DRC-2021-024941 - 0901a06881083cf4

DRC -202 1 -024* ( UTAH DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-SERP-01
SAFETY AND ENVIRONMENTAL REVIEW PANEL ANNUAL REPORT REVIEW
ENERGY FUELS RESOURCES- WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UT1900479
References: Utah Administrative Code RML UT 1900479 License Condition 9.4
Year Reported Date of Report Date of Review
2020 March 24, 2021 March 25, 2021
1) Describe what subject(s) were reviewed by the Mill's SERP.
Subject 1: Update and review the existing high thorium content standard operating procedure ("HTC
SOP").
The original SOP was approved by the Nuclear Regulatory Commission ("NRC") by letter dated
December 27, 2000. The SOP has been used as the baseline (reference point) for the development of
other HTC feed-specific SOPs including but not limited to those for the Heritage, Fansteel, Sequoyah,
and Calcined Byproduct Material alternate feed materials. All feed-specific changes were as approved
by EFR1's SERP, as appropriate to incorporate information and results obtained from the evaluation of
health physics surveys, monitoring and controls implemented pursuant to keeping radiological
exposures to employees, the public and the environment ALARA.
Because the HTC SOP was approved by NRC as part of the license amendment for the WR Grace
alternate feed materials, it has been adopted for use by reference since that time. An official SOP
number was not assigned to the HTC SOP and it was not published for general staff use because the
WR Grace material was not received at the Mill; however, the HTC SOP is considered active and
available in accordance with the ALARA program requirements.
The HTC SOP as written, does not apply to any HTC ores that are the subject of a SERP-approved
procedure specific to the HTC ore, which contains provisions substantially similar to the applicable
provisions contained in the HTC SOP, adjusted to suit the receipt, storage, handling, processing,
disposal and characteristics of the specific HTC ore while maintaining the applicable environment,
health and safety protections set out in the HTC SOP. The HTC SOP assumes thorium content
comparable to the WR Grace alternate feed materials or greater. The protections in the HTC SOP may
be adjusted by the SERP and documented as appropriate for HTC ores with lesser concentrations of
thorium, or to eliminate provisions if comparable or more protective provisions are already contained in
other applicable SOPs or existing Mill monitoring requirements. A SERP-approved procedure specific
to an HTC ore will generally be considered to satisfy the applicable environment, health and safety
protections set out in the HTC SOP if it contains similar protections as set out in a SERP-approved SOP
for a comparable HTC ore that has been safely received, stored, processed and disposed of at the Mill in
the past.
Some minor adjustments were made to the Radiation Protection Manual ("RPM") to provide
consistency with the HTC SOP.
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2) Did the subject(s) meet the criteria found in License Condition 9.4.A? Yes X No
Explain:
Subject 1:. The SERP reviewed the Procedure described above and determined that:
• Making changes in the procedure is within the authority of the SERP committee.
DWMRC Staff Review: Subject 1 was a change in an existing procedure. Therefore, the subject
reviewed by the SERP met the criteria in License Condition 9.4.A.
3) Did the subject(s) meet the criteria found in License Condition 9.4.B? Yes X No
Explain:
• The SERP determined that the Change (publication of the HTC SOP and revisions to the RPM)
does not conflict with any requirement stated in the license or any license requirement contained
in any license tie-down letters. Therefore, this criterion is met.
• The HTC SOP was approved by NRC as part of the license amendment for the WR Grace
alternate feed materials. The NRC approval process would have reviewed the HTC SOP for
compliance with all license conditions at the time. The SERP reviewed the HTC SOP against
current license conditions and concluded that there are no conflicts with the current license and
provides options for additional protective measures for high thorium content ore management.
• The RPM was reviewed by the SERP, and the SERP concluded that there are no conflicts with
the license and that the changes better define protective measures/calculations.
• The SERP determined that the Change (publication of the HTC SOP and revisions to the RPM)
does not impair EFRI's ability to meet any regulations. Therefore, this criterion is met.
• The SERP assessed that there would be no change in the safety or environmental commitments
in the license application or reclamation plan.
• Processing according to the HTC SOP 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.
• Incorporation of the HTC SOP and the revisions to the RPM will:
Not introduce any new constituents to the tailings system,
Not require any changes to spill control or storm water management plans,
Not require additional tailings capacity or changes to tailings management plans, and
Not introduce any new pathways of contamination to the environment.
• Incorporation of the HTC SOP and the revisions to the RPM are within the envelope of
conditions evaluated in the Mill's MILDOS model for dose to off-site receptors.
• Incorporation of the HTC SOP and the revisions to the RPM will have no effect on
commitments or the quantities addressed in the Reclamation Plan.
