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Home My WebLink AboutDRC-2017-001661 - 0901a068806c800dEnergy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.conn Oiv of Waste Management and Radiation Control March 1,2017 3 2017 Sent VIA OVERNIGHT DELIVERY wc-mi-ODikb Mr. Scott Anderson Director Division of Waste Management and Radiation Control Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144880 Salt Lake City, UT 84114-4820 Re: Transmittal of Revised Standard Operating Procedure (“SOP”) PBL-19 Feed Material Receipt/Storage Procedure for the White Mesa Uranium Mill Dear Mr. Anderson: Pursuant to the Division of Waste Management and Radiation Control (“DWMRC”) inspection conducted January 25 and January 26, 2017, Energy Fuels Resources (USA) Inc.’s (“EFRI”) is proposing revisions to the White Mesa Mill SOP, PBL-19 Feed Material Receipt/Storage. The changes were made to address issues noted during the aforementioned inspection. For ease of review we have provided both redline/strikeout and clean versions of the document. If you should have any questions regarding this SOP please contact me. Yours very truly. Energy Fuels Resources (USA) Inc. Kathy Weinel Quality Assurance Manager CC: David C. Frydenlund Mark Chalmers David E. Turk Logan Shumway Scott Bakken REDLINE No.: PBL-19 Rev. No.: 23 Date: April 1, 4£March 1.2017 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: Containerized Alternate Feedsteek Material Receipt/Storage Procedure Page 1 of 3 1.0 Purpose The purpose of this procedure is to assure that the receipt and storage of feedstock materials is conducted in a manner so as to preclude the release of Mill feed material to the environment. 2.0 Scope Feed materials delivered to the White Mesa Mill must be stored in a manner which precludes the release of the materials to the environment. In the case of bulk materials, such as unrefined natural ores and alternate feeds delivered in inter-modal containers, these materials are offloaded from the truck or shipping container directly onto the approved ore pad where migration of material is precluded by the pad’s design and operating procedures (i.e. low permeability pad material, dust control procedures and limited stockpile height). However, certain feeds are received in drums or other containers which serve to effectively contain the material during storage and, as such, are amenable for storage either on the ore pad or at locations other than the ore pad. It is the intent of this procedure to describe the environmental safety precautions utilized for contained feed storage. 3.0 Procedure 3.1 Contained-Feed Material Inspections All contained feed materials received at the White Mesa Mill are inspected upon arrival, prior to entering the Restricted Area, to determine that the containers and/or conveyances are not leaking and to assure container integrity prior to placing the material into storage. Each container and/or conveyance will be observed on all sides for damage or leakage of contents. If any container and/or conveyance has signs of leakage, the inspector must notify the RSO, or their designee, immediately. The RSO, or their designee, will make the determination through visual observation and radiological assessment if a leak has occurred. If a leak has occurred, the RSO, or their designee, will make the proper notifications to Corporate Management and regulatory agencies and complete page 2 of the Feed Material Receipt form. All containers exhibiting signs of leakage will be re packed or placed in over-pack containers prior to placing the materials into storage. Dented drums are acceptable if the dent is not located near a seam or when the dent is not accompanied by a damage crease on the drum surface. Drums damaged by dents near the seam, crease damaged drums or containers that have been otherwise compromised during shipment are re-packed or placed in over-pack containers prior to storage. Containers which are not damaged at the time of receipt are transferred directly for placement at the storage location. 3.2 Storage Locations 3.2.1 Defined Feedstock Storage No.: PBL-19 Rev. No.: 23 Date: April 1, 4£March 1,2017 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: Containerized Alternate Feedsteek Material Receipt/Storage Procedure Page 2 of 3 Feedstock materials stored at the defined storage location indicated on the map attached hereto as Attachment A) the “Defined Feedstock Area” can be stored in containers or in bulk form and are subject to the routine inspections described by the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan-m Section 3.3 of the Mill’s Environmental Protection Manual. 3.2.2 Storage of Contained Feeds in Location Other Than the Defined Feedstock Area a) Over-pack Containers Materials received or transferred into over-pack containers can be stored at locations other than the Defined Feedstock Area absent a hardened ground surface or containment berms due to the fact that the over-pack container provides a secondary containment for the packaged material. Over-pack materials are subject to the routine inspections described by the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan at Section 3.3. b) Hardened Surface Storage Locations Contained feed materials, including materials in containers which have not been provided with over-pack protection, can be stored at locations other than the Defined Feedstock Area when a hardened ground surface storage location is used and has been provided with containment berms. These materials are subject to the routine inspections described by the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan at Section ^2. c) Single Lined Containers Stored Outside the Defined Feedstock Area Where Hardened Surfaces and Containment Berms Are Not Utilized Contained feeds can also be stored in locations, other than the Defined Feedstock Area, that have been selected to avoid impact by site drainage and/or pooling. Prior to storage at these locations, planks or pallets are placed beneath the drum storage locations in order to raise the container from the ground surface and avoid corrosion from water which may accumulate during precipitation events (despite site selection) and from rusting due to soil moisture when drums are stored directly on the ground. These contained materials are subject to the more particular storage protocols and inspections outlined below. 