DRC-2012-001980 - 0901a0688030cb24

DRC-2012-001980
EnErgy FUEIS RESourcES (U5RJ Inc.
September 7,2012
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr Rusty Lundberg
Executive Secretary
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
PO Box 144850
Salt Lake City, UT 84114-4820
Re Response to Utah Division of Radiation Control ("DRC") August 8, 2012 Letter Regarding
Radiological Data for March 25, 2012
Dear Mr Lundberg
This letter responds to DRC's above-named letter dated August 3, 2012, which Energy Fuels Resources
(USA) Inc ("EFR") received on August 8, 2012, regardmg White Mesa Mill radiological data for the leach
area on March 25, 2012
As discussed with Philip Goble and Kevm Camey of DRC during a phone conversation on September 5, 2012,
EFR agrees with DRC that quantification of particulate and other forms of radiation m upset conditions should
be done by collection of samples, where practicable
With respect to the situation on March 25, 2012, as we discussed by phone, the Mill focused first on worker
safety, which involved evacuatmg the building, and then on collectmg chemical data, which was considered to
be of primary importance in order to control the source of the upset and to assess any potential immediate
danger to worker health and safety As the upset was very short-lived, by the time chemical gas sampling was
completed, the source of the upset was under control, and the visible vapors had dissipated, leavmg little
opportunity to collect radiological samples
Nonetheless, EFR agrees, in the event of future upsets, to collect either area airborne samples or breathing zone
samples for gross alpha measurement, in the buildmg or part of the plant affected by the upset, to the extent
practicable under the circumstances In fact, the Mill's Emergency Response Plan ("ERP"), in Section 5 5 13
"Momtormg", addresses the collection of samples dunng emergency situations such as this, specifically
"In the event of an accident, such as an accident that mvolved the dispersion of yellowcake, or
a fire in the SX building or elsewhere m the facility that could mvolve the dispersion of
radioactive materials, breathing zone samples will be taken if practicable m the circumstances "
Energy Fuels Resources (USA) Inc
Lakewood, CO 80228
225 Union Boulevard, Suite 600
Phone [phone]
Letter to Rusty Lundberg
September 7, 2012
Page 2 of2
During the March 25, 2012 upset, EFR's primary concems were the protection of worker health and safety, and
control ofthe source of the emergency Given the nature of the feed matenal in the leach circuit, and the short
nature ofthe upset, collection of radiological samples was not considered to be practicable in the circumstances
However, as we discussed during our September 15, 2012 phone call, EFR agrees to collect the types of
additional radiological monitoring samples identified above if sampling can be performed without risk to the
radiation or environmental personnel, and to the extent sampling can be performed without deterring the
sampling personnel from their role in protecting the safety of other personnel and/or controlling the source of
the emergency
In hindsight. Mill personnel may have been able to collect radiological samples simultaneously with the
chemical samples on March 25, 2012, had they been better prepared for the circumstances In order to be in the
best position possible to collect such radiological samples in any future incident of this nature, EFR is in the
process of retraining Mill environmental and emergency response personnel, to clarify and emphasize the intent
of Section 5 3 I 3 of the ERP, and to ensure collection of additional data during emergencies to the extent data
can be collected safely under the circumstances
Please contact me if you have any questions or require any further information
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Director, Compliance
cc David C Frydenlund
Daniel C Hillsten
Harold R Roberts
David E Turk
Kathy A Weinel
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