DRC-2013-001959 - 0901a068803670d6

Department of
Environmental Quality
Ainanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
March 18,2013
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RETURN RECEIPT REQUESTED
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd., Suite 600
Lakewood, CO 80228
U.S. Postal Service
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RE: ocmpliance; mod 73 RFI / rjt
JO ANN TISCHLER
ENERGY FUELS RESOURCES (USA) INC.
225 UNION BLVD., STE 600
LAKEWOOKCO 80228
PS Form 3800, August 2006 See Reverse for Instructions
Subject: Compliance: Engineering Module 73, Inspection of Disposal of Bulk Byproduct
Material: Radioactive Materials License UTl900479 (RML): DRC Findings and
Request for Information.
Dear Mr. Frydenlund: DRC-2013-001959
On March 7, 2013, the Utah Division of Radiation Control (DRC) conducted an inspection of
disposal operations for 1 le.(2) byproduct material. The DRC findings were as follows:
1. EFR has an approved Standard Operating Procedure, No. PBL-10, Revision No. R-3
(SOP), dated November 10, 2011 which sets forth an orderly methodology for achieving
compliance with the conditions of the RML governing receipt and disposal of 11 e.(2)
byproduct material. The DRC has in hand Revision R-3.2, which is currently under
review.
2. The inspections performed on the above referenced dates did not reveal incidents of
noncompliance with either the RML or either revision of the SOP.
3. The disposal operation occurred on the tailings beach near the remaining solution pool. In
this location, no interim cover had been placed. As such, the solution level in the disposal
excavation reached nearly to the beach surface at the rim of the excavation. The waste
materials and cover soils placed in the excavation formed a viscous paste which did not
respond well to compaction. As such, EFR was unable to finish work on the disposal
operation while DRC staff were present.
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
www deq Utah gov
Printed on 100% recycled paper
^ David C. Frydenlund
Page 2
March 13,2013
4. The SOP contains a form, identified as Attachment 2, and appearing on Pages 10 through
12 of Revision R-3 ofthe SOP and on Pages 11 through 13 of Revision R-3.2. Revision R-
3.2 contains a line item on the first page of Attachment 2 (page 11) for a unique load
identifier. This responds to a request made in the DRC letter of January 14, 2013.
5. The DRC suggests an additional revision to the SOP to indicate that the unique load
identifier should be hand-written on each page or sheet that makes up the packet
documenting the characteristics and disposal of an individual load. The DRC suggests
selection of phrasing in this revision to avoid making this change a regulatory requirement.
The DRC offers this suggestion as a means to reduce the chance of collation errors should
papers from one or more load documentation packets become separated.
Request for Information
As noted in Bullet Item 3 above, EFR was unable to complete the requirements of the SOP for
compaction of the waste and cover soils because of the high moisture content ofthe materials in
the excavation while DRC staff were present. The SOP calls for wheel-walking or track-walking a
specific number of passes to density the materials. The high moisture content not only makes the
materials too soft to work, the moisture also prevents densification. Therefore, field crews
proposed, and the DRC field inspector agreed, to wait until the moisture content of the cover soils
decreased sufficiently to complete the required compaction. As EFR becomes able to perform the
compaction of these soils, please forward a brief narrative and photographs documenting what
took place.
If you have any questions on these matters, please contact at Russ Topham at [phone].
Sincerely,
Rusty Lundberg V_J
Director
cc: EFR White Mesa Mill: David Turk
RL/RJT:rjt
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RE: ocmpliance; mod 73 RFI/rjt
1^5 UNION BLVD.. STE 600
LAKBWOOKCO 80228
below:
• Yes
2. Article Number
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