DRC-2021-007045 - 0901a06880e96002

State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Douglas J. Hansen
Director
MEMORANDUM
TO: Project File C-2021-31
PRG THROUGH: Phil Goble, Uranium Mill Section Manager 05/18/2021
FROM:
DATE:
Heather Mickelson, PE, PG (/~ ~;,t, 5/18/2021
May 18, 2021
SUBJECT:
Authority
May 13, 2021 Inspection of the Disposal of l le.(2) Decommissioning Debris from In
Situ Leach Facilities at the White Mesa Uranium Mill. Radioactive Material License No.
UT 1900479.
Radioactive Materials License #UT1900479 Amendment 9, Condition 10.5: "In accordance with the
Licensee's submittal to the NRC dated May 20, 1993, the Licensee is hereby authorized to dispose of
byproduct material generated at licensed in situ leach (ISL) facilities, subject to the following
conditions:" (Conditions are included below in the Requirements section.)
R313-12-3 (quoting 10 CFR 40.4): "Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes."1
10 CFR Part 40 Appendix A, Criterion 2: "To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal
1 This definition amends the language given in Section 11 e.(2) of the Atomic Energy Act as amended in 1954 to include ISL
facilities on the same footing as conventional uranium mills. This is done by referencing "solution extraction" in the
definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume 1, No. 10.
DRC-20 195 North 1950 West• Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on I 00% recycled paper
Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
May 18, 2021
Page 2
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations."
Observations
Heather Mickelson, PE, PG of the Utah Division of Waste Management and Radiation Control
(Division) observed the disposal of one (1) loads of 1 le.(2) byproduct material on May 13, 2021 at the
White Mesa Uranium Mill. The mill is owned and operated by Energy Fuels Resources (Licensee).
Notification of the disposal was received by the Division on May 6, 2021.
Operating Procedures and Records
This inspection was specific to the Licensee's implementation of Standard Operating Procedure SOP
PBL-10, which governs disposal of l le.(2) byproduct material from ISL facilities. Revision R-3.4,
dated February 1, 2018, is the most recent version.
The Licensee maintains hard copies of the buried 1 le.(2) material records onsite. The current year's
disposal records are stored inside the White Mesa Mill's office building and prior years' records are
stored in an onsite storage container within the restricted area. Copies of the data packets for each load
disposed during this inspection are attached to this report.
The Licensee maintains a map of Tailings Cell 3 in the mill office that shows the dedicated disposal
locations for each 11 e.(2) byproduct material generator. The current map, most recently updated
6/22/2020, is attached to this report.
11 e.(2) Byproduct Material Disposal Activities and Description
Prior to May 13, 2021, the disposal pit location was determined, located by survey, and excavated. The
bottom of the excavation extended into the tailings sand. The 11 e.(2) byproduct material was placed
near the burial pits and processed for burial (Photo 1 ).
During the May 13, 2021 inspection, the Division observed the final disposal activities. Prior to
placement, the excavation depth was surveyed (Photo 2). Once the 11 e.(2) byproduct material was in
the excavation, the top of the material was surveyed (Photos 3). Clean cover was then placed over the
1 le.(2) byproduct material and then compacted to further minimize void spaces (Photos 4). The vertical
extent of the burial was below the top of the tailings and above the bottom liner.
The load of l le.(2) byproduct material was from EFR Alta Mesa -Mestena in Encino, Texas. The
material from this load consisted material from in-situ mining operations such as: pipe, soil, valves,
hoses (Photo 1)
Close Out Meeting
A close out meeting to discuss observations during the inspection included Heather Mickelson, Terry
Slade (Radiation Safety Officer), Tanner Holliday, and Garrin Palmer.
Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition JO.SB: "All ISL contaminated equipment shall
be dismantled, crushed or sectioned to minimize void spaces. Barrels containing waste other than soil or
sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges
Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
May 18, 2021
Page 3
shall be verified by the licensee to be full prior to disposal. Barrels not completely full shall be filled
with tailings or soil prior to disposal."
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. Barrels were not present during this disposal
inspection.
Radioactive Materials License #UTJ9OO479, Condition JO.SC: "All ISL waste shall be buried in Cell
No. 3 unless prior written approval is obtained from the Director for alternate burial locations."
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. All 11 e.(2) byproduct material was buried in Tailings
Cell No. 3.
Radioactive Materials License #UTJ9OO479, Condition JO.SD: "All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include descriptions of the
ISL waste and the disposal locations, as well as all actions required by this license condition."