3.3 Storage Protocol Single Lined Containers No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: 23 STANDARD OPERATING PROCEDURES Page 3 of 3 Date: April 1,Title: Containerized Alternate Feedstock Material 2014February fOMarch 1.2017 Receipt/Storage Procedure In accordance with MSHA requirements, container storage must be implemented in such a manner as to limit the potential for a container to tip or fall onto a worker. For drummed materials, the agency limits such stacks to three drums in height due to stability considerations. In keeping with these concerns, EFR will configure single lined storage drums (stored off the Designated Feedstock Area) in rows no more than two containers wide at the base and may place a one- container row either on top of a single row or in the middle of a lower two- container row, in each case so as to straddle the tops of drums in the lower container row(s). This stacking configuration distributes the single upper row across bottom row(s) of containers in such a manner as to hold the bottom row(s) from leaning and allowing for limited stacking on top of these lower row(s). accordingly, when stacking is necessary, this configuration minimizes the risk of falling drums, limits stacking height for safety reasons and allows for a thorough inspection of each of the individual containers from the outside of the container row(s). 3.4 Single Lined Container Storage Area Inspections The single lined container storage area(s) that are off of the Designated Feedstock Area will be inspected on a weekly basis (and after significant precipitation events) on both sides of any row in order to assure that the stored materials remain intact, that standing water has not accumulated and that materials are not leaking or migrating from the storage area. 3.5 Single Lined Container Storage Inspection Records EFR will record all instances where single lined containers are received damaged (or leaking) and require re-packing or the provision of an over-pack container. This information will be recorded on a container receipt form (see Attachment B) which documents the receipt of drummed materials to be stored in locations other than the Defined Feedstock Area. Similarly, each weekly inspection shall be recorded on the inspection form referred to in the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan at Attachment A-3 and attached as Attachment C to this procedure. Such inspections require the documentation of container condition, the drainage conditions in the storage location, the presence of leakage, if any, and any corrective actions taken due to leakage of containers or standing water at the storage location. Feed Material Receipt Inspection Date: Inspector: Is the shipment leaking? Yes or No If Yes, complete the other side of this document. Number of containers/drums in shipment:____ Radiation Activity Levels:_________________ Location of Storage:______________________ Corrective Action Taken for Damaged Drums: Observations (note dented or damaged drums) Inspector: (Print Name) (Signature) CLEAN No.: PEL-19 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: 3 STANDARD OPERATING PROCEDURES Page 1 of 3 Date: March 1, 2017 Title: Feed Material Receipt/Storage Procedure 1.0 Puipose The puipose of this procedure is to assure that the receipt and storage of feed materials is conducted in a manner so as to preclude the release of Mill feed material to the environment. 2.0 Scope Feed materials delivered to the White Mesa Mill must be stored in a manner which precludes the release of the materials to the environment. In the case of bulk materials, such as unrefined natural ores and alternate feeds delivered in inter-modal containers, these materials are offloaded from the truck or shipping container directly onto the approved ore pad where migration of material is precluded by the pad’s design and operating procedures (i.e. low permeability pad material, dust control procedures and limited stockpile height). However, certain feeds are received in drums or other containers which serve to effectively contain the material during storage and, as such, are amenable for storage either on the ore pad or at locations other than the ore pad. It is the intent of this procedure to describe the environmental safety precautions utilized for contained feed storage. 3.0 Procedure 3.1 Feed Material Inspections All feed materials received at the White Mesa Mill are inspected upon arrival, prior to entering the Restricted Area, to determine that the containers and/or conveyances are not leaking and to assure container integrity prior to placing the material into storage. Each container and/or conveyance will be observed on all sides for damage or leakage of contents. If any container and/or conveyance has signs of leakage, the inspector must notify the RSO, or their designee, immediately. The RSO, or their designee, will make the determination through visual observation and radiological assessment if a leak has occurred. If a leak has occurred, the RSO, or their designee, will make the proper notifications to Corporate Management and regulatory agencies and complete page 2 of the Feed Material Receipt form. All containers exhibiting signs of leakage will be re packed or placed in over-pack containers prior to placing the materials into storage. Dented drums are acceptable if the dent is not located near a seam or when the dent is not accompanied by a damage crease on the drum surface. Drums damaged by dents near the seam, crease damaged drums or containers that have been otherwise compromised during shipment are re-packed or placed in over-pack containers prior to storage. Containers which are not damaged at the time of receipt are transferred directly for placement at the storage location. No.: PEL-19 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: 3 STANDARD OPERATING PROCEDURES Page 2 of 3 Date: March 1, 2017 Title: Feed Material Receipt/Storage Procedure 3.2 Storage Locations 3.2.1 Defined Feedstock Storage Feedstock materials stored at the defined storage location indicated on the map attached hereto as Attachment A) the “Defined Feedstock Area” can be stored in containers or in bulk form and are subject to the routine inspections described by the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan of the Mill’s Environmental Protection Manual. 