111 product at the Mill. The Change would therefore allow the Mill to:
• Eliminate the RE _,roduction with associated consumption of chemicals and
energy,
• Eliminate one set of packaging steps with associated consumption of packaging
materials,
• Eliminate shipping of RE , therefore eliminating the consumption
of fuel and generation of greenhouse gases ("GHGs") associated with international
shipping, and
• Eliminate shipping of product from -to US customers, allowing direct shipping
from the Mill to US customers with overall reduction of fuel use and GHG generation.
The Mill evaluated the proposed Changes in comparison to EFRI's specific sustainability
objectives, including the following:
• Will the Change be implemented with the least hazardous or non-hazardous chemicals?
Yes. The Mill evaluated a number of precipitation agents for preparation of_
is both the most effective and least hazardous material that
pplication, as discussed in Section 5.1.
• Did the design of the change attempt to minimize the footprint of environmental
disturbances?
Yes. The Mill developed an equipment layout that reuses equipment to the extent
possible, minimizes the need to construct pads or foundations outside the existing built
areas, and does not require any construction outside the Mill's existing disturbed area.
12.14.2022 Technical Memo ra ndum Pg.19
10.0 Conclusions and Recommendations
Based on the foregoing information, it can be concluded that:
I . The proposed change will not produce any environmental impacts outside the
envelope of those already addressed in the approved Environmental Reports
("ERs") for the Mill. No license amendment is required for the proposed change.
2 . The proposed Change generates no additional environmental emissions. Once the
type of-equipment is specified, it will be determined whether the Change
may produce fewer emissions than the previously-approved vanadium -
which will be replaced in the AAO.
3 . All chemicals or material to be discharged to the TMS under the proposed change
are already present in the tailings system and/or well represented by other analytes
already monitored in the tailing solutions and under the GWDP., The proposed
change will not require any modification of the Mill's GWDP.
4. No RCRA requirements apply to the proposed change .
5. All proposed materials are acceptable under TSCA.
6. As listed above, revisions will be required to certain documentation referred to in
the RML application as itemized in Section 10.0, below.
7. The AAO revision, as required, will be addressed separately.
8. The proposed Change is consistent with the Mill's sustainability objectives.
11.0 Action Items
Based on the above evaluation, the following action items need to be implemented.
• Update the SPCC tables.
• Update the SWBMPP.
• Update the SOPs books to include appropriate additional SOPs.
• Confirm the SOPs have been reviewed for proper PPE.
12.14.2022 Technical Memo ra ndum Pg.20
• Update the ERP.
• Update the Tailings Capacity Evaluation.
• Confirm or update the Surety estimate
• Add SDSs for each of the new chemicals to be used or produced in the RE process,
specifically:
• is to be packaged and sold as an interim product, prepare an SDS for
this product.
12.14.2022 Techn ical Memorandum Pg.21
11.0 References
Dames & Moore Environmental Report White Mesa Uranium Mill San Juan County, Utah
January 30, 1978
Farnsworth, R.K. and C.R. Hymas, August 1989 The Compatibility of Various Polymeric Liner
and Pipe Materials with Simulated Double-Shell Slurry Feed at 900C. Pacific Northwest
Laboratory, US. Department of Energy , Battelle Memorial Institute
Haxo, H.E., Jr., Robert S. Haxo, Maney A. Nelson, Paul 0. Haxo, Richard M. White, and Suren
Dakessian Liner Materials Exposed to Hazardous and Toxic Wastes US EPA Hazardous Waste
Engineering Research Laboratory EPA-600/S2-94-169 January 1985
Impact Environmental Consultants, Inc. Amendment to Final Environmental Statement US
Nuclear Regulatory Commission White Mesa Uranium Project May 1981
Lichty, D. M . Journal of Physical Chemistry 1907, 11, 3 , 225-272 accessed at
hnps ://doi .org/10 .102 1/j l 50 08 4a 003 March J, 1907
McBride, Murray, Kelch, Sabrina, Michael Schmidt, et. al. Lead Solubility and Mineral
Structures ofCoprecipitated Lead/Calcium Oxalates American Chemical Society Publications,
Environmental Science & Technology Nov. 12, 2019
National Institute of Occupational Safety and Health Online NIOSH Pocket Guide to Chemical
Hazards https ://www.c dc.go /nio sh/np g/se arch.html accessed November 2022
