DRC-2017-002206 - 0901a068806d9601

Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
March 27, 2017
Div of Waste Management
and Radiation Control
Sent VIA EXPRESS DELIVERY AND E-MAIL
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
PpC-2017- OOZZOk
Re: White Mesa Uranium Mill- RML UT1900479
Safety and Environmental Review Panel ("SERP") Annual Report
Dear Mr. Anderson:
Condition 9.4 D of the White Mesa Mill, State of Utah Radioactive Materials License No. UT 1900479
("RML"), requires that Energy Luels Resources (USA) Inc. ("LERI") submit an annual Safety and
Environmental Review Panel ("SERP") Report. Attached is the annual 2016 SERP Report required by
RML Condition 9.4D.
It is important to note that EFRI received the Division of Waste Management and Radiation Control
("DWMRC") letter dated August 12, 2015, which provided comments on the annual SERP Reports for
2012, 2013 and 2014. EFRI has noted DWMRC's comments and has made the changes as noted below.
DWMRC comments noted during their review of the annual SERP Reports for 2012, 2013 and 2014 are
listed in italics below. EFRI responses follow each DWMRC comment.
• Members of the SERP, as defined in License Condition 9.4C., were not documented in the report;
EFRI Response:
The Annual Report format has been modified and a section entitled “SERP Membership and
Qualifications” has been added to the report. This section delineates the personnel and
responsibilities as required in License Condition 9.4C.
• Changes to existing and new procedures that were reviewed by the SERP were not attached to
two of the SERP reports as required in License Condition 9.4D.
EFRI Response:
License condition 9.4D states “In addition, the licensee shall annually submit to the Director changed
pages to the Operations Plan and Reclamation Plan of the approved license application to reflect
changes made under this condition.” The SOP reviewed and implemented during the 2016 SERP is
not attached to the annual report as requested because the subject SOP is not a change to the
Operations Plan or Reclamation Plan, and in addition is considered Proprietary - Confidential
Business Information. The process reviewed by the SERP in 2016 relies on previously submitted
SOPs for the precipitation and packaging circuits. No changes to those documents are necessary as a
result of the 2016 SERP. Further, no changes to the Reclamation Plan were required as a result of the
SERP and no updated pages are required. Specifically, EFRI has not previously submitted SOPs for
alternate feed processing due to the fact that they are not changes to the Operations Plan or
Reclamation Plan and due to the proprietary nature of the information contained therein.
The SOPs and full SERP documents are available at the Mill for DWMRC review.
If you should have any questions regarding this report please contact me.
Yours very truly,
''U'yllL
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David C. Frydenlund
Mark Chalmers
David E. Turk
Logan Shumway
Scott Bakken
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WHITE MESA MILL
SAFETY AND ENVIRONMENTAL REVIEW PANEL (“SERF”)
2016 ANNUAL REPORT
Submitted to the Utah Department of Environmental Quality
Division of Radiation Control
Submitted by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 27, 2017
1.0 INTRODUCTION
This report is being submitted by Energy Fuels Resources (USA) Inc. (“EFRI”), licensee of the
White Mesa Uranium Mill (the “Mill”) to the Utah Division of Waste Management and
Radiation Control (“DWMRC”) in compliance with condition 9.4D of State of Utah Radioactive
Materials License No. UT 1900479 (“RML” or the “License”).
There was one Safety and Environmental Review Panel (“SERF”) evaluation conducted for the
period of January 1, 2016 through December 31, 2016. The SERF evaluation and review was
conducted in accordance with SERF procedures set forth in the Mill’s Standard Operating
Procedure PBL-1, Rev. No. R-6 (the “SERF SOP”). The evaluation is summarized below in
Section 2.0.
2.0 SUMMARY OF EVALUATIONS
This section describes the change, test, or experiment evaluated by the SERF pursuant to License
condition 9.4, and summarizes the evaluations performed and actions taken by the SERF relative
to each.
