DRC-2016-011658 - 0901a0688068b9f7

State of Utah
GARY R HERBERT
Governor
Spencer .1 Cox
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T Anderson
Director
DRC- ZO\G - 0[\Qp53
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
File C-2016-36
Phil Goble, Section Manager
Russell J. Topham, P.E.
November 30, 2016
r
SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material November 11.
Radioactive Materials License UT1900479 (License) - Energy Fuels Resources (USA) Inc.
(EFR) White Mesa Mill, Blanding, Utah
On November 10, 2016, I traveled to the White Mesa Uranium Mill to perform multiple inspections,
including an inspection of in-situ leach (ISL) waste disposal operations on behalf of the Utah Division of
Waste Management and Radiation Control (DWMRC). This report pertains to the waste disposal operation
inspection and responds to a 1 le.(2) Byproduct Receipt Notification from EFR, dated October 3 1,2016.
EFR is allowed to dispose this byproduct material in Tailings Cell 3 only, which is allowed by License
Condition 10.5 of the EFR Radioactive Material License.
On October 31,2016 the DWMRC received notice that EFR would receive one load of 1 le.(2) byproduct
material, and intended to dispose of that waste in Cell 3 on August 24, 2016. One load was ultimately
received.
I checked in at the White Mesa Mill at 7:30 AM on October 11,2016, and asked to see David Turk, Site
Manager for Environmental Health and Safety. Mr. Turk assigned Garrin Palmer to oversee the disposal
operation.
At approximately 7:45 AM the crew assembled at the disposal area with the requisite equipment (a loader).
The load of waste was disposed in one excavation. The field crew used the appropriate paperwork, i.e.
Revision 3.3 of Procedure PBL-10, to guide the operation.
Material disposed consisted of piping and other debris, much of it burned beyond recognition in a fire,
along with loose soil from the ISL plant near Mestena, Texas, shipped by Energy Fuels Resources Alta
Mesa, bearing Shipper Numbers 163.
The bill of lading for this load appears in the attachments to this report.
Mr. Palmer, with assistance from Tanner Holiday, surveyed the level at the bottom of the excavation prior
to waste placement. Using a front-end loader, the crew placed the waste in the excavations and tamped it
195 North 1950 West • Sail Lake Citv, UT
Mailing Address PO Box 144880 • Sail Lake City, LIT 84114-4880
Telephone [phone] • Fax [phone] • T D D. [phone]
ummi.rteq.utah gov
Printed on 100% recycled paper
C-2015-54
Memorandum: Inspection of November 11,2016
Page 2
down. Mr. Palmer then surveyed the elevation of the top of the waste, and the crew filled the excavation to
the top with soil. As Photos 6 through 8 from the photo log show, the excavation was only filled on one
side and covered, leaving the remaining portion of the hole open for receipt of a future load.
The crew wheel-walked the cover soil to provide compaction.
EFR appears compliant with Part I0.5.E.(2) of the RML with respect to the elevation of burial. It appeared
that all provisions of the approved disposal SOP were followed during placement and burial of the bulk
waste.
Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial
operation.
Recommendation: I recommend closing out the inspection of August 24, 2016.
I discussed the inspection with Logan Shumway, the Mill Manager, prior to departing.
Attachments: Receipt Notification dated October 3 1,2016, Bill of Lading and Disposal Documentation for
the load disposed on November 1 1,2016, photos of the disposal operation.
c C , Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
Div of Waste Management
and Radiation Control
October 31,2016
VIA Electronic Mail (PDF) and UPS
Mr. Scott Anderson
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. Anderson,
Re: 1 le.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT 1900479 condition 10.5.L, 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 of 1 le.(2) byproduct material by November
11,2016.
If there are any questions regarding this shipment or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4113.
Regards,
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
NOV -1 2016
cc: Denver Central Files
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13
Date: November 13,
2014
Title: 1 le.(2) Byproduct Disposal
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: Lq1zSlIi&___
Name of employee receiving the load: _________
Generator of the Byproduct Material: AAcSi _______
Shipper’s Manifest or Bill of Lading number: 1^3 _____________
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
LoV 3‘ ilil_____________________________________________________________________
Description of byproduct material disposal area/activities:
.—S.ert- f.Uo.to—a-o-vA ____________
Has each drum been inspected to identify the presence of any void spaces? Ay 4
Have all drums with void spaces been filled with tailings sands or soil? yf/'/V'
Which tailings cell was the material placed in? 1 3
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
AA f or T fc ( U-^JT ftc.Lc.ck. Or. r r.yi/^Uv. UOgLi it!
Was the material segregated from any Mill material or equipment disposed of in the cell?
__________________________________________________________________________________
Was the material segregated from byproduct material from other 1SL sources disposed of in the cell?
