DRC-2014-007365 - 0901a068804d2d16

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R. HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
SPENCER J. COX
Lieutenant Governor
December 29, 2014 DRC-2014-007365
Kathy Weinel
Quality Assurance Manager
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject: Compliance—Radioactive Material License No. UT1900479
2014 Radiation Protection Inspection, Module RADMOD-Alternate Feed-2014
Dear Ms. Weinel:
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility in Blanding, UT
on December 4, 2014 by a representative of the Division of Radiation Control (DRC), Utah Department of
Environmental Quality.
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Materials License Number UT 1900479. The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector.
The activities and practices reviewed during the inspection with respect to the management of Alternate
Feed Materials were found to be in compliance with relevant requirements.
Additionally, this acknowledges the receipt of your letter dated December 19, 2014. The DRC concurs
with the manner in which the FMRI/Fan Steel alternate feed material is to be stored.
The inspection is considered closed. A copy of the Inspection Report is enclosed.
If you have any question, please contact Boyd Imai at [phone].
Sincerely,
Rusty Lundberg, Director
RL/BMI:bi
Enclosure
cc/enc: David Turk, Energy Fuels Resources (USA), Blanding, UT
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deg.utah.gov
Printed on 100% recycled paper
INSPECTION REPORT
Inspection Module: RADMOD-AF-2 014: Alternate Feed Management
Radioactive Material License No. UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blanding, UT
Inspection Date(s): December 4, 2014
Inspector: Boyd Imai, Utah Division of Radiation Control (DRC)
Personnel Contacted: Harold Roberts, Terry Slade, David Turk, Kathy Weinel (Energy Fuels
Resources)
Consulted With: Phil Goble, Ryan Johnson, Russ Topham (Utah Division of Radiation
Control)
Inspection Summary
The inspection was opened on December 4, 2014 with a meeting with D. Turk.
Areas/Topics inspected included:
• Alternate Feed Material Inventory
• Maximum Quantity of Feed Material Stored on the Mill Site
• Tailings Cell Capacity
• FMRI, Muskogee Facility (Fan Steel) Alternate Feed Material Management
• Dawn Mining Alternate Feed Material Management
• Visible Dust Assessment
The inspector held a closeout meeting on December 4, 2014 with D. Turk of Energy Fuels
Resources to review the inspection activities, observations, and conclusions.
Findings
One questionable practice was observed during the inspection. There was some uncertainty
regarding the appropriateness of the manner in which the FMRI/Fan Steel feedstock was being
stored.
Inspection Items
Alternate Feed Material Inventory
D. Turk conducted a tour of the feed materials stored at the mill site. Materials stored at the site
include:
• Cabot Performance Materials which is stored on the ore pad in a pile with a 6"-8" soil cover
• FMRI/Fan Steel feedstock where material received earlier is stored on the ore pad in a pile
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with an approximately one foot soil cover. More recently received material is stored
adjacent to the pile but are stored in the synthetic sacks/bags in which it was shipped.
Material continues to be received and stored in the synthetic bags.
• Dawn Mining Uranium Material is stored on a concrete pad in multi-layered synthetic sacks.
• Polydrums overpacked in yellow outer polydrums contain material from Cameco
Corporation and are stored on a concrete pad.
In addition to the above alternate feed material uranium ore continues to be stored in a pile on the
ore pad and material cleaned from the SAG mill is stored in a pile for future uranium recovery
processing.
A review of shipping documents showed that manifested material corresponded with the records
maintained at the mill site. Shipment dates, manifest numbers, material weights (both shipper and
Licensee measurements) were verified with mill records and tracking documents.
Maximum Quantity of Feed Material Stored on the Mill Site
The mill site maintains records of the quantities of feed material that is received at the site and also
the amount of product that is exported from the site. The corporate office tracks the feed material
to ensure that the quantity limits are not exceeded. A Utah Division of Radiation Control (DRC)
engineer verifies that quantities specified in the surety are not exceeded.
Tailings Cell Capacity
It was reported that as of December 13, 2013 the remaining capacity in the tailings system was
3,286,533 dry tons. With limited processing having taken place during 2014, it is concluded that
excess capadty^xlsts for-now and in the near future.
The licensee cannot receive any feed materials that would cause the facility to exceed the tailings
cell disposal capacity. Except for a very small fraction (the percentage of uranium found in feed
material, <1%), essentially all the material by volume/mass will be placed in the tailings disposal
cell. Therefore, it can easily be determined whether or not additional feed material can be accepted
for processing based on the cell capacity.
