DRC-2021-004049 - 0901a06880e45e0c

March 24, 2021
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
DRC — 2.0 2 - 4-0 www.energyfuels.com
Div of Waste Management
and Radiation Control
MAR 2 6 2021
Sent VIA EXPRESS DELIVERY AND E-MAIL
Mr. Ty L. Howard
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: White Mesa Uranium Mill- RML UT1900479
Safety and Environmental Review Panel ("SERP") Annual Report
Dear Mr. Howard:
Condition 9.4 D of the White Mesa Mill, State of Utah Radioactive Materials License No. UT 1900479
("RML"), requires that Energy Fuels Resources (USA) Inc. ("EFRI") submit an annual Safety and
Environmental Review Panel ("SERP") Report. Attached is the annual 2020 SERP Report required by
RML Condition 9.4D.
Copies of the Standard Operating Procedures ("SOP") that were revised as a result of these SERPs were
included in the annual transmittal of SOPs which was transmitted to the Division of Waste Management
and Radiation Control ("DWMRC") on December 21, 2020.
If you should have any questions regarding this report please contact me at 303-389-4134.
Yours very, truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: Scott Bakken
David Frydenlund
Garrin Palmer
Logan Shumway
Terry Slade
ATTACHMENT A
2020 Annual SERP Report
SAFETY AND ENVIRONMENTAL REVIEW PANEL ("SERP")
2020 ANNUAL REPORT
Submitted to the Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
Submitted by:
Energy Fuels Resources (USA) Inc.
225 Union Boulevard, Suite 600
Lakewood, CO 80228
March 24, 2021
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 were two Safety and Environmental Review Panel ("SERP") evaluations conducted for the
period of January 1, 2020 through December 31, 2020. These SERP evaluations and reviews were
conducted in accordance with SERP procedures set forth in the Mill's Standard Operating
Procedure PBL-1, Rev. No. R-6 (the "SERP SOP"). The evaluations are summarized below in
Section 2.0.
2.0 SUMMARY OF EVALUATIONS
This section describes the change, test, or experiment evaluated by the SERP pursuant to License
condition 9.4, and summarizes the evaluations performed and actions taken by the SERP relative
to each.
In each case, the SERP consisted of those individuals specified in License condition 9.4 C, with
additional members included as appropriate, to address specific technical issues.
The SERP followed the SERP 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. SERP Report No. 2020-01 August 17, 2020
SOP for High Thorium Content Ore Management
2.1.1. Proposed Action
Update and review the existing high thorium content standard operating procedure ("HTC SOP").
The 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,
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and Calcined Byproduct Material alternate feed materials. All feed-specific changes were as
approved by EFRI'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.
2.1.2. Descriptions of Change, Tests or Experiments
The proposed HTC SOP will be used as the baseline (reference point) for the development of other
HTC feed-specific S OPs.
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:
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 (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.
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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.
Does the change create any degradation in the essential safety or environmental commitments in
the license application, or provided by the approved reclamation plan?
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.
Is the change consistent with the conclusions of actions analyzed in the EA dated February 1997?
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.
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Neither the HTC SOP nor the revised RPM expand the Mill or change any environmental conditions.
The HTC SOP and RPM provide additional protections for workers and Mill facilities.
2.1.4. SERP Documentation
Condition 9.4D of the RML requires the submission of change pages to the operations plans and
Reclamation Plan of the approved license application to reflect changes made during the SERP
process. There are no changes required to the operational documents or Reclamation Plan required
as the result of this SERP and as such, no change pages are required. A revised HTC SOP has
been completed and was included in the annual 2020 SOP transmittal submitted to DWMRC on
December 21, 2020.
2.1.5. SERP Action
The SERP concluded that incorporation of the HTC SOP and the revisions to the RPM meet the
criteria set forth in the SERP SOP for approval, and approved the HTC SOP.
The SERP authorized immediate incorporation of the HTC SOP and revisions to the RPM.
2.1.6. SERP Membership and Qualifications
This SERP consisted of the following members:
Responsibility Name/Position
Corporate Radiation Safety Officer or equivalent;
Assuring Tests conform to radiation safety and
environmental requirements
Terry Slade
Mill Radiation Safety Officer
(Member)
Management Expertise;
Responsibility for managerial and financial approvals
David Frydenlund
Chief Financial Officer, General
Counsel and Corporate Secretary
(Member)
Operations and/or Construction
Management;
Responsibility for implementing operational
procedures
Logan Shumway
Mill Manager (Member)
Responsibility for regulatory compliance at
WMM
Kathy Weinel
Quality Assurance Manager
Implementation of Environmental and Radiation
Safety Practices
Garrin Palmer
Assistant Mill RSO
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2.2. SERP Report No. 2020-02 August 19, 2020
Mini-SX (DEHPA Process)
2.2.1. Proposed Action
Review and approve 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.
2.2.2. Descriptions of Change, Tests or Experiments
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 ("DEHPA") 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 RIVIL, worker safety, process safety, and
environmental protection.
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.
2.2.3. 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:
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 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.
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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.
Does the change create any degradation in the essential safety or environmental commitments in
the license application, or provided by the approved reclamation plan?
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 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.
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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
• Not introduce any new pathways of contamination to the environment.
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 cominitments or the quantities
addressed in the Reclamation Plan.
Is the change consistent with the conclusions of actions analyzed in the EA dated February 1997?
The SERP determined that there would be no significant expansion of the Mill site. The DEHPA
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 in radiation exposure or derived air
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 DEHPA 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
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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 DEHPA is within the envelope of
conditions evaluated in the EA for the tailings management system.
2.2.4. SERP Documentation
Condition 9.4D of the RML requires the submission of change pages to the operations plans and
Reclamation Plan of the approved license application to reflect changes made during the SERP
process. There are no changes required to the operational documents or Reclamation Plan required
as the result of this SERP and as such, no change pages are required. A revised CSX SOP has
been completed and was included in the annual 2020 SOP transmittal submitted to DWMRC on
December 21, 2020.
2.2.5. SERP Action
The SERP concluded that using the Chloride Pond Return Process in accordance with the CSX
SOP meets the criteria set forth in the SERP SOP for approval, and approved the CSX SOP.
The SERP authorized immediate implementation of the CSX SOP.
2.2.6. SERP Membership and Qualifications
This SERP consisted of the following members:
Responsibility Name/Position
Corporate Radiation Safety Officer or equivalent;
Assuring Tests conform to radiation safety and
environmental requirements
Terry Slade
Mill Radiation Safety Officer
(Member)
Management Expertise;
Responsibility for managerial and financial
approvals
David Frydenlund
Chief Financial Officer,
General Counsel and
Corporate Secretary (Member)
Operations and/or Construction Management;
Responsibility for implementing operational
procedures
Logan Shumway
Mill Manager (Member)
Responsibility for regulatory compliance at
WMM
Kathy Weinel
Quality Assurance Manager
Corporate responsibility for regulatory
compliance
Scott Bakken Vice President,
Regulatory Affairs
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In addition, the following Mill Personnel attended the SERP:
Reason for Attendance Name/Position
Implementation of Environmental
Radiation Safety Practices
and Garrin Palmer
Assistant Mill
Officer
Radiation Safety
Implementation of the CSX SOP Timo Groves
Process Engineer
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