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Home My WebLink AboutDRC-2016-010164 - 0901a0688066c09eState of Utah GARY R HERBERT Governor Spencer J Cox Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director Div of Waste Managers.•‘-r and Radiation Control SEP 2 I 2016 DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T Anderson Director C- 201G-OIO \(ok- MEMORANDUM TO: THROUGH: FROM: DATE: SUBJECT: On August 23, 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 June 10,2016. 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 June 10, 2016 the DWMRC received notice that EFR would receive one load of I le.(2) byproduct material, and intended to dispose of that waste in Cell 3 on August 24, 2016. One load was ultimately received, and that load arrived concurrently with my arrival at the mill the morning of August 24, 2016. I checked in at the White Mesa Mill at 7:40 AM on August 24, 2016, in company with two other inspectors from the DWMRC who were there for other purposes, 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 8:30 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 tote bags filled with miscellaneous decommissioning debris, along with loose and bagged soil received at the plant during the inspection from URI, Kingsville Dome, near Kingsville, Texas, shipped by Environmental Evolutions, bearing Shipper Numbers 16KVD-002. 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 File C-2016-36 Phil Goble, Section Manager Russell J. Topham, September 21,2016 i, P E Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material August 24, 2016 and Review of Disposal Operation Files for 2015 and 2016 to Date. Radioactive Materials License UT1900479 (License) - Energy Fuels Resources (USA) Inc. (EFR) White Mesa Mill, Standing, Utah 195 North 1950 Wesi • Salt Lake City, UT Mailing Address. P O Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T D D (801) 903-3978 umni’.deq.utali.gov Printed on 100% recycled paper C-2015-54 Memorandum: Inspection of August 24, 2016 Page 2 to waste placement. Using a front-end loader, the crew placed the waste in the excavations and tamped it 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 5 and 6 from the photo log shows, 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 10.5.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. Following completion of the burial activity, 1 requested to see the records of all waste loads received and disposed during 2015 and the portion of 2016 to date. Review of those files revealed no failure to follow appropriate procedures or to complete the appropriate paperwork during receipt and disposal operations. A total of 19 packets were reviewed for 2016 and 37 for 2015. Each packet included the following, except as noted: • Pages 11 through 13 of SOP PBL-13 properly completed for that load, • The weigh-in ticket generated on receipt of the load, • The shipper’s bill of lading, • Documentation of the radiological survey taken at the point of origin of the load, • Photos of the waste as received, • Incoming radiological survey (recorded on the last page of the SOP PBL-10 excerpt), • Field survey of the depth of burial, and • A copy of the notice provided to the DWMRC of the expected burial date of the waste (missing in the packet for load 3/15-14). All packets were uniquely labeled on each sheet of paper in the packet pertaining to that load with the unique shipper number for that load. The only anomaly noted in the files was that Load 4/15-17 was incorrectly labelled with the burial date rather than the shipper’s bill of lading number. Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial operations represented in the 20-month record examined. Anomalies noted were communicated to Mill management. The anomalies do not reflect a violation of any Rule or license provision. Recommendation: I recommend closing out the paperwork inspection of August 24, 2016. C-2015-54 Memorandum: Inspection of August 24, 2016 Page 3 1 discussed both inspections with Logan Shumway, the Mill Manager, prior to departing. Attachments: Receipt Notification dated February 23, 2016, Bill of Lading and Disposal Documentation for the load disposed on August 24, 2016, photos of the disposal operation. Energy Fuels Resources (USA) Inc. 6425 South Highway 191, PO Box 809 Standing, UT. US, 84511 435 678 2221, fax 435 678 2224 www.energyfuels.com Jt' -oO'Z- 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 POBox 144880 Salt Lake City, UT 84114-4880 Dear Mr. Anderson, June 10, 2016 A 9c5 ^ Re: 1 le.(2) Byproduct Receipt Notification Pursuant to Radioactive Materials License (RML) UT 1900479 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 five loads of 1 le.(2) byproduct material by July 1, 2016. 