In each case, the SERF consisted of those individuals specified in License condition 9.4 C, with
additional members included as appropriate, to address specific technical issues.
The SERF followed the SERF SOP as it performed its evaluations, to ensure that the actions
taken satisfy the following three conditions specified in License condition 9.4 B:
a) The change, test or experiment does not conflict with any requirement specifically stated
in the License, or impair the licensee’s ability to meet all applicable regulations.
b) There is no degradation in the essential safety or environmental commitments in the
License application or provided by the approved reclamation plan.
c) The change, test or experiment is consistent with the conclusions of actions analyzed and
selected in the Environmental Assessment dated February 1997 (the “1997
Environmental Assessment).
2.1. SERF Report No. 2016-01 February 19, 2016
Dawn Mining Process Standard Operating Procedure (“SOP”)
2.1.1. Proposed Action
Review and approve a proposed SOP for processing Dawn Mining alternate feed
materials.
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2.1.2. Descriptions of Change. Tests or Experiments
EFRI’s White Mesa Mill is authorized to process alternative feed materials other than natural
uranium ore under the RML. RML condition 10.20 allows the White Mesa Mill to receive and
process source material from Dawn Mining Company’s Midnight Mine in accordance with
statements, representations, and commitments contained in the Amendment Request and
associated submittals. The Dawn Mining material is Water Treatment Plant (“WTP”) solids
resulting from treatment of natural uranium mine storm water and groundwater at an inactive
uranium mine.
EFRI plans to process uranium containing materials from the Dawn Mining site. The material
has been shipped in super sacks from the facility in Wellpinit, WA. The proposed process is a
modification of processes in practice at the Mill as described in the Mill’s 2007 license renewal
application and existing EA documents. The SERP evaluated the process with respect to the
requirements of condition 9.4 of the Mill’s RML, worker safety, process safety, and
environmental protection.
The proposed system will process the materials utilizing one process node. The material will be
fed to the process by dumping directly into process vessels. The material will be digested in acid
leach solution, and clear leach solution will be fed to solvent extraction, precipitation, and drying
circuits. The recovered solution will be precipitated and dried the same as the yellowcake
product from all other feeds.
2.1.3 Safety and Environmental Evaluation of this SERP Action
In order for a change in the facility or process, as presented in the license application, to be
eligible for approval by the SERP, the three SERP Approval Criteria, detailed in the SERP SOP,
must be satisfied. The three SERP Approval Criteria were reviewed and discussed, as follows:
2.1.3.1 Does the change conflict with any requirement specifically stated in the license, or impair
EFRI’s ability to meet all applicable regulations?
The SERP determined that the Change (processing Dawn Mining material) does not conflict with
any requirement stated in the license and does not impair EFRI’s ability to meet applicable
regulations. Therefore, this criterion is met.
EFRI received a License amendment from Utah Department of Environmental Quality
(“UDEQ”) during the third quarter of 2014. The letter confirmed that the material could be
received and processed under the amendment (License Condition 10.20).
The process is consistent with the plans and SOPs referenced in the License and its renewal
application. The process does not require the modification of the Mill’s Air Approval Order or
any other approved management plans.
The Mill has remained in compliance with the License and other regulatory requirements while
processing, purifying, and concentrating other alternate feed materials; hence there is no reason
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to expect the Mill cannot remain in compliance with the same requirements when running the
Dawn Mining material.
The purified and concentrated yellowcake that will be produced will not cause the Mill to exceed
the yellowcake production limit under the License.
The approved License limits the quantity of Dawn Mining material that can be received to no
more than 1000 dry tons per year and a total limit of 4500 dry tons total. To date approximately
300 dry tons have been received which is within the quantities specified in the License.
