DRC-2024-007178

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director
M E M O R A N D U M
TO: Project File C-2024-34

THROUGH: Adam Wingate, Uranium Recovery Section Manager

Ryan Johnson, PG, Health Physicist

FROM: Heather Mickelson, PE, PG

DATE: October 10, 2024

SUBJECT: October 3, 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 #UT1900479 Amendment 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.”1
10 CFR Part 40 Appendix A, Criterion 2: “To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
1 This definition amends the language given in Section 11e.(2) of the Atomic Energy Act as amended in 1954 to include ISL
facilities on the same footing as conventional uranium mills. This is done by referencing “solution extraction” in the
definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume 1, No. 10.
Fourth Quarter 2024 ISL Decommissioning Debris Disposal Inspection Report
October 10, 2024
Page 2

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, PG of the Utah Division of Waste Management and Radiation Control
(Division) observed the burial of two (2) loads of 11e.(2) byproduct material on October 3, 2024 at the
White Mesa Uranium Mill (Mill). The Mill is owned and operated by Energy Fuels Resources
(Licensee). The Division received notifications (DRC-2024-006885 and DRC-2024-006977) of the
disposal on September 19, 2024 and September 30, 2024.

Operating Procedures and Records
The Standard 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 each load are attached to this report.

11e.(2) Byproduct Material Disposal Activities and Description
Prior to October 3, 2024, the disposal pit location was determined, located by survey, and excavated in
Impoundment No. 3. The bottom of the excavation extended into the tailings sand. The 11e.(2)
byproduct material was placed near the burial pit for burial (Photo 1).

During the October 3, 2024 inspection, the Division observed the final disposal activities. The
excavation depth was surveyed (Photo 2). The 11e.(2) byproduct material was moved into the
excavation (Photo 3) and the top of the material was surveyed (Photo 4). Clean cover was then placed
over the 11e.(2) byproduct material and then compacted to further minimize void spaces (Photos 5 and
6). The vertical extent of the burial was below the top of the tailings and above the bottom liner.

The disposal activities were for two (2) loads of 11e.(2) byproduct material from Encore Alta Mesa in
Texas. The material consisted of crushable and non-crushable metal pipes, and wooden pallets.

Upon leaving the restricted area, all personnel scanned themselves and no individual had a measurable
reading.

Close Out Meeting
A preliminary inspection findings meeting was held on October 3, 2024 and observations made during
the inspection were discussed. This meeting included: Heather Mickelson, Garrin Palmer, and Tanner
Holliday. During this meeting, the Licensee committed to submitting requested information. It was
received on October 8, 2024 and the inspection was finalized on October 8, 2024.

Fourth Quarter 2024 ISL Decommissioning Debris Disposal Inspection Report
October 10, 2024
Page 3

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.

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
Impoundment 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
Fourth Quarter 2024 ISL Decommissioning Debris Disposal Inspection Report
October 10, 2024
Page 4

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-2024-006885
and DRC-2024-006977) of the disposals electronically on September 19, 2024 and September 30, 2024
with expected disposal dates associated with these notifications were October 3, 2024 and October 8,
2024, respectively. These notifications comply with RML Condition 10.5F.

As the DWMRC was already inspecting the disposal of the load on the September 19, 2024 notification,
the load on the September 30, 2024 notification was buried on October 3, 2024.

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 September 19, 2024
11e.(2) byproduct receipt notification dated and received on September 30, 2024
Document packet for Alta Mesa 11e.(2) byproduct material bearing Bill of Lading #192
Document packet for Alta Mesa 11e.(2) byproduct material bearing Bill of Lading #193
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September 19, 2024
VIA Electronic Mail (PDF) and UPS
Mr. Hansen
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Hansen,
Re: 11e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of one load by October 3rd, 2024.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4114.
Regards,
Garrin Palmer
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
September 30, 2024
VIA Electronic Mail (PDF) and UPS
Mr. Hansen
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Hansen,
Re: 11e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of one load by October 8th, 2024.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4114.
Regards,
Garrin Palmer
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com