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 435.678.4113. Regards, David Turk Environmental Health & Safety Manager Energy Fuels Resources (USA) Inc. 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 Ue.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date; g/2-H j j£ Name of employee receiving the load: T^r 1C________ Generator of the Byproduct Material: L> |ZX- Shipper’s Manifest or Bill of Lading number: I A KV & — OC>~<L Was the State of Utah given notice to the receipt/disposal activities associated with this loac^ No ^Ye^ or Who gave and when was the notification given? __T~ur l^-i._____________^ /lO /1 4_______________ Description of byproduct material disposal area/activities: _Dtr-V _b^g. See- ck Has each drum been inspected to identify the presence of any void spaces? fiJA: Have all drums with void spaces been filled with tailings sands or soil?_____A/A__________ Which tailings cell was the material placed in?___U TS 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? /AtK.1 o<- . c?-l—laJj-feS—pAux.uk.—Li-—fe, .LrcACrU—V__ulisi_________in__V-Ue- Was the material segregated from any Mill material or equipment disposed of in the cell? Yc/ Was the material segregated from byproduct material from other ISL sources disposed of in the cell? _______la_________ _________ ____________ 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: lle.(2) Byproduct Disposal Manifest or BOL #: tMO/ft 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? Documentation of approval # ut a-*.~ 7 <gr Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. yr//3 Hr-l jO<&>evs( 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 /%// ? L--J-------------------- & Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? /ex Refer to drawings used to confirm. ^// ? Co^st,& Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? Mn How was this confirmed (e.g., survey or review) ____________ 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? l^f. Were void spaces filled with tailings? _________YcJ__________________ Was the shipment properly covered? _____Vt-j, 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#: l£Hi>fc>'OQ"7- Are additional settlement monitors required to be placed for this generator? _________/t/A------------------------------------------------------------------------- If required, where were settlement markers were placed? ______a/A ___________________________ Radiological receipt survey measurements: P.** +-D O--?-/I-*' . Breathing Zone: 1. Was a Breathing Zone Sample collected'^Yes^pr No 2. If yes, what were the results of the sampling? ______Sc-c ________________________ Was a photograph taken during the unloading activities?(Yes or No Breathing Zone Sampling Field Sheet Energy Fuels Resources (USA) Inc. White Mesa Mill Month:August-16 Sampled By:Radiation Department Filter Location Date Run Time Flow Rate Volume Sampled CommentsID(Min.)(LPM)(mL)By BZ11 YCPkg 08/21/16 83 40 3.32E+06 KR Weekly YC Pkg - PAPR worn BZ12 YC Slacks 08/24/16 360 4 I.44E+06 DT Collected on roof as (he South YC stack was being tested. BZ13 I le.(2)08/24/16 39 4 1.56E+05 DT Collected during the dumping and burial of 1 le.(2) Byproduct material. BZ14 YC Area 08/24/16 106 4 4.24E+05 HL RWP 1373 - Respirators wom BZ15 40 0.00E+00 Reviewed by: Air Particulate Calculations Summary Sheet Count Dale/Time Filter ID Instrument Serial No.Efficiency Total Count/Time CPM Bkg. Count/Time Net Count (Tot.-Bkg.) LLD (uCi/mL) Concentration uCi/ mL Percent of DAC Sample Counted By 08/22/16 BZ11 2929 11.44%3147 314.7 11.10 303.60 6.I5E-12 3.60E-10 1636.67%HL 08/25/16 BZ12 2200 12.50%161 16.1 13.90 2.20 1.44E-11 5.5 IE-12 0.00% DT 08/25/16 BZ13 2929 11.44%67 6.7 11.10 0.00 1.3 IE-10 0.00E+00 0.00%DT 08/25/16 BZ14 2929 11.44%1388 138.8 11.10 127.70 4.82E-11 1.19E-09 5390.43%DT BZ15 11.79%0 11.60 0.00 #DIV/0!#DFV/0!#DIV/0! Time of Sample Concentration ( nCi/cc)= _______(Net CPM)_______ Ts= Background Count Time in Minutes (2.22 E6)(V)(Eff.d) Tb= Detector efficiency in Counts per Disintegration Eff. d= Filter Efficeincy ________________ Eff. f = Total Volume in millilitres of Cubic centimeters LLD or MDA= 2,71+3.29 Bkg.