3.2.2 Storage of Contained Feeds in Location Other Than the Defined Feedstock Area a) Over-pack Containers Materials received or transferred into over-pack containers can be stored at locations other than the Defined Feedstock Area absent a hardened ground surface or containment berms due to the fact that the over-pack container provides a secondary containment for the packaged material. Over-pack materials are subject to the routine inspections described by the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan. b) Hardened Surface Storage Locations Contained feed materials, including materials in containers which have not been provided with over-pack protection, can be stored at locations other than the Defined Feedstock Area when a hardened ground surface storage location is used and has been provided with containment berms. These materials are subject to the routine inspections described by the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan. c) Single Lined Containers Stored Outside the Defined Feedstock Area Where Hardened Surfaces and Containment Berms Are Not Utilized Contained feeds can also be stored in locations, other than the Defined Feedstock Area, that have been selected to avoid impact by site drainage and/or pooling. Prior to storage at these locations, planks or pallets are placed beneath the drum storage locations in order to raise the container from the ground surface and avoid corrosion from water which may accumulate during precipitation events (despite site selection) and from rusting due to soil moisture when drums are stored directly on the ground. These contained materials are subject to the more particular storage protocols and inspections outlined below. No.: PBL-19 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: 3 STANDARD OPERATING PROCEDURES Page 3 of 3 Date: March 1, 2017 Title: Feed Material Receipt/Storage Procedure 3.3 Storage Protocol Single Lined Containers In accordance with MSHA requirements, container storage must be implemented in such a manner as to limit the potential for a container to tip or fall onto a worker. For drummed materials, the agency limits such stacks to three drums in height due to stability considerations. In keeping with these concerns, EFR will configure single lined storage drums (stored off the Designated Feedstock Area) in rows no more than two containers wide at the base and may place a one- container row either on top of a single row or in the middle of a lower two- container row, in each case so as to straddle the tops of drums in the lower container row(s). This stacking configuration distributes the single upper row across bottom row(s) of containers in such a manner as to hold the bottom row(s) from leaning and allowing for limited stacking on top of these lower row(s). accordingly, when stacking is necessary, this configuration minimizes the risk of falling drums, limits stacking height for safety reasons and allows for a thorough inspection of each of the individual containers from the outside of the container row(s). 3.4 Single Lined Container Storage Area Inspections The single lined container storage area(s) that are off of the Designated Feedstock Area will be inspected on a weekly basis (and after significant precipitation events) on both sides of any row in order to assure that the stored materials remain intact, that standing water has not accumulated and that materials are not leaking or migrating from the storage area. 3.5 Single Lined Container Storage Inspection Records EFR will record all instances where single lined containers are received damaged (or leaking) and require re-packing or the provision of an over-pack container. This information will be recorded on a container receipt form (see Attachment B) which documents the receipt of drummed materials to be stored in locations other than the Defined Feedstock Area. Similarly, each weekly inspection shall be recorded on the inspection form referred to in the White Mesa Mill Tailings Management System Discharge Minimization Technology (DMT) Monitoring Plan at Attachment A-3 and attached as Attachment C to this procedure. Such inspections require the documentation of container condition, the drainage conditions in the storage location, the presence of leakage, if any, and any corrective actions taken due to leakage of containers or standing water at the storage location. Feed Material Receipt Inspection Date: Inspector: Is the shipment leaking? Yes or No If Yes, complete the other side of this document. Number of containers/drums in shipment:____ Radiation Activity Levels:_________________ Location of Storage:______________________ Corrective Action Taken for Damaged Drums: Observations (note dented or damaged drums) Inspector: (Print Name) (Signature) Feed Material Receipt Inspection Name of generator of shipment: Bill of Lading #: Activity in Curies: Radionuclides: The amount of material that leak out of the package (if known): The amount of material that leak out of the conveyance (if known): Can it be determined when the leak occurred? Corrective Actions: RSO: (Print Name)(Signature)