OSHA Hazard Communication Standards as stated in 29 CFR 1900.1200
Union Oil Company US Patent 4497785A Production of Rare Earth Compounds 1983
US EPA EPCRA Section 313 Chemical List for Reporting Year 2018, Table II 2019-03
accessed at h lt ps://ww w.ep a .gov/sites/p roduction/files/2019-
03/documents/ry 2018 tri chemical list.pdf 9/26/19
US EPA List of Lists Consolidated List of Chemicals Subject to EPCRA, CERCLA and CAA 550-
B-19-03 June 2019
US EPA Toxic Substances Control Act Chemical Inventory Chemical Substance Inventory
February 2019
US EPA, 1988. Risk Reduction Engineering Laboratory . Lining of Waste Containment and
Other Impoundment Facilities EPN600/2-88/052 September 1988
12.14.2022 Technical Memorandum Pg.22
US Nuclear Regulatory Commission Environmental Assessment for Renewal of Source
Material License SUA-1358 Energy Fuels Nuclear, Inc. White Mesa Uranium Mill March 14,
1997
Attachments
• Attachment 1 Technical and Regulatory Review
• Attachment 2 Safety Data Sheets
Ir
12.14.2022 Technical Memorandum Pg.23
ACGIH
AO
CAA
CCD
CDC
CERCLA
EFRI
EPCRA
ER
GWDP • HCS
HDPE
NIOSH
OSHA
PEL
PPE
PVC
RCRA
REE
REU
RML
RQ
SARA
sos
SERP
SOP
LIST OF ACRONYMS
American Conference of Government Industrial Hygienists
Air Approval Order
Clean Air Act
Counter Current Decantation
Centers for Disease Control
Comprehensive Environmental Restoration, Compensation and Liability Act
("Superfund")
Energy Fuels Resources (USA) Inc.
Emergency Preparedness and Community Right-to-Know Act
Environmental Report
Groundwater Discharge Permit
Hazard Communication Standard
High density polyethylene
National Institute for Occupational Safety and Health
Occupational Safety and Health Administration
Permissible Exposure Limit
Personnel Protective Equipment
Polyvinyl Chloride
Resource Conservation and Recovery Act
Rare Earth Elements
Rare Earth Bearing Uranium Ore
Radioactive Material License
Reportable Quantity
Superfund Amendments and Reauthorization Act
Safety Data Sheet
Safety Environmental Review Panel
Standard Operating Procedure
12.14.2022 Technical Memorandum
SPCC
STEL
SWBMPP
sx
TLV
TMS
TRI
TSCA
TWA
Spill Prevention, Control, and Countermeasure Plan
Short-Term Exposure Limit
Storm Water Best Management Practices Plan
Solvent Extraction
Threshold Limit Value
Tailings Management System
Toxic Release Inventory
Toxic Substances Control Act
Time-Weighted Average
Pg.24
ATTACHMENT 1
TECHNICAL AND REGULATORY REVIEW
Chemical and Regulatory Summary
Chemical Composition
Physical State
Storage Location, Method, Quantity
Where Introduced in Process, Quantity
Used
Properties
Hazards
Worst Case S
Emissions
Compatibility with Tailings Management
System Solutions
Compatibility with Tailings Management
System Liners
Compliance with RML, License Application
RCRA/TSCA
SARA Title II Section 302 R
Section 313 TRI Reporting
Other Regulatory Considerations
References for-
No flashpoint. Not flammable. Incompatible with strong acids,
bases, oxidizers.
Can form an explosive dust mixture with air. Keep surfaces
free of dust.
Will be added to the circuit and present in the circuit in solution
only. Mist will be scrubbed by wet demister. No emissions to
stacks.
Will react with dissolved metals to form
re will be no residual in solution.
te as -and will not be accumulated or
tact with the liners.
cation • cipates other similar materials will be
osed in taili (from laboratory).
Not a RCRA hazardous waste. Not regulated under TSCA.
No RQ in Consolidated List of Lists
Not subject to TRI reporting. Uranium-vanadium-radium
industries, SIC code I 094, are exempt from TRI reporting. No
listin s in Consolidated List of Lists.
None.
US EPA EPCRA Section 313 Chemical List for Reporting Year 2018, Table II 2019-03 accessed at
https://www.epa.gov/sites/production/files/2019 -03/documents/ry 2018 tri chemical list.pdf 4/6/2021
US EPA List of Lists Consolidated List of Chemicals Subject to EPCRA, CERCLA and CAA 550-B-19-03 June 2019
US EPA Toxic Substances Control Act Chemical Inventory Chemical Substance Inventory February 2019
Chemical and Regulatory Summary
Chemical Com osition
Physical State
Storage Location, Method, Quantity
Where Introduced in Process, Quantity
Used
Properties
Hazards
Worst Case S
Emissions
Compatibility with Tailings Management
System Solutions
Compatibility with Tailings Management
System Liners
Compliance with RML and License
A lication
Compliance with GWDP
Compliance with AO
RCRA/TSCA
SARA Title Il Section 302 RQ
Section 313 TRI Reporting
Other Regulatory Considerations
ntainers.