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. The Licensee maintains records of the 11 e.(2)
byproduct material disposed of onsite. These records document the nature of each load of material
received, where it is buried, and how it was handled, including all measures taken to comply with all of
License Condition 10.5.
Radioactive Materials License #UTJ9OO479, Condition JO.SE: "ISL Disposal Requirements. The
licensee shall perform ISL disposal activities in accordance with the currently Director approved
Standard Operating Procedure (SOP) for ISL disposal. Said plan includes the following minimum
prov1s10ns:
(I) The material disposal area must be located on a tailings beach area of the disposal cell or on
an area of the cell that is underlain by tailings sands;
(2) The elevation of the material disposal area shall not exceed the plane or grade of the
elevations of the uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material shall be segregated from any mill material and equipment
disposed of in the cells pursuant to License Condition 10.4, and the ISL byproduct material from
each in-situ leach source shall be segregated from the byproduct material from all other in-situ
leach sources;
( 4) Absence of void space inside barrels disposed, including physical verification before
disposal; and
(5) Detailed engineering drawings which demonstrate:
a. There are at least four feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings cell."
The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Licensee met the requirement to submit the
procedure with the initial version of SOP PBL-10, and now uses Revision R-3.4, dated February 1,
2018. Revision R-3.4 addresses all of the items specified in License Condition 10.5. The original
Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
May 18, 2021
Page 4
version and every subsequent revision of this procedure were submitted to the Division for review and
approval prior to implementation.
Further, the Licensee is complying with the SOP, such as segregating generator l le.(2) byproduct
material streams, minimizing void space, and placing the waste in the tailing sands with at least four feet
of sands below it and at least 12 feet from the side or dike of the cell.
Radioactive Materials License #UTJ900479, Condition JO.SF: "The licensee shall notify the Director
in writing at least seven calendar days prior to the proposed scheduled date for disposal of any
byproduct material generated at ISL facilities in the tailings cells.
An annual summary of the amounts of waste disposed of from off-site ISL generators shall be sent to the
Director on or before November 1 of each calendar year."
The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Division received notice of the disposal on May
6, 2021, which is complies with the 7 days in advance of burial that occurred on May 13, 2021. The
annual summary submittal will be evaluated by DWMRC separately from this inspection.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 11 e.(2) byproduct material generated as decommissioning debris
from ISL uranium recovery facilities.
Attachments: l le.(2) Byproduct Receipt Notification dated May 3, 2021
l le.(2) Disposal Location Map
Document packet for EFR Alta Mesa -Mestena l le.(2) byproduct material bearing Shipment ID #176
Photo 1. Alta Mesa -Mestena l le.(2) byproduct material to be buried.
Photo taken on May 13, 2021.
Photo 3. EFR measuring the top elevation of the Alta Mesa -Mestena
1 le.(2) byproduct material. Photo taken on May 13, 2021.
Photo 2. EFR measuring the bottom elevation of the Alta Mesa -Mestena
burial location. Photo taken on May 13, 2021.
Photo 4. Compacting the final cover over the buried Alta Mesa -Mestena
1 le.(2) byproduct material. Photo taken on May 13, 2021.
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No.: PBL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
S'f ANDARD OPERATING PROCEDURES
Title: 1 le.(2) B)'l)IOCm9t Disposal
ATTACHMENT l
Page 11 of 13
Ue.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: S / 3 / l l
Name of employee receiving the load: j"'s h.--. Pc..-t;.; .... s
Generator of the Byproduct Material: A I :t-._ Mc,£ A .,,, M,c..s f ~
Shipper's Manifest or Bill of Lading number: __ J"_._7_,,{;.,..._ _____ _
Was the State of Utah given notice to the receipt/disposal activities associated with this load@r
No
Who gave and when was the notification given?
6-4,cclo-P v-Lid, c S / ~/ ~ '---------------
Description of byproduct material disposal area/activities:
i)~r-t , £1.c. fh«tu 0-1½ fl0ff, ___________________ _
Has each drum been inspected to identify the presence of any void spaces? NA
Have al) drums with void spaces been filled with tailings sands or soil? MA:
Which tailings cell was the material placed in? -~C-e-_1_1~3 _______ _
Was the ma~al placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
M0--tu-,e:-.l L)1;,,J pl4?:\l ,"-t;, tcC'.:AJcb t kAt L.J,z.s e,,¼1,,v-"\..
t v tk .Sc,,J.s
Was the material segregated from any Mill material or equipment disposed of in the cell?
