DRC-2024-005518

M E M O R A N D U M
TO:Project File C-2024-38
THROUGH:Phil Goble, Radioactive Materials Section ManagerAdam Wingate, Uranium Recovery Section Manager
FROM:Heather Mickelson, PE, PG
DATE:May 6, 2024
SUBJECT:April 16, 2024 Inspection of the Disposal of 11e.(2) Decommissioning Debris from In Situ Leach Facilities at the White Mesa Uranium Mill. Radioactive Material License No. UT
1900479, Amendment 10.
Authority
Radioactive Materials License #UT1900479Amendment 10, Condition 10.5: “In accordance with the licensee's submittal to the NRC dated May 20, 1993, the licensee is hereby authorized to
dispose of 11e.(2) byproduct material generated at licensed in-situ recovery (ISR) [previously known as in-situ leach (ISL)] facilities as per 10 CFR 40 Appendix A, Criterion 2 and from
other uranium recovery facilities, subject to the following conditions:” (Conditions are included below in the Requirements and Compliance Determination section.)
R313-12-3 (quoting 10 CFR 40.4): “Byproduct Material means the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for
its source material content, including discrete surface wastes resulting from uranium solution extraction processes.”
10 CFR Part 40 Appendix A, Criterion 2: “To avoid proliferation of small waste disposal sites and thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction
operations, such as residues from solution evaporation or contaminated control processes, and wastes from small remote above ground extraction operations must be disposed of at existing
large mill tailings disposal sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the costs and environmental impacts of transporting
the wastes to a large disposal site, such offsite disposal is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual
surveillance obligations.”
Observations
Heather Mickelson, PE, PGof the Utah Division of Waste Management and Radiation Control (Division)observed the burialof four(7) loadsof 11e.(2) byproduct material on April 16, 2024at
the White Mesa Uranium Mill (Mill). The Mill is owned and operated by Energy Fuels Resources (Licensee). The Division receivednotices (DRC-2024-005182 and DRC-2024-005277)of the disposal
electronically onApril 3, 2024 and April 11, 2024.
Operating Procedures and Records
TheStandard Operating Procedure (SOP) PBL-10, dated August 23, 2023, governs the disposal of 11e.(2) byproduct material from ISL facilities. The Mill’s staff were most recently trained
on this SOP on January 9, 2024.
The Licensee maintains hard copies of the buried 11e.(2) material records onsite. Records are moved from the Mill’s office building to an onsite storage container within the restricted
area when file space inside the office building becomes limited. The storage area was confirmed by visual observation during this inspection.
Copies of the data packets for eachload are attached to this report.
11e.(2) Byproduct Material Disposal Activities and Description
Prior to April 16, 2024, the disposal pit location was determined, located by survey, and excavated. The bottom of the excavation extended into the tailings sand. The 11e.(2) byproduct
material was placed near the burial pitfor burial (Photos 1 and 2).
During the April 16, 2024inspection, the Division observed the final disposal activities. The excavation depth was surveyed(Photo3).The 11e.(2) byproduct material was moved into the
excavation (Photo 4) and the top of the material was surveyed (Photo 5). Cleancover was then placed over the 11e.(2) byproduct material and then compacted to further minimize void spaces
(Photos6 and 7). The vertical extent of the burial was below the top of the tailings and above the bottom liner.
Pipe segments that were approximately 10 inches in diameter and four feet in length were separated (Photo 6). It was not possible to crush these pipes with the track on the bulldozer.
These pipes were filled with sand and buried at a separate time.
The disposal activities were for6 loads of 11e.(2) byproduct material fromURI – Rosita in San Diego, Texas;South Texas Mining Venture LLP, in Hobson, Texas; and South Texas Mining Venture
LLP in La Palangana, Texas. The material consisted ofcrushed barrels and totes, wooden pallets, crushable and non-crushable metal pipes, PVC and ABS pipes, fiberglass pipes, and wiring.
Upon leaving the restricted area,all personnel scanned themselves and no individual had a measurable reading.
Close Out Meeting
A preliminary inspection findingsmeetingwas held on April 16, 2024and observations made during the inspection were discussed. This meeting included: Heather Mickelson,GarrinPalmer,
and Tanner Holliday. During this meeting, the Licensee committed to submitting requested information. It was received on May 2,2024 and the inspection was finalized on May 2, 2024.

Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition 10.5B:“All ISR contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste
other than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified by the Licensee to be full prior to disposal.
Barrels not completely full shall be filled with tailings or soil prior to disposal. ”
The activities observed and information gathered during this inspection support the conclusion that the Licensee is complying with this license condition. The licensee confirmed that
all materials were crushed by rolling over them with the bulldozer prior to being placed in the excavation. Crushable pipes were crushed as they were placed into the excavation pit
and compacted.
Radioactive Materials License #UT1900479, Condition 10.5C:“All ISR byproduct material shall be buried in Impoundment No. 3 unless prior written approval is obtained from the Director
for alternate burial locations.”
The activities observed and information gathered during this inspection supports a conclusion that the Licensee is complying with this license condition. All 11e.(2) byproduct material
was buried in Tailings Cell No. 3.
Radioactive Materials License #UT1900479, Condition 10.5D: “All disposal activities shall be documented and records thereof maintained on-site. The documentation shall include all items
required by this License.”
The activities observed and information gathered during this inspection support the conclusion that the Licensee is complying with this license condition. The Licensee maintains records
of the 11e.(2) byproduct material disposed of onsite. These records document the nature of each load of material received, where it is buried, and how it was handled, including all measures
taken to comply with all of License Condition 10.5.
Radioactive Materials License #UT1900479, Condition 10.5E:“Disposal Requirements for 11e.(2) byproduct material: the licensee shall perform byproduct material disposal activities in

accordance with the current Standard Operating Procedure (SOP) for 11e.(2) byproduct material disposal. Said plan includes the following minimum provisions:
(1) The material disposal area must be located on a tailings beach area of the conventional impoundment or on an area of the impoundment that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of the uppermost flexible membrane liner of the conventional impoundment;
(3) (Reserved)
(4) Absence of void space inside barrels disposed, including physical verification before disposal; and
(5) Detailed engineering drawings which demonstrate:
a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the impoundment.”
The activities observed and information gathered during this inspection support the conclusion that the Licensee is complying with this license condition. The Licensee met the requirement
to submit the procedure with the initial version of SOP PBL-10, and now uses Revision R-4.0, dated August 23, 2023. Revision R-4.0 addresses all of the items specified in License Condition
10.5. The original version and every subsequent revision of this procedure were submitted to the Division for review and approval prior to implementation.
Further, the Licensee is complying with the SOP, such as, minimizing void space, and placing the waste in the tailing sands with at least four feet of sands below it and at least 12
feet from the side or dike of the cell.
Radioactive Materials License #UT1900479, Condition 10.5F: “The Licensee shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal
of any 11e.(2) byproduct material in the conventional impoundments.
An annual summary of the amounts of 11e.(2) byproduct material disposed of from off-site generators shall be included in the Annual Technical Evaluation Report required in License Condition
12.2.”
The activities observed and information gathered during this inspection supports the conclusion that the Licensee is complying with this license condition. The Division received notice
(DRC-2024-005379) of the disposal electronically on April 3, 2024 and April 11, 2024. These notifications comply with the 7 days advance notice requirement.The loads listed on April
11, 2024 letter, were buried on April 16, 2024, instead of April 18, 2024. The DWRMC was already inspecting the disposal of the loads mentioned in the April 3, 2024 letter, which facilitated
a more efficient disposal process.
The annual summary submittal will be evaluated by DWMRC separately from this inspection.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements, and license conditions with respect to disposal of 11e.(2) byproduct material generated as decommissioning
debris from ISL uranium recovery facilities.
Attachments:11e.(2) Disposal Photolog
11e.(2) byproduct receipt notification dated and received on April 18, 2024
Document packets for URI, Inc. 11e.(2) byproduct material bearing Bill of Lading #24-ROS -003 and 24-ROS-004
Document packet for UEC Hobson11e.(2) byproduct material bearing Bill of Lading #HOB-148
Document packet for UEC La Palangana 11e.(2) byproduct material bearing Bill of Lading #LP-032, #LP-033, #LP-034, #LP-035