• The SERP determined that the Change (publication of the HTC SOP and revisions to the RPM)
is consistent with the 1997 EA. Therefore, this criterion is met.
• The HTC SOP was approved by NRC as part of the license amendment for the WR Grace
alternate feed materials. The NRC approval process would have reviewed the HTC SOP for
consistency with the 1997 EA.
• The RPM revision is reflective of the HTC SOP and is therefore consistent with the 1997 EA.
4) Did the SERP members meet the expertise criteria found in License Condition 9.4.C? Yes X
No
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Person and/or Job Title
Managerial and Financial David Frydenlund, Chief Financial Officer,
General Counsel and Corporate Secretary
Operations and/or Construction Logan Shumway, Mill Manager
Radiation Safety Terry Slade, Radiation Safety Officer
Other: Responsible for regulatory compliance at
the White Mesa Mill
Kathy Weinel, Quality Assurance Manager
Other: Implementation of Environmental and
Radiation Safety Practices
Garrin Palmer, Assistant Radiation Safety Officer
Explain:
DWMRC Staff Review: Documented members of the SERP Committee meet the requirement.
5) Did the SERP Annual Report meet the criteria found in License Condition 9.4.D? Yes X No
Explain:
DWMRC Staff Review: The SERP report was submitted prior to March 31of the following year.
Changes to the existing procedure was included with the 2020 SOP transmittal. The SERP followed the
Mills operating procedure for SERP reviews. Therefore, the SERP report did meet all of the criteria in
License Condition 9.4.D. Staff will verify that records are being maintained in a future site inspection.
6) Describe what subject(s) were reviewed by the Mill's SERP.
Subject 2: Reviewed and approved a proposed Standard Operating Procedure ("CSX SOP") for
operation of a Chloride Pond Return Solvent Extraction ("SX") circuit using equipment from the
vanadium SX area for uranium recovery.
EFRI plans to modify uranium solvent extraction in the Mill for a specific project or use, by configuring
a Chloride Pond Return SX circuit using equipment in the vanadium SX area that could be activated as
needed to allow recovery of uranium from tailings pond return solution and other uranium solvent
extraction streams containing high chloride solutions. Pond return solutions, or other high-chloride
solutions, will be extracted in full scale equipment with a modified organic that will produce a loaded
organic solution containing the uranium, and a raffinate solution containing the chloride. Loaded
organic will be stripped with soda ash to produce a concentrated uranium solution that can be stored in
available mill tanks and can be processed in the normal Uranium SX ("USX") process at a later time.
The Chloride Pond Return SX circuit will use tridecyl alcohol, diethylhexyl phosphoric acid ester
("DEHP A") and kerosene diluent, all of which have been and are currently used in SX operations in the
Mill.
The proposed CSX SOP addresses a modification of processes in practice at the Mill as described in the
Mill's 2007 license renewal application and existing EA documents, which uses DEHPA, as previously
approved in the May 2019 SERP review. The proposed process is referred to in this report as the
Chloride Pond Return SX, or the "Change." 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.
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The uranium solution acidification step that will precede the SX has been used in the Mill previously for
any number of other uranium bearing solutions from alternate feed materials and ores, and did not need
to be re-evaluated.
7) Did the subject(s) meet the criteria found in License Condition 9.4.A? Yes X
Explain:
Subject 2:. The SERP reviewed the Procedure described above and determined that:
• Making changes in a procedure presented in the application (i.e. 2007 application) is within the
authority of the SERP committee.
DWMRC Staff Review: Subject 2 was a change in an existing procedure that was presented in the
2007 renewal application. Therefore, the subject reviewed by the SERP met the criteria in License
Condition 9.4.A.
8) Did the subject(s) meet the criteria found in License Condition 9.4.B? Yes X No
Explain:
• The SERP determined that the Change (processing according to the CSX SOP) does not conflict
with any requirement stated in the license or any license requirement contained in any license
tie-down letters. Therefore, this criterion is met.
• The Mill has remained in compliance with the License and other regulatory requirements while
operating the main USX circuit, and the proposed Chloride Pond Return SX is a version of the
USX circuit utilizing the same DEHPA that has been used safely in the Mill in the past. Hence
there is no reason to expect the Mill cannot remain in compliance with the same requirements
when running the Chloride Pond Return SX in accordance with the CSX SOP.
• The yellowcake that will be produced will not cause the Mill to exceed the yellowcake
production limit under the License.
• Processing according to the proposed CSX SOP is consistent with the plans and SOPs
referenced in the License and the Mill's renewal application.
• Processing according to the CSX SOP does not require modification of the Mill's Air Approval
Order.