License condition lO.l.e requires that the Mill may not receive any alternate feed materials or
other ores if those materials would cause the facility to exceed the tailings cell capacity
established by the currently approved reclamation plan and/or the annual surety report. The
volume of tailings that will be generated during processing the Dawn Mining material will be
significantly less than the tailings that would be generated by producing the same amount of
yellowcake from ore. It is expected that the majority of the Dawn Mining material will
“dissolve” during the acid digestion and the tailings will be de minimis.
2.1.3.2 Does the change create any degradation in the essential safety or environmental
commitments in the license application, or provided by the approved reclamation plan?
Processing the Dawn Mining material will not produce any degradation in the essential safety or
environmental commitments in the License application, or provided by the approved reclamation
plan, and therefore this criterion is met.
The process is consistent with the plans and SOPs referenced in the License and its renewal
application. The Mill is already approved to process, purify, and concentrate yellowcake and to
dispose of tailings in the tailings system.
The process will not require the use of any new chemicals not already in use in the Mill.
The process will not produce any new types or increased quantities of emissions. The
yellowcake will be processed and dried in the existing Mill circuits and will produce the same
quantity of emissions as any other yellowcake in the Mill circuit. Because the Dawn Mining
material is stored in super sacks, it will produce fewer fugitive emissions/dusts than would be
generated by producing the same quantity of yellowcake from conventional ores.
The Dawn Mining material will not produce any additional respiratory hazards. There will be no
new chemical reactions or off-gasses associated with processing the Dawn Mining material
under the SOP.
The Dawn Mining material will not require any additional spill control measures beyond those
already in place. The Dawn Mining material is a wet solid material and does not contain any
appreciable, measureable liquid.
The Dawn Mining material will have no effect on the Reclamation Plan. The volumes of
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solutions and solid tailings that would be transferred to tailings will be significantly less than
those that would be generated by producing the same amount of yellowcake from conventional
ore.
2.1.3.31s the change consistent with the conclusions of actions analyzed in the EA dated
February 1997?
The Dawn Mining material is not expected to produce any environmental impacts beyond those
assessed in the EA dated February 1997, and is consistent with the conclusions regarding actions
analyzed in the EA. As a result, this criterion is also satisfied.
As discussed above, processing the Dawn Mining material will:
• Produce less airborne dust than conventional ores and bulk alternate feed materials since
the material is stored in sealed super sacks throughout its life,
• Not use any new chemicals,
• Not produce any increased levels of radionuclides in processes or wastes beyond those
anticipated in the EA,
• Not introduce any new constituents to the tailings system,
• Not produce any new emissions or pathways for exposure to workers or the public,
• Not require any changes to spill control or storm water management,
• Not require additional tailings capacity or changes to tailings management plans, and
• Produce lower tailings volume than production of an equivalent quantity of product via
conventional ore or alternate feed materials.
Processing the Dawn Mining material will not introduce any new pathways of contamination to
the environment. Processing the Dawn Mining material is within the envelope of conditions
evaluated in the Mill’s MILDOS model for dose to off-site receptors.
2.1.4 SERP Action
The SERP concluded that processing the Dawn Mining material meets the criteria set forth in the
SERP SOP for approval, and approved the SOP.
The SERP authorized immediate implementation of the SOP.
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3.0 SERF MEMBERSHIP AND QUALIFICATIONS
This SERF consisted of the following members:
Responsibility Name/Position
Corporate Radiation Safety Officer or
equivalent;
Assuring Tests conform to radiation safety
and environmental requirements
David Turk
Manager Environmental Health and
Safety and Mill Radiation Safety
Officer (Member)
Management Expertise;
Responsibility for managerial and financial
approvals
Harold Roberts
Executive Vice President
Conventional Operations (Member)
Operations and/or Construction
Management;
Responsibility for implementing operational
procedures
Logan Shumway
Mill Manager (Member)
Corporate responsibility for regulatory
compliance
Scott Bakken, Sr. Director,
Regulatory Affairs
Responsibility for regulatory compliance at
WMM
Kathy Weinel Quality Assurance
Manager
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