One drum , 1,000 lbs.
No stack emissions associated with process through-
intennediate . to be determined
for Air A roval Order, based on e ui ment selected.
Compatible with solutions in all proportions.
Compatible with liners in all proportions .
-have been present in previously processed and
a roved alternate feeds and some natural ores.
Previous SERPs determined REs do not require amendment to
GWDP.
No dust or fugi tive emission thro ugh -pro duction step .
Amen dment to AAO will be requir ed fo r-when
selected.
NoCERCLARQ
Uranium-vanadium-radium industries, SIC code 1094, are
exempt from TRI reporting. No TRI reporting requirements
associated with rare earths.
SDSs need to be developed for ~roduct, and potentially
for roduct ifit is acka ed and sold in the interim . .__ _________________ _,___,
References for
CDC Center for Disease Control NIOSH National Institute for Occupational Safety and Health accessed at
https://www .cdc.gov/niosh/npg/npgd0492.htm I 11/15/22
Union Oil Company US Patent 4497785A Production of Rare Earth Compounds 1983
USEPA EPCRA Section 313 Chemical List for Reporting Year 2018, Table II 2019-03 accessed at
https://www.epa_gov /sites/production/fi les/20 19-03/documents/ry 2018 tri chemica l lis t.pdf 11/15/22
US EPA List of Lists Consolidated List of Chemicals Subject to EPCRA, CERCLA and CAA 550-B-19-03 June 2019
US EPA Toxic Substances Control Act Chemical Inventory Chemical Substance Inventory February 2019
ATTACHMENT 2
SAFETY DATA SHEETS
3
----
-
---.. -------
----"-------
;;: .-------------
.________ ---'---___ ___.
--I •L-----__._I _
-.,.
-
-
~---~----------'
;-----'------'
LD50 Dermal
•1 ACGIH I -I aj
-·----------
~~------'------'
-.---------------1 -, I • I I I -1•1 ~
·----
I
-----
7
-
-
I I
Safety Data Sheet
------~------'
I --
Safety Data Sheet
---
Safeo/ Data Sheet
-
-
-
Safety Data Sheet
-
Safety Data Sheet
--
Other information
ATTACHMENT 2
-SOP
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 11
Rare Earth
Preface
Communication
Date : 03-23 Revision: EFR-1
Page I of3
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. lnfonnation is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written fonn almost daily. As above, if you do not understand
any instruction, ask your supervisor.
HeaJth and Safety
Hazards:
• Acidic solutions
• Elevated temperatures
• Elevated work areas
• Pressurized process lines
• Pumps, if hose pumps are restricted on either the intake or discharge the hose will fail
spraying solution.
• Pumps, pumps requiring gland seal water if the gland seal water is not turned on the pump
will fail. If the pump is off and the gland seal water is left on it will dilute process solutions
and cause problems in the process.
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 11 -
Personal Protective Equipment (PPE)
Date : 03-23 Revision : EFR-1
Page 2 of3
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc . are required to be removed while working.
2. Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor .
3. Each employee is responsible for the condition of their protective equipment. Report any defects ,
etc., to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c . Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work Permit
5. The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6. It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators .
IMPORTANT: This pump is a hose (peristaltic) pump. This type of pump builds high pressures. The feed
and discharge line and valves must be open before the pump is turned on or the discharge line or pump will
fail.
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 11 -
-
----
It is important
to ensure that any samples taken are representative of the tank's contents. This means using clean sampling
equipment and purging sample ports before sampling.
Op erating In s tructions
I . Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: temperature, feed flow rate, and tank levels.
2.
I
I
I
I
I
I
I
Start-up Procedures
I
I
I
I
Shutdown Procedures
I
I
Emergency Shut-down Procedures
I
I
I
White Mesa Mill-Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 -
Communication
Date: 03-23 Revision: EFR-1
Page 1 of4
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safety
Hazards:
•
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• Stairs and elevated work areas
•
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White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 -
Personal Protective Equipment (PPE)
Date: 03-23 Revision: EFR-1
Page 2 of 4
l. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2. Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3. Each employee is responsible for the condition of their protective equipment. Report any defects,
etc., to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work
Permit
5. The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6. It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly. Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
Equipment and Important Information
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 --
-
I
I
-Sampling
Sampling of the various solutions in this circuit is required on a regular basis. It is important to ensure that
any sample taken is representative of the tank's contents. This means that tanks should be well mixed,
sampling equipment should be clean, and any sample ports purged before collecting the sample.
