DRC-2014-007324 - 0901a068804cfbb3

ENERGYFUELS
DRC-2014-007324
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
December 19, 2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: Response to Utah Division of Radiation Control ("DRC") December 4, 2014 Alternate
Feed Inspection at the White Mesa Mill, and teleconference of December 10, 2014
between DRC and Energy Fuels Resources (USA) Inc. ("EFRI"), regarding storage of
Fan Steel Feed Materials, Radioactive Materials License ("RML") 1900479
Dear Mr. Lundberg:
This letter responds to the above referenced teleconference of December 10, 2014, regarding
the DRC alternate feed inspection conducted at the White Mesa Mill (the "Mill") on December
4, 2014.
The DRC noted during the December 4, 2014 inspection, that the FMRI material staged on the
Ore Storage Pad, was covered with clean soil prior to processing. EFRI placed the clean soil
cover as a dust control measure during storage. DRC noted that EFRI's actions in using a clean
soil cover were adequate and appropriate and provided sufficient dust mitigation. However,
DRC noted that in the RML amendment application, EFRI planned to keep the FMRI material in
the shipping bags until the material was readied for processing. The RML amendment
application stated that the shipping bags were the planned dust mitigation measure.
EFRI added the clean soil cover as an added dust mitigation measure when it was noted during
weekly inspections that the shipping bags were not sturdy enough for long term storage. The
shipping bags began to show wear and began tearing a few months after delivery. To provide
continuous dust mitigation, EFRI added the clean soil cover.
During the December 10, 2014 teleconference, DRC requested that EFRI provide documentation
of the change in dust mitigation strategy. This letter serves as the documentation of the change
in dust mitigation methods that are currently employed for the FMRI materials housed at the
Mill.
Letter to Rusty Lundberg
December 19,2014
Page 2 of 2
As previously noted, all ores or feeds are inspected weekly as required by the DRC-approved
Discharge Minimization Technology Plan ("DMT"). Any inconsistencies in the dust
minimization for the FMRI material will be addressed as a result of the weekly inspections.
Further, any new FMRI materials received at the Mill will be subject to the same dust
minimization strategy that is currently used. The FMRI material will be maintained in the
shipping bags, as long as the shipping bags provide adequate dust minimization and are
maintaining their integrity. Should the shipping bags show signs of wear or disintegration, the
material from the worn or broken bags will be segregated, then covered with clean soil as the
dust minimization and control. Soil cover will be placed within 2 weeks of the inspection noting
shipping bag damage.
As previously noted, the soil cover is sufficiently protective and provides adequate dust
minimization and this letter serves as the documentation of the change.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Harold R. Roberts
David E. Turk
Dan Hillsten
Scott Bakken
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