DRC-2021-007401 - 0901a06880e9e8d0

State of Utah
GARY R. HERBERT
Governor
SPENCER J COX
Lieutenant Governor
Department of
Environmental Quality
L. Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
v or 'Vail,te. M.3,r,agement
and Radiation Control
MAY 2 4 2021
1)4 P\ C-204-00740
MEMORANDUM
TO: Project File C-2021-30
THROUGH: Phil Goble, Uranium Mill Section Manager
FROM: Russell J. Topham, PE ifr
DATE: April 27, 2021
SUBJECT: 2021 Engineering Module 73, Inspection of disposal of lle.(2) decommissioning debris
from in situ recovery facilities — Disposal Activity March 30, 2021
Authority
Radioactive Materials License #UT1900479, 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) [aka in situ recovery (ISR) facilities, subject to [...]
conditions." (Conditions are cited below as Requirements.)
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
This definition amends the language given in Section 1le.(2) of the Atomic Energy Act as amended in 1954 to include in
situ recovery (or in situ leach) 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 (801) 5364284
www.deq.utah.gov
Printed on 100% recycled paper
2021 ISR Decommissioning Debris Disposal File Inspection Report
March 30, 2021
Page 2
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations."
Requirements
1. Radioactive Materials License #UT1900479, Condition 10.5A: "Disposal of ISL waste is limited to
5,000 cubic yards from a single source." The Division considers a source to be a discrete facility
defined by its geographic boundaries.2
2. Radioactive Materials License #UT1900479, Condition 10.5B: "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 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."
3. Radioactive Materials License #UT1900479, Condition 10.5C: "All ISL waste shall be buried in
Cell No. 3 unless prior written approval is obtained from the Director for alternate burial locations."
4. Radioactive Materials License #UT1900479, Condition 10.5D: "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."
5. Radioactive Materials License #UT1900479, Condition 10.5E: "The Licensee shall also submit for
Director approval a revised written Standard Operating Procedure (SOP) for ISL disposal on or
before December 1, 2010. The revised SOP shall describe the documentation required for ISL
disposal, which shall include but is not limited to the following:"
(1) 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 will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material will 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 will 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:
2 A "source" in this context is a geographically discrete facility. See Letter from Rusty Lundberg to Jo Ann Tischler dated
November 7, 2013 (DRC-2013-005682)
2021 ISR Decommissioning Debris Disposal File Inspection Report
March 30, 2021
Page 3
a. There are at least 4 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.
6. Radioactive Materials License #UT1900479, Condition 10.5F: The Licensee shall notify the
Director in writing at least 7 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.
Observations
Russell J. Topham, PE of the Utah Division of Waste Management and Radiation Control (the
Division), inspected the disposal of two loads of decommissioning debris from the Strata Energy facility
near Ross, Wyoming.
The material included filters, piping, fittings, and other assorted debris from the in-situ leach uranium
recovery facility noted above and was transported in fabric/plastic bags. The material qualifies as
lle.(2) byproduct material, and is appropriate for disposal in the Impoundment 3 cap. Upon arrival at
the mill, the material was staged near the excavation dedicated for disposal of material from this
generator. (see Photos 2, 3 and 5 in the accompanying Photo Log)
This inspection focused on the Licensee's implementation of Standard Operating Procedure SOP PBL-
10, which governs disposal of lle.(2) byproduct material from in situ recovery facilities. (pertinent data
sheets from PBL-10 used in this inspection are attached) Incoming shipments for all materials are
subject to another procedure, SOP PBL-19, which was not the subject of this inspection.
The Licensee used revision R-3.4 of SOP PBL-10, dated February 1, 2018 for this disposal event.
Revision R-3.4 is the most recent version of the procedure.
The Licensee maintains a map of Tailings Impoundment 3 in the Mill office that shows the dedicated
disposal location assigned for each 11e.(2) debris generator. Examination of that map reveals that if
disposal operations are limited to the lateral extents of the dedicated disposal plots and if the vertical
location of placement of material is limited to within two feet below the upper surface of the tailings, as
required in the governing procedure, neither the excavation nor the debris will endanger the integrity of
the impoundment liner.
Lateral disposal pit locations are determined and located in the field by survey prior to excavation. The
bottom of the excavations is extended into the tailings sand, and the depth is surveyed prior to placement
of material into the excavation. (see Photo 5 in the accompanying photo log) Once the debris is placed
in the excavation and compressed, the top of debris is surveyed, after which cover soil is placed and
compacted. Lateral locations were checked by the inspector onsite. The examined disposal data packets