J
Was the material segregated from byproduct material from other ISL sources disposed of in the cell? Ve
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: February 1, Title: J l e.(2) Byproduct Disposal
2018
Manifest or BOL #: _ ___.1_7 .......... 6'---
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
Environmental
Coordinator's
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? _._,,~_.i:........,..---~---
Documentation of a· roval Z, 'c. c ;I. u r / PO o/ 7 "I ~
Was the ISL material segregated from disposed Mill material and other
ISL material? _y ___ , .... 1 _____ _
Referto I s usedtoconfirm. Cell .3 lle.Z-t',_t s-1t1I A-,,,,.;
Was the maximum lift thickness above tailings less than 4 feet
thick? y_, s
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick? Yes
Has 4 foot of tailings sands been maintained under each disposal
area? Y"s
Refer to drawin used.to confinn tell 3 Co,,sl. t?r~-,;., s
Is the botto:in of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?_Y~e ~t __ _
Refer to drawin s used to corifum. C• 'I 3 c.~ I Q.,.,.,,},
Will the elevation of the material exceed the plane or grade of the
el~on of the uppennost flexil>Ie membrane liner of the cell?
How was this confirmed ( e.g., survey or review) ~~ ~
How was the area compact~? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
A; re...-,,, en Mf c...c, h:rA ; c:'' f:lA °' L"'c."l...,_ 4' t-I re, ) t Y, ±. /\,\..C.. S
Were void spaces filled with tailings?
l
Was the shipment properly covered?
,k,c, v C..
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 13 of 13
Date: February 1, Title: l le.(2) Byproduct Disposal
2018
Manifest or BOL #: l 7 6
Are additional settlement monitors required to be placed for this generator?
If required, where were the settlement markers placed?
A
Radiological receipt survey measurements:
(?. 'l,. M~/ {;...,-PJ:DrQ
Breathing Zone:
1. Was a. Breathing Zone Sample collected? Yes ~
2. If yes, what were the results of the sampling?
Was a photograph taken during the wiloading activities~r No
Generator of Byproduct material:
BOL Number:
Controled Elevation used (Cell 3)
Mestena
176
Area Elevation
Initial shot for trench
Top oftrench 5610.1
Bottom of trench 5601.8
5613.04
Transit Shot
3.06
6
14.3
Initial shot used for material 3.06
Top of material in trench 5607.28 8.82 -----'-----==
Top of cell 3 Liner
Feet below liner
5608.5
1.22
Energy Fuels Resources (USA) Inc.
Equipment Survey for Unrestricted Release
Container ID: Cr£ b I) \ l.O(,
Inside Locations
Surveyed By:;G,s+i,,.. e 1-f'l(: hS
Outside Locations
Front
19
28
L. Side 23 RSide Front Truck
13 14 15 16 17 18 27 37 29 .and Tire Survey
34
22 26 36 30 0 7 8 9 10 11 12 0 2
21
1 2 3 4
20
Tailaate
Total Removable
Alpha AJpha Beta
2
3
4
5
6
7
8
9
10 <, .,
11
12
13
14
15
16
17
18
19
Tota/Alpha
Instrument: ~ SN
Cal. Date:
Efficiency:
Eff. Check ©I N
Removable alpha -1,000 dpm/100cm2
Fixed alpha • 5,000 dpm/100cm2 average
1s;ooo dpm/100cm'maxlmum
Beta · Gamma • 0.2 nu/hr@ 1cm average
1,0 mrlhr@ 1cm maximum
ma
5 6
dpm/100cm•
Location#
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Ralls
33
35
25 31
32
24
Total Removable
Alpha Alpha Bala
dpm/100cm• dpm/100cm' Gamma
1fn.Q f\llr:... ~0-1:'} (.,
114.l.. l:l..S
<o11.o ~BK<r
l'HJ J. IP,1
~~K.~ rllA.
"", V
~O-nl.
',/
.....,/ \V !-.o.o(o
,J ti., rJ ,.. NIA
Instrument Data
Removable Alpha Total Beta/Gamma
Model: ~lf! Model#: ~i1bi SN: SN:
Cal. Date: }~ s. t,?r ~\) Cal. Date: U;s:u~'-o
Efrtciency: )).,:300/4 Source: ~ Eff. Check l9Jt N Reading:
8kg Q·Dlil~~
3
5
Location
1
2
3
4
5
6
;
:
:
:
;
Truck Ext. ;
00 004
00 00 6
Total Beta-
Alphe Gamma
dom ,... In rl 14.