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: 1 le.(2) Byproduct Disposal
Manifest or BOL #: 7^>
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer’s or
Environmental
Coordinator’s
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? )r <
Documentation of approval ur /WoVri &
Was the ISL material segregated from disposed Mill material and other
ISL material? y^<
Refer to plat(s) used to confinn. £eij 3 Ht.Z ^ct &
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?&
Has 4 foot of tailings sands been maintained under each disposal
area? £ <
Refer to drawings used to confirm ^//3 &
Is the bottom of each disposal area at least 12 feet from th£ sides or
dikes of the tailings cell? ^
Refer to drawings used to confirm. Se // 3 $s
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
M.
How was this confinned (e.g., survey or review)
3?
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
_Ui±-
Were void spaces filled with tailings?
____________________________________________________________________________________
Was the shipment properly covered?
Vt->. S>C ^ A-tjQU-d ,__________
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13
Date: November 13,
2014
Title: 1 le.(2) B>product Disposal
Manifest or BOL #: 1 6> 3
Are additional settlement monitors required to be placed for this generator?
...................A/A_________________________________________________________________
If required, where were settlement markers were placed?
______^zA___________________________________
Radiological receipt survey measurements:
PT-D-^)_________p.OZ sip-/US'
Breathing Zone:
1.
2.
Was a Breathing Zone Sample collected? Yes o
If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities^ Yesj^r No
Energy 'rue1, s Resource^ rJS.Q) Corp.
Wh its Me 5 a Mill
64E5 3. Highway 131
Blanding UT 84551
Tr'a.n sart i on Mo.
5£91 0
V e h 5. c l e I D ;
Trailer ID:
Account ID:
Ord e r ID:
Owner ID:
Material ID
D e s t i n. ID:
Date Time Scale
In: .1.0/S8/S01& 13:37 1
Out: 10/2Q/8016 14:03 1
T 4
Gr o s s :79160 ] b (M)
MESTENA AL MESlEMft ALTA PROJECT Tar e :43240 lb
Net; 35920 lb
i 1 (e ) £ Mat 11 I e > S Mac er 1 a 1 Rsc& i pt-
BLAND I IMG
Comments: COMlPlINER GFI..U 00148
Charge by U!eight
5 £3 10
T 4
MEGTENm hL
11(8)8 Mat
1 0 / £ 8 / 8 0 i £■ i 3 ; 3 7 ‘ i 3 i. 8 0 lb (M>
10/88/30t& 14:03 43840 lb
35980 1
0 T o t C h. y : 3Met Chy:
Generator of Byproduct material:Mestena
Controled Elevation used (Cell 3)5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5612.26
7.88
8.66 [3Bottom of trench 5602.32 18.6
Initial shot used for material 7.88 >63
Tod of material in trench 5607.37 13.55
Top of cell 3 Liner
Feet below liner
5608.5
1.13
BILL OF LADING
SHIPMENT ID# 163 SHIPMENT DATE: October 26. 2016
SHIPPER (From):
EFR ALTA MESA LLC
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Highway 191
Blanding, UT 84511
ADDRESS:
755 Co. Rd. 315 Encino, TX 78353
ADDRESS:
P. 0. Box 809, Blanding UT 84511
SHIPPER LICENSE NO.: RO5360 SHIPPER USDOT NO.:CONSIGNEE
LICENSE NO.:
UT- 1900479
CONSIGNEE TELEPHONE NO.:
[phone]
SHIPPER LICENSE NO.:SHIPPER TELEPHONE
NO.:361-568-3549
CARRIER NAME AND ADDRESS:
Greenfield Logistics, LLC
CARRIER USDOT CARRIER HAZMAT REG. NO.:
Trailer# Container# GFLU001483 Seal # Seal#
DESCRIPTION OF MATERIAL AND PACKAGING VOLUME
Cubic feet
or
QUANTITY
CLASSIFICATION
1 pkg.
RQ
UN2913, Radioactive Material, Surface Contaminated
Objects (SCO-1), non-fissile,, Class 7
Dry 11 (E).2 By-Product material.
Activity: 2.0 E6 Ba (5e-5 Cil
EMERGENCY CONTACT:
P. Lutbiger: 1-361-816-0150
35,000 lbs.
(gross)
Surface contaminated objects
(SCO-1)
Exclusive use shipment
Placards applied
CERTIFICATION: These is to certify that the above named articles are properly classified,
described, packaged, marked and labeled, and are in proper condition for transportation,
according to the applicable regulations of the Department of Transportation.
