DRC-2013-001948 - 0901a068803670bf

State of Utah
JON M. HUNTSMAN, JR
Governor
GARY HERBERT
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Acting Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
April 5, 2013
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600 «r%/^ ^ o J "7 f\ r% i C\ i Q
Lakewood,CO 80228 DRC-2U13-OU-LV40
SUBJECT: Compliance: Review of Revision R-3.2 of Standard Operating Procedure PBL-10;
Radioactive IVIaterials License UT1900479 (RML) and Groundwater Discharge Permit
(GWDP) UG370004, Energy Fuels Resources, Lie. (EFR) White Mesa IVIill, Blanding,
Utah: Approval and Closeout
Dear Ms. Tischler:
On February 28, 2013 the Utah Division of Radiation Control (DRC) received proposed revisions
to Standard Operating Procedure PBL-10 (SOP). The SOP bears revision mark R-3.2, and was
submitted in response to a Request for Information from the DRC dated January 14, 2013 (RFI).
As documented in the cover letter accompanying the SOP, communication took place in which
better understanding of some of the issues underlying the RFI was reached. The following
summarizes the key findings of the DRC review of the SOP.
1. EFR has in place sufficient robust protocols to handle rejection of a load of 11 e.(2)
byproduct material at virtually any location within the secured area if it fails to meet the
description on the shipping manifest. The DRC had concerns that a load might be rejected,
but the transport conveyance could not be decontaminated to meet Department of
Transportation (DOT) requirements for release.
2. EFR has amended Attachment 2 to the SOP to include a unique identifier for the material
being documented. This will help facilitate re-collation of document packets for loads of
disposed 1 le.(2) material should the packets become separated. A further improvement
could be made by including that unique identifier on all pages of all documents in the
packet. The DRC suggests including language in the SOP stating that each page of
documentation should bear that unique identifier. Since the DRC does not intend this to be
a compliance point, the DRC will not require a response to this suggestion.
3. The language of the SOP has been amended to allow inspections of incoming loads at the
un-tarping station (preferred practice) or in other areas of the plant (current cold-weather
practice includes inspection at the disposal site). This clarifies the process for DRC
168 North 1950 West • Salt Uke City, UT
Mailmg Address P O Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq Utah gov
Printed on 100% recycled paper
Jo Ann Tischler
April 5, 2013
Page 2
inspectors as well as for plant personnel.
4. Minor textual changes have been made to reflect changes in job titles and responsibilities
at EFR and at the DRC (changing reference from Executive Secretary to Director),, and to
acknowledge the recent change of ownership of the plant.
The amendments made to the SOP do not constitute significant changes to protocol. Each ofthe
changes makes an improvement, clarification, or reference change which will make future use of
the SOP easier and/or more effective. Revision R-3.2 of SOP PBL-10 is hereby approved and
the associated RFI is closed out.
If you have questions about these matters, please contact Russ Topham at [phone].
Sincerely
Rusty Lundberg, Director
RL:RJT:rjt