,v ,v
TRAILER TIRES
7 00 0 0 8
9 00 0 0 10
11 00 0 012
Total Beta-
Location Gamma
7
8
9
10
11
12
Chassis Ext.
Comments =~s~~;. .. z;t:.!.~v-er~ J~rl''°'~~e,~ Oqt: fdor :to
}A <-~+<!N>.. .#:-I 7 fJ
Energy Fuels Resources (USA) Corp .
Whi t e Mesa Mill
6425 S . Hi g hway 191
Bl anding UT 84511
Vehic l e ID: 1002
Trai l er ID:
Account ID :
Order ID :
Owner ID :
Material ID :
Destin . ID:
MESTENA Mestena Uranium , LLC
11(e)2 Mat 1 1(e)2 Material Receipt
BLANDING
:omments : TRL#GFLU1206-BOL#176
Jperator : 4 Charge by Weight
Signature : ~-
In :
Out :
Transaction No .
56491
Date Time Sca le
05/03/2021 07 :34 1
05/03/2021 08 :01 1
Gr oss : 56880 lb (M)
Tare : 4 4620 lb
Net : 12260 lb
BILL OF LADING
SHIPMENT ID# 176 SHIPMENT DATE: 2.q I 2-/ _ __,_-1---'-,,f----''----
SHIPPER (From):
EFR AL TA MESA LLC
ADDRESS:
755 Co. Rd. 315 Encino, TX 78353
SHIPPER LICENSE NO.: R05360 SHIPPER USDOT NO.:
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Highway l 91
Blandin , UT 84511
ADDRESS:
P. 0. Box 809, Blanding UT 84511
CONSIGNEE CONSIGNEE TELEPHONE l'iO?
LICENSE NO.: [phone]
UT-1900479
SHIPPER LICENSE NO. : SHIPPER TELEPHONE I CARRIER NAME AND ADDRESS:
NO.:361-568-3549 Greenfield Logistics, LLC
CARRIER USDOT CARRIER HAZMAT REG. NO.:
I
Trailer# Container# GFLU01206 Seal# 422 Seal# 423 Seal# 424
DESCRIPTION OF MATERIAL AND PACKAGING VOLUME
Cubic feet
or
t:ANTITY
CLASSIFICATION
1 pkg. UN2913, Radioactive Material, Surface Contaminated
Objects (SCO-1) and soil, non-fissile, Class 7 30,000 lbs.
Surface Contaminated Ob}ects -
(SCO) waste material and soils RQ
Dry 11 (E).2 By-Product material. Natural uranium and
daughters.
Activity: 4.4 E6 Bq (1.2 E-4 Ci)
EMERGENCY CONTACT:
P. Luthiger: 1-361-816-0150
max (net)
Exclusive use shipment
Net quantity =
19.2 yd3 Placards applied
CERTIFICA TIOX These is to certify that the above named articles are properly classified,
described, packaged, marked and labeled, and are in proper condition for transportation,
~:::~~~ :~:~=l;cab~T~[ ::pMme:~~,T~;f LJ_ -
Driver's Signature: ·z;-~~
EFR Alta Mesa LLC
RELEASE AUTHORIZATION FOR BY-PRODUCT MATERIAL
DESTINATION:
SHIPMENT NUMBER:
NAME OF DRIVER:
Energy Fuels Resources (USA) lnc. -White Mesa Mill
6425 S. Hwy 191
Blanding, UT 84511
DESCRIPTION OF MATERIAL: By-product material from an in-situ uranium mining
operation ( e.g., sand, filter cloths, piping, soil, valves, hoses, personal protective equipment,
etc.)
DRIVER 7,i}~
ature
By execution below, it is represented that the byproduct material being transported is properly
classified, described, loaded and labeled; and, that the byproduct material is completely
contained and in proper condition for transportation, according to the applicable regulations for
the state and federal transportation departments.
The shipper certifies the byproduct material is not listed hazardous waste as defined in the
1 Resource Conservation and Recovery Act, as amended, 40 CFR 261 et. seg. or comparable state
1 laws. The byproduct material has no been mixed or commingled with hazardous waste as
defined in 40 CFR 261 et. seq .. No processes are operated on the site which are RCRA-listed
1 processes as defined in 40 CFR 261 et. seq. All of the Byproduct Material is byproduct material
defined under the Atomic Energy Act of 1954 as amended, 42 U.S.C. § 2014(e)(2) and 10
CFR§40.4(a-i).
I DATE: 'L / A-p< ZJ
Signature: 'iniit-#.7 (jpbte
Phillip Go ~!May 18, 202112:25 MDT)
Email: [e-mail]