FMRI, Muskogee Facility (Fan Steel) Alternate Feed Material Management
The FMRI/Fan Steel material stored at the mill is currently made up of two "piles." One pile is
comprised of material from the first round of shipments. As described by the Licensee, the material
arrived in synthetic sacks but due to exposure to the elements the sacks began to deteriorate so the
decision was made to remove the material from the sacks and consolidate the material into a large
pile, and to prevent the material from becoming dispersed an approximately one foot earthen cover
was placed over the pile.
The second pile is being created with the second round of shipments. The plan was to duplicate the
process of removing the material from the sacks and to place over the resulting pile an earthen
cover. A shipment of sacks had just been received by the mill indicating that the second pile is not
yet completed.
A review of License Condition 10.20 and the referenced amendment request raised the concern that
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the Fan Steel material was not being stored properly. The amendment request stipulates that:
"The Uranium Material will not be unloaded from the shipping bags until just prior to being
introduced into the Mill processing circuit. Leaving the material in the shipping bags will
eliminate the need for additional dust control measures during storage."
The manner the material is stored does not conform to this requirement.
It is acknowledged that the sacks/bags are susceptible to weathering and deterioration and if left
without remedial actions could result in exposed contaminated material and a dispersal problem.
Dawn Mining Alternate Feed Material Management
License Condition 10.20.A(1) requires that:
"Dawn Mining Uranium Material stored (stockpiled) at the Mill Site longer than 14 days
shall be covered with a durable geomembrane cover resistant to damage by ultraviolet (UV)
radiation and sufficient ballast shall be place over the cover to prevent wind uplift ofthe
cover during peak wind conditions at the site."
This material has been in storage longer than 14 days. Initially, it was planned to transport the
material in bulk form thus the need for a cover to prevent the material from being dispersed. Before
the first shipment it was decided to contain the material in synthetic sacks for transport and storage.
Although this does not strictly adhere to the specifications of the license condition, the practice
satisfies the intent of the requirement as deemed by other DRC representatives. The sacks have
three inner layers of containment and will inhibit dispersal of any of the material provided the
integrity of the sacks has not been compromised. Visual inspection of the sacks verified that they
are intact and in good condition. Upon request, the Licensee provided specifications for the sacks'
synthetic outer layers which indicate a resistance to UV rays.
Visible Dust Assessment
An unusual rain storm was taking place during the day of the inspection so dust was not of concern
at that time and could not be assessed further.
Closeout Meeting
The inspector held a closeout meeting with D. Turk of Energy Fuels Resources (USA) on December
4, 2014. The observations made during the inspection were summarized during the meeting.
The storage of the FMRI/Fan Steel material was discussed. The inspector pointed out that the
manner the material was being stored was not in accordance with the commitments made in the
license and in the amendment request. The Licensee indicated that the material was being "staged
for processing." The inspector recognized the dilemma created by the specific storage requirement;
strict compliance could cause undesirable consequences with respect to release and spread of
contamination.
The inspector suggested that further discussion with the DRC management would be required to
determine the extent and severity of the irregularities regarding the material storage; therefore, the
inspection would remain open.
Post Inspection Action
Internal DRC discussions concluded that, notwithstanding the license requirements, the FMRI/Fan
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Steel material must be contained while in storage. A mutually (Licensee and DRC) agreed upon
approach to resolve the dilemma would be required.
On December 10, 2014 a conference call between the Licensee (H. Roberts, D. Turk, and K.
Weinel) and the DRC (P. Goble, B. Imai, and R. Johnson) was held to discuss the FMRI/Fan Steel
material storage issue.
It was concluded that the practice of removing the material from the sacks/bags and placing the
earthen cover over the material was an acceptable resolution to the issue; provided that once the
cover was placed it would be inspected regularly to ensure that the cover has not been compromised
in any manner during the duration of the storage. It was agreed that this resolution could be
documented in formal correspondence(s) between the Licensee and DRC and that a license
amendment would not be required.
Once the resolution is finalized the Licensee is expected to take whatever internal actions are
necessary to ensure satisfactory implementation.
On December 19, 2014 the DRC received the Licensee's letter specifying the actions to be taken
regarding the FMRI material storage and "dust mitigation strategy." With this information the
inspection will be able to be closed.
Conclusion
With the resolution of the material storage concern, and based on the items inspected, it is
concluded that the Licensee is in compliance with the management of alternate feed material.
Recommendations for the Licensee
It is recommended that the Licensee use its discretion and manage the stored FMRI/Fan Steel
material in the most efficient manner. It is not necessary to wait for the sacks/bags to fail before the
feed material is separated and covered.
Recommendation for the DRC Director
It is recommended that no enforcement action be taken at this time.
Prepared By. Boyd M. Imai December 24, 2014
(Name) ^(Signature) (Date)
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