Operating Instructions
l . Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: flow rates, tank levels, solution concentrations.
2. Perform a pre-work exam of the Inspect all lines and tanks for any leaks .
Check all walkways and travel areas for general cleanliness. Ensure all process controls, readouts
and safety showers are functioning properly.
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 12 -
Date: 03-23 Revision: EFR-1
Page 4 of4
3. Check the process parameter targets. Remember that process parameters may have changed since
the previous shift.
4. Check and record all flow rates and tanks levels on the Operator Sheet.
5. Ensure that the bench pH probe is calibrated and functional.
6.
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8. Adjust the recycle valves to achieve the specified organic to aqueous ratio in the mixers.
9. Sample the circuit as directed by the Metallurgical Departmen t.
Start-up Procedures
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Shutdown Procedures
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Emergencv Shutdown Procedures
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White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 -
Communication
Date: 03-23 Revision: EFR-1
Page 1 of4
To be successful as an operator in achieving the desired results in your circuit, good communication
between you, the metallurgical department, and your supervisor should exist. Information is given to the
operator verbally, written and by test results. As an operator, if you do not understand any information
given, you have the responsibility to ask questions until you do understand.
White Board. In a few locations in the mill, critical information about mill operations will be written on
White Boards. Information such as circuit parameters, required changes in circuit operations, or special
instructions about maintenance.
Circuit Sheets. Circuit sheets will have operating parameters on them along with sampling times for the
circuit. They will also have a place for you to pass along written information about your circuit.
Verbal. One of the most important times of your shift is at Shift Change. You have the responsibility to
pass along information about your circuit to the person relieving you. You will be given verbal instructions
from your supervisor or metallurgical department which you need to be sure you understand.
Written. Instructions will be handed out in written form almost daily. As above, if you do not understand
any instruction, ask your supervisor.
Health and Safety
Hazards:
I
I
• Stairs and elevated work areas
I
I
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 -
Personal Protective E quipment (PPE)
Date: 03-23 Revision: EFR-1
Page2 of4
1. Minimum PPE requirements at White Mesa Mill while in the restricted area is hard hats, safety
glasses, and steel toed shoes. No ragged or lose fitting clothing is allowed. Body jewelry, rings,
wrist watches, etc. are required to be removed while working.
2. Other personal protective equipment includes, but is not limited to: ear plugs, respirators, wet suits,
welding helmets, goggles, gloves, and rubber boots. Face shields and safety belts are required in
designated areas and/or while performing certain jobs. If in doubt, contact your supervisor.
3. Each employee is responsible for the condition of their protective equipment. Report any defects ,
etc., to your supervisor.
4. The following equipment is required when working on pipelines or vessels containing acids or
caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the Safe Work
Permit
5. The use of a safety belt and properly adjusted lifeline is required where there is a danger of falling
four feet or more, except while performing work under the ladder and scaffold section of this
manual. This rule applies when going beyond the handrails of walkways on top of any tanks in the
mill area.
6. It is a condition of employment that all personnel who may be required to wear a respirator must
be clean shaven to assure that the respirator fits properly . Personnel will be fully trained consistent
with the Mill's Respiratory Protection SOP, prior to using respirators.
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 --
-
I
I
-Sampling
Sampling of the various solutions in this circuit is required on a regular basis. It is important to ensure that
any sample taken is representative of the tank's contents. This means that tanks should be well mixed,
sampling equipment should be clean, and any sample ports purged before collecting the sample.
Operating Instructions
1. Conduct a proper Shift Change with the person you are relieving. Get information about all circuit
parameters, including, but not limited to: flow rates, tank levels, solution concentrations.
2. Perform a pre-work exam of the Inspect all lines and tanks for any leaks.
Check all walkways and travel areas for general cleanliness. Ensure all process controls, readouts
and safety showers are functioning properly.
White Mesa Mill -Uranium Bearing Rare Earth Ore Operating
Procedures
Book 15 Section 13 -
Date: 03-23 Revision: EFR-1
Page 4 of4
3. Check the process parameter targets. Remember that process parameters may have changed since
the previous shift.
4. Check and record all flow rates and tanks levels on the Operator Sheet.
5. Ensure that the bench pH probe is calibrated and functional.
6.
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I I -the circuit as directed by the Metallurgical Department.
10.
Start-up Procedures
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Shutdown Procedures
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Em.er encv Shutdown
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