• Processing according to the CSX SOP does not require modification of the Mill's Clean Air Act
Risk Management Plan.
• Processing according to the CSX SOP does not require modification of the Mill's Groundwater
Discharge Permit ("GWDP"). The additional chemical, DEHPA, will degrade into phosphoric
acid and phosphate after discharge into the Mill's tailings management system. The Mill
currently measures sulfate in groundwater as an indicator of tailings management system
integrity. Sulfate is an appropriate and conservative surrogate for phosphate in the environment.
• Under normal conditions, processing according to the CSX SOP will not produce any additional
respiratory hazards beyond those already managed at the Mill in connection with other leach
processes. Processing according to the CSX SOP involves use of DEHPA, which has been
previously handled in the Mill for processing of certain alternate feed materials.
• Any spilled material would be cleaned up and transferred in non-metal containers to the tailings
management system. It is important to note that there is no reportable quantity ("RQ") for
DEHPA.
• The SERP assessed that there would be no change in the safety or environmental commitments
in the license application or reclamation plan.
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• Processing according to the CSX SOP 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.
• Processing according to the CSX SOP will:
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 plans,
Not require additional tailings capacity or changes to tailings management plans, and
• Processing according to the CSX SOP is within the envelope of conditions evaluated in the
Mill's MILDOS model for dose to off-site receptors.
• Processing according to the CSX SOP will have no effect on commitments or the quantities
addressed in the Reclamation Plan.
• The SERP determined that there would be no significant expansion of the Mill site. The DEHP
A material would be stored in the SX building or other secure location.
• The SERP assessed potential emissions and effluents and determined that the CSX SOP would
not produce any change in the quantities or types of effluents.
• The SERP assessed that that there would be no change m radiation exposure or derived alr
concentrations ("DACs").
• DEHPA does not require any additional respiratory protections or produce any additional
inhalation hazards during routine operations and use.
• The SERP assessed potential emissions and determined that the proposed CSX SOP would not
produce any increase in the quantity of emissions.
• The SERP assessed that the wastes from the Chloride Pond Return Process would be comparable
to those produced by the Mill's existing solvent extraction processes. The tailings management
system liners have been determined to be suitable for the presence of the level of DEHPA that
could be disposed in the worst-case spill or shut down scenario.
• The SERP determined that due to a) DEHPA having no respiratory exposure limits and b)
DEHPA emissions from a potential fire have limited environmental half-life, this material does
not produce any risk of airborne hazard off site.
• The maximum quantity of DEHP A on site is expected to be 2,000 gallons in 250-gallon plastic
totes. If the entire quantity were to be transferred to the Mill's tailings management system as a
result of a spill or disposal without use, the maximum concentration in any one cell would be
approximately 4 ppm. The SERP and Technical Memorandum evaluated information on the
PVC and HDPE liners in use in the tailings management system and concluded that the liners
have suitable resistivity at concentrations of organic acids and acid esters, such as phosphoric
acid esters, 1,000 times greater than the maximum that could be produced in the worst-case
disposal. Therefore, the SERP concluded that use and disposal of DEHP A is within the
envelope of conditions evaluated in the EA for the tailings management system.
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9) Did the SERP members meet the expertise criteria found in License Condition 9.4.C? Yes X
No
Person and/or Job Title
Managerial and Financial David Fiydenlund, Chief Financial Officer,
General Counsel and Corporate Secretary
Operations and/or Construction Logan Shumway, Mill Manager
Radiation Safety Terry Slade, Radiation Safety Officer
Other: Responsible for regulatory compliance at
the White Mesa Mill
Kathy Weinel, Quality Assurance Manager
Other: Implementation of Environmental and
Radiation Safety Practices
Garrin Palmer, Assistant Radiation Safety Officer
Other: Corporate responsibility for regulatory
compliance
Scott Bakken, Vice President, Regulatory Affairs
Explain:
DWMRC Staff Review: Documented members of the SERP Committee meet the requirement.
10) Did the SERP Annual Report meet the criteria found in License Condition 9.4.D? Yes X No
Explain:
DWMRC Staff Review: The SERP report was submitted prior to March 31of the following year.
Changes to the existing procedure was included with the 2020 SOP transmittal. The SERP followed the
Mills operating procedure for SERP reviews. Therefore, the SERP report did meet all of the criteria in
License Condition 9.4.D. Staff will verify that records are being maintained in a future site inspection.
Identified Deficiencies:
None
Report Ryan Johnson Reviewed By:
Supervisory
Review By:
(Print Name)
Phil Goble
3/25/2021
(Date)

(Print Name) (Signature) (Date)
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