*Ts(l+Ts/Tb)______ V= Factor to convert DPM to uCi ^ (Ts)(Eff. d)(Eff. 0(V)(2.22E6) 2.22E6 = Total Counts - Background Count Net CPM = Percent of DAC= Actual Concentration DAC \(^c> Controled Elevation used (Cell 3) Area Elevation 5613.04 Transit Shot Initial shot for trench 4.88 Top of trench 5608.44 9.48 Bottom of trench 5603.42 14.5 Initial shot used for material 4.88 Tod of material in trench 5606.33 11.59 Top of cell 3 Liner 5608.5 Feet below liner 2.17 (USA) Corp. . DO Energy Fuels Resource UJh i t e Mesa M i J 1 £425 S. Highway 191 Blanding LIT 64511 U e hic1e ID; Trai1er ID; Account ID; Order JD: Owner ID; Material ID: Destin. IDs UP I-HUD UR I-KINGSVILLE DOME life) Mat 1 1 ( e ) 2 Mat er i a 1 Race i pt BLONDIMG i ransection Wo» 52BD3 Dat n Time Sea 1e 0S/E‘4/£01& 07;h£ 1 06/24/2016 08:18 1 Gross: 70300 lb (M) Tare; 3173® lb Net: 365£® lb C o in in e n t s ; Operator: Signature TRAILER tf T0®5 4 Charge by Weight 52833 3031 URI-KYD 11 (e)£ Mat 0Q/£4/£®16 07:46 703®0 lb <M> 08/£4/£016 08:18 31780 lb 365£0 lb 0 Tot Chg;Net Chg:0 URI, INC.STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 16KVD-002 Trailer# 'TopS' Date: 8/22/2016 A Seal # fl/a^ NAME OF CARRIER: Environmental Evolutions DRIVER: Xl\\i\K SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 city Kingsville state Texas zip 78363 COUNTRY USA phone 361-595-5731 cosignee (to) Energy Fuels- White Mesa Mill DESTINATION STREET 6425 S. Hwy 191 city Blanding state UT zip 84511 COUNTRY U.S.A.phone 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT **These contents are contaminated with natural uranium and its daughters 226Ra and 230Th IDENTIFICATION NUMBER: UN 2912 PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activity (LSA-P. HAZARD CLASS: _7 FORM: Solid Oxide ACTIVITY: 0.0008 TBo SPECIAL INSTRUCTIONS: Do not remove contents without authorization WEIGHT: Tare'MHSO lbs. NET 38^0° lbs. GROSS lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) SHIPPER’S CERTIFICATION This is to certify that the abovi proper condition for transporta CONSIDERED A PACKAGE s materials are properly classified, described, packaged, marked, placarded and labeled, and are in ition according to the applicable regulations of the Department of Transportation. THIS VEHICLE IS IN'COhQPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date /fc/JZ // CARRIER’S CERTIFICATION Carrier acknowledges receijH'bf packages and required placards. Carrier certifies emergency response information was made available and has th^appropriate emergency response document in the vehicle. Department of Transportation. \w Date Receivedz/jl/zoit.Date Relinquished Carrier Signature 2 Date Received Date Relinquished Carrier Signature 3 Date Received Date Relinquished ^ CONSIGNEE’S RECIEPT of S.HIPMENT Cosignee's Signature / / _____________'i Lm/l.______________________________________________ Date _____*kyltk. SHIPPER’S RELEASE AUTHORIZATIGN P0R BYPRODUCT MATERIAL DESTINATION: Energy Fuel’s - White Mesa Mill 6425 S. Hwy 191 ____________Blending, UT 84511_________ SHIPMENT NUMBER: NAME OF DRIVER: 16KVD-002 description of material: Byproduct material from an in situ uranium mining operation consiting of Process Material, Soil and Bulk Material with gamma readings no higher than 50mR/hr. Bulk material may contain items such as submersible well pumps. polyethylene pipe, PVC pipe, PPE, pond liner, visqueen plastic sheeting, cartridge or bag filters, equipment parts and pieces, lab trash, crushed contaminated drums, pallets, etc DRIVER: X Signature By execution below, it is represented that the 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 appli cable 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 not been mixed or commingled with hazardous waste as defined in 40 CFR 261 eL seq.. No process are operated on the site which are RCRA- listed process as defined in 40 CFR 261 eL 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-l) 77 0 URI, INC.11.e.2 Byproduct SUPER SACK AND TRANSPORT SURVEY Date: 8/22/2016 Lot No. 16KVD-002 Meter Model Serial Number Probe Model Serial Number Check Source (cpm) Eff (cpm/d pm) Bkg a 2241-3 228154 43-9 PR243270 3084 0.31 1 p/y 2241-3 228154 44-7 PR241506 305 0.07 31 y 19 101727 N/A Front Surface Survey Back Left Side Right Side CPM DPM/IOOcm1 CPM DPM/IOOcm1 CPM DPM/IOOcm1 CPM DPM/IOOcm1 a*0 0 0 0 0 0 1 4 p/y**0 0 0 0 0 0 0 0 Limits Per 100 cm1, *2200 dpm/ 100cm1 (22 dpm/ cm1), ** 22,000 dpm/ 100cm1 (2200 dpm/ cm1) Externa! Exposure Rate* Back'** Left Side*’*Right Side* Surface O-a'6jeciJ.hr..*■70,jX.o- Driver's Cab* Two Meters C>-02r~altr 09~/n 200 mrem/hr) O.IJT* mSi/t 0- 13 **/>- Limits per mSi/hr (mrem/hr), ***2 mSi/hr (200 mi ****.02 mSi/hr. (2 mrem/hr.) ) surface; 1 mSi/hr. (10 mrem/hr) 2m „ 1 riti -------LSurvyeys conducted by: Photo 1: Excavation prepared for burial of soil and decommissioning debris from URI, Kingsville, Texas. Photo taken August 24, 2016. Photo 3: Off-loading soil and decommissioning debris preparatory to burial. Photo taken August 24, 2016. Photo 2: Excavation prepared for burial of soil and decommissioning debris from URI, Kingsville, Texas. Photo taken August 24, 2016. Photo 4: soil and decommissioning debris awaiting disposal. Photo taken August 24, 2016. Photo 7: Wheel-walking capping fill in place to increase fill density. Photo taken August 24, 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 August 24, 2016. Photo 8: Final condition of burial site. Photo taken August 24, 2016.