Date:
Date: I'P/'i
\o
[Type text]
EFR Alta Mesa LLC
________________________SHIPPER’S________________________
RELEASE AUTHORIZATION FOR BY-PRODUCT MATERIAL
DESTINATION: Energy Fuels Resources (USA) Inc. - White Mesa Mill
6425 S. Hwy 191
Blanding, UT 84511
SHIPMENT NUMBER: 163
NAME OF DRIVER: ( f)L^
DESCRIPTION OF MATERIAL: By-product material from an in-situ uranium mining
operation (e.g., sand, filter cloths, piping, soil, valves, hoses, personal protective equipment,
etc.)
By execution below, it is represented thafthe byproduct material being transported is properly
classified, described, loaded and labeled; and, that the byproduct material is completely
contained and in proper condition for transportation, according to the applicable regulations for
the state and federal transportation departments.
The shipper certifies the byproduct material is not listed hazardous waste as defined in the
Resource Conservation and Recovery Act, as amended, 40 CFR 261 et. seg. or comparable state
laws. The byproduct material has no been mixed or commingled with hazardous waste as
defined in 40 CFR 261 et. seq.. No processes are operated on the site which are RCRA-listed
processes as defined in 40 CFR 261 et. seq. All of the Byproduct Material is byproduct material
defined under the Atomic Energy Act of 1954 as amended, 42 U.S.C. § 2014(e)(2) and 10
CFR§40.4(a-i).
DATE: tCOpf/to BY:
EFR Alta Mesa LLC
D.O.T. RADIATION SURVEY RELEASE RECORD
Survey Date {0 [ 16 filp Technician P LkMa v Cj xsf
Alpha Survey Instrument
Model Wjclli/iY\ 12- Serial Numbej^ZO^j^T^ Efficiency 6)- ZOS"
Model
Gamma Survey Instrument
______ Serial Number 2-/ 'HI 90
SHIPMENT#16 3 Shipment Type
Gamma
Contact
(uR/hr)
Gamma
2 meters
(uR/hr)
Alpha
Removable
(cpm)
Comment
Cab of Truck 7 N/A N/A
Trailer - Rear /o S N/A ■ew*/ Iych/has
Trailer - Driver Side UQO 30 N/A
Trailer - Passenger Side 100 10 N/A
Trailer - Front /o 10 N/A
Trailer - Bottom N/A N/A
Trailer-Left door N/A N/A <r
Trailer - Right door N/A N/A 3
Trailer - Handle N/A N/A 0
Trailer - Tires N/A N/A 3
Tractor Cab - Tires N/A N/A ■2.
Tractor Cab - Floorboard N/A N/A 3
Placards Installed: ^T) NO Seals Provided
Comments
EFR Alta Mesa LLC
RADIATION SURVEY - D.O.T. PACKAGE
Survey Date (G 'Z^~)f ip Technician TZ
Alpha Survey Instrument
Model L(j(y |\JWl 1 2_ Serial Number 2A Q b) 3 Efficiency (9>Z8f~
Gamma Survey Instrument
Model |C\ Serial Number
Package S/N 0 QIH Package Capacity (yd3) 2LST
Contact
Gamma
(uR/hr)
Alpha
Removable
(cpm)
Comment
Package - Rear Left too z
Package - Rear Right /OO *6
Package - Driver Side - Left izo
-----------/
Package - Driver Side - Right /so &
Package - Passenger Side - Left /OO &
Package - Passenger Side - Right /«S>0 z
Package - Front - Left 10
Package - Front - Right so i
Package - Bottom - Left Xl)\
Package - Bottom - Right A//47
D.O.T. Markings/Labels Installed on Package: (YE NO
Comments
Radiation/Contamination Limits
Gamma (contact reading) - 200 milliRem/hr
Removable (U nat - low toxicity alpha emitter) - 220 dpm/cm2
Photo 1: Excavation prepared for burial of soil and decommissioning debris
from Mestena, Texas. Exposed debris is from a previous burial. Photo taken
November 11, 2016.
Photo 3: Placing soil and decommissioning debris in the excavation. During
this part of the operation, exposed debris was also pressed down into the
excavation. Photo taken November 11, 2016.
•r
te
Photo 2: Surveying bottom of excavation for burial of soil and
decommissioning debris from Mestena, Texas. Photo taken November 11,
2016.
Photo 4: Placing cover soil to close excavation. Photo taken November 11,
2016.
Photo 5: Placing cover soil to close excavation. Photo taken November 11,
2016.
Photo 7: Wheel-walking capping fill in place to increase fill density. Photo
taken November 11.2016.
Photo 6: Placing capping fill over waste. The crew part of left the excavation
open to receive a future load of waste. Photo taken November 11,2016.
Photo 8: The crew erected a berm beside the portion of the excavation left
open to enhance safety. The crew also saw-cut protruding pipe to keep the top-
of-waste elevation at the measured elevation. Photo taken November 11,2016.