included survey data that shows that the vertical placement is below the peripheral top of liner and well
above the liner beneath the excavation.
2021 ISR Decommissioning Debris Disposal File Inspection Report
March 30, 2021
Page 4
SOP PBL-10 requires that material must be accepted for disposal prior to departure of the transport
vehicle from the generator. This allows the Licensee to ascertain that the material characteristics meet
the requirements for classification as 11e.(2) byproduct material, and to verify that the quantity to be
shipped will not exceed the 5,000 cubic yard per source limit established in License Condition 10.5A.
Checks of running receipt totals confirmed that the volume limits had not been exceeded. The material
is checked upon receipt to verify that what was shipped is what was expected.
Once the material is accepted for shipment, the receipt and burial are scheduled and the Licensee sends a
seven-day advance notice to the Division of the date scheduled for the burial event and number of loads
anticipated for disposal. The Division received the written notice for both loads disposed.
Observations
Items reviewed during the inspection included:
1. Initiation date for load document packet
2. Generator identification
3. Pre-shipment radiological report
4. Certification of absence of RCRA-listed products (RCRA Certification)
5. Shipper's manifest
6. Bill of Lading
7. Scalehouse weigh ticket
8. 7-Day notice to the Division
9. Equipment release form (used to document decontamination)
10. Disposal event-related surveys
The above list is more extensive than one generated from the Requirements section of this report, but
reflects the items required in SOP PBL-10.
The burial operation commenced after a brief delay as the field crew enlarged the disposal excavation.
During the burial, appropriate safety precautions were followed, including field hands and inspectors
positioning themselves upwind of the burial to prevent inhalation of dust or contaminants. As detailed
in the photos, the material was placed in the excavation following survey of the excavation depth. The
top of the material was surveyed once placed in the excavation. The survey data demonstrates that the
disposal operation did not impact the impoundment liner. Following the survey, clean fill was placed
over the debris to complete the burial. The equipment operator densified the cover soil by wheel
walking the loader over the cover soil several times. The surface was not yielding to the weight of the
loader when the crew discontinued the operation.
Following the disposal operation, the inspector reported his findings to Mr. Garrin Palmer, the highest-
ranking member of the management staff available at the time.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 11e.(2) byproduct material generated as decommissioning debris
from in situ uranium recovery facilities during this operation.
2021 ISR Decommissioning Debris Disposal File Inspection Report
March 30, 2021
Page 5
The inspection should be closed out.
Photo 1: Workers taking backsight prior to surveying operation at burial Photo 2: Stockpiling clean fill prior to burying decommissioning debris from
location. Photo taken March 30, 2021. Strata Energy's Ross, Wyoming facility. Photo taken March 30, 2021.
Photo 3: Plastic piping, fittings, filters and rniscellaneous debris from Strata Photo 4: Excavation prepared to receive decommissioning debris from Strata
Energy's Ross, Wyoming facility in bags, staged for placement in the Energy's Ross, Wyoming facility. Photo taken March 30, 2021.
excavation. Photo taken March 30, 2021.
Photo 5: Workers surveying the bottom of the excavation prepared to receive
decommissioning debris from Strata Energy's Ross, Wyoming facility. Photo
taken March 30, 2021.
Photo 6: Introducing decommissioning debris from Strata Energy's Ross,
Wyoming facility into the disposal trench. Photo taken March 30, 2021.
Photo 7: Decommissioning debris from Strata Energy's Ross, Wyoming
facility in the disposal trench awaiting survey of top and installation of cover
soil. Photo taken March 30, 2021.
Photo 8: Workers surveying the top of the emplaced decommissioning debris
from Strata Energy's Ross, Wyoming facility. Photo taken March 30, 2021.
Photo 9: Placing capping soil over decommissioning debris from Strata Photo 10: Placing capping soil over decommissioning debris from Strata
Energy's Ross, Wyoming facility. Photo taken March 30, 2021. Energy's Ross, Wyoming facility. Photo taken March 30, 2021.
Photo 11: Wheel walking capping that was placed soil over decommissioning
debris from Strata Energy's Ross, Wyoming facility to densify the cap. Photo
taken March 30, 2021.
Generator of Byproduct material: Strata Energy
BOL #: 21-037#2, 21-037#1
Controled Elevation used (Cell 3) 5612.6
Area Elevation Transit Shot
Initial shot for trench 4.9
Top of trench 5606.9 10.6
Bottom of trench 5599.7 17.8
Initial shot used for material 4.9
Top of material in trench 5604.74 12.76
Top of cell 3 Liner 5608.5
Feet below liner 3.76
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 56332
Blanding UT 84511
Date Time Scale
In: 03/17/2021 12:17 1
Out: 03/17/2021 13:09 1
Vehicle ID: 19034
Trailer ID:
Account ID: STRATA ENE STRATA ENERGY
Order ID:
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin. ID: BLANDING
Gross:
Tare:
Net:
59160 lb (M)
44140 lb
15020 lb
Comments: BOL 21-037#1 2 CONTAINERS
Operator: 4 Cha -ge by Weight
Signature:

BILL-OF-LADING & LICENCE MATERIAL SHIPPING FORM
Shipment It 21-037 82
Carrier Name: MP Environmental Services
Carrier HazMat Registration 053019550116BD
HazMat Company ID: 4665
To:

From:

Facility: White Mesa Mill
License UT 190047
Address: 6425 S. HWY 191, Blanding, Utah, 84511
Contact Person: Terry Slade
Phone II: 435-678-2221 x113
Facility: Strata Energy, Inc. Ross Pro)ect
License # WYSUA-1601
Address: 2929 New Haven Rd., Oshoto, WY, 82721
Contact Person: John Durand
Phone: [phone]

HazMat Company ID: 174549

Proper Shipping Name: UN 3321, Radioactive material, low specific activity (LSA-II) non fissile or fissile excepted , 7
Radionuclide Quantity (Bq)
Radionuclides Present U (nat) 1.77E+08 J-
Ra-226 6.68E+06
Th-230 5.86E+07
Pb-210 1.57E+07
Po-210 3.90E+06
Radionuclides Present: Natural Uranium, Ra-226, Th-230 (1 Ci = 3.7E10 Bq)
Physical Form: Surface contamination on processing wastes
Cheniical Form: U04, RaCO3, Th504
Package: roll-off container which meets the requirements of 49 CFR 173.410
Volume of Material: 9 YdA3
Total Activity: 2.62E+08 Bq 7.07E-03 (CI )
Exclusive Use Shipment'
0:1401,4
3'1e/s
"I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name,
and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport
according to applicable international and
pApper's Signature: Date: 3-15- —2.621
24 Hr Emergency Response Number: 307-467-9392
Proper Shipping Name: UN 3321, Radioactive material, low specific activity (LSA-II) non fissile or fissile excepted , 7
Quantity (8q}
8.63E+08
2.43E+07
1.56E+08
4.28E+07
1.10E+07
Radionuclides Present: Natural Uranium, Ra-226, Th-230 (1 CI.= 3.7E10 lig)
PhysiCal Form: Surface contamination on processing wastes
Chemical Form: U04, RaCO3, ThSO4
Package: roll-off container which meets the requirements of 49 CFR 173.410
Volume of Material: 32 YdA3
Total Activity: 1.10E+09 Bq 2.97E-02 (CI )
Exclusive Use 94ment
(wed 114
Radionuclides Present
Radionuclide
U (nat
Ra-226
Th-230
Pb-210
Po-210
BILL-OF-LADING & UCENCE MATERIAL SHWPING FORM
Shipmem #: 21-037 #1
Carrier Name: MP Environmental Services
Carrier HazMat Registration #: 053019550116BD
HazMat Company ID: 4665
To:

From:

Facility: White Mesa Mill
Ucense #: UT 190047
• Address: 6425 S. HWY 191, Blanding, Utah, 84511
Contact Person: Terry Slade
Phone #: [phone] x113 '

Facility: Strata Energy, Inc. Ross Project
License 8: WYSUA-1601
Address: 2929 New Haven Rd., ()shot% WY, 82721
Contact Person: John Durand
Phone: [phone]
HazMat Company ID: 174549

"I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name,
and are classified, packaged, marked and fabeled/placarded, and are in all respects in proper condition for transport •
according to applicable international anti hatIonal governmental regulations.'
Shipper's Signature: . •
•.'
Date:

24 Hr Emergency Response Number: 307-467-9392
f i
No.: P1311-10
Rev. No.: R-3.4 Date: February 1, 2018
ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Page 11 of 13 Title: 1 1042) Byprodapt Disposal
ATTACHMENT 2 nen) ' ROD CT MATERL4L DISPIMAL DOCUMENTATION FORM
Date: 3/1712-i
Name of employee receiving the load: t.4 6‘..+1". Lt1. 6-0,,rt4
Generator of the Byproduct Material: s y
Shipper's Manifest or Bill of Lading number: I - 037 2. I 2 — 3? 4. 1
Was the State of Utah given notice to the mceipt/disposal -activities associated with this load? fes)or No
Who gave and when was the notification given?
0.44.r-- 3 h.? txt
Description of bypioduct material disposal area/activities:
St/ at SfekliCi A' I t 44A. AA... i•L. tr,„
Has each drum been inspected to identify the presence of any void spaces? 4/4
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in? et. t t 3
Was the natal& placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
6, e A.— C to% 4" LAIL. I
10.4, .
Was the material segregated from any Mill material or equipment disposed of in the cell?
Yr
Was the material segregated from byproduct material from other ISL sources disposed of in the cell? Vt.)
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 13 of 13 Date: Febniaty 1, Title: lle.(2) Byproduct Disposal 2018
Manifest or BOL #: 2 03-71111 Z1 374 a
Are additional settlement monitors reqUired to be placed for this generator? A-
ff required, where were the settlement markers placed?
Radiological receipt survey measurements: n-e.) 3,0 4A(?I Lv
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 unloading activities? or No
eir ENERGY FUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com

March 17, 2021
VIA Electronic Mail (PDF) and UPS
Mr. Howard
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Howard,
Re: 1le.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of one